ML20217C186
| ML20217C186 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 04/20/1998 |
| From: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-317-97-08, 50-317-97-8, 50-318-97-08, 50-318-97-8, NUDOCS 9804230237 | |
| Download: ML20217C186 (7) | |
Text
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CnAntes II. CRUSE Baltimore Gas and Electric Company Vice President Calvert Cliffs Nuclear Power Plant Nuclear Energy 1650 Calven Cliffs Parkway Lusby. Maryland 20657 410 495-4455 April 20,1998 U. S. Nuclear Regulatory Commission Washington, DC 20555 A'ITENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50 317 & 50-318 Reply to a Notice of Violation: NRC Region I Integrated Inspection Report Nos. 50-317/97-08 and 50-318/97-08
REFERENCE:
(a)
Letter from Mr. L. T. Doerflein (NRC) to Mr. C. H. Cruse (BGE), dated March 20, 1998, NRC Region 1 Integrated Inspection Report Nos. 50-317/97-08 and 50-317/97-08 and Notice of Violation This letter provides Baltimore Gas and Electric Company's response to Reference (a). Your letter identified three violations which require a response. Each of the violations cited has been individually addressed as specified in the Enclosure to Reference (a). Individual responses to each of these violations are provided in Attachments (1) through (3). Information contained in Reference (a) concerning Violation 97-08-05 accurately reflects our corrective actions and our position. Therefore, no response to this violation is being submitted.
Should you have questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours,
/46:,V waw CHC/JMO/ dim
.-...v031 Attachment cc:
R. S. Fleishman, Esquire Resident Inspector, NRC J. E. Silberg, Esquire R.1. McLean, DNR hg O Director, Project Directorate 1-1, NRC J.11. Walter, PSC A. W. Dromerick, NRC L. T. Doerflein (NRC)
H. J. Miller, NRC 9804230237 900420 PDR ADOCK 05000317 G
ATTACHMENT (1)
NRC REGION 1 INTEGRATED INSPECTION REPORT NOS. 50-317/97-08 AND 50-318/97-08 VIOLATION 97-08-01 Criterion XI, Test Control, ofAppendix B to 10 CFR Part 50 requires a test program be established to assure that all testing required to demonstrate that systems and components willperform satisfactorily in service is identified andperformed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents.
Contrary to the above, as ofJanuary 6,1998:
1.
BGEfailed to establish a written test procedure to verify that the [ control element assembly]
(CEA) reed switch position indicator voltage divider retwork power supply voltage was within the acceptance limit specified by the applicable design documents.
2.
BGEfailed to establish a written test procedure to verify that the CEA voltage divider reed switch position indication channel was capable ofdetermining the absolute CEA position within 1.75 inches as required by Technical Specification L miting Conditionfor Operation (LCO] 3.1.3.3.
I.
ADMISSION OR DENIAL OF THE AILFGED VIOLATION
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Baltimore Gas and Electric Company accepts the violation mted.
l II.
REASONS FOR THE VIOLATION l
Each refueling outage, we perform the following procedures:
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Maintenance Procedure 1-23," Control Element Drive System Alignment" to verify control element l
assembly (CEA) reed switch position indicator voltage divider network power supply voltage; Maintenance Procedure I-14," Control Element Drive System Reed Switch Zeroing" to calibrate the
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l Reed Switch Position Transmitters to zero which verifies the
- 1.75 inches criteria; and
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Post Startup Test Procedure (PSTP) -13," Control Element Drive Mechanism Performance Testing" to verify that the pulse counting (i.e., primary) position indicator channel computer digital display, I
the secondary CEA reed switch position indication system, and the secondary CEA digital display l
system are within 4.5 inches ot'each other.
Ilowever, because we did not routinely verify CEA reed switch position indicator voltage divider network power supply voltage, we were not aware that it had drifted to the point that we no longer met the 4.5 inches acceptance cr;teria of PSTP-13.
I III. CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED Surveillance Test Procedure M-211," Secondary CEA Position Display Out of Sequence And Deviation Alarm Functional Check," has been revised to verify, on a monthly basis, CEA reed switch position J
indicator voltage divider network power supply voltage. Maintenance Procedure I-23, " Control Element j
Drive System Alignment" was revised to change the power supply voltage setting to increase the accuracy of the indicator system.
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ATTACIIMENT (1)
NRC REGION 1 INTEGRATED INSPECTION REPORT NOS. 50-317/97-08 AND 50-318/97-08 VIOLATION 97-08-01 I
IV.
CORRECTIVE STEPS TIIAT WILL BE TAKEN TO AVOID FURTIIER YLQLATIONS To avoid further violations of this nature, no further actions are required.
V.
DATE WIIEN FULL COMPLIANCE WILL BE ACIIIEVED j
Full compliance was achieved when Surveillance Test Procedure M-211, " Secondary CEA Position Display Out of Sequence And Deviation Alarm Functional Check" and Maintenance Procedure I-23,
" Control Element Drive System Alignment" were revised.
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l ATTACHMENT (2)
NRC REGION 1 INTEGRATED INSPECTION REPORT NOS. 50-317/97-08 AND 50-318/97-08 VIOLATION 97-08-02 Technical.Specipcation (TS) 3.1.3.3 requires, in part, two of the following three control element assembly (CEA) position indicating channels be operable for each shutdown and regulating CEA:
(a) CEA voltage divider reed switch position indicatur channel; (b) CEA " Full Out" or "FullIn" reed switch position indicator channel; and, (c) CEA pulse countingposition indicator channel.
