ML20079A894
| ML20079A894 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 12/22/1994 |
| From: | Denton R BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9501040138 | |
| Download: ML20079A894 (7) | |
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Rost:T E. DENTON Baltimore Gas and Electric Company Vice President Calvert Cliffs Nuclear Power Plant Nuclear Energy 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 410 586-2200 Ext.4455 Local 410 260 4455 Baltimore December 22,1994 i
1 U. S. Nuclear Regulatory Commission i
Washington, DC 20555 l
ATTENTION:
Document Control Desk
SUBJECT:
Calvert Clifrs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Notice of Violation Response l
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REFERENCE:
(a)
Letter from Mr. C. J. Cowgill (NRC) to Mr. R. E. Denton (BGE), dated l
November 23, 1994, NRC Region I Resident Inspection Report Nos. 50-317/94-29 and 50-318/94-28 (September 11, 1994 October 29,1994) and Notice of Violation Please find attached our response to the Notice of Violation contained in Reference (a). The Notice of Violation contained two violations. The first violation cited three examples of maintenance activities not conducted in accordance with written procedures, the second cited the installation of a temporary cable for welding purposes without an accompanying engineering analysis.
Should you have any questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours,
[
RED /MDM/bjd Attachments:
(1)
Notice of Violation Part A, Activities Not Conducted in Accordance with Written Procedures (2)
Notice of Violation Past B, Unauthorized Modification
$1040139941222 ADOCK 05o00337 j[j g
Docu' ment Control Desk December 22,1994 Page 2 cc:
D. A. Brune, Esquire J. E. Silberg, Esquire L. B. Marsh, NRC D. G. Mcdonald, Jr., NRC T. T. Martin, NRC P. R. Wilson, NRC R. I. McLean, DNR J.11. Walter, PSC
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ATTACHMENT (1)
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p NOTICE OF VIOLATION PART A-ACTIVITIES NOT CONDUCTED IN 'ACCORDANCE
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WITH WRITTEN PROCEDURES
~L DESCRIPTION AND CAUSE Technical Specification 6.8.1.a requires written procedures be' established, implemented and maintained covering the applicable procedures in Appendix ' A of Reguw y' Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33 includes procedures governing implementation of surveillance testing, bypass of safety functions and jumper controls, and maintenance on safety-.
related equipment. Contrary to this, three examples of these types of activities were not conducted -
in accordance with written procedures.- The three examples were:
A.
On September 15, 1994, while performing Surveillance Test Procedure M-200B-1,
" Engineered Safety Features Actuation System Channel ZE Functional Test," an Electrical and Controls (EAC) Section instrument maintenance technician installed test equipment and opened slidelinks for the wrong instrument channel.' The procedure required the slidelinks for Channel ZE be opened and then the test equipment installed. Instead, the test equipment was installed out of sequence, and the slidelinks for Channel ZF were opened.
B.
On September 21, 1994, while conducting testing on Unit 2 Reactor Vessel Level Monitoring System (RVLMS) Channel"A," E&C instrument maintenance technicians mispositioned a slidelink. The jumper control form used during the maintenance showed the slidelink was left open (its normal position), when it was actually restored to the closed position.
C.
On October 26, 1994, E&C electricians performing routine breaker cleaning and' inspection in accordane with Maintenance Procedure E-19 failed to re-terminate a control transformer lead in twa motor control center feeder breakers for the No.12 Emergency Diesel Generator (EDG). ' The lifted lead and terminate sheet attached to the procedure indicated the control transformer lead had been re-terminated and verified re-terminated.
Baltimore Gas and Electric Company accepts the violation.
Each of the examples cited above has been investigated to determine the casual factors involved.
The central casual factor involvul in each example was a failure to select or apply the proper established self-checking or verification practice to ensure intended actions were correct. Over the past several years Cahrrt Cliffs has conducted extensive initial and follow-up training on self-checking and verification practices designed to ensure work is completed in an event-free fashion.
These practices include STAR (Stop, Think, Act, Review) and verification techniques or tools which support the STAR concept. Although we have continued to emphasize how to perform these processes properly and in the proper situations, we have experienced lapses in their proper implementation.
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I ATTACIIMENT 0)
NOTICE OF VIOLATION PART A-ACTIVITIES NOT CONDUCTED IN ACCORDANCE WITil WRITTEN PROCEDURES IL CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED A.
Each of the specific examples described have been corrected in the following manner:
1.
Opening the slidelink on the wrong instrument channel during Engineered Safety Features Actuation System testing was immediately noticed by Control Room operators when the channel went into alarm. An operator communicated the problem to the E&C Technicians performing the test, and they returned the channel to a normal status. This event and its specific corrective and preventive actions are discussed in LER 318-94-002.
2.
On October 1,1994, operators wrote an Issue Report (IR) to document spurious and sometimes hanging alarms on Unit 2 RVLMS Channel A. The shut slidelink was discovered and restored to the open position during troubleshooting to address this IR on October 4,1994.
3.
