ML20104B453
| ML20104B453 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 09/11/1992 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9209150327 | |
| Download: ML20104B453 (3) | |
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y er B ALT IMOftC GAS AND ELECTRIC 1650 CALVERT Cl.'FFS PARKWAY e LUSBY, MARYLAND 20657-4702 Otonat C CnrEt st w oei v.ca enc air,e en September 11,1992 m om.o.aera U. S. Nuclear Regalatory Commission Washington, DC 20$55 ATTENTION:
Document Control Desk SUWECE Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50 318 Reply to a Notice of Violation, Inspection Report Nos. 50-317f3219 and Sldl&."S:19
REFERENCE:
(a)
NRC Inspection Repeds 317/92-19 and 318/92-19 L
Gentlemen:
Reference (a) identified a vioiation of 10 CFR Part 50 Appendix B. Attachment (1)is our response to the violation.
Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours, n
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Attachment cc:
D. A. Brune, Esquire J. E. Silberg, Esquire R. A. Capra, NRC D. G. Mcdonald, Jr., NRC T. T. Martin, NRC P. R. Wilson, NRC g6,ff R.1. McLean, DNR J. IL Walter, PSC 150126 f
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NITACilMENT m REPLY TO A NOTICE OF VIOLATION j.gfJrFION REPORT NOS. 50 317/9219 AND 50-318/9219 1,
DESCRIPTION ANJLCAUSE OF VIOLATION.
Quality Verification (QV) hold 30ints are inspection steps written into maintenance werk procedures. For adequate QV 1ald point inspection, verification must occur either while work is in progress or before work proceeds. Procedures require that QV be notified when a job is started and when the points are reached to ensure they are at the job site when needed.
j Through a variety of mechanisms, Maintenance on several jobs failed to make the required notifications to QV. Some missed notifications resulted in Maintenance working through hold points without the required QV unit concurrence. These missed. notification tssues were identified through, and addressed by, the Issue Report (IR) corrective action system.
i Beginning in 1990, the Independent Safety Evaluation Unit (ISEU) at Calvert Cliffs noted j
the incidence of these issue Reports and tracked missed notifications as a specific trend. In 1991, ISEU presented the trend concerns at Management Resiew Board meetings on three occasions: May 3 June 14, and August 14.
As the line organization directly involved in the QV notification trered, Maintenance was primarily responsible for its assessment and correction. In idling the individual Issue Reports, Maintenance initiated preventive actions for the coserved deficiencies. These consisted primarily of trarmng sessions to reinforce existing procedural requirements. In addition, the work control process was being significantly revised during 199L Revised procedures and work planning changes were expected to correct the administrative ambiguities which contributed to tf occurrence of failed notifications. Maintenance did not assess any of the reported occurrences as safety sigailicant, nor did it assess their aggregate effect as significantly compromising the assurance that maintenance was effective in restoring equipment to full quality and compliance.
De Quality Assurance (QA) organization was also aware of the instances of missed notification and inspection and of Maintenance's actions, nnd they concurred in the overall assessment that equipment quality was being maintained. In addition, QA assessed that these omissions did not represent a significant degradation in their ability to effectively evaluate the quality of line organization work. QA believed that they could improve the procedures for QV nethities to clarify requirements, and these concernt were included in the major rewrite of Quality Program procedures begun in early 1992.
. in summary, our retrospective view of the missed OV notification trend is that these instances did not significantly degrade either our maintenance ~or quality program effectiveness. Identification of the trend at an early stage by ISEU was appropriate. Our initial corrective actions-(enhanced training) were not effective in preventing recurrence.
While we were actively pursuing additional corrective actions at the time that this issue was cited by your inspection aethities, management should have taken further actions sooner.
II.
CORii: JIVE STEPS TAKEN AND RESU[Ll'S ACillEVED.
QV and Maintenance management expectations regarding 09 notification were provided to propriate personnel. A strong Plant General Manager's statement was also issued.
Maintenance procedure MN-1-100, Conduct of Maintenance, was immediately revised to strengthen procedural controls over work resumption when QV "STOP WORK" orders are issued.
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ATI ACllMENT (1)
ItEPLY TO t. NOTICE OF VIOLATION J,NSPECIM)N REPOltT NOS. 50-317/9219 AND 50 318/92-19 The QV inspection point stamping process was changed to eliminate one missed notification cause.
Calvert Cliffs Instruction (CCI)116, Program Deficiency Report (PDR) Program was appsuved. 'This procedure classifies missed hold point and notification issues as ones which require the initiation of a progra'n PDR.
Ill.
[ORRECflVX,JCrlONS WillCil )yll,L llE TAKEN TO M'OIO FUl(TilliR 310ldTIONS.
Calvert Cliffs will continue the Quality Program procedural improvement; already under review as part of our Procedure Upgrade Program cifort. CCI 116 was a part of this, and other key elements of the revised procedural hierarchy for Quality Programs have been reviewed to incorporate concerns reflected in this violation. These elements, some OL-3 series procedures, are scheduled for implementation by October 1,1992.
Line management and Quality Assurance will ensure that all affected parties understand QV Program expectations. Nuclear Maintenance Section will accept responsibliity for tracking the OV-notification trend. The trend will be evaluated monthly and further corrective ections will be taken to correct it, if n.:cessary.
IV,
]) ATE WilEN FUl4 COMPldANCE WIL],ilE AC))1EVED.
Compliance was achieved when immediate conective action was taken to addrus the adverse trend.
Significant trend reduction was seen following issuance of the management expectations.
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