ML20236R041
| ML20236R041 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 07/15/1998 |
| From: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-317-98-04, 50-317-98-4, 50-318-98-04, 50-318-98-4, NUDOCS 9807210208 | |
| Download: ML20236R041 (15) | |
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Curutr.s II. CausE Baltimore Gas and Electric Company Vice President Calven Cliffs Nuclear Power Plant Nuclear Energy 1650 Calven Cliffs Parkway Lusby, Maryland 20657 410 495-4455 July 15,1998 U S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
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 -- Notice of Violation (NRC Inspection Report Nos. 50-317/98-04 and 50-318/98-04)
REFERENCES:
(a)
Letter from Mr. J. T. Wiggins (NRC) to Mr. C. H. Cruse (BGE), dated June 15, 1998, Notice of Violation (NRC Inspection Report Nos. 50-317/98-04 and 50-318/98-04)
(b)
Letter from Mr. J. T. Wiggins (NRC) to Mr. C. II. Cruse (BGE), dated May 1,1998, NRC Region 1 Maintenance Rule Team Inspection Report Nos. 50-317/98-04 and 50-318/98-04 This letter provides Baltimore Gas and Electric Company's response to Reference (a), which identified four violations. The violations cited have been addressed as specified in the Enclosure to Reference (a).
The responses to these viciations are provided in Attachments (1) through (4). The corrective actions in this letter were discussed at the Predecisional Enforcement Conference held in response to Reference (b).
In order to assure continued management support and oversight of the Maintenance Rule Program, I have instituted additional monitoring and reporting. In addition to the monthly sycem reports, a specific report to plant management will be made relative to the Maintenance Rule Plant Level indicators.
,o 6 9807210208 980715' PDR ADOCK 05000317 G
Document Control Desk July 15,1998 Page 2-4-
r Should you have questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours, 6.
/
for C. H. Cruse Vice President-Nuclear Energy CHC/KRE/ dim -
Attachments: (1) Response to NRC Inspection Report Nos. 50-317/98-04 and 50-318/98-04 --
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. Violation Al i
(2) Response to NRC Inspection Report Nos. 50-317/98-04 and 50-318/98-04 --
l Violation A2 (3) Response to NRC Inspection Report Nos. 50-317/98-04 and 50-318/98-04 --
Violation B (4) Response to NRC Inspection Report Nos. 50-317/98-04 and 50-318/98 Violation C R. S. Fleishman, Esquire Resident Inspector,NRC cc:
. J. E. Silberg, Esquire R. I. McLean, DNR S. S. Bajwa, NRC J. H. Walter, PSC A. W. Dromerick, NRC J. T. Wiggins, NRC H. J. Miller, NRC l
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ATTACIIMENT (1)
RESPONSE TO NRC INSPECTION REPORT NOS. 50-317/98-04 & 50-318/98-04 VIOLATION A1 Baltimore Gas and Electric Company l
Calvert Cliffs Nuclear Power Plant l
July 15,1998 L-
ATTACIIMENT (1)
RESPONSE TO NRC INSPECTION REPORT NOS. 50-317/98-04 AND 50-318/98-04 VIOLATION Al 10 CFR 50.65(a)(1) requires, in part, the holders of an operating license shall monitor the performance or condition ofSSCs [ systems, structures, and components] within the scope of the monitoringprogram as defined in 10 CFR 50.65(b) against licensee-established goals, in a manner sufficient to provide reasonable assurance that such SSCs are capable offulfilling their intendedfunctions. Such goals shall be established commensurate with safety. When the performance or condition ofan SSC does not meet establishedgoals, appropriate corrective action shall be taken.
10 CFR 50.65(a)(2) requires, inpart, that monitoring as specified in 10 CFR 50.65 (a)(1) is not required where it has been demonstrated that the performance or condition of an SSC is being effectively controlled by performing appropriate preventive maintenance, such that the SSC remains capable of performingits intendedfunction.
Contrary to the above, the licensee permitted a number ofSSCs within the scope ofthe Maintenance Rule to remain under 10 CFR 50.65(a)(2) when preventive maintenancefailed to assure that these SSCs remained capable ofperforming their intendedfunction, as evidenced by thefollowing examples, each of which constitutes a separate violation:
1.
