ML20245D250
| ML20245D250 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 04/18/1989 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8904280185 | |
| Download: ML20245D250 (4) | |
Text
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BALTI M OR E GAS AND ELECTRIC CHARLES CENTER P.O. BOX 1475 BALTIMORE, MARYLAND 21203 GEORGE C. CREEL Vict PntsiotNT Nyctran ENcROY (3o0 aeo-44ss April 18,1989 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 Reniv to NRC Insoection Recort Nos. 50-317/89-03: 50-318/89-03 Gentlemen:
The subject inspection report identified one item of non-compliance with NRC require-ments. Enclosure (1) to this letter is our reply to the Notice of Violation.
Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
/
Very truly yours, 1
/
GCC/DLS/ dim Enclosure cc:
D. A. Brune, Esquire J.
E.
Silberg, Esquire R. A. Capra, NRC S. A. McNe11, NRC W. T. Russell, NRC bq[
H. Eichenholz/V. L. Pritchett, NRC T. Magette, DNR r/[p dd 7
450 8904280185 890418
/
PDR ADOCK 05000317 i
i Q
PDC 1
L__
1 ENCLOSURE (1)
REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-317/89-03; 50-318/89-03 Re-statement of Violation Technical Specification 4.3.1.1 requires that "Each reactor protection instrumentation channel shall be demonstrated operable by the performance of the Channel Check, Channel Calibration and Channel Functional Test operations for the modes and at the frequencies shown in Table 4.3.1."
Table 4.3.1 requires that a channel functional test of the manual reactor trip be performed prior to a reactor startup if not completed within the past seven (7) days.
Contrary to the above, on August 25, 1988, November 15, 1988, and January 11, 1989, reactor startups were performed without the manual reactor trip channel functional test being accomplished within the preceding seven (7) days.
BG&E RESPONSE This violation is a reportable event and was reported in LER 317/89-01, dated March 7,
1989. The event was directly caused when the Surveillance Test Procedure (STP) page that includes the steps to test the manual reactor trip channels was lost i
from the master copy. The root cause was inadequate document control in that there was not an administrative check that would have detected the missing page. A tardy biennial review directly contributed to the repeat occurrences.
CORRECTIVE STEPS TAKEN i
Corrective steps taken following the discovery of the event include:
The STP involved was corrected by adding the missing steps.
A temporary change was instituted to place labels on all STPs. The labels require documentation of page checks before performance of the procedure.
The last performance of each STP was page checked to ensure that no other pages were omitted. No discrepancies were noted.
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No instances of missing procedure pages have occurred since the event.
STEPS TAKEN TO AVOID FUTURE VIOLATIONS 1
The following actions have been identified that will ensure that information has not been lost from procedures, enhance our STP program, improve our biennial procedure review program, and address audits and lessons learned from this violation.
1.
ENCLOSURE (1)
REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-317/89-03; 50-318/89-03 o
To address the aspect of detecting lost pages, procedures were divided into two categories based on their manner of use and, therefore, their susceptibility to pages being lost:
Category 1:
Procedures where copies are made for one-time perform-ance and/or that involve data collection and/or sign-offs, i.e.,
- STPs, Preventive Maintenance Proce-
- dures, Engineering Test Procedures, or Maintenance Procedures. These procedures are most susceptible to lost pages.
Category 1 procedures will be verified to contain the correct pages and revision before masters are filed for use.
Category 1 procedures are checked by the performers for all necessary pages before and after performance of procedures.
Category 2:
Procedures in continuous use to operate and maintain the plant such as Operating Procedures, Operating Instruc-tions, Emergency Operating Procedures, or Abnormal Operating Procedures. Pages are not copied or written on. These procedures are less susceptible to lost pages i
than Category I procedures.
Category 2 procedures will have a periodic page check performed. Periodicities for each type of procedure will be established.
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o An effort had already been initiated prior to this violation to add a 1
purpose statement to each STP to give performers and reviewers a better i
understanding of the scope of what is being accomplished. This action will j
be completed by January 31, 1991.
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We will survey the nuclear industry to identify superior practices and continue to evaluate enhancements in the STP area.
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Biennial review check lists are presently used for some types of procedures i
to ensure consistency of reviews and that the objectives of the reviews are l
satisfied. Check lists will be developed for the remaining types of I
biennially reviewed procedures.
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Biennial reviews are being audited for delinquency and will be promptly performed, if delinquent.
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EN_, CLOSURE (1)
REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-317/89-03; 50-318/89-03 o
A step will be added to Operating Procedure - 6, " Pre-Startup Checkoff," to verify that the Manual Reactor Trip Channels have been tested.
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o Each year, a different 20% of the Technical Specification Surveillance J
Requirements are audited. Every five years, 100% of the Surveillance Requirements are audited. A Quality Assurance audit of the section of the Technical Specifications involved in this violation could have caught this discrepancy, but did not. These audits are not intended to be a 100%
i verification, and do not necessarily check the procedures for both Units.
__ill ensure that g!1 Surveillance Future Quality. Assurance audits w
Requirements being audited are covered by implementing procedures for bath l
Units.
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o Supervisory personnel have been made aware of this event so that lessons learned can be conveyed to those who need to know.
We believe these actions' correct the existing problem of not having an adminis-trative check that would detect a missing procedure page and we believe these actions will prevent recurrence. These actions also strengthen the back-up administrative areas of biennial reviews, quality audits, and STP completion reviews.
FULL COMPLIANCE Full compliance with Technical Specification 4.3.1.1 is being achieved at this time. -
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