ML20085K913
| ML20085K913 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 09/16/1983 |
| From: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20085K905 | List: |
| References | |
| NUDOCS 8310210210 | |
| Download: ML20085K913 (4) | |
Text
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BALTIM ORE GAS AND ELECTRIC CHARLES CENTER R O. BOX 1475 BALTIMORE, MARYLAND 21203 5ePtember 16 1933 8
ARTHUR E. LUNDVALL, JR.
VtCE PRESIDENT SUPPLY U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 ATTENTION:
Mr. R. W. Starostecki, Director Division of Project & Resident Programs Gentlemen:
On September 2,1983, Messrs. 3. A. Tiernan, L. B. Russell, J. T. Carroll, and I met with you and other members of the NRC Region I staff to discuss an event that recently occurred at our Calvert Cliffs Nuclear Power Plant. This event involved the operation of Units 1 & 2 beyond the Technical Specification Limiting Conditions for Operation (LCO) concerning emergency diesel generator operability. As these events were fully discussed at our meeting and in NRC Inspection Report 50-317/83-22; 50-318/83-22, the details will not be repeated. In our meeting, we provided you with preliminary information concerning our corrective measures. This le~tter provides a written summary addressing corrective measures we have taken or plan to take for each area of concern specified in your Inspection Report.
ADEQUACY OF INDEPENDENT VERIFICATION OF PLANT SYSTEM VALVE LINE-UPS 1.
Upon discovery of the event, the instrument bridle lower isolation valve on each fuel oil day tank was verified open and the surveillance tesc was successfully run on each diesel generator.
2.
Personnel Incident Reports (PIRs) were written by each individual involved in the performance of the Preventive Maintenance (PM) and Surveillance Test Procedures (STPs) associated with the August 10,198?, violation. The purpose of this program is to increase personnel awareness of the event by having each individual confront, acknowledge, and document their involvement in personnel errors. The PIRs are selectively routed as required reading or are disseminated (e.g., for training) to affected groups at Calvert Cliffs.
3.
The Technicians and Operations personnel involved in the event were counseled by the Division Vice President, Plant Superintendent, and respective General Supervisors.
The purpose of this counseling was to communicate Management concerns regarding the seriousness of the event.
8310210210 831005 gDRADOCK 05000317 PDR
Mr. R. W. Starostecki September 16,1983 Page 2 4.
Training sessions are being scheduled with all Maintenance and Operations personnel to ensure all personnel are aware of the expectations (requirements) inherent in an independent verification of valve positon, (i.e., independent hands-on verification that the valve is in the proper pestion).
This training will be completed by no later than October 30,1983.
5.
A meeting was scheduled with each Instrument Shop for the purpose of providing th(. vygtunity for the cognizant Instrument Technicians and General Supervisor to review the event and provide a description of the lessons learned. This action was completed on September 9,1983.
6.
A weakness was identified in the practice of some Electrical & Control shops in the nature of assigning work to some Technicians on one job.
To correct this deficiency, whenever more than one technician is assigned to a job, the Shop Work Coordinator will designate a lead individual to instill a stronger sense of responsibility and accountability for that job. This action has been implemented.
7.
All PMs, STPs, and Functional Tests (FTIs) in the Instrument & Controls Section, will be reviewed by no later than December 31,1983, to determine the adequacy of the independent verification steps in these procedures. In addition to the above, an evaluation of all Instrument & Controls PMs will be performed to determine whether it is advisable to include (in the verification step), a listing of all valves repositioned during the performance of the PM. This action will be completed by no later than September 30,1983.
8.
Calvert Cliffs Instruction-211D for Preventive Maintenance will be revised to be consistent with our present practice to require an independent verification step in all PMs that involve valve repositioning. This action will be completed by no later than September 30,1983.
9.
All Instrument & Controls PMs will be reviewed to evaluate the adequacy of post maintenance testing to ensure, where feasible, that the functional operability of involved components are adequately tested. This action will be completed by no later than September 1984.
VALIDITY OF OPER ATOR VERIFICATION OF FUEL OIL DAY TANK LEVEL 1.
