ML20085K239
| ML20085K239 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 10/25/1991 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9110300248 | |
| Download: ML20085K239 (5) | |
Text
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B ALT IMORE GAS AND ELECTRIC CHARI.ES CENTER
- P.O. BOX 1475 e BALTIMORE, MARYLAND 21203 1475 Gronot c cnttu
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October 25,1991 oeo m 4..
U. S. Nuclear Regulatoly Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Clift..uclear Power Plant Unit Nos.1 & 2; Docket Nos. 50 317 & $0-318 NRC Region i Resident inspection Report Nos. 50-317NI 16 and 50 318.91 16 (Julv 7.199) to August 10.1991)
REFERENCE:
(a)
Letter from hit. C. J. Cowgill (NRC) to hir. G. C. Creel (BG&E),
NRC Region I Resident inspection Report Nos. 50 317N116 and 50-318N1 16 (July 7,1991 to August 10,1991), dated September 25, 1991 B
Gentlemen:
Reference (a) forwarded a Notice of Violation [ Appendix A to Reference (a)) regarding two violations. The first violation involved the failure to implement proper work controls during maintem.nce activities, Attachment (1) provides our response to this Notice of Violation as requested in the - Reference (a).
The second violation has been addressed in separate correspondence.
Should you have any further questions regarding this matter, we will be pleased to discuss them with
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%.Yor) truly yours, f?
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' October 25 1991 Page 2 O
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D. A.Brune,lisquire J. E. Silberg,11uluire R. A.Capra, NRC D. G. Mcdonald, Jr., NRC T, T. Martin, NRC i
A. O. llowe, NRC R.1. Mclean, DNR J. I1. Walter, l'5C I
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NITACllMENT10 ItEPINTO A NOTICi:OFYlOISI'lON INSPEClION REPORT NOS. 50-317/91 16 AND 50 318/91 16 VIOL ATION NO, i 1.
jl[EllJyHON ANllCAUSE OF VI01 AT[OE.
%e Notice of Violation l Appendix A of Reference (a)l cites five examples that our maintenance activities have not been conducted in accordance with written procedures, instructions, or maintenance orders (h10s) that implernent the requirements of to CFR 50.
Appendix il Criterion V.
The last example provided in Reference (a) was the removal and reinstallation of a single circuit card for troubleshooting. This was cited as the " disassembly and reassembly" of a Unit 1 Reactor Protection System (RPS) channel. 'lhe ' disassembly and reassembly" of a component under a generic ' rover" h!O is contrary to Calvert Cliffs Instruction (CCl).200 requirements. This type of investigative activity, however, is properly characterited as troubleshooting in CCI-117. We cons.'Jer the actions taken as appropriate and allowable under CCI-200.
The remal..!nc examples cited were licemee identified instances of inappropriate maintenar.cc actions. W were promptly and formally investigated by the responsible line organization and they were considered collectively as a potential trend. This potential was identified to the Plant Operations Experience Review (POER) organization, which conducted a detailed investigation of the occurrences.
'Ihe four instances were:
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the pulling of an energized relay to facilitate a modification installation, contrary to the requirements of an approved hiO and CCI.200," Nuclear hiaintenance System,'
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the use of a Surwillance Test Procedure 'STP) as informal guidarce which led to the failure to iemove an electric circuit jumper and icsulted in the inoperability of one shutdown cooling suction and two safety injection tank outlet valves,
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the incorrect termination cf containment sample valve power icads and the failure to p*operly verify the restoration, contrary to the requiiements of CCI 117," Temporary Modification Control," and
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the incorrect tetmination of turbine driven Auxiliary Feedwater pump steam admission valve wiring connary to the requirements of an approved h10 and CCI 200.
Our investigation determined that certain commonalities linked the event causes. Pour work practices (independent vdication/self checking) contributed to each of these four events.
Supervisory oversight deficiencies contributed to three events.
II.
CORRECTIVE SU:PS TMliS_AND RESj))M6QljEYEJJ.
The POER investigation identified the lluman Performance issues r.ssociated with all four events and recommended corrective action to plant management. 'Ihese corrective actions are currently being pursued and are discussed in Part 111 of this attachment.
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MTACilMENT (11 HEPLY TO A NOTICE OF VIOLATION-INSPELTION REPORT NOS. 50 317/91 16 ANI) 50-318/91 16 L ylOIATION NO, [ _
In parallel with the POER investigative efforts, the General Supervisor Electrical and P
-Controls Maintenance (GS-E&C) issued 4 memorandum to all E&C maintenance personnel, in this memo, he reinforced his expectations in three areas:
1.)
Inform the Shift Supervisor of any abnormal conditions. E&C personnel should also consuh with their own supervision, acsuming there is no immediate safety concern.
ii.)
Stop and resolve unanticipated occurrences during maintenance or testing.
iii.)
Ask for help if it is needed, if tecimicians are not sure of the actions needed to be taken, then they should ask.
The line organization informed appropriate personnel of management expectations and concerns. The GS-E&C conducted a meeting with the E&C Section to discuss these events.
The Plant General Manager addressed all attendecs at this meeting. Additionally, the General Supervi;ct of-Nuclear Plant Operations stressed continued reliance' on administrative andimplementing piocedures to all Shift Supenisors.
We began training selected senior E&C personnel in the Human Performance Evaluation System (IIPES) to enhance their ability to conduct barrier analysis in their pre-job reviews and brictings. This training will allow them to better understand the causal factors that may effect human performance.
Shortly after these events, we proceduralized a Troubleshooting Guide which clarifies and strengthens our maintenance program and work practices.
111.
CORRECTIVE ACI'lONS WillCil WILL llE TAKEN TO AVOID FURT1IER VIOLATIONS.
As a result of our inveation into these events, we plan to take the following corrective hetbns:
6 emphasize the self-checking / verification - process routinely in the Maintenamt Supervisory Job Observation prograin and in lab qualification practice and exercises.
-4 include requirements in the Planner Work -Development Guidelines to include precautions in work packages for equipment not completely de-energized or depressurized,
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stress in pre-task briefs the need for supervisory involvement when problems or questions arise, -
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discuss these and other similar industry events at the next E&C Industry and Recent Events training session, -
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prepare a procedure to. reaffirm the appropriate uses of the term independent verification, and
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continue providing HPES training to senior level E&C personnel.
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611MllMIEL(ll itEl'IN TO A NOTICE Ol' VIOL ATION INSI'ECTION llEPOllT NOS 50 317/91 16 AND 50 318/91 16 VJOlr110N nod iv.
IM1'E wilEN FillMin111LE03RidliAD111Xilll.
Full compliance was achieved on July 15, 1991 when the GS E&C distributed his memorandum to E&C petronnel concerning his expectations. Maintenance continues to be conducted in accordance with pnwedures, approved maintenance orders, and instructions.
Compliance will be checked regularly during periodic maintenance job observations.
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