ML20203D722
| ML20203D722 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 11/28/1997 |
| From: | Doerflein L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| References | |
| 50-317-97-05, 50-317-97-5, 50-318-97-05, 50-318-97-5, NUDOCS 9712160274 | |
| Download: ML20203D722 (2) | |
See also: IR 05000317/1997005
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-November 28, 1997
Mr. Charles H. Cruse
Vice President Nuclear Energy
Baltimore Gas and Electric Company
- Calvert Cliffs Nuclear Power Plant
1650 Calvert Cliffs Parkway
Lusby, MD 20657- 4702-
SUBJECT:
NRC INSPECTION REPORT NOS. 50 317/97 05 AND 50-318/97-05
Dear Mr. Cruse:
This letter refers to your November 10,1997, correspondence in response to our
October 9,1997, letter.
Thank you for informing us of the corrective and preventive actions documented in your
letter. These actions will be examined during a future inspection of your licensed program.
We appreciate your c'ooperation.
Sincerely,
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Original Signed by:
Lawrence T. Doerflein, Chief
Projects Branch 1
Division of Reactor Projects
Docket Nos. 50 317
50 318
cc:
T. Pritchett,' Director, Nuclear Regulatory Matters (CCNPP)
R. McLean, Administrator, Nuclear Evaluations
J. Walter, Engineering Division, Public Service Commission of Maryland
cc w/ copy of Licensee's Response Letter:'
K. Burger, Esquire, Maryland People's Counsel
R. Ochs, Maryland Safe Energy Coalition
State of. Maryland (2)
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9712160274 971128
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ADOCK 05000317
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0FFICIAL RECORD COPY
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Charles H. Cruse
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- Distribution w/ copy of Licensee's Response Letter:
K. Kennedy, RI EDO Coordinator
- S. Stewart Calvert Cliffs
S. Bajwa, NRR
A. Dromerick, NRR
L. Doedbin , DRP
T. Mostak, CRP
R. Junod, DRP
M. Campion, RI
Nuclear Safety information Center (NSIC)
PUBLIC
Region I Docket Room (with concurrences)
Inspection Program Branch, NRR (IPAS)
DOCDESK
DOCUMENT NAME: A:\\RL970505.CC
To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure
"E"
=
Copy with attachment / enclosure
"N" = No copy
OFFICE
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Rl/DRP
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NAME
TMoslaM(
LDoerflein ptJ
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DATE
11Tj$797 ' ' \\
1167/97
OFFICIAL RECORD COPY
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Csiants.s 11. Cnoss:
Baltimore Gas and Electric Company
Vice President
Calvert Cliffs Nuclear Power Plant
Nuclear Energy
1650 Calvert Cliffs Parkway
laby, Maryland 20657
410 495 4455
November 10,1997
U. S. Nucleer Regulatory Commission
Washington, DC 20555
ATTENTION:
Documer.t Control Desk
SUlWECT:
Calvert Cliffs Nuclear Power Plant
Unit Nos.1 & 2; Docket Nos. 50-317 & 50 318
NRC Region i integrated Inspection Report Nos. 50-317/97-05 and
50-318/97-05 and Notice of Violation
REFERENCE:
(a)
Letter from Mr. L. T, Doerfl in (NRC) to Mr. C. H. Cruse (BGE), dated
e
October 9,
1997, NRC Region I integrated Inspection Report
Nos. 50-317/97 05 and 50-318/97-05 and Notice of Violation
Please find attached our response to a Notice of Violation contained in Reference (a) concerning the
prompt identification and correction of problems associated with the installation of compression fittings
used in plant systems. Also, please note that a response to a second Notice of Violation contained in
Reference (a), concerning correctise actions to prevent recurrence of emergency lighting failures, is not
included in this submittal. An extensic 1 to the 30-day response period was discussed with and approved
by Mr. R. V Crienjak (NRC) on November 6,1997, Based on the aforementioned extension, we will
submit this response by November 17,1997.
Should you have questions regacding this matter, we will be pleased to discuss them with you.
Very truly yours,
,
a
for
C. H. Cruse
Vice President - Nuclear Energy
CIIC/CDS/bjd
Attachment
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Document Control Desk
November 10,1997
- Page 2
cc:
R. S. Fleishman, Esquire
11. J. Miller, NRC -
J. E. Silberg, Esquire
Resident inspector, NRC
Director, Project Directorate 1 1, NRC
R.1. McLean, DNR
A. W. Dromerick, NRC
J. II. Walter, PSC
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NITACIIMENT (1)
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INSPECTION REPORT NOS, 50-317(318)/97-05-02
10 CFR Part 30, Appendix B, Criterion XVI, Corrective Action," requires that measures be established
to assure that conditions adverse to quality, such as failures, deficiencies, defective equipment, and
noncortformances are promptly identified and corrected. In the case ofsignificant conditions adverse to
quality, the measures shall assure that the cause of the condition is determined and corrective action
taken topreclude repetition.