On July 10, 1996, the licensee elected to place the containment spray system under Section 50.65(a)(2). Following a repetitive functionalfailure, identsfied by the NRC, which occurred in March 1997, the licensee incorrectly allowed this system to remain under 10 CFR 50.65(a)(2). The repetitivef,,nctionalfailure demonstrated that thepreventive maintenance being performed on this system was not appropriate in that itfailed to assure that the system remained capable ofperforming its intendedfunction. '.he system should have been placed under 10 CFR 50.65(a)(1)following the repetitivefailure.
I.
ADMISSION OR DENIAL OF THE AII FGED VIOLATION Baltimore Gas and Electric Company accepts the violation as stated.
IL REASON FOR THE VIOLATION Pan of the Maintenance Rule (MR) Baseline Inspection focused on the identification of repetitive functional failures of plant equipment within the scope of the MR. During this review, it was identified that a repetitive functional failure of Unit 2 Containment Spray Check Valve SI-330 had occurred.
Ilowever, this system was not identified as part of the Calvert Cliffs MR Plant Level Indicators. The failure of 2-SI-330 occurred on March 24,1995, and Merch 19,1997.
At Calvert Cliffs Nuclear Power Plant, repetitive functional failures are one element of the MR Plant Level Indicators. Repetitive functional failures are defined as two functional failures occurring to the same device type, within a 24-month period that have the same MR Cause Code, and the same failure mode.
During the review of the methodology used to identify repetitive functional failures, two errors were detected in the methodology as follows:
When identifying repetitive functional failures, the date of occurrence should be used as a screening criteria; however, the out-of-service date was used in the search program; and 1
i ATTACHMENT (1)
RESPONSE TO NRC INSPECTION REPORT NOS. 50-317/98-04 AND 50-318/98-04 l
VIOLATION Al The search period was limited to 24 months.
The definition for repetitive functional failures includes "date of occurrence." Neither the originator nor the reviewer identified the difference between the equipment out-of-service date and the date of occurrence. This error was caused by a lack of attention to detail by both the originator and reviewer.
Use of a 24-month time frame also contributed to the error in not identifying the repetitive functional failore. The causes of this error are that the person performing the search did not recognize the e:ror in using 24 months vice 25, and the search program development was not independently reviewed.
III. CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED The software for identifying repetitive functional failures has been revised to use the date of discovery of a functional failure. Validation testing has been performed on the new software to verify that it correctly identifies all repetitive functional failures. The results of the validation testing have been documented and independently reviewed. The site MR Program was revised to include the System Manager in the identification of functional failures as well as repetitive functional failures.
IV. CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIOM No additional corrective actions are necessary beyond those already taken.
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DATE WHEN FULL COMPLIANCE WILI BE ACHIEVED Full compliance was achieved on May 27,1998, with the issuance of the procedure Managing System Performance (MN-1-112), Revision 3.
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ATTACHMENT (2) l l
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RESPONSE TO NRC INSPECTION REPORT i
NOS. 50-317/98-04 & 50-318/98-04 VIOLATION A2 l
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Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant July 15,1998 u-_-___-------------------_--------------
ATTACIIMENT (2)
RESPONSE TO NRC INSPECTION REPORT NOS. 50-317/98-04 AND 50-318/98-04 1
VIOLATION A2 10 CFR 50.65(a)(1) requires, in part, the holders of an operating lice >tse shall monitor the performance l
or condition ofSSCs within the scope of the monitoring program as defined in 10 CFR 50.65(b) against licensee-established goals, in a manner suficient to provide reasonable assurance that such SSCs are capable offulfilling their intendedfunctions. Such goals shall be established commensurate with safety.
When the performance or condition of an SSC does not meet established goals, appropriate corrective action shallbe taken.
l 10 CFR 50.65(a)(2) requires, in part, that monitoring as specified in 10 CFR 50.65 (a)(1) is not required where it has been demonstrated that the performance or conditious of an SSC is being effectively controlled by performing appropriate preventive maintenance, such that the SSC remains cwable of performing its intendedfunction.
