ML20217M157
| ML20217M157 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 03/31/1998 |
| From: | Hehl C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| References | |
| NUDOCS 9804080020 | |
| Download: ML20217M157 (4) | |
Text
(
y March 31,1998 Mr. Charles H. Cruse Vice President - Nuclear Energy Baltimore Gas and Electric Company (BGE)
Calvert Cliffs Nuclear Power Plant
'1650 Calvert Cliffs Parkway Lusby, MD. 20657-4702 i
SUBJECT:
EXERCISE OF ENFORCEMENT DISCRETION FOR BALTIMORE GAS AND ELECTRIC COMPANY (BGE) REGARDING CALVERT CLIFFS NUCLEAR STATION UNIT 1 (NOED No. 98-01-002)
Dear Mr. Cruse:
By letter dated March 30,1998, you submitted a written request that the NRC exercise j
discretion not to enforce compliance with the actions required in Calvert Cliffs Technical 1
f Specification Action Statement (TSAS) 3.8.1.1.b. That letter documented information previously discussed with the NRC in a telephone conversation held at approximately
' 0015 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> on March 28,1998. During the teleconference you stated that on March 25, i
1998, at 0025 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />, when Emergency Diesel Generator (EDG) 1B failed to start, Calvert '
)
Cliffs' Nuclear Station Unit 1 entered TSAS 3.8.1.1.b. That Action Statement requires that, when in Modes 1-4 with less than two separate and independent diesel generators
. operable, ' two diesel generators must be restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or Unit 1 must be placed in at least Hot Standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Cold Shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. You requested that a Notice of Enforcement Discretion (NOED) be issued pursuant to the NRC's policy regarding exercise of discretion for an operating facility, set out in Section Vll.c, of the " General Statement of Policy ar.d Procedures for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, and be effective for the period beginning at 0025 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> on March 28,1998, and ending at 0625 hours0.00723 days <br />0.174 hours <br />0.00103 weeks <br />2.378125e-4 months <br /> on March 28,1998.
At approximately 0025 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> on March 25,1998,in preparation for taking No.1 A Diesel Generator out-of-service for maintenance, operability testing (Surveillance Requirement
)
= 4.8.1.1.2.a.4)was performed on No.1B EDG as required by TSAS 3.8.1.1.b. During the test, the diesel did not start. The diesel was declared inoperable, and Unit 1 entered the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Action Statement of Limiting Condition of Operation 3.8.1.1, Action b, at the time of taking the 1B EDG out-of-service for testing. Twelve hours of troubleshooting pointed
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to a possible problem with the diesel's governor. The governor was flown to the vendor
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for inspection and confirmation of the troubleshooting findings. Vendor inspection
[
confirmed a problem with a piece of nylon materialin the shutdown solenoid. Following 1
this determination, Calvert Cliff's attempted to return the 1B diesel back to service 4 sing a J
spare governor. This attempt was unsuccessful. As a result, a new governor was
- installed and was shown to be functioning properly. To accommodate completion of testing of the 1B EDG with the new governor, Calvert Cliffs requested enforcement r.
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Charles H. Cruse 2
Idiscretion in the form of a one-time 6-hour extension to the 72-hour Limiting Condition of Operation Action Statement allowed outage time (AOT). Without this discretion, Unit 1 was would have been required to commence a shutdown at 0025 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> on March 28, 1998.
Baltimore Gas and Elec.tric Company (BGE) had evaluated the extension of the period that the EDG would be out-of-service against the probability of a design basis accident and
. believed the risk associated with this condition to be of small consequence due to the short duration and the availability of other mitigating equipment. BGE also~ evaluated the
"?.
increase in the EDG out-of-service time compared to the base AOT using the risk-based maintenance assessment tools available for this purpose. BGE Judged this risk to be acceptable and comparable to the risk of maintenance activities routinely performed within j
the Technical Specification AOTs. BGE considered the possibility of significant hazards associated with this period of noncompliance with Technical Specifications and determined that there were no significant hazards considerations, q
During the period of noncompliance, BGE implemented the following risk-management
{
measures:
Ensured the No.1 A EDG remained operable;
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Ensured the Station Blackout EDG was available in the event the 1B EDG was 1
required;.
