ML20117D649
| ML20117D649 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 08/23/1996 |
| From: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9608290020 | |
| Download: ML20117D649 (7) | |
Text
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CHARLES II. CRUSE Baltimore Gas and Electric Company Vice President Calvert Cliffs Nuclear Power Plant Nuclear Energy 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 410 495-4455 August 23,1996 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Renly to a Notice of Violation -- Inspection Report Nos. 50-317(318V96-04
REFERENCE:
(a)
Letter from Mr. C. J. Cowgill (NRC) to Mr. C.11. Cruse (BGE), dated July 26, 1996, NRC Region I Integrated Inspection Report Nos. 50-317/96-04 and 50-318/96-04 and Notice of Violation in response to Reference (a), Attachments (1) and (2) detail our response to the cited violations concerning inadequate storage of radioactive material and missed fire watches.
Should you have questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours,
/
CilC/DWM/bjd
/ ttachments cc:
D. A. Brune, Esquire
- 11. J. Miller, NRC J. E. Silberg, Esquire Resident inspector, NRC Director, Project Directorate I-1, NRC R. I. McLean, DNR A. W. Dromerick, NRC J. II. Walter, PSC 9608290020 960823 PDR ADOCK 05000317 G
PDR acuzo fp I
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l AITACIIMENT m REPLY TO NOTICE OF VIOLATION 50-317(318)/96-04-02 FAILURE TO FOLLOW RADIATION PROTECTION PROCEDURES Notice of Violation Nos. 50-317/96-04-02 and 50-318/96-04-02 describe a nonconformance involving inadequate storage of radioactive material. The Notice of Violation states, in part, that:
4 On June 21,1996 an undetermined number of radioactive materialpackages, stored outdoors and outside a posted contaminated area in the old Sally Port, exhibitedfaded labels or tags that were not protectedfrom the environment. Further, the old Sally Port contained a package of radioactive material that was breached, not protectedfrom environmental conditions, and the damagedpackage hadnot been replaced, as necessary, toprevert the spread ofcontamination.
I.
REASON FOR TIIE VIOLATION On June 21,1996, a Nuclear Regulatory Commission Region I inspector toured the old Sally Port, a i
storage area for radioactive material typically staged for reuse during outages, and a temporary storage area for outage materials brought by contractors. During this tour, he identified several radioactive material packages with faded labels or tags. In addition, a package of radioactive material (a steel box) was breached in that one side was pushed in, exposing the interior of the box. The box contained a High Efficiency Particulate Air ventilation system which, according to the label on the box, could measure up 2
to 40,000 dpm/100 cm of removable contamination. Subsequent investigation found no contamination on the outside of the box or in the breached area.
At the time of this violation, the old Sally Port was used as a common staging area for material owned by
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several groups. Although the Materials Processing Unit Supervisor had ownership of the area, there was a common understanding among these various groups that they would be responsible for their own material.
The procedures governing inspections in outside radiological material storage areas lacked sufficient inspection guidance. Management's expectations regarding ownership and accountability for material stored in the area were not clearly stated.
Additionally, personnel performing inspections in the area did not exhibit a sufficient questioning attitude. Shortly before the Nuclear Regulatory Commission inspector found the breached container, an ALARA Technician had inspected the area and had not identified the container as being damaged.
II.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED A.
Immediately upon discovery, the breached container was taken to an indoor storage area and repaired. Radiological surve).2 determined that there was no release of radioactivity from the container.
B.
Subsequently, accessible radioactive waste and material containers were inventoried pnd inspected to ensure compliance with established plant procedures. No other breached containers were identified. All faded labels or tags were replaced with ones suitable for an outside environment.
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1 ATTACHMENT (1)
REPLY TO NOTICE OF VIOLATION 50-317(318)/96-04-02 FAILURE TO FOLLOW RADIATION PROTECTION PROCEDURES C.
Awareness training was given to appropriate Radiation Safety personnel concerning the specifics of this violation and particularly, management's expectations concerning ownership, accountability, and the need for a good questioning attitude.
III.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS We are revising our procedures to clearly identify the inspection criteria, ownership responsibilities, and controls governing the maintenance and inspection of radiological material storage areas. Appropriate Radiation Safety personnel will be trained on the revised procedures.