Contrary to the above, as of Afay 29,1997, BGE did notpromptly identify and correctproblems with the
installation of compression fittings used in plant systems, including the reactor coolant pressure
boundary. Problems with thefittings had been identified byfailures that occurred in 1992 and 1995. As
a result, afitting that had been improperly installed in 1996 on a pressurl:er instrument line, failed on
Afay 29,1997,
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REASON _ FOR TIIE VIOLAllON
Licenste Event Repon 317/97 005 was issued on June 30,1997, detailing the compression Htting failure
that occurred on Mr.y 29,1997, and the immediate corrective actions taken. Since issuance of this
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Licensee Event Report, we have completed a root cause analysis for this event. The immediate cause of
the failure to promptly address problems with compression fittings was that conyctive actions from
industry and site operating experience were not promptly identified and effectively incorporated into site
practices due to less than adequate ownership and follow-up. In addition, job performance standards
were not well defined and enforced co.ncerning wcrk on compression fittings.
In March 1992, we received Nuclear Regulatory Commission Information Notice 9215 describing an
unisolable reactor coobit kak at Oconce. The cause of this event was a separated compression fitting
on a 3/4 inch instrument line.
The Information Notice identified six common problems with
compression fittings. Calvert Cliffs reviewed this Information Notice and conc!aled that it applied to
our facility, We identified process improvements for tightening compression fittings and included these
improvements in plant instructions. These instructions included guidelines for verifying tightness of
Httings and for reassembly of fittings. We also determined that all compression fittings on tubing
connected to the Reactor Coolant System and related high pressure systems should be examined for
tightness,
in June 1992, action items were assigned to evaluate the issue, review and revise the appropriate plant
processes, and inspect as many compression littings as practicable. The use of go/no-go gauges and
development of specific procedures for the installation and make-up of"high demand" fittings was also
recommended.
Approximately 1500 compression fittings were inspected on each unit. Maintenance placed i temporary
hold and control on all compression fitting work to ensure no substandard compression Ot ngs were
installed while the inspections were being conducted. The inspections identified that less than
one percent of the compression fittings inspected were failed, and required replacement. About
30 percent of the compression fittings inspected required tightening to meet gap requirements.
Subsequently, the Maintenance group issued detailed guidance concerning compression fitting
installation and make-up to all major maintenance disciplines and required that any work done on
compression fittings must reference this guidance, llowever, since the guidance was considered a
reference document, strict adherence to it was not considered mandatory and was not enforced.
Management placed too little emphasis on guideline compliance, relying heavily instead on " skill of the
craft" to ensure compression fittings were properly installed
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A'ITACHMENT (1)
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INSPECTION REPORT NOS. 50 317(318)/97 0$-42
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In March 1993, an issue report was written documenting that several compression fittings were not
properly assembled according to manufacturers specifications, ne resolution to this issue report
consisted of several recommendations concerning combining training resources for compression fittings
and requiring all contractors to attend training, and climinating the use of go/no go gaug:s. These
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recommendations were not implementcd because there was not sufficier.t priority or emphasis by site
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management to resolve this ongoheg problem.
in April 1995, an issue report was written concerning the possible over tightening of compression
fittings on a turbine bypass valve and one ferrule being installed backwards. He corrective actions for
this issue report were still uaderway at the time that the thing failed on an instrument line to the
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pressurizer vaper space, which resulted in a plant shutdown on May 29,1997. Dem corrective actions
included development of a technical procedure for fabrication and installation of compression fittings. A
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due date of September 15, 1997, for development of this procedure had been justified based on the
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existence of other practices and guidelines concerning compression fitting installation and makeup.
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%c root cause analysis concerning this issue identified the following major causes:
Corrective acticns from industr- and site operating experience were not promptly identified and
effectively incorporated into site practices due to less than adequate ownership and follow up. In
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addition, self assessment was less than adequate to identify the poor responses to this issue. Failure to
implement fully effective personnel training :md procedures contributed to future compression fitting
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installation errors. Subsequentl on May 29,1997, the falhtre of a compression fitting on a pressurizer
instrument line caused a plant shutdown.
- Job performance standards were not well defined. Work practices for inrtallation and make-up of
comptrssion fittit. were developed, but issued only as guidelines. Since strict adherence to theee
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guidelines was not ensidered mandatory, and the guidelines were inconsistently used, nese guidelines
would have been effer.tive in preventing the May 29,1997 compression fitting failure if they had been --
strictly followed.
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I f, CORRECHVE SIEPS TilAT IMVE HEEN TAKEN AND Tur_ RESETS ACHJEEED
Licensn I? vent Report 317/97 005 umtain = 'ist ofimmediate corrective actions that were taken after
the convression fitting failure on May 29,1997. In addition to these corrective actions, the following
actions have been completed:
A formal root cause analysis has been completed that identifies the causal factors for this issue. He root
cause ualysis report c.intained recommendations designed to prevent recurrence of similar events in the
future.
To address the lack of effective self-assessment ti.at contributed to this issue, the lessons learned from
this event have been summanzed and are in the process of being communicated to appropriate levels of
plant supervision and personnel. De focus of this exercise is to provide feedback to plant supervision
concerning this fallute to effectively resolve industry expcrience and prevent such failures in the future.
A inandatory co npliance technical procedure for tubing installation has been developed and replaced the
guidelines previously used. His procedure consