ML20105B769
| ML20105B769 | |
| 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 9209210171 | |
| Download: ML20105B769 (3) | |
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e B A LT IMORE GAS AND ELECTRIC 1650 CALVERT CLIFFS PARKWAY e LUSBY, MARYLAND 20657 4702 orcmot c cntu si,wa v u n n o m moneo mo September 11,1992 i
F U. S. Nucles.r Regulatory Commission Washington, DC 20555 NITENTION:
Document Contr01 Desk
SUBJECT:
Calvert Cliffs Nuclear Powcr Plant Unit Nos.1 & 2: Docket Nos. 50J17 & 50-318 Reply to Notice of Violation. Inmectiodlepe1N,q. 92-1R
REFERENCE:
(a) letter from hir. J. P. Durr (NRC) to hir. G. C Creel (BG&E), dated August 5,1992, insersice Testing Inspection at Calvert Cliffs Units 1 and 2, NRC Combined Inspection Report Nos. 50-317f>218 and 50-318S2-18 Gentlemen:
Attachment (1) is provided as our response to Reference (a).
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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GCC/JV/jv/bjd
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Attachment ec:
D. A. Brune, Esquire J. E. Silberg, Esquire R. A. Capra, NRC D. G. hicDonald, Jr., NRC T. T. h1artin, NRC P. R. Wilson, NRC
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9259210171 920911
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AlTAC!! MENT 0]
REPIN TO NOTICE OF VIOLATION INSPECTION RKl' ORT NO,9218 Notice of Violation 50-318N218-01 states that as of June 26,1W2, llaltimore Gas and lilectric Company h_d not taken measures to identify the cause of sepeated failures of valve 2-SW 5173-CV on December 8-10, lWl, April 4, IW2, May 10, IW2, and May 22,1W2. Corrective actions to preclude repetition had also not been identified.
1.
I!!2iGlirrlON AND CAIISl? OF EVEN r.
On December 10,1W1, Unit 2 Salt Water system valve 2-SW-5173-CV failed to pass Surveillance Test Procedure (STP) 0-65 2, Quarterly Valve Operability Verification, by not 1xnitioning to full open. Valve 2 SW-5173-CV is an air-operated butter 0y valve used for controlling the Salt Water system flow to the 22 Emergency Core Cooling System (ECCS) pump room air cooler. The normal operating position of the valve is shut, and the valve -
safety position is open, ensuring a cooling water How path to the coolers. STP O-65 2 is used to stroke the valve and verify the full range of motion of the valve. In response to the failed test, the valve was manually opened and a Temporary Note was attached to the switch for the valve. The Temporary Note indicated the valve was to be left in the open Ixnition because it had failed STP O-65 2. A Maintenance Request (MR) for the valve was initiated. An MR tag was also hung next to the switch. A Maintenance Order (MO) was generated from the MR and included specified hardware changes necessary for the proper operation of the valve. Ilecause the valve was kept in a safe position, a high priority was not placed on the MO when replacement parts were hard to obtain.
On February 29,1W2, STP O-65 2 was performed on 2 SW 5173.CV per the routine STP schedule. The valve passed the STP, but was kept locked open. On April 4, IW2, STP O-65-2 was performed again and the valve failed the STP. No furthes action was taken because the associated MO was still open.
On May 1, IW2, the valve was manually fully shut for work unrelated to the valve problems.
The valve subsequently operated properly. Maintenance personnel reported to the Control Room Supervisor (CRS) that 2 SW 5173-CV would probably pass STP O 65 2. STP O 65 2 was performed and the valve passed. The CRS then shut 2-SW-5173-CV, which is its normal 1xnition. 130th the CRS and the Maintenance personnel kncw that the associated MO existed, but felt that appropriate action had been taken to restore the valve to its normal position. The CRS did not want to have the MO clos-d out, but the Temporary Note and the M R tag on the valve switch were removed.
On May 10, IW2, vaive 2 SW 5173-CV was positioned open to complete a system evaluation.
Personnel noticed that 2-SW-5173.CV would not fully open. Though the valve was manually opened for the evaluation, when the evaluation was completed, the valve was ekned and an MR written to address the issue. On May,22,1W2, after a question by an NRC Resident inspector, it was identified that 2-SW-5173 CV should have been left open, the valve was-cpened and a Temporary Note attached to the switch regarding the problem.
Maintenance and Engineering intended to remove, inspect, and repair the valve. Until this could be done, a Temporary Note on the valve was used to ensure it remained in the open position. When the CRS was told that the valve worked properly and it subsequently passed STP O.65-2, he determined this satisGed the requirements on the note and was sufficient reason to remove the Temporary Note control without further discussion with the technical staff. The lack of pertinent background information available and not clearly understanding 1
A'ITACllMENT (1)
W-My ItEPLY TO NOTICE 0F VIOLATION
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INSPECTION ItEPoltT NO 9113
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the necessary corrective me:isures to.ulted in the CVS making na incorrect decision on
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control of the valve.
11.
COltiq'CI'lVE STEPS TAKEN AND ltESULTS AQIIEVED.
The General Supenisor - Nuclew Plant Operations has discussed with Operations shift personnel the importance of verilying that deficient components are fully operational and 1
cmphasized the importance of better understanding the nature of corrective measures
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required before removing temporary controls. The Temporary Note on the valve switch now states that the note cannot be rt: moved until asseciated maintenance and post maintenance testing are compicie.
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COltr.TI'lVE STEPS WillC11 WILL llE TAKEN TO AVOID FUltTilElt VIOL ATIONS.
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Applicable procedures to ad.iress equipment maintained outside its normal position to meet L
design requirements will be changed. Such equipment will not be made fully operational unless applicable MOs, asscciated documentation and post mi oce testing are complete or a recommendation is rencived from the appropriate techn sport organization stating that the equipment can be made fully operational without u,-
iction of applicable MOs.
b Temporary Notes will be attached to appropriate equipment with improved descriptions of i
why the equipment must be left in its accident condition.
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PA'I E WilEN FULL COM PLI ANCE Wil L 11E AC11111111 Full compliance was achieved when 2-SW-5173-CV was opened on May 22,1992.
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