ML20244C968
| ML20244C968 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 06/09/1989 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8906160005 | |
| Download: ML20244C968 (7) | |
Text
. 6 BALTIM O R E
. GAS AND ELECTRIC CHARLES CENTER P. O. BOX 1475 BALTIMORE, MARYLAND 21203 l
l GroRGE C. CatrL l VicE PRESIDENT l
NucLCan ENEmov (301) 260 445E June 9,1989 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 Combined Insoection Renort No. 50-317/89-04: 50-318/89-04
REFERENCES:
(a) Letter from Mr. J. P. Wiggins (NRC) to Mr. G. C. Creel (BG&E),
dated May 5,1989, same subject Gentlemen:
This transmits our response to Reference (a). Appendix A to Reference (a) is a Notice of Violation which cites four individual violations of NRC requirements. Enclosure (1) provides our response to the Notice of Violation, as required.
Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours,
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GCC/CDS/dtm j Enclosure ec: D. A. Brune, Esquire J. E. Silberg, Esquire R. A.Capra, NRC S. A.McNeil,NRC W. T. Russell, NRC II. Eichenholz/V. L. Pritchett, NRC T. Magette, DNR
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ENCLOSURE' (1) - l
-J RESPONSE TO NRC INSPECTION REPORT 3
' 50-317/89-04; 50-318/89-04 '
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Appendix A of NRC Combined Inspection Report 50-317/89-04; 50-318/89-04 is a Notice of - -
Violation. This Notice of Violation cites four individual violations of NRC requirements. .y i
Below is our response to the vialations listed in Appendix A of the ~ subject Inspection- 'l Report. An extension of five days was . requested of and granted by the ' NRC on -
May 16,1989,' and May 18,1989, respectively, i
- 1. FAILURE TO STRICrLY ADilERE TO ERPIP 3.1, 'IMMEDIATE ACrlONS - FIR E" i A. We have counseled - our Licensed Operators on 'the importance of' strict <
l adherence to pr ocedures regardless of the situation. We have emphasized .l that ERPIP 3.1 contains no latitude with respect to announcing. fires, including fires which are capable of being quickly extinguished. j
.j-l B. We recognize that the broader implications - of a lack ~f o procedural )
compliance are of much greater concern and importance than the specific l
L cases cited in the Notice of Violation. One of the central issues ~. of our' ] ,
Performance Improvement Plan is to assure strict,- uniform . procedural i compliance by reinforcing management expectations regarding ' procedure compliance.
The Quality Assurance Program has been revised with statements of clear, uniform expectations with respect to procedural compliance that apply to all site personnel.
C. Calvert Cliffs is currently in compliance with the procedures ' cited in the Notice of Violation.
We fully realize the importance of strict procedural adherence and the potential consequences of less than complete procedural adherence . by all l site personnel. Improvement in this area has been ~ and will continue to be one of our top priorities as' we implement our Performance Improvement Plan.
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ENCLOSURE (1)-
RESPONSE TO NRC INSPECrlON REPORT 50-317/89-04; 50-318/89-04
- 2. SAFETY- RELATED SNUBBER SURVEILLANCE REQUIREMENT NOT COMPLETELY SATISFIED A. The immediate corrective action was to test greater than 10% of the safety-related snubbers required to support MODE 5 and 6 operation. The complete snubber functional test was recently completed and is . currently awaiting ' final Plant Operations and Safety Review Committee -(POSRC) -
approval.
B. Although our current Surveillance Test Program complies with the require-ments of our Technical Specifications, the Performance Improvement Plan has recognize / that implementation of this program is too decentralized.
Currently, the Procedures Development, Maintenance Planning, Mechanical Maintenance and System Engineering Groups are responsible for test procedure content, test scheduling, test performance, and review of tee results, respectively.
As detailed in our Performance Improvement Plan, we are taking steps to establish central Surveillance Test Program control and to strengthen its lines of responsibility. By August 31, 1989, responsibility for coordina-tion of surveillance test procedure development, scheduling, and review of test results shall be assigned to individual Functional Surveillance Test Coordinators (FSTCs). Each FSTC will be responsible for a particular functional surveillance area, such as fire protection or snubbers, and shall be matrixed to a Site Surveillance Test Coordinator (SSTC). The SSTC will have overall responsibility for implementation and control of the Surveillance Test Program.
