ML20055E080
| ML20055E080 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 07/03/1990 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9007100358 | |
| Download: ML20055E080 (3) | |
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BALTIMORE
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~'E CHARLES CENTER e P.O. BOX 1475 e BALTIMORE, MARYLAND 21203-1475 I
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,1 Gcomoc C. Cncet-s vice pacaiocat July 3,1990 '
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' U. S. Nuclear Regulatory Commission Washington,DC 20555 ATTENTION:
Document Control Desk.
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SUBJECT:
. Calvert Cliffs Nuclear Power Plant.
Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318
>l NRC Region' I Resident? Inspection Report Nos. 150-317/90-08 and '
50-318/90-08 9
REFERENCE:
(a)
Letter from J. C..Linville (NRC) to G. C. Creel (BG&E), dated -
June 4,1990, same subject o
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Gentlemen:
1 Attachment (1) is our response to the Notice of Violation contained within the subject Inspection i
Repor t.
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..a Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
J Vey truly yours,
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GCC/JV/bjd i
Attachment
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D. A. Brune, Esquire i
J. E. Silberg, Esquire.
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' R. A. Capra, NRC a
D. G. Mcdonald, Jr., NRC 1
T. T. Martin, NRC '
4' L E. Nicholson, NRC R.' I. McLean, DNR d
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{pl 9007100308-900703 7
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REPLY TO NOTICE OFVIO1ATION NRCINSPECTION REPORT I
50 317/90-08 AND 50-318/90-08 STATEMENT OF VIOLATION Calvert Cliffs Technical Specification 6.8.1 states that written procedures shall be established, maintained, and implemented covering the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978. Appendix "A" of Regulatory Guide 1.33, Rev. 2, i
1978, requires administrative procedures for equipment control (e.g., locking and tagging).
i Administrative procedure Calvert Cliffs Instruction (CCI) 309B requires that the operation of any locked valve be annotated and approved in the " Locked Valve Deviation Log".
Contrary to the above, on April 90, l'r>0, three valves were unlocked and repositioned in the Waste Gas Decay system without acequate documentation and verification which resulted in an unplanned release of the #13 Waste Gas Decay Tank.
HACKGROUND An unplanned release of #13 WGDT occurred during the recent startup of Unit One. The event was reviewed by cur Startup Review Board which consisted of all site Managers. Evidence of insufficient attention to detail and informality of communications was revealed. This has received management attention and additional emphasis through communications and monitoring will bc provided.
A Iluman Performance Evaluation System review was performed and identified the lack of clarity regarding the intent of CCI 309B, " Locked Valves," as contributing to the event. The following specific problems were noted in CCI-309B:
y CCI 309B states that, "Whenever any locked valve is taken out of its locked position, such deviation shell be logged in the Locked Valve Deviation Log." However, CCI 309B does not specify that the valve be logged before it is taken out of its locked position. In this event, the log was completed after the valve was taken out of its locked position.
CCI 309B requires that the Control Room Supervisor (CRS) approve a locked valve deviation before the valve is placed in the out of normal position, but does not specify how the approval must be given. A space is provided in the log for his initials approving the deviation, but since the log is not required before the valve manipulation, the procedure implies that he can give his approval by other methods. In this case, CRS permission was given to manipulate the valves prior to their being logged by directing the WGDT release to.
be performed.
The event and all corrective actions are discussed in LER 50-317/90-16.
CORRECTIVE STEPS TIIAT llAVE BEEN TAKEN The intent of CCI 309B regarding control of locked valves was formally communicated in writing to the operating shifts. A valve deviation sheet will be completed prior to operating locked valves and the Control Room Supervisor will document his approval of those operations by initialing the sheet.
CORRECTIVE STEPS TilAT WILL HE TAKEN TO AVOID FURTilER VIO1ATIONS A revision _to CCI 309 to clarify the required documentation and verification of the operation of locked valves has been recommended for approval by the Plant Operations and Safety Review Committee and is expected to be implemented by July 31,1990.
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NITACIIMENT (1).
l REPLY TO NOTICE OF VIO1ATION NRC INSPECI'lON REPORT j
$0 317/90 08 AND 50-318/90 91 DATE WIIEN FULL COMPL1ANCE WILL BE ACIIIEVED i
Full compliance was achieved with the formal written communication of the intent of CCI 309B to the operating shifts on April 24,1990.
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