IR 05000317/1993002
| ML20035G029 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 04/19/1993 |
| From: | Blough A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Denton R BALTIMORE GAS & ELECTRIC CO. |
| References | |
| NUDOCS 9304260044 | |
| Download: ML20035G029 (3) | |
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%FR 1 9 1993 f
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. Docket Nos. 50-317
.j 50-318
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i Mr. Robert Vice President - Nuclear Energy
Baltimore Gas and Electric Company l
Calvert Cliffs Nuclear Power Plant j
1650 Calvert Cliffs Parkway l
Lusby, Maryland 20657 - 4702 i
Dear Mr. Denton:
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COMBINED INSPECTION REPORT 50-317/93-02 AND 50-318/93-02 l
i This refers to your March 29,1993 correspondence, in response to our February 25,1993
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letter.
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Thank you for informing us of the corrective and preventive actions documented in pur f
letter. These actions will be examined during a future inspection of your licensed program.
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Your cooperation with us is appreciated.
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Sincerely,
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A. Randolph Blough Projects Branch 4
Division of Reactor Projects
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9304260044 930419 PDR ADOCK 05000317
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PDR OFFICIAL RECORD COPY-f a:RL9302 u
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Mr. Robert ;
cc w/ encl:
G. Detter, Director, Nuclear Regulatory Matters (CCNPP)
R. Mclean, Administrator, Nuclear Evaluations i
J. Walter, Engineering Division, Public Service Commission of Maryland K. Burger, Esquire, Maryland People's Counsel
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R. Ochs, Maryland Safe Energy Coalition
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K. Abraham, PAO (2)
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Public Document Room (PDR)
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Local Public Document Room (LPDR)
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Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of Maryland (2)
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i OFFICIAL RECORD COPY a:RL9302
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i Mr. Robert bec w/ encl:
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Region I Docket Room (with concurrences)
C. Cowgill, DRP
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J. Yerokun, DRP L. Nicholson, DRP
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D. Weaver, DRP P. Wilson, SRI - Calvert Cliffs V. McCree, OEDO i
R. Capra, NRR
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D. Mcdonald, NRR DRS/EB SALP Coordinator
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D. Holody, EO
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pFWilso LBriggs RBlough l
I 04/ /93 04//93 04/(/93
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OFFICIAL RECORD COPY a:RL9302
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',..- l BALTIMCRE j
GAS AND l
ELECTRIC 1650 CALVERT CUFFS PARKWAY. LUSBY, MARYLAND 20657-4702 RostRT E.DENTON VICE PRESCENT NUCLE AR ENERGY (**o) 260-sets March 29,1993 U. S. Nuclear Regulatory Commission i
Washington,DC 20555 ATI'ENTION:
Document Control Desk SUBJECT:
Calvert Cliffs Nuc! car Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Besponse to Spent Fuel Pool Crane Testine Notice of Violation REFERENCb:
(a)
Letter from Mr. C. J. Cowgill (NRC) to Mr. R. (BG&E),
dated June 5,1992, NRC Region I Resident Inspection of Calvert Cliffs Units 1 and 2, Combined Inspection Report Nos. 50-317/93-02 and 50-318S3-02 Gentlemen:
In response to Reference (a), Attachments (1) and (2) are provided.
Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
Very trulyyours.
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for R. Vice President-Nuclear Energy RED /DWM/dwm/bjd Attachments r. ~; ;
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Document Control Desk l
March 29,1993 l
Page 2
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cc:
D. A. Brune, Esquire
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l J. E. Silberg, Esquire
.I R. A. Capra, NRC l
D. G. Mcdonald, Jr., NRC
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T. T. Martin, NRC
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P. R. Wilson, NRC i
l, R. L McLean, DNR
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J. H. Walter, PSC
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A~ITACIIMENT (1)
NOTICE OF VIOLATION 50-317(318)/93-02/01 Notice of Violation 50-317 and 50-318S3-02/01 states that contrary to Technical Specification 6.8.1.g, during spent fuel pool crane testing between January 4-19,1993, five personnel exceeded 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of work in a seven day period without prior written authorization.
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DESCRIPTION AND CAUSE OF EVENT
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In December of 1992, a new single failure proof spent fuel pool (SFP) area crane trolley wm installed above the SFP, upgrading a preexisting crane. The crane upgrade was installed to enable transfer of a spent fuel cask from the SFP to a vehicle which transports the spent fuel cask to the Independent Spent Fuel Storage Installation. The SFP crane was tested by contractors directed by BG&E personnel.
During the testing of the SFP crane, the test coordinator, test engineer, two vendor l
representatives and one BG&E electrician worked more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a seven day period
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without pre-approvalin wTiting by the Plant General Manager, appropriate Superintendent or General Supenisor. This violated the provisions of Calvert Cliffs Instruction (CCI)-159,
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Use of Overtime."
The cause of this event is that the personnelinvolved were not familiar with the need to have written approval prior to exceeding the overtime limits. They did not receive adequate instruction on the applicability of this Calvert Cliffs procedure to their work.
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IL CORRECTIVE STEPS TAKEN AND RESUt;TS ACIIIEVED
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We have counseled the appropriate personnel involved in this matter and have provided instruction to personnel involved in similar projects on the applicability of procedures regarding use of overtime. De specific problems resulting in this violation were reviewed with all project personnel, emphasizing the errors made.
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IIL CORRECTIVE STEPS WIIICII M7LL BE TAKEN TO AVOID FURTIIER VIOLATIONS
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ne overtime policy will be added to the Calvert Cliffs Initial Supenisor Training Program, including discussion of the industry experience which led to these controls. New Project l
Management supervisors will receive this training.