The leads to the motor control center feeder breakers for No.12 EDO were discovered and properly re-terminated prior to exiting its associated 72-hour Technical Specification Action Statement. The EDG remained out-of-service for approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> longer than anticipated.
B.
The personnel involved in each of these events has been appropriately counseled.
C.
The day after the third event, the E&C Section held a STOP WORK tailgate meeting to communicate management expectations regarding the proper use of STAR, the techniques that support STAR, and compliance with procedures. The specific details and resultant adverse effects of these specific events were also discussed during the meeting.
Ill.
CORRECTIVE ACTIONS TAKEN TO AVOID FURTIIER VIOLATIONS A.
The site stopped work on November 8,1994 and held a site-wide tailgate meeting to discuss these events, how similar errors may be eliminated, and how safety and quality is improved through use of proper self-checking and verification techniques.
D.
The E&C Sectior. has begun implementation of a STAR improvement action plan. This plan includes re-establishing the supervisory holdpoints process, development of training and laboratory exercises to challenge the proper selection and use of available self-checking and other STAR techniques and tools during troubleshooting and maintenance activities. These actions are intended to re-focus attention at all levels of E&C on the proper selection and use of the techniques that support event-free maintenance.
Supenisory holdpoints provide supervisors a way to stop the job at the points of their i
choosing to maximize the level of emphasis on the important work steps. It also allows supervisors to determine the p' per verification technique needed to ensure the remainder of the job is donc correctly and monitor the effectiveness that the techniques are applied.
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1 ATTACIIMENT (1) i NOTICE OF VIOLATION
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PART A-- ACTIVITIES NOT CONDUCTED IN ACCORDANCE
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WITII WRITTEN PROCEDURES
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Re-establishing the use of these holdpoints has raised the sensitivity and awareness of the E&C Section to utilizing the proper self-checking verification technique in the proper
' situations and has increased E&C supervisors level of detailed involvement in work packages and procedures.
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ATTACHMENT (2)
PART B - UNAUTHORIZED MODIFICATION i
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DESCRIPTION AND CAUSE 10 CFR Part 50, Appendix E, Criterion III, Design Control, states, in part, " Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design and be approved by the organization that performed the original design unless the applicant designates another responsible organization." Contrary to the above, in January 1994, a temporary 440V cable was mounted to safety-related piping supports and conduit supports in the Unit I component cooling water room without the performance of a seismic analysis. Specifically, we did not have in place established criteria for attaching temporary -
services to safety-related structures prior to attaching the cable to the conduit supports.
Evaluations required for modifications were not performed at any point in this evolution, thus J
Baltimore Gas and Electric Company accepts the violation.
On January 3,1994, the temporary cable was installed to support welding work in the Unit I component cooling room, during the Unit 1 1994 spring refueling outage. Two utility elu:tricians installed the cable under a large maintenance work order dealing with temporary power. Based on accepted site practices the cable was routed in the overhead area. The routing of cable was not considered a temporary modification from an electrical standpoint since the cable was plugged into an existing receptacle designed for temporary loads. From a seismic standpoint, the routing of cables was not recognized as a concern.
At the end of the outage work was still in progress so the cable remained in place. The majority of the work covered under the temporary power work order was completed, so the electrical maintenance group closed out the large work order with the intention of eventually removing the cable under a rover work order. When the work in the component cooling room was completed the maintenance group who used the temporary power failed to notify the Electrical Maintenance group so the cable could be removed. The cable remained in place until October 28, 1994, whereupon it was removed after seismic concerns were raised. The cable remained in place after maintenance activities were completed and should have been removed.
The failure to have established criteria for attaching temporary services to safety-related structures, like the conduit supports, prior to routing the 440 V cable is the cause of the violation.
II.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED In response to this event, the following actions were taken:
A.
The temporary power cable in the component cooling room was removed.
B.
An engineering analysis was performed to access the impact of the cable on the conduit support. The analysis concluded that the configuration was acceptable and that no seismic or cable separation concems were created by the attachment of this cable to the conduit supports.
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ATTACHMENT (2)
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NOTICE OF VIOLATION PART B - UNAUTIIORIZED MODIFICATION i
C.
Plant walkdowns were performed to identify and correct, as necessary, other cases where the routing of temporary senices such as electrical power cords, could impact safety--
related equipment.
III.
CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER VIOLATIONS Design Engineering Section issued interim guidance to the plant on routing temporary services in areas of the plant that contain safety-related equipment. A detailed engineering evaluation will be performed to determine the bounding requirements, such as seismic and electrical separation, for routing temporary services. This evaluation will determine the acceptable weights and criteria for routing these senices. Temporary senices that exceed a stated criteria will be considered alterations and will be evaluated using the appropriate site procedures. Training will be provided to affected groups on the new guidance.
Additionally, we will revise management controls with respect to maintenance work closcout. All temporary power requests will be initiated using a temporary power request fonn and will be recorded in a log. 'Ihe temporary power requests and temporary power work orders controlling the installation and removal of temporary power will not be closed out until all work is completed and the temporary power is removed. Electrical maintenance supenision will continue to review the log and work order status to ensure temporary power is removed once maintenance is completed.
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