IR 05000317/1996006

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-317/96-06 & 50-318/96-06

ML20134M746
Person / Time
Site:	Calvert Cliffs
Issue date:	11/14/1996
From:	Doerflein L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Cruse C BALTIMORE GAS & ELECTRIC CO.
References
NUDOCS 9611260028
Download: ML20134M746 (2)

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1g November 14,1996 l l

l Mr. Charles Vice President - Nuclear Energy l Baltimore Ga,s and Electric Company Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway ,

I Lusby, Maryland 20657 - 4702 l

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Dear Mr. Cruse:

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Subject: NRC Inspection Report Nos. 50-317/96-06; 50-318/96-06 and Notice of Violation j

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This letter refers to your October 22,1996 correspondence, in response to our j September 23,1996 letter, j

, . l l Thank you for informing us of the corrective and preventive actions documented in your l l letter. These actions will be examined during a future inspection of your licensed program, j Your cooperation with us is appreciated.

Sincerely, Original Signed by:

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l Lawrence T. Doerflein, Chief '

Projects Branch 1 l l Division of Reactor Projects l'

Docket Nos. 50-317 50-318 l cc:

T. Camilleri, Director, Nuclear Regulatory Matters (CCNPP)

R. McLean, Administrator, Nuclear Evaluations J. Walter, Engineering Division, Public Service Commission of Maryland (

l l- cc w/ copy of Licensee's Response Letter:

. K. Burger, Esquire, Maryland People's Counsel

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R. Ochs, Maryland Safe Energy Coalition

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State of Maryland (2)

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9611260028 961114 PDR G

ADOCK 05000317 I PDR OFFICIAL RECORD COPY IE:01

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t Robert E. Denton 2 Distribution w/ copy of Licensee's Response Letter:

W. Dean, OEDO (WMD)

S. Bajwa, NRR A. Dromerick, NRR G. Vissing, NRR l M. Campion, RI l S. Stewart - Calvert Cliffs D. Screnci, PAO Region i Docket Room (with concurrences)

PUBLIC Nuclear Safety Information Center (NSIC)

Inspection Program Branch, NRR (IPAS)

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DOCUMENT NAME: G:\ BRANCH 1\RL960606.CC

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To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" =

Copy with attachment / enclosure "N" = No copy OFFICE Rl/DRP Hl/DRP NAME SStewart dfh) h LDoerfleiVfU

. DATE Jy/d/96 ' -

ly/q/96 OFFICIAL RECORD COPY T

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d l CHARLES II. CRUSE Baltimore Gas and Electric Company l

Vice President Calven Cliffs Nuclear Power Plant Nuclear Energy 1650 Calven Cliffs Parkway Lusby, Maryland 20657 l

410 495-4455 j

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October 22,1996 i

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I U. S. Nuclear Regulatory Commission l

Washington, DC 20555 i ATTENTION: Document Control Desk SUBJECT: Calvert Cliffs Nuclear Power Plant

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Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 3 Reoly to a Notice of Violation --Insocction Reoort Nos. 50-317(318V96-06

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j REFERENCE: (a) Letter from Mr. L. T. Doerflein (NRC) to Mr. C. (BGE), dated September 23, 1996, NRC Region I Integrated Inspection Report Nos. 50-317/96-06 and 50-318/96-06 and Notice'of Violation i.

In response to Reference (a), Attachment (l's details our response to the cited violation concerning a i failure to follow procedures during the return of a saltwater header to operation following system maintenance.

Should you have questions regarding this matter, we will be pleased to discuss them with you.

Very truly yours, N

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/ &frV CHC/DWM/bjd Attachment cc: D. A. Brune, Esquire II. J. Miller, NRC J. E. Silberg, Esquire Resident Inspector,NRC Director, Project Directorate I-1, NRC R. I. McLean, DNR A. W. Dromerick, NRC J. II. Walter, PSC

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A'ITACIIMENT (I)

J NRC INSPECTION REPORT NOS. 50-317(318)/96-06-01 NOTICE OF VIOLATION - SAFETY SYSTEM MISALIGNMENTS DURING SALTWATER AND SERVICE WATER SYSTEM MAINTENANCE.

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Notice of Violation 50-317/96-06-01 and 50-318/96-06-01 describes a nonconformance involving a I failure to follow procedures during the retum of a saltwater header to operation following system maintenance. The Notice of Violation states, in part, that:

On August 12, 1996, an activity affecting quality was not accomplished in accordance with documentedprocedures when the No. I1 Emergency Ccre Cooling System (ECCS) air coolerfan control switch was not placed in AUTO during the return of the No.11 saltwater header to l operationfrom the drainedcondition. Instead, the switch wasplacedin STOP.

I. REASON FOR THE VIOLATION l

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On August 12, i996 at 2325 hours0.0269 days <br />0.646 hours <br />0.00384 weeks <br />8.846625e-4 months <br />, a Control Room Operator (CRO) restored the 11 saltwater

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header to service in accordance with Operating Instruction 01-29, " Saltwater System," following scheduled maintenance. A step in the procedure required the 11 ECCS Air Cooler to be set in AUTO. A later procedure step required that Performance Evaluation PE l-12-ll-O-C be performed to test the saltwater header following restoration. This PE would not have resulted in any additional actions with the ECCS Air Cooler Ventilation System. The CRO, however, erroneously performed PE l-12-11-0-M, which required thn the air cooler be started. He had l

correctly performed 01-29 three times in the previous monto ud was relying on memory rather than a careful step-by-step self-check. As a result, he performed the wrong PE. After the l completion of this procedure step, at approximately 2325 hours0.0269 days <br />0.646 hours <br />0.00384 weeks <br />8.846625e-4 months <br />, the CRO, focusing on the fact I

that the test was complete, placed the fan handswitch in STOP. This was not in accordance with the Performance Evaluation, which included a step to return the handswitch to AUTO. He did i

not perform proper self-checking to ensure that the handswitch was left in the proper position, as l

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l required by the procedure and in accordance witt management's expectation. Independent verification of this handswitch position was not performed nor was it required either at this time or during shift turnover.

The Control Room Supervisor had been monitoring the CRO's actions but was called away due to a plant computer problem prior to performance of the PE Ilis post-evolution review did not include any specific panel checks to verify that the header was properly restored. It was not a management expectation that he do so.

On August 13,1996 at 1310 hours0.0152 days <br />0.364 hours <br />0.00217 weeks <br />4.98455e-4 months <br />,12 Service Water header was administratively removed from service for routine flow capacity testing. As a result, the IB Emergency Diesel Generator, which supplies backup power to 12 ECCS train, was out-of-service since the 12 Service Water header is

its heat sink. With the 11 ECCS cooler handswitch in STOP and backup power unavailable to j the 12 ECCS train, Technical Specification 3.0.5, which requires full restoration of one of the i

systems within two hours, was inadvertently entered. The mispositioned handswitch was

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discovered during a routine panel walkdown by the Unit 2 Control Room Supervisor at 1335

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hours, approximately 25 minutes later. It was restored after a brief consultation with the Unit 1 Control Room Supervisor and the Shift Supervisor. At the ti.me, the Control Room personnel

realized that the plant had been in Technical Specification 3.0.5 for the previous 25 minutes.

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ATTACHMENT (1)

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NRC INSPECTION REPORT NOS. 50-317(318)/96-06-01 NOTICE OF VIOLATION - SAFETY SYSTEM MISALIGNMENTS DURING

, SALTWATER AND SERVICE WATER SYSTEM MAINTENANCE. I l

Contributing to this event was poor human factors design of the fan position indicating lights. l Both the STOP and AUTO lights for this switch are lit when the switch is in either the STOP or l l AUTO position. The only method for determining actual position is to look at the indicating l l arrow on the switch knob. The arrow is difficult to see due to its location on the panel and is !

misleading since, with the switch in AUTO, the arrow points straight up between the STOP and :

. AUTO positions. A panel check performed at the time 12 Service Water header was administratively removed from service failed to note the mispositioned handswitch primarily due i

to the poor human factors design of the fan position indicating lights.

t l A similar event had occurred on March 20,1996 when the 21 Service Water heat exchanger had

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been taken out of service and, on restoration, a blowdown recovery valve was not placed in its correct position. In light of this and other previous similar events, the root cause analysis of this item concluded that the current Operations human performance model does not adequately account for the risk sensitivity of certain evolutions and ensure that secondary barriers are in place to increase the probability of success. In this event, correct performance of the CRO was the only barrier to ensure that the procedure was properly performed and the equipment was l correctly restored.

II. CORRECTIVE STEPS TAKEN AND RESULTS ACIHEVED l l

l The handswitch was restored to the AUTO position shortly after it was discovered in the STOP position.

l l The CRO who mispositioned the switch was provided appropriate coaching and counseling to improve his self-assessment techniques. This event has been reviewed with all shift crews.

IIL CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER I

l VIOLATIONS l

l The ECCS fan handswitch has been administratively controlled such that a second check of position is required upon changing the handswitch po;iiion. We are currently evaluating a modification to the switch to incorporate an automatic return to the AUTO position after maaipulation. Once this modification is in place, the second check of handswitch position will be discontinued. The ECCS fan handswitch position indicators are being modified to incorporate appropriate human factors. Control Room walkdowns will be conducted to determine if similar

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problems exist with other indicators.

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! Procedure 01-29 is being reviewed to ensure that adequate second checks are in place for restoration of critical equipment. Other risk sensitive evolutions will be evaluated to determine if similar actions are warranted.

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. ATTACHMENT (1)

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NRC INSPECTION REPORT NOS. 50-317(318)/96-06-01 NOTICE OF VIOLATION - SAFETY SYSTEM MISALIGNMENTS DURING SALTWATER AND SERVICE WATER SYSTEM MAINTENANCE.

I IV. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on August 13,1996 at 1335 hours0.0155 days <br />0.371 hours <br />0.00221 weeks <br />5.079675e-4 months <br /> when the ECCS fan handswitch i was restored to the AUTO position.

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