Contrary to the above, the licensee permitted a number ofSSCs within the scope ofthe Maintenance Rule to remain under 10 CFR 50.65(a)(2) when preventive maintenance failed to assure that these SSCs remained capable ofperforming their intendedfunction, as evidenced by thefollowing examples, each of which constitutes a separate violation:
l 2.
On July 10,1996, the licensee electedtoplace the 4KVelectricaldistribution bus, instrument air system air amphfier, hydrogen recombiner, hydrogen analy:er and auxiliaryfeed water systems under Section 50.65(a)(2). Following repetitivefunctionalfalures and/or excess unavailability times, the licensee incorrectly allowed the systems to remah under 10 CFR 50.65(a)(2) for excessiveperiods oftime rangingfrom three months to 1.5 years. The repetitivefunctionalfailures and/or excess unavailability times demonstrated that the preventive maintenance being performed on these systems was not appropriate in that itfailed to assure that the systems remained capable ofperforrsing their intendedfunctions. The systems should have been placed under 10 CFR 50.65(a)(1) in a timely manner commensurate with safety follow'ng the repetitive functional l
failures and/or excess unavailability times.
I.
ADMTSSION OR DENIAL OF THE AII FGED VIOLATION Balttnore Gas and Electric company accepts the violation as stated.
IL REASON FOR THE VIOLATION The causes of this violation are as follows:
l A.
The site Maintenance Rule Coordinator (MRC) failed to generate an Issue Report to classify SSCs as (aXI) due to repetitive functional failures. The MRC is responsible for evaluating the results and designating SSCs as (aXI).
B.
The process used to capture functional failures for updating MR performance indicators delayed identification of (aXI) performance. The original process developed for MR implementation relied exclusively on the performance indicators for (a)(1)/(aX2) determinations. System Managers were not expected to identify SSCs for (aXI) status by any other means then their system level performance indicators.
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RESPONSE TO NRC INSPECTION REPORT NOS. 50-317/98-04 AND 50-318/98-04 VIOLATION A2 I
The process for capturing failures relied on a maintenance order review by the Reliability Engineering Unit following close-out of the maintenance order.
In many instances, a l
maintenance order would remain open for extended periods, wisich would delay including the L
failures in the performance indicators.
C.
System Managers did not understand the relationship between system performance and system level performance indicators. The initial performance indicators developed for the MR used a single indicator that included both reliability and unavailability. With this indicator, it was l
difficult to determine the impact of a failure or unavailability on the (aXI)/(a)(2) status of an SSC.
D.
The (a)(1) classification process relied on the publishing of the quarterly performance indicators to make the (aXI)/(aX2) determination. As stated earlier, it was difficult to determine the impact of failures or unavailability on the Reliability Index. The MR process used at the time, directed the System Managers to evaluate their systems for (aX1) based on the performance indicators, not their assessment of system performance.
III. CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED All SSCs identified as remaining in (aX2) status when they should have been considered (a)(1) were placed in (aXI) prior to the NRC inspection of our MR Program. As part of the replacement of the Reliability Index with individual reliability and unavailability indicators, all scoped SSCs were reviewed for(aXI) status.
Two SSCs, the Main Steam Safety Valves and the Pressurizer Heater Sleeves, were designated (a)(1) i l
during the 1998 Refueling Outage while the process changes were being made. In both cases, the System Manager designated the SSC as (aXI) within one week of the event that challenged the system performance criteria. Once System Mangers were made aware of the new expectations, they were easily able to implement the changes.
The MR implementation procedure, MN-1-ll2, has been revised to provide System Managers with additional guidance for failure and unavailability review. System Managers are now instructed to evaluate their systems for (aXI) anytime an event occurs that may challenge the performance criteria.
Failures are now identified by the System Manager for inclusion in the next quarterly performance indicator report. All repetitive functional failures have been reviewed.
The Reliability Index has been replaced with separate reliability and unavailability indicators. In addition, the requirement to write an issue Report when a performance criteria is exceeded has !wn reinforced with all System Managers.
IV. CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS No additional corrective actions are necessary beyond those already taken.
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s ATTACHMENT (2)
RESPONSE TO NRC INSPECTION REPORT NOS. 50-317/98-04 AND 50-318/98-04 i
l VIOLATION A2 i
V.