A change to Quality Assurance Procedure-7, " Records Management".
Section 9.0, Lost or Damaced Records, is currently in _ progress. This change shall specify the requirements of individuals who are regenerating test records from alternative data sources. It is. estimated that these changes will be complete by the end of June '1989.
C. Calvert Cliffs Unit 2 has been in compliance with Technical Specification Surveillance Requirement 4.7.8.1.c since testing was completed on 10% of the snubbers required for MODE 5 and 6 operation. The Unit will remain in compliance after POSRC review and approval of the regularly scheduled snubber functional test and the implementation of the more centralized Surveillance Test Program.
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- ' ENCLOSURE (1) l RESPONSE TO NRC INSPECTION REPORT. ]
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50-317/89-04; 50-318/89-04. ?
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- 3. FOUR SEPARATE EXAMPLES OF FAILURE TO ESTABLISH ORL IMPLEMENT PROCEDURES AS REQUIRED BY TECHNICAL SPECIFICATION-- 6.8.1 -
2 A. The first three : examples cited failure , to implement procedures. The cause of each example ; was cognitive . personnel- error. ' To prevent' similar personnel ferrors, ' the ; following. corrective . actions have been completed.
o Appropriate personnel actions, including formal- documented counseling of personnel directly involved, was . performed as necessary.
o The General Supervisor - Nuclear Operations. (GS-NO) has emphasized j through. GS-NO Notes and Instructions the seriousness of these events. i These notes have been reviewed with each Operations crew .' and .
suggestions for ways to prevent recurrence have been solicited from the Operations' crews. )
q o GS-NO Standing Instruction 89-2,- " Supervision of Operations j Activities," has been revised to remind Senior. Licensed Operators of their responsibilities when supervising plant evolutions. '];
o A formal Human Performance Evaluation System (HPES) evaluation of the events was performed, - concentrating - on, appropriate preventive I actions. INPO assisted in the evaluation. The HPES evaluation results are currently being . evaluated and implemented as required.
Examples of HPES actions include; human factor review of Operations !
procedures, training of - operators on the administrative aspects of watchstanding, human factors training for procedure writers, review -
of Operations Procedure Writing Guide, and evaluation of additional place-keeping mechanisms for - Operations procedures. )
o A human factors revision to Surveillance Test Procedure STP-O-7, )
" Engineered Safety Features Monthly Logic Test," is. being performed ;
to make it more user-friendly..
The fourth example cited a failure to establish a procedure. Specifically, a Maintenance Order failed to provide clear and specific - instruction for-performing post-maintenance testing. A procedure to clarify instructions for the specific evolution during which the violation occurred, aligning l the actuator for the AFW pump trip / throttle valve, has been developed. ;
Furthermore, Calvert Cliffs . Instruction-200, " Nuclear Maintenance System,"
which controls Maintenance Orders, has been revised. The revision defines - l the difference between detailed planning and a step-by-step procedure and !
the procedure now includes a separate section on planning of post-maintenance testing. This procedure revision is currently awaiting ' final 4 approval of the POSRC. '!
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l 8 -b ENCLOSURE (1)
.f i
RESPONSE TO NRC INSPECTION REPORT i 50-317/89-04; 50-318/89 1 1
B. Our Performance Improvement Plan (PIP) indicates that we have a ' strong ' 1 desire to assure that all required procedures are established and i implemented at Calvert Cliffs. One of the objectives of the PIP is "to j instill an operating philosophy ' throughout the organization where day-to-day approach to the job reflects a commitment to safety and quality first -- where strict adherence to procedures is second nature -- ....
We are aggressively pursuing this environment at Calvert Cliffs. Specific examples in the PIP which - pertain directly to effective implementation and establishment of procedures are:
o Focus meetings to help employees understand the expectations of their Supervisors, e.g., strict procedural compliance; and o The Procedures Upgrade Plan is focused on improving the usability of procedures by providing a higher level of detail and training, and depending less on worker knowledge and experience, in addition to the above cited actions, all significant procedure violations will have a Human Performance Evaluation System or similar investigation performed with the results made available to the NRC. This commitment was previously made in our Restart Commitments letter which was submitted to the NRC on May 23, 1989.