Periodic self-assessments by Radiation Safety supervision will verify that radiological material storage areas are being properly maintained.
IV.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on June 21,1996, when the faded labels and tags were replaced, and the breached container was moved into a closed building and repaired.
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ATTACHMENT (2)
REPLY TO NOTICE OF VIOLATION 50-317(318)/96-04-06 MISSED TECHNICAL SPECIFICATION FIRE WATCH PATROLS Notice of Violation Nos. 50-317/96-04-06 and 50-318/96-04-06 describes a nonconformance involving three occurrences of failure to complete fire watch patrols in safety-related areas. The Notice of Violation states, in part, that:
On April 10,1996, and thereafterforfour days and 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />, hourlyfire watch patrols were not completedfor the Unit I service waterpump room when thefire detection system in the room was not operable.
On May 22,1996,for two hours, the hourlyfire watchpatrols were not completed in the Unit 2 i
service water pump room after the fire barrier penetration had been made inoperable at 7:34 a.m. and thefire detection system had been demonstrated operable.
On June 19,1996,from 6:00 a.m. until 1:30 p.m., hourlyfire watches were not conducted in the Unit 2 component cooling pump room when the fire detection system in the room was not operable.
L REASON FOR THE VIOLATION A.
The hourly fire watch patrol for Unit 1 Service Water Room was not completed from 0835 April 10,1996, to 0700 April 15,1996. During this time, the fire detection system was out-of-service in the room. The hourly fire watch patrol had been previously 4
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combined with the continuous fire watch when the room doors were opened. When the doors were closed, the continuous fire watch was suspended, but the hourly patrol was not reinstated.
5 The cause of this event was ineffective ownership and oversight of the fire watch process by the Safety and Fire Protection Unit (SFPU). Fire Protection, SA-1-100, defines the process for initiating and maintaining fire watches. While the group that impairs a fire protection system or barrier is responsible for obtaining and maintaining a fire watch, SFPU is responsible as the program owner to ensure that these watches remain in place.
l The process defined in SA-1-100 did not contain appropriate tools to maintain oversight I
i of the process. There was no documentation to indicate the responsible work group when a fire system is impaired or removed from service. The fire barrier permits did not indicate responsibility for the fire watch and did not contain a review to verify if other Action Statements are in effect when the permit is closed out.
4 B.
The maintenar.ce worker assigned hourly fire watch patrol for Unit 2 Service Water Room did not complete or document patrols for the first 2-1/2 hours that the room doors were open. The security contractor monitoring the room completed and documented the patrol upon discovery.
The cause of this event was inattention to detail and a failure of the assigned individual 4
to meet expectations and perform his assigned task. The worker was briefed by SFPU 1
ATTACHMENT (2) l REPLY TO NOTICE OF VIOLATION 50-317(318)/96-04-06 i
MISSED TECHNICAL SPECIFICATION FIRE WATCH PATROLS when the permit was issued and advised of the time the first hourly patrol would be d
required. The worker posted the permit at the door and entered the room to work. He did not turnover responsibility for the fire watch patrol to any other workers or the security contractor.
C.
A Temporary Alteration was installed to remove the smoke detection system from service in the Unit 2 Component Cooling Room at 0600 on June 19,1996. Notification was not made to SFPU by the work group as required by the Temporary Alteration Work Package. Although not procedurally required to do so, the Operations Shift Supervisor's normal practice is to contact SFPU prior to installation of temporary alterations of this type. In this case, he did not make the notification. No compensatory measures were put in place because no notification was made to SFPU.
The cause of this event was failure to follow procedure by the Electrical Maintenance worker. Either he or the Operations Shift Supervisor could have provided an effective barrier in ensuring that compensatory measures were carried out.
IL CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED A.
Immediately upon discovery, an hourly fire watch patrol was reinstated and a tour was i
completed.
The SFPU also put in place a policy that hourly and continuous compensatory measures fire watches could not be combined until such time as they can be procedurally controlled.
B.
Immediately upon discovery, an hourly fire watch patrol was completed and the person originally assigned was relieved.
C.
Immediately upon discovery, SFPU completed a tour of the area and a functional test of the sprinkler system to meet Technical Specification Action Statement requirements.