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D ATE WIIEN FULL COMPLIANCE WILL IIE AClIIEVED l
Full compliance was achieved when the problem was discovered and the affected personnel j
were informed of overtime policies regarding written authorization.
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ATTACIIMENT (2)
l NOTICE OF VIOLATION 50-317(318)/93-02/01
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Notice of Violation 50-317 and 50-318/93-02/02 states that contrary to Technical Specification 6.8.1.a. there were four instances of procedural noncompliance associated with testing of the spent fuel pool area crane between January 4 and January 19,1993.
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DESCRIPTION AND CAUSE OF EVENTS
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The recently installed spent fuel pool (SFP) area crane has two hooks, a small auxiliary hook, and a large main hook. Three Engineering Test Procedures (ETPs) were written to perform the testing. Engineering Test Procedure 92-129 performed a functional test of the overall crane. Engineering Test Procedure 92-130 tested the interlocks and protective circuitry for j
the auxiliary hook. Engineering Test Procedure 92-131 tested the interlocks and protective circuitry for the main book.
A.
An individual who signed three changes to ETPs as a Procedure Screener was not i
fully certified to screen changes to ETPs. The individual had been trained and his qualification card was complete, but the card had not been signed by a General Supervisor as required by PR-1-102.
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Performance of an ETF was not immediately halted when it was discovered that the ETP could not be performed as written. On January 19,1993, personnel performing ETP 92-129 found that physical obstructions in the building and the size of the test l
load platform did not allow the loaded crane trolley to be moved to the full travel limits specified in the procedure.
A Quality Verification (OV) technician recommended that project personnel lower the load putting the equipment in a safe condition. While the QV technician was calling his supervisor, the Project Manager had the crane moved to determine what other physical limitations would restrict the l
crane's movements. He thought this was within the scope of the existing procedure i
since the procedure specified moving the load to the full travel limits and believed it to be conservative as the load would not need to be raised a second time following revision of the ETP to reflect the physicallimitations. The move was completed and the load was placed on the floor before the QV technician finished speaking to his
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supemsor.
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A procedure step was not performed in accordance with the procedure and was incorrectly signed off as being done as written. On January 17, 1993, the vendor technical representative found that a step in ETP 92-131 for the main hook could not be performed as written. Calvert Cliffs Instruction (CCI)-132, " Requirements for Implementation, Use, and Record Keeping of ETPs." requires that if an ETP can not be performed as written, the test will be stopped and the affected equipment placed i
i in a safe condition. The ETP shall then be changed in accordance with Calvert Cliffs
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Administrative Procedure PR-1-101, ' Preparation and Control of Calvert Cliffs l
Technical Procedures." Although the step for setting the load cell was changed in ETP 92-130 for the auxiliary hook, the identical step was not revised in ETP 92-131 for the main hook. Tne technical representative did not perform the step in accordance with ETF 92-131 and this step in the test was incorrectly signed off as
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D.
Attendance at the pre-evolution briefings did not include all personnel involved in i
the ETPs, as required by CCI-132 and CCI-140.
Engineering Test l
Procedures92-129,92-130 and 92-131 were begun January 4,1993, and concluded
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ATTACIIMENT (2)
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NOTICE OF V101ATION 50-317(3IS)/93-02/01
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January 19,1993. Calvert Cliffs Instruction (CCI)-132 requires that pre-evolution l
briefs be conducted as described in CCI 132 and CCI-140, " Conduct of Operations." -
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CCI-140 also states that any persons not attending the brief that need to become
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involved in the evolution shall be properly briefed prior to beginning any involvement in the evolution. Though briefings were held, attendees consisted of the Test
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Coordinator and representatives from Construction Inspection and contractor l
supervision. He Test Coordinator briefed Operations personnel in the Control Room prior to performing the ETPs. Crane operators and crane vendor technical representatives participated in separate briefings on the deck. Written records of I
attendance were incomplete and not all personnel involved in preparing for the lifts i
and their conduct were included.
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The cause of these events was that personnel imulved were not familiar with the
administration of technical procedures applicable to post modification testing and did not provide adequate supervision of the vendor technical representatives. Normally, System j
Engineering personnel would provide support for Post Modification Testing as specified in
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CCI-705, " Design Change and Modification Implementation." In this instance, a project l
manager inexperienced with Calvert Cliffs administration of technical procedures directed j
the testing without sufficient System Engineer involvement. There was a lack of attention to j
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CORRECTIVE STEPS TAKEN AND RESULTS ACIllEVED l
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All of the SFP crane testing was successfully re-performed and properly documented.
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His event was reviewed with System Engineering and Project Management personnel, emphasizing the requirements in CCI-705 concerning customer participation in projects.
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ne specific crane testing problems resulting in this violation were reviewed with all Project Management personnel, emphasizing the errors made.
Appropriate personnel actions have been taken.
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III.
CORRECTIVE STEPS MTIICII WILL IIE TAKEN TO AVOID FURT!IER VIOLATIONS The above actions are sufficient to avoid similar future violations.
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DATE %1IEN FIJLL COMPLIANCE WILL IlE ACIIIEVED
Because post-modification testing had not been previously completed, the crane had never
been improperly certified or used for fuel movement. Full compliance with test requirements
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was achieved by suspending testing when the procedural compliance problems werc
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discovered. The crane was subsequently successfully tested in accordance with procedures.
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