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No discretionary maintenance or testing was performed on Unit 1~ safety-related equipment; Plant operators reviewed the actions to be taken in the event of a loss of offsite
- power while the No.1B EDG was not available;
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1 I
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' Had severe weather with the potential to interrupt offsite power occurred during the period of non-compliance, a controlled shutdown of Unit 1 would have taken place; and
- All four offsite power circuits were maintained available.
. The staff reviewed your request to grant enforcement discretion for an additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> from 0025 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> to 0625 hours0.00723 days <br />0.174 hours <br />0.00103 weeks <br />2.378125e-4 months <br /> on March 28,1998,to complete testing of the 1B EDG governor without the need to challenge plant equipment by taking the plant to Cold Shutdown. Consideration for discretion was based on the information provided during the
- telephone conference as outlined above.
,p.
4 On the basis of the staff's evaluation of your request, the staff concluded that an NOED is
. warranted because we are clearly satisfied that this action involved minimal or no safety impact and had no adverse radiological impact to the public's health and safety.
l Thereforefwe have exercised discretion not to enforce compliance with TSAS 3.8.1.1.b for the period from 0025 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> to 0625 hours0.00723 days <br />0.174 hours <br />0.00103 weeks <br />2.378125e-4 months <br /> on March 28,1998. This letter documents our telephone conversation on March 28i 1998 when we verbally issued this notice of 4
'I
Charles H. Cruse 3
enforcement discretion at 0015 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />. We understand that the condition causing the need for this NOED was corrected by you, allowing you to exit from the TSAS 3.8.1.1.b and from this NOED at 0248 hours0.00287 days <br />0.0689 hours <br />4.100529e-4 weeks <br />9.4364e-5 months <br /> on March 28,1998.
As stated in the Enforcement Policy, the NRC will normally take action, to the extent that violations were involved, for the root cause that led to the noncompliance for which this NOED was necessary.
Sincerely, Original Signed by:
Charles W. Hehl, Director Division of Reactor Projects Docket No. 50-317 NOED No. 98-01-002 cc:
T. Pritchett, Director, Nuclear Regulatory Matters (CCNPP)
R. McLean, Administrator, Nuclear Evaluations J. Walter, Engineering Division, Public Service Commission of Maryland K. Burger, Esquire, Maryland People's Counsel R. Ochs, Maryland Safe Energy Coalition State of Maryland (2) i.
Charles H. Cruse 4
Distribution:
H. Miller, RA/W. Axelson, DRA (1)
B. Boger, ADPR, NRR J. Goldberg, OGC J. Lieberman, OE (OEMAIL)
D. Holody, EO, RI B. Fewell, RC D. Screnci, PAO N. Sheehan, FPAO Nuclear Safety Information Center (NSIC)
PUBLIC NRC Resident inspector i
Region 1 Docket Room (with concurrences)
L. Doerflein, DRP S. Barr, DRP T. Hoeg, DRS M. Oprendek, DRP R. Junod, DRP d
NOED File Distribution: (VIA E-MAIL)
B. McCabe, RI EDO Coordinator I
S. Stewart - Calvert Cliffs S. Bajwa, NRR A. Dromerick, NRR M. Campion, RI
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Inspection Program Branch, NRR (IPAS) j DOCDESK DOCUMENT NAME: G:\\ BRANCH 1\\CCNOED.WPD T3 receive a copy of thb document, Indicate in the box:
"C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure "N" = No
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OFFICE RI/ORP b/
RI/DRP l c. RI/0RA A A l
RI/RC M/ l RI/DRP1 jl NAME THoeg /kfV LDoerflein Jigh DHolody V,faf BFewell@
CHehy/ W DATE 03/31/98 03/ 3 /98 03/%\\/98 03/.M /P8 03/// /98 0FFICIAL RECORD COPY I