C. We realize the importance of a strong procedural compliance program that includes the elements of individual attention to detail when performing procedures. We feel that complete, well written, user-friendly procedures will complement a strict procedural compliance _ program with a minimum of operational events.
- 4. FAILURE OF POSRC TO DETECT POTENTI Al, SAFETY HAZARDS I l
A. Technical Specification 6.5.1.6.g specifies that the POSRC shall be responsible for review of facility operations to detect potential safety '
l hazards. After thorough review we agree that the three examples cited do represent a failure of the POSRC to meet its responsibility of reviewing operations to detect potential safety hazards. Each case was caused by )
insufficient sensitivity to the issue, i
In the case of No. 22A Steam Generator Blowdown Line, the Chairman of the i POSRC believed that a potential safety hazard had been identified. l Consequently, it was evaluated by members of the technical staff. Based on their report, he made an informed judgement regarding the associated risk.
Having established controls to monitor and trend the degree of leakage, he believed the degree of risk to be acceptable; and thus, authorized start-up l
of the Unit.
l r.
ENCLOSURE (1)
RESPONSE TU NRC INSPECTION REPORT 50-317/89-04; 50-318/89-04 j In the case of the abnormal sulfate concentrations, . some discussion of the !
issue had occurred at POSRC prior to startup. Although the Committee did ]
not smvene and decide to start up with the abnormal sulfate condition, it j was generally aware of the situation. Again the Chairman of the POSRC assessed the condition, relying on information provided by the technical . ;
staff. A peak value of 1.9 ppm sulfate had been identified and was subsequently reduced to less than 0.1 ppm (within the limits of Chemistry.
Procedure CP-204) before the plant startup was commenced on March 26,1989.
In the case of the bearing failure on No. 22 Containment Spray Pump, members of the Maintenance Activity Subcommittee and the Operations .
Subcommittee were aware of the event but apparently did not. consider it a i significant potential safety hazard for the full Committee's consideration. ,
The General Supervisor - Nuclear Operations did identify the need for !
training of non-licensed operators concerning the operation and monitoring l of oil level indicators. At his request, the fall 1987 training schedule was revised to include a training module on oil level indicators.
B. The corrective actions taken include the protracted discussions relating to these three cases between members of the Nuclear Regulatory Commission staff and members of the Calvert Cliffs staff. These discussions have heightened the awareness and increased the sensitivity of the POSRC members with respect to reviewing potential safety hazards. i On March 22, 1989, the Vice President of the Nuclear. Energy Division met with the POSRC members and . their alternates to express his exsetations of the Committee. Specific ernphasis was given to their responsibility for nuclear safety. As a follow-up to the Vice President's message, the Chairman of the POSRC issued a memo on April 6,1989, endorsing the Vice President's expectations of POSRC and stressing his concern for nuclear safety. The Chairman of the POSRC has added a standing agenda item to specifically ask if any Committee member has identified any potential safety hazards. The POSRC charter was revised on May 16, 1989, to add a minimum requirement that the General Supervisor - Quality Assurance have all Level 1 Audit and Surveillance Findings
- and Type A Non-Conformance Reports ** reviewed by the POSRC.
C. The corrective actions identified above also serve to minimize the probability of further violations of this type. . Additionally, the POSRC reviewed the No. 22 Containment Spray Pump bearing failure on May 30, 1989.
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ENCLOSURE (1) 4'
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' RESPONSE- TO NRC INSPECTION REPORT.
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'50-317/89-04; 30-318/89-04 .i j
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- Any l deficient ~.L eondition' that' affects- nuclear . safety . public safety,:
or ~ equipment f operability L as : defined lin the Technical Specifications:
or' the Updated Final Safety Analysis- Report.'
- Type A :NCRs' are, defined as; o procedure , violations - resultirig in ' a stop wor'k order that L eannot be resolved between L the , Supervisor - Quality Control- and.1 the Supervisor of a Work Group, or; 4
o any other condition ' discovered that creates' ' or : may create ' a -
Condition Adverse to' Quality and, as determined by. the
~ Supervisor - Quality Control warrants ' action by the Manager of the Responsible Department.
An exception would be a non-conformance that . is already ' the subject :
of another approved method of documentation and control, such . as, c a Possible Reportable Event form or Licensee Event Report.
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