Contrary to the above, between January 4 and 5,1998, BGE [ Baltimore Gas and Electric Company}
failed to meet TechnicalSpecipcation Limiting Conditionfor Operation 3.1.3.3for Unit 1 when both the Contro.' Element Assembly (CEA) voltage divider reed switch position indicator channel and the CEA
" Full Out" reed switch position indicator channel were inoperable, and no associated Action requirement existed.
I.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Baltimore Gas and Electric Company accepts the violation.
II.
REASONS FOR THE VIOLATION During the last half of 1997, there had been approximately sixteen separate problems with the control element assembly (CEA) pulse counting (i.e., primary) position indicator channel system. The frequency of problems predisposed the operators to conclude that a rod position discrepancy between the primary CEA position indication and the secondary (i.e.,CEA voltage divider reed switch position indicator channel] indication was a problem with the primary CEA indication system.
III. CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED A root cause analysis of the event has been performed.
All primary CEA position indication system computer cards have been replaced. For Unit 1, the replacements were done in late January 1998 and, for Unit 2, they were done in early March 1998. There have been no problems with the primary CEA position indication system since then.
Each Operations shift has been trained on the event both in classroom and the simulator. At the simulator sessions, the General Supervisor of Nuclear Plant Operations gave his expectations of how Operators should respond to situations like this one. Training stressed conservative decision-making and requesting technical support when necessary.
IV.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS To avoid further violations of this nature, ne further actions are required. However, to provide earlier l
notification of problems, Design Engineering is investigating the possibility of tightening the alarm limits for voltage drift on the voltage divider position indication power supply, i
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ATTACIIMENT (2)
NRC REGION 1 INTEGRATED INSPECTION REPORT NOS. 50-317/97-08 AND 50-318/97-08 VIOLATION 97-08-02 V.
DATE WIIEN FULL COMPLIANCE WII L BE ACHIEVED Since the response to Violation 97-08-01 is related to this violation, full compliance was achieved when Surveillance Test Procedure M-211," Secondary CEA Position Display Out of Sequence And Deviation Alarm Functional Check" and Maintenance Procedure I-23," Control Element Drive System Alignment" were revised and the primary CEA position indication system computer cards were replaced.
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ATTACilMENT (3)
NRC REGION 1 INTEGRATED INSPECTION REPORT NOS. 50-317/97-08 AND 50-318/97-08 VIOLATION 97-08-06 10 CFR 50.54(q) requires licensees authori:ed to possess and operate a nuclear power reactor tofollow and maintain in effect emergency plans which meet the standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50. 10 CFR 50.47(b)(9) requires the onsite emergency response plansfor nuclearpower reactors have adequate methods, systems, and equipmentfor assessing and monitoring actual or potential offsite ccnsequences ofa radiological emergency condition.
The Calvert Chffs Nuclear Power Plant Emergency Response Plan (ERP) Paragraph 1V, Accident Assessment, of Chapter 4, Emergency Measures states, in part, Emergency Response Plan implementation Procedures (ERPIP) provide methods and techniques for determining radioactive materialrelease source term.
Contrary to the above, on January 15, 1998, methods and techniques for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition were not adequately implemented, during tabletop walkthroughs, in that two techniciansfimctioning as interim Radiological j
Assessment Directors, assumed incorrect isotopic concentrations of the radioactive material release source term which resultedin non-conservative ofpite doseprojections.
I.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Baltimore Gas and Electric Company accepts the violation.
1 II.
REASONS FOR THE VIOLATION The reasons for this violation are as follows:
Emergency Response Plan Implementation Procedure (ERPIP)-107, " Interim Radiological Assessment" was not sufficiently detailed to address the actions assessed by the NRC inspectors;
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Training for technicians serving in the Interim Radiological Assessment Director (IRAD) position has focused on higher probability accident scenarios such as those at the Alert level emergency; and,
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Proficiency expectations for lower probability situations (Site and General Emergency) that require the technicians to make core damage estimates in severe accidents without the Technical Support Center and Emergency Operations Facility support have not been delineated, conveyed to the technicians in training, nor tested and evaluated.
III. CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS AClHEVED The procedure used by the on-shift Chemistry Technicians, ERPIP-107, " Interim Radiological Assessment," has been reviewed and is currently going through the revision process.
In response to the findings of the Nuclear Regulatory Commission inspection, a training package was developed for the on-shift Chemistry Technicians to clarify expectations regarding the identification of the accident type (which determines the isotopic concentrations). The training was completed for all IRAD qualified personnel on February 3,1998.
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ATTACIIMENT (3) l NRC REGION 1 INTEGRATED INSPECTION REPORT NOS. 50-317/97-08 AND 50-318/97-08 VIOI ATION 97-08-06 Additionally, a dose assessment scenario has been assigned to each qualified IRAD. The scenario includes determination of the accident type using the current ERPIP-107. The four scenarios, completed j
to date, have shown no problem with accident identification.
l IV.
CORRECTIVE STEPS TIIAT WILL BE TAKEN TO AVOID FURTIIER VIOLATIONS To avoid further violations of this nature, no further actions are required. Ilowever, to strengthen IRAD performance, the following additional steps will be taken:
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A. The procedure used by the on-shift Chemistry Technicians, ERPIP-107, " Interim Radiological Assessment,"is being revised to simplify its use and provide more detail on using instruments to determine magnitude of core damage.
B. Chemistry Technicians that are qualified for Interim Radiological Assessment will be provided training on the revised ERPIP-107 functions prior to its implementation and proficiency evaluations on its use thereafter.
V.
DATE WIIEE FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on February 3,1998 when the on-shift Chemistry Technicians were I
trained on the expectations regarding identification of the accident type.
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