DATE WHEN FULL COMPLIANCE WII T BE ACIIIEVED l
Full compliance was achieved on July 10, 1998, with the completion of the review of all current l
repetitive functional failures.
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ATTACHMENT (3)
RESPONSE TO NRC INSPECTION REPORT NOS. 50-317/98-04 & 50-318/98-04 VIOLATION B
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Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant July 15,1998 l
ATTACHMENT (3) l
. RESPONSE TO NRC INSPECTION REPORT NOS. 50-317/98-04 AND 50-318/98-04 VIOLATION B 1
l 10 CFR 50.65(a)(1) requires, in part, that holders ofan operating license shall monitor the performance or condition of SSCs, within the scope of the monitoring program, as defined by 10 CFR 50.6S(b),
against licensee-established goals, in a manner sufficient to provide reasonable assurance that such SSCs are capable cffulfilling their intendedfunctions. Such goals shall be established commensurate l
with safety and, where practical, take into account industry-wide operating experience. When the
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performance or condition of a SSC does not meet establishedgoals, appropriate corrective action shall be taken.
.10 CFR SO.65(a)(2), requires, in part, that the monitoring as specified in 10 CFR 50.6S(a)(1) is not required where it has been demonstrated that the performance or condition of a SSC is being efectively controlled by performing appropriate preventive maintenance, such that the SSC remains capable of performingits intendedfunction.
Contrary to 10 CFR $0.65(a)(2), as ofJuly 10,1996, the time that the licensee elected to not monitor the performance or condition of the emergency diesel generator building heating, ventilation and air conditioning system against establishedgoals pursuant to the requirements ofSection (a)(1), the licensee failed to demonstrate that the performance or condition ofSSCs within the scope of10 CFR 50.65 had been efectively controlled byperforming appropriate preventive maintenance. Specifically, the licensee i
hadfailed to establish performance measuresfor the system and was therefore unable to efectively demonstrate the system remained capable ofperforming its intendedfunction.
I.
ADMISSION OR DENIAL OF THF MLFGED VIOLATION l
Baltimore Gas and Electric Company accepts the violation as stated, i
IL REASON FOR THE VIOLATION The Emergency Diesel Generator (EDG) Heating, Ventilation, and Air Conditioning (HVAC) System was added as part of a plant modification to install additional EDGs. This project was completed and i
became operational in the spring of 1997. This system was not part of the plant design when the original l
MR scoping work was completed. As part of the scoping process, informal methods were established to -
l' periodically review site documents for changes that would require an update to the MR scoping l
document. This included changes to Emergency Operating Procedures, Quality List, and plant modifications. The EDG HVAC System was included in the scope of the MR as part of Revision 3 to the MR scope document, which was issued September 30,1997. At this time, the MR scoping document l
was controlled by the Life Cycle Management Unit, which only had responsibility to maintain the scoping document. The Reliability Engineering Unit was responsible for developing performance l
criteria for risk-significant SSCs. Reliability Engineering developed performance criteria for one of the L
new EDGs (No. lA) using the Reliability Index that included the HVAC System. The other diesel l
generator (No.OC) was monitored by separate unavailability and reliability indicators for the EDG.
Separate indicators were not developed for the new EDG HVAC System.
There are two causes for our failure to develop specific SSC level performance indicators for this system.
A formal tie was not established with the modification process to review modifications during close-out for changes to the MR Program. With a formal process in place, the MR scoping document would have been updated soon after the EDG HVAC System had been placed in service. The second cause involves 1
ATTACIIMENT (3)
RESPONSE TO NRC INSPECTION REPORT NOS. 50-3I7/98-04 AND 50-3I8/98-04 VIOLATION B multiple ownership of responsibilities with the MR Program. Life Cycle Management maintained the scope document and Reliability Engineering developed performance indicators.
No one had responsibility to ensure that the performance indicators developed were in alignment with the MR l
scoping document.
III. CORRECTIVE STEPS TIIAT IIAVE BEEN TAKEN AND RESULTS ACIIIEVED The MR scoping document was revised to explicitly define the functions of concern for the EDG liVAC System. This was done as part of our MR scoping document review of all SSCs. In addition, performance criteria were developed and published in the first quarter 1998 MR performance indicator report. As a result of the performance indicator development, the EDG IIVAC System has been classified as (a)(2) under the MR Program.
