ML20035B276
| ML20035B276 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 03/29/1993 |
| From: | Denton R BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9304010129 | |
| Download: ML20035B276 (5) | |
Text
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BALTIMORE GAS AND ELECTRI I
1650 CALVERT CLIFFS PARKWAY. LUSBY, MARYLAND 20657-4702 ROBERT E. DENTON VicE PRESIDENT NUCLEAR [NERGY (4so) e6o-44ss March 29.1993 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 Response to Spent Fuel Pool Crane Testine Notice of Violation
REFERENCE:
(a)
Letter from Mr. C. J. Cowgill (NRC) to Mr. R. E. Denton (BG&E),
dated June 5,1992, NRC Region I Resident Inspection of Calvert Clifts Units 1 and 2, Combined Inspection Report Nos.50-317S3-02 and 50-318S342 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 truly you:s,
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for R. E. Denton Vice President-Nuclear Energy RED /DWM!dwm/bjd Attachments pd,p/1 o
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9304010129 930329 i
PDR ADOCK 05000317 G
Document Control Desk i
- March 29,1993 Page'2 cc:
D. A. Brune, Esquire J. E. Silberg, Esquire j
R.- A. Capra, NRC D. G. Mcdonald, Jr., NRC T. T. Martin, NRC l
P. R. Wilson, NRC R. I. McIzan, DNR J. H. Walter, PSC F
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ATTACilMENT U) j NOTICE OF VIOLATION 50-317(318)/93-02/01 P
Notice of Violation 50-317 and 50-318/93-02/01 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.
L DESCRil' TION AND CAUSE OF EVENT In December of 1992, a new single failure proof spent fuel pool (SFP) area crane trolley was 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 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 without pre-approval in writing by the Plant General Manager, appropriate Superintendent or General Supenisor. This violated the provisions of Calvert Cliffs Instruction (CCI)-159, "Use of Overtime."
The cause of this event is that the personnel involved were not familiar with the need to have l
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.
IL CORRECTIVE STEPS TAKEN AND RESULTS ACIIIEVED
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We have counseled the appropriate personnel imolved in this matter and have provided instruction to personnel im'olved in similar projects on the applicability of procedures regarding use of overtime. The specific problems resulting in this violation were reviewed with all project personnel, emphasizing the errors made.
IIL CORRECTIVE STEPS WillCil WILL IIETAKEN TO AVOID FURTIIER VIOLATIONS The overtime policy will be added to the Calvert Cliffs Initial Supenisor Training Piogram, including discussion of the industry experience which led to these controls. New Project Management supenisors will receive this training.
IV.
DATE WilEN FULL COMPLIANCE WILL IIE ACillEVED Full compliance was achieved when the probicm was discovered and the affected personnel were informed of overtime policies regarding written authorization.
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A*ITACIIMENT (2)
NOTICE OF VIDIATION 50-317(3181/93-02/01 -
Notice of Violation 50-317 and 50-318/93-02/02 states that contrary to Technical i
Specification 6.8.1.a, there were four instances of procedural noncompliance associated with testing i
of the spent fuel pool area crane between January 4 and January 19,1993.
P I.
DESCRIPTION AND CAUSE OF EVENTS The recently installed spent fuel pool (SFP) area crane has two hooks, a small ausiliary hook, and a large main hook. Three Engineering Test Procedures (ETPs) were written to perform t
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 the auxiliary hook. Engineering Test Procedure 92-131 tested the interlocks and protective circuitry for the mein book.
A.
An individual who signed three changes to ETPs as a Procedure Screener was not fully certified to screen changes to ETPs. The indhidual 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.
B.
Performance of an ETP 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 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 l
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 crane's movements. He thought this was within the scope of the existing procedure 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 j
supervisor.
C.
A procedure step was not performed in accordance with the procedure and was i
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.
l 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 in a safe condition. The ETP shall then be changed in accordance with Calvert Cliffs j
Administrative Procedure PR-1-101, " Preparation and Control of Calvert Cliffs Technical Procedures.".Although the step for setting the load cell was changed in ETP 92-130 for the auxiliary book, the identical step was not revised in ETP 92-131 l
for the main hook. The technical representative did not perform the step in i
accordance with ETP 92-131 and this step in the test was incorrectly signed off as i
being done as written.
D.
Attendance at the pre-evolution briefings did not include all personnel involved in the ETPs, as required by CCI-132 and CCI-140.
Engineering Test Procedures92-129,92-130 and 92-131 were begun January 4,1993, and concluded 1-i i
A'ITACIIMENT (2)
NOTICE OF VIOLATION 50-317(318)/93-02/01 January 19, 1993. Calvert Cliffs Instruction (CCI)-132 requires that pre-evolution briefs be conducted as described in CCI-132 and CCI-140, " Conduct of Operations."
CCI-140 also states that any persons not attending the brief that need to become 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 Coordinator and representatives from Construction Inspection and contractor supervision. The 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 attendance were incomplete and not all personnel involved in preparing for the lifts and their conduct were included.
The cause of these events was that personnel involved 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 Engineering personnel would provide support for Post Modification Testing as specified in CCI-705, " Design Change and Modification Implementation." In this instance, a project manager inexperienced with Calvert Cliffs administration of technical procedures directed the testing without sufficient System Engineer involvement. There was a lack of attention to detail on the part of certain personnel involved in this testing.
II.
CORRECTIVE STEPS TAKEN AND RESULTS ACIIIEVED All of the SFP crane testing was successfully re-performed and properly documented.
This event was reviewed with System Engineering and Project Management personnel, emphasizing the requirements in CCI-705 cancerning customer participation in projects.
The specific crane testing problems resulting in this violation were resiewed with all Project Management personnel, emphasizing the errors made.
Appropriate personnel actions have been taken.
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CORRECTIVE STEPS WillCII WILL IIE TAKEN TO AVOID FURTIIER VIOLATIONS The above actions are sufficient to avoid similar future violations.
IV.
D ATE WIIEN FUI.L COMPLIANCE WILL IIE 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 was achieved by suspending testing when the procedural compliance problems were discovered. The crane was subsequently successfully tested in accordance with procedures.
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