Facility Change Request (FCR 81-129), which specifies the addition of a gauge glass on each fuel oil day tank, is being expedited. Although the FCR specifies the use of a gauge glass, equivalently effective alternative methods such as dipstick, float, or air bubbler indicators are under consideration. Pending engineering and parts availability, we are proceeding on a schedule to install local level indicators during the scheduled fall 1983 Unit I refueling outage.
Mr. R. W. Starostecki September 16,1983 Page 3 2.
' STP 0-8-0 (Diesel Generator Weekly Test) has been revised to include: (a) a step to verify the frequency and duration of the fuel oil transfer pump operation when the diesel is i>eing tested in a fully loaded condition, (b) a step to verify that the fuel oil day tank low level alarm is cleared, and (c) a separate data sheet for the Outside Operator to log the above information.
3.
All Operations STPs will be reviewed no later than December 31, 1983, to determine if separate or additional data sheets (similar to the above) are appropriate.
MANPOWER AND TIME ALLOCATIONS FOR PM WORK Managment has in the past and will continue in the future to be sensitive to the issue of manpower and time allotment for performing safety-related activities. This is an issue which is faced, essentially, on a daily basis. We do not view this area as being deficient in Management Controls, but instead an invalid defense by the Technicians involved.
Management has never tolerated shortcuts to meet a schedule. In the incident cited above, controls were exercised to alleviate the concern regarding manpower and time allotment. The PM scheduling includes estimates of man-hour requirements (in this case, 2 men /10 hours and 2 men /8 hours). To meet operational constraints during the above incident, one additional technician was assigned to the task to ensure timely performance.
Maintenance supervisors at Calvert Cliffs are highly experienced at assigning safety-related work during rigorously scheduled periods and are very aware of personnel performance and capability.
We continue to emphasize never sacrificing nuclear or personnel safety for time as a very basic Management objective in our training and awareness programs.
RECURRENCE OF PERSONNEL ERROR-RELATED SAFETY PROBLEMS As discussed at our meeting, one of our major goals is to reduce personnel errors. In this regard we have implemented a program that draws upon existing controls and implements new controls that we feel will produce positive results for achieveing our goal.
Awareness and attitude programs have been one area of concentration, including:
(a) emphasis on discussions with Supervisors and others to increase communications and awareness, (b) the formation of Interdepartmental Quality Circles, and (c) Corporate studies on quality workmanship.
Training programs continue to provide a basic framework for achieving a reduction in personnel error. We have upgraded a number of areas in training including system descriptions, staffing, facilities, and feedback of plant events.
In addition, error reporting and personnel counseling programs have been improved.
Currently, Personnel incident Reports are used at Calvert Cliffs.
Comprehensive and independent event reports are prepared for serious events and when necessary direct counseling is performed with involved personnel and Line Supervision (up to the Vice Presidenth level).
Data analysis and evaluation programs have been implemented to assemble and review error information for trends and root causes.
' s.
.s Mr. R. W. Starostecki September 16,1983 Page 4 As an integral part of our continuing effort to reduce personnel errors, we currently track and report personnel error trends to our Plant Operations and Safety and Off-Site Safety Review Committees. In the recent (September 1983) report a significant decrease in the number of personnel error initiated Licensee Event Reports (LERs) for the current year is noted as compared to an equivalent eight month period in 1982. This decreasing trend indicates approximately 64% fewer personnel error LERs reported. To ensure that all appropriate individuals on-site are informed and made aware of personnal error incidents and Management objectives in this area, meetings have been held with affected units and Calvert Cliffs Supervisors and key personnel to provide a forum for discussion on the seriousness of such trends.
The previous discussions provide a summary of steps we have taken or intend to take regarding the August 10, 1983, incident. We share your conccrn regarding the events culminating in the violation of our Technical Specifications. We believe that the above measures will provide assurance that similar events will not recur in the future.
Should you desire additional information, please do not hesitate to contact us.
Very truly yours,,
)
~ JLh' wl&J
-q AEL/ LOW /gla cc:
J. A. Biddison, Esquire G. F. Trowbridge, Esquire R. E. Architzel, NRC D. H. Jaffe, NRC i
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