The General Supervisor-Nuclear Plant Operations, communicated the expectation, via night orders, that no fire protection related Action Statements would be entered without first discussing with SFPU. All planned fire watches have been made continuous to i
avoid missing a single hourly tour. The Supervisor-SFPU provided awareness training to key maintenance and security groups.
An interim traveler document was initiated by SFPU that:
Requires work group supervisory involvement to enter an action statement.
Physical verification by SFPU that the compensatory measures are in place before SFPU will discuss the Action Statement with Operations'.
The Fire Barrier Permit includes fire system impairments. This places all compensatory measures for fire protection within one process.
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ATTACHMENT m
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REPLY TO NOTICE OF VIOLATION GO-317(318)/96-04-06 i
j MISSED TECHNICAL SPECIFICATION FIRE WATCH PATROLS The Fire Barrier / Impairment Permit requires the supervisor signature of the e
3 work group assigned responsibility for the fire watch or compensatory measures.
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A new Fire Barrier / Impairment Permit is required any time the type of j
compensatory measure changes or the responsible fire watch group changes.
Safety and Fire Protection Unit reviews all Fire Barrier / Impairment Permits on 2
- initiation or close-out to determine if any other Action Statements are impacted.
We have reviewed these three events and concluded that, although the end results were similar, each event was unique. One event is attributed to an ineffective element of the program, and the others were 7
caused by human error. The corrective actions taken were effective in addressing the cause of each event.
IIL CORRECTIVE STEPS WHICH WHL BE TAKFN TO AVOID FURTHER VIOLATIONS In addition to incorporating the above noted items temporarily performed via the interim traveler document, the following program improvements are being made in procedure SA-1-100, Fire Protection:
Statements are being added to clarify ownership and responsibility for compensatory measures.
Safety and Fire Protection Unit will conduct periodic reviews to verify all fire-related l
Technical Specification Action Statements are being met.
Although not yet proceduralized, this action is currently being done.
There will be a reconciliation of the SFPU and Control Room logs, for compensatory measures in place, completed each shift. Although not yet proceduralized, this action is currently being done, Fire watches will be required to report completion of hourly tours via a dedicated pager e
number. This will enable SFPU to obtain nearly real-time confirmation that tours have been done. Safety and Fire Protection Unit will complete unreported tours and then investigate the issue.
Training on the procedure changes of key program users will take place prior to implementation.
An independent assessment of the fire protection program is in progress to identify if other problems exist in Fire Protection Program implementation.
Following these three events, Nuclear Regulatory Commission Resident Inspectors conducted a follow-up inspection and noted several fire protection program weaknesses in -Inspection Report Nos. 50-317/96-04 and 50-318/96-04.
'l The first weakness was an informal, uncontrolled walkdown list, or attachment, to the fire watch patrol list. This list was maintained by the security contractor to indicate active fire watch patrol areas and was 3
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i oo MACHMENT (2)
REPLY TO NOTICE OF VIOLATION 50-317(318)/96-04-06 MISSED TECilNICAL SPECIFICATION FIRE WATCII PATROLS not reviewed by Baltimore Gas and Electric Company personnel. This list was used contrary to program requirements in that fire watches would refer to the " attachment" rather than make an entry on the fire watch patrol log to indicate the areas patrolled. In addition, SFPU personnel would make reference to this same list when completing shift turnover documentation. When informed of this issue, use of the list l
was immediately suspended. Provisions have been made in the revision to SA-1-100 to generate a controlled list when multiple areas are being patrolled.
l The second weakness was indicated by failure of Fire and Safety Technicians to sign an approval signature on SA-1-100, Attachment 11, Fire Watch Patrol Log. This form was used as a continuation sheet for a fire watch patrols that exceeded one shift or when no Fire Barrier Permit was associated with j
a fire watch patrol. When informed of the issue, immediate guidance was given to Fire and Safety Technicians to sign the Attachment 11 when initially presented by the fire watch and to do a walkdown each shift to sign the Attachment 11 for patrols exceeding one shift. With all entries into fire protection j
Action Statements being on a permit approved by a Fire and Safety Technician, this signature requirement is being eliminated in the revision to SA-1-100.
IV.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED I
Full compliance was achieved on June 19,1996, at 12 noon when a sprinkler functional test and tour was f
completed by the Safety and Fire Protection Unit in Unit 2 Component Cooling Room.
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