ML20056D540

Notice of Violation from Insp on 930510-21.Violations Noted:Overtime Limits Required by TS 6.8.1.g Were Exceeded W/O Prior Written Authorization & Several Nondestructive Exam Inspectors Worked Overtime in Excess of Limits

ML20056D540
Person / Time
Site:	Calvert Cliffs
Issue date:	08/11/1993
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20056D531	List: ML20056D530 ML20056D540
References
50-317-93-14, 50-318-93-14, EA-93-190, NUDOCS 9308170057
Download: ML20056D540 (21)

Text

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l APPENDIX A NOTICE OF VIOLATION Baltimore Gas and Electric Company Docket Nos. 50-317 Calvert Cliffs Nuclear Power Plant Units 1 & 2 50-318 License Nos. DPR-53 DPR-69 EA No.93-190 g During an NRC inspection conducted on May 10 - 21, 1993, two examples of a violation of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:

10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires that conditions adverse l to quality such as failures, malfunctions, deficiencies, defective material and equipment, and nonconformances are promptly identified, corrected and action taken to preclude recurrence.

Contrary to the above, between May 10-21, 1993, it was determined that the following nonconformances were not promptly corrected or actions taken to preclude recurrence.

A. In NRC Inspection R.eport 50-317/93-02 and 50-318/93-02, several instances were identified where overtime limits required by Technical Specification 6.8.1.g were exceeded without prior written authorization. In a letter dated March 29, 1993, l

l BG&E stated that corrective actions for this problem had been completed.

Subsequently, during the month of April 1993, several nondestructive examination l (NDE) inspectors worked overtime in excess of the limits specified in Technical Specification 6.8.1.g (over twenty instances) without prior written authorization.

B. The applicable ASME Code,Section XI,1983 Edition, Summer 1983 Addenda, IWA-2221, states that magnetic particle examination shall be conducted in accordance with Article 7,Section V. Article 7,Section V, requires that magnetic particle examination procedures be based on information regarding the materials, shapes, or l sizes to be examined, the extent of examination, magnetization technique to be used, i equipment to be used for magnetization, type of ferromagnetic particles to be used (manufacturer, color, wet or dry), and magnetization current (type and amperage).

In 1989, the licensee had recognized deficiencies in their NDE procedures and started to review the set of corporate NDE procedures for use in conducting NDE at the Calvert Cliffs Nuclear site for conformance with applicable Code requirements.

9308170057 930811 PDR ADOCK 05000317 O PDR

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Appendix A 2  !

During the period from May 10 to 14,1993, timely corrective action was not completed in that the licensee's magnetic particle procedure nos. NDE 5.100, Revision 6, NDE 5.102, Revision 3, NDE 5.104, Revision 3, and NDE 5.107, Revision 2, failed to include information required by Article 7,Section V, such as the extent of examination, a description of the ferromagnetic particles used for the examination, how, when, and where to measure the intensity of the black light required for examinations using fluorescent particles, and the method for calculating  ;

field strength when an electromagnetic coil is used to establish the magnetic field.

This is a Severity Level IV violation (Supplement I).

Pursuant to provision of 10 CFR 2.201, Baltimore Gas and Electric Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory _

Commission, ATTN: Document Control Desk, Washington, D.C.,20555, with a copy to the Regional Administrator, Region I, and a copy to the Resident Inspector within 30 days of ,

the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each example of violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that will be taken to avoid further violations, and (3) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked, or why such other action as may be proper-should -

not be taken. Where good cause is shown, consideration will be given to extending the response time.

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APPENDIX B l Calvert Cliffs Nuclear Power Plant Enforcement Conference  !

August 5,1993 '

AGENDA  :

i Introduction - R. E. Denton Overtime Issues -

C. H. Cruse j NDE - P. G. Chabot Closing Remarks -

R. E. Denton j l.

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Calvert Cliffs Nuclear Power Plant Enforcement Conference August 5,1993 BACKGROUND FOR OVERTIME ISSUES 9

Extent of overtime use Very few workers worked overtime above GL-82-12 guidelines Jobs where overtime is used Few cases where high overtime was used in Operations, and all were in accordance with GL 82-12 Overtime properly controlled throug'hout key functions, did not jeopardize safety Effectiveness of overtime control In vast majority of cases, amount of overtime being performed is acceptable Controls in Operations, Maintenance and Radiation Safety have proven effective Controls in several areas did not meet expectations, Contractors, Engineering, NDE i

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Calvert Cliffs Nuclear Power Plant  !

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SAFETY SIGNIFICANCE OF EXCESSIVE OVERTIME - 1 Low safety significance In the last two years there is one known event where i fatigue / overtime contributing factor l Behavioral observation program is a good backup in  !

identifying fatigue problems ,

o Plant not adversely affected  ;

i No trend of problems caused by overtime  ;

1 Review of NDE identified documentation problems, no {

performance problems 3 3

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CAUSES OF OVERTIMEISSUES . _ _ .

Expectations were not well defined CCI-159, which implements GL 82-12, did not capture the intent of GL 82-12 well ,

Expectations regarding CCI-159 applicability and rolling 72 hourlimit were unclear Training needs enhancement -

Inadequate planning .

Schedules tended to challenge the process l Feedback /self-assessment was lacking in some groups I

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August 5,1993 -

t SHORT-TERM CORRECTIVE' ACTIONS OF OVERTIME ISSUES Detailed investigation completed ,

i Plant General Manager discussed concern at 8:00 l meeting, issued memo on subject to Supervisors, and .l established an interim monitoring process l 4

l Superintendent of Operations directed Shift Supervisor  :

not to approve overtime extension unless required for i safe operations and efforts .to contact line supervisors  !

has been exhausted j Appropriate disciplinary action taken j

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August 5,1993 NEAR-TERM CORRECTIVE ACTIONS __ _.

OF OVERTIME ISSUES Planned procedure revisions Establish site-wide overtime procedure for situations ,.

other than those addressed in GL 82-12 Revise CCI-159, which addresses GL 82-12 requirements Clarify expectations regarding' the approval of overtime Establishing threshold for extraordinary work Training on expectations and new procedure Improve self-assessment program t

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l REGULATORY CONSIDERATIONS _ . . .

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Licensee identified l Hotline Report - Started 4/28/93, Completed 5/7/93  :

Issue report - written 4/29/93, Issue Report Review- .

Group review - 05/3/93, POSRC review - 05/10/93. ,

Conclusions of previous investigation.

Procedure compliance. issues were attributed to the  ;

organization involved in the Spent Fuel Pool Crane  :

Project No generic problem with overtime existed in key areas such as Operations and Maintenance l

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Enforcement Conference August 5,1993 ~~

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NDE REVIEW '

Potential violation

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.i Corrective actions: Immediate and Long-term  ;

e Regulatory significance l

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POTENTIAL NDE VIOLATION l i

MT procedures don't meet ASME code requirements .  ;

1 Condition has persisted j

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BG&E ASSESSMENT __

Initially, generic procedures intended for both l ASME XI and non-ASME'XI use .

t Level of detailin documentation not-always sufficient to 1 compensate for lack of procedural detail i

37 of 42 NDE Procedures (Technica} Control, PT, and-  ;

VT) upgrade complete  !

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t RELATEDISSUES . _. . . .. . . . ..

a Past NRC-identified problems

- Authorized nuclear inservice inspector issues  !

t Self-assessments

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ROOT CAUSES . . _ _ . _ _

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Corrective action not timely  !

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CAUSAL FACTORS s

i Weaknesses identified in: f l

NDE leadership and oversight on site  :

a' Site management follow-up Definition of NDE interfaces and responsibilities-l Use of corrective action system -

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Enforcement Conference August 5,1993 -

IMMEDIATE CORRECTIVE ACTIONS . . . . .

Issue Reports written MT performance review completed PT peiformance review completed VT performance review completed j i

l Section XI MT procedure completed July 15,1993 l

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August 5,1993-LONG-TERM CORRECTIVE ACTIONS Senior NDE representative on-site On-site NDE to report operationally to Tech Support 1 Special processes directive will address responsibilities l and interfaces .

j Corrective action system  ;

NDE Corrective Action Plan approved 1

ISEU assessment completed 3 1

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REGULATORY SIGNIFICANCE i

No nuclear safety significance Corrective actions not timely l

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REGULATORY ASSESSMENT _ _. ..

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Procedure inadequacies self-identified i t

.i Few similar violations; None in NDE  !

No safety significance j Appropriate immediate and long-term actions were taken P

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I APPENDIX C NITENDEES AT ENFORCEMENT CONFERENCE ON AUGUST 5,1993 BALTIMORE GAS & ELECTRIC COMPANY S. Buxbaum Principal Engineer, NDE Unit P. Chabot Superintendent, Technical Support C. Cruse Plant General Manager R. Denton Vice President K. Hoffman Principal Engineer, Nuclear Inspection Services M. Proctor Plant General Manager Assistant L. Russell Director, Nuclear Planning & Safety D. Snyder General Supervisor, Technical Services J. Volkoff Engineer, Compliance Unit U.S. NUCLEAR REGULATORY COMMISSION R. Capra NRR C. Cowgill Chief, Projects Branch No.1, DRP J. Durr Chief, Engineering Branch, DRS H. Gray Chief, Materials Section, DRS-W. Hodges Director, Division of Reactor Safety D. Holody Enforcement Specialist R. McBrearty Reactor Engineer D. Mcdonald NRR C. Miller Acting Deputy Director, DRS M. Modes Chief, NDE Mobile Laboratory L. Nicholson Chief, Projects Branch No. l A, DRP P. Peterson NDE Technician K. Smith Regional Counsel P. Wilson Sr. Resident Inspector, Calvert Cliffs