A change has been made to the site modification procedure (EN-1-100) to include notification of the MRC in the close-out process. 'Ihis involves a formal review of the modification to capture any changes to the MR Program. In addition, ownership of the MR scoping document has been given to the MRC. It is now the responsibility of the MRC, working with the System Managers, to ensure that all SSCs have adequate performance indicators established.
IV. CORRECTIVE STEPS TIIAT WILL BE TAKEN TO AVOID FURTIIER VIOLATIONS No additional corrective actions are necessary beyond those already taken.
V.
DATE WIIEN FULL COMPLIANCE WILL BE ACIIIEVED Full compliance was achieved on May 12,1998 with the is:uance of the new EDG IIVAC performance criteria.
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ATTACHMENT (4) l I
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RESPONSE TO NRC INSPECTION REPORT NOS. 50-317/98-04 & 50-318/98-04 VIOLATION C l
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Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant July 15,1998 t
ATTACHMENT (4)
RESPONSE TO NRC INSPECTION REPORT NOS. 50-317/98-04 AND 50-318/98-04 VIOLATION C 10 CFR 50.65(a)(1) requires, in part, that the holders of an operating license shall monitor the performance or condition of SSCs within the scope of the rule as defined by 10 CFR 50.65(b) against licensee-established goals, in a manner sufficient to provide reasonable assurance that such SSCs are capable offulfilling their intendedfunctions. Such goals shall be established commensurate with safety.
When the performance or condition of an SSC does not meet established goals, appropriate corrective l
action shallbe taken.
10 CFR 50.65(b)(1) requires, in part, that the holders of an operating license shall include within the scope of the monitoring program specified in 10 CFR 50.65(a)(1), safety-related SSCs that are relied upon to remainfunctional during andfollowing design basis events to ensure the integrity of the reactor coolant pressure boundary, the capability to shut down the reactor and maintain it in a safe shutdoun condition, and the capability to prevent or mitigate the consequences of accidents that could result in potential offsite exposure comparable to the 10 CFR Part 100 guidelines. The scope shall also include non-safety related structures, systems, or components that are relied upon to mitigate accidents or transients, or are used in the plant emergency operating procedures, or whose failure could prevent safety-related structures, systems, and componentsfromfulfilling their safety-relatedfunction, or whose failure could cause a reactor scram or actuation ofa safety-relatedsystem.
Contrary to the above, as of July 1997, the licensee hadfailed to include within the scope of the Maintenance Rule program the portion of the emergency lighting system located outside the control room, which is requiredfor safe shutdown oftheplant.
I.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Baltimore Gas and Electric Company accepts the violation as stated.
II. REASON ED O*HE V7JLATION l
Baltimore Gas and Electric Company's interpretation of the MR scoping criteria did not support inclusion of the entire Emergency Lighting System. We included the safety-related portions based on the MR scoping criteria, but did not originally feel the 10 CFR Part 50, Appendix R, portion outside the Control Room provided a significant contribution to successful completion of emergency operating procedure activities. In addition, alternative means are available for illumination in plant areas. (hand-carried flashlights) A review of several NRC baseline inspections and Regulatory Guide 1.160, Revision 2, indicated that our conclusions differed from the NRC's.
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III. CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED Baltimore Gas and Electric Company made the decision in June 1997 to include additional portions of the Emergency Lighting System within the scope of the MR. The revised MR scoping document was issued on September 30,1997 to incorporate this change.
During the MR scoping document review and new performance indicator development, a broader interpretation of the MR scoping criteria was used. Additionally,if there is any question as to whether an SSC should be in the scope of the MR, the decision will be referred to the MR Expert Panel for resolution.
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ATTACHMENT (4)
RESPONSE TO NRC INSPECTION REPORT NOS. 50-317/98-04 AND 50-318/98-04 VIOLATION C IV. CORRECTIVE STEPS THAT WIIL BE TAKEN TO AVOID FURTHER VIOLATIONS No additional corrective actions are necessary beyond those already taken.
V.
DATE WHEN FULL COMPLIANCE WII L BE ACHIEVED Full compliance was achieved on September 30,1997, with the inclusion of emergency lights in the scope of the MR.
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