ML20056H261
| ML20056H261 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 09/03/1993 |
| From: | Denton R BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9309090058 | |
| Download: ML20056H261 (4) | |
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BALTIMORE 1 GAS AND 1 ELECTRIC i
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1650 CALVERT CLIFFS PARKWAY. LUSBY, MARYLAND 20657-4702 ROBERT E. DENTON v.cr PResior=T September 3,1993 NUCLE AR rNERGY (4to) reo 445s U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nt dear Power Plant Unit Nos.1 & 2; Docket Nos. 50 317 & 50-318 Non-destructive Examinatic,n Notice of Violation
REFERENCE:
(a)
Letter from Mr. M. W. Hodges (NRC) to Mr. R. E. Denton (BG&E),
dated August 11, 1993, Notice of Violation and Enforcement Conference Results, Combined Inspection Report Nos. 50-317/93-14 and 50-318/9314 In response to Reference (a), Attachment (1)is provided.
1 As we discussed at the August 5,1993 Eaforcement Conference, we agree that minimum compliance with the ASME Code is not enough and that we need to have more ownership of Non-destructive Examination onsite. We are taking steps to correct this. We will closely monitor the results of our initiatives and pertinent industry and Nuclear Regulatory Commission information. If these indicate additional actions are needed, we will take them.
Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours,
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RED /DWM!dwnt'bjd Attachment D. A. Brune, Esquire cc:
J. E. Silberg, Esquire R. A. Capra, NRC D. G. Mcdonald, Jr., NRC T. T. Martin, NRC P. R. Wilson, NRC R. I. McLean, DNR J. H. Walter, PSC j
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r ATTAC!IMENT (1]
NOTICE OF VIDIATION 50-318'93-14-01 Notice of Violation 50-318/93-14-01 describes two non-conformances invohing untimely or ineffective corrective actions, violating 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions. In the first, Non-destructive Examination (NDE) personnel exceeded overtime limits of Technical Specification 6.8.1.g without prior written authorization.
This occurred after implementation of corrective actions resulting from a previous similar violation. The second non-conformance imolved magnetic particle procedure deficiencies identified in 1989 not having been corrected by May 1993.
I.
OVERTIME.
A.
DESCRIPTION AND CAUSE OF EVENTS.
Nuclear Regulatory Commission Inspection Report 50-317/93-02 and 50-318/93-02 documented instances in which Project Management personnel testing a new Spent Fuel Pool area crane last December exceeded the overtime limits of Technical l
Specification 6.8.1.g without prior written authorization per Calvert Cliffs Instruction l
(CCI)-159, which implements Generic Letter 82-12 overtime requirements. Our l
review of this item conciuded that the problem was confined to the project organization based on other procedural compliance isries related to the Spent Fuel l
Pool crane testing and the lack of obvious overtime problems found in a review of the l
Operations and Maintenance areas.
During the recent Unit 2 outage, from March to June, NDE inspectors worked overtime in excess of the Technical Specification 6.8.1.g limits without proper i
authorization. The excessive overtime was the result ofinadequate planning with the result that not enough inspectors were availabh during periods of high activity. The lack of proper authorization resulted from a lack of understanding and inadequate management of CCI-159 by supenisors and workers.
Contributing to the authorization problem was the fact that NDE management is located offsite. Non-destructive Examination inspectors routinely received overtime authorization from the Shift Supenisor since NDE management was not routinely available onsite.
Management was therefore not involved in, nor aware of, the excessive overtime use.
11.
CORRECIWE STEPS TAKEN AND RESULTS ACllILTED.
Following our discovery of the problems with overtime in NDE, we reviewed ute of overtime onsite and found other instances in which overtime controls had not met expectations. The Plant General Manager discussed this concern at the daily planning meeting, issued a memo on the subject to site supervisors, and established an interim monitoring process. The Superintendent of Operations directed Shift Supenisors not to approve overtime extensions unless they are required for safe operation and all efforts to contact line supenisors have been exhausted.
Appropriate personnel actions have been taken.
C.
CORRECIIVE STEPS WillCll WILL IIE TAKEN TO AVOID FURTIIER VIOLATIONS.
Calvert Cliffs Instruction-159 will be revised to clarify expectations regarding the use and approval of overtime. We will conduct training on management's expectations and the procedure revisions. We will review possible improvements to our self-assessment program.
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e A'ITACIIMENT (1) o NOTICE OF VIOIEfp)N 50-318/93-14-01 II.
PROCEI)URES.
A.
DESCRIPTION AND CAUSE OF EVEN'IS.
The magnetic particle procedures were written before the late 1980's ano were originally intended for use in either ASME Section XI and non-ASME Section XI applications. They therefore lacked certain Code-reo6ed detail, relying instead on skill-of-the-craft. This lack of detail was identified by the Authorized Nuclear Insenice Inspector in late 1988 and a program was initiated to revise technical control, liquid penetrant, visual inspection, and magnetic particle procedures. The procedure changes were scheduled and prioritized. As of July 1993, 39 of 42 identified procedures had been revised.
We initially scheduled the procedure revisions to be completed by the end of 1989.
liigher priority items, including the plant shutdown to repair pressurizer leaks, intervened and, although there was a steady stream of NDE procedure changes, it took several years longer than originally planned to get to the magnetic particle procedures, which had received a lower priority than other NDE procedures. The decision to delay the procedure revisions was made within the NDE organization and were not being tracked onsite by the corrective action system.
Because the procedure deficiencies were not viewed as items which would result in any performance problems, they were given a low priority and frequently postponed.
H.
CORRECTIVE STEPS TAKEN AND RESULTS AClllEVED.
An upgraded magnetic particle procedure for Section XI work was approved July 15.1993.
Prior to completion of the Unit 2 outage, we reviewed the performance of affected Insenice Inspection NDE inspections and identified examinations to be repeated during the current Insenice Inspection interval. None of these involve operability concerns as all rework can be performed later in this inten al.
C.
CORRECTIVE STEPS WillCll WILL IIE TAKEN TO AVOID FURTIIER VIOLATIONS.
All remaining NDE procedure revisions will be completed prior to their next use in Section XI work. As part of our Procedure Upgrade Project, we are reviewing other procedures utilized by offsite support organizations which impact Calvert Cliffs operation.
111.
NON-DESTRUCTIVE EXAMINATION PROGRAM.
A.
DESCRIPTION AND CAUSE OF EVENTS.
Collectively, these two problems indicate programmatic weaknesses in the management of our NDE program. As a result of earlier administrative problems, we had previously reviewed the NDE program for possible enhancements. The NDE organization is part of the Fossil Support Senices Department in the Fossil Energy Division. It provides services at Calvert Cliffs but does not report functionally to 2
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ATTACIIMENT (1)
NOTICE OF VIO1ATION 50-318/93-14-01 Calvert Cliffs management. While some NDE personnel are located onsite, no senior personnel, vested with appropriate authority to administer, manage, and monitor the NDE program at Calvert Cliffs, are located onsite. Is r procedure clearly i
identifies NDE interfaces and responsibilities.
B.
CORRECTIVE STEPS TAKEN AND RESULTS AClllEVED.
i Self-assessments of the NDE program have been completed. Additionally, corrective action tracking systems put into place subsequent to the NDE procedure problem will assist in making similar concerns more visible to onsite and offsite supervision and management.
C.
CORRECTIVE STEPS WillCli WILL IIE TAKEN TO AVOID FURTilER VIOLATIONS.
A senior NDE representative will be assigned onsite and will report to the site Technical Support organization. A Special Processes Directive is being developed which will clearly define ownership and accountability for the NDE program at Calvert Cliffs. An NDE Corrective Action Plan has been developed which provides specific actions to improve and monitor performance.
I IV.
DATE WIIEN FULL COMPLIANCE WILL HE ACIIIEVED.
Full compliance was achieved when management implemented enhanced overtime controls and the new ASME Section XI magnetic particle procedure was approved on July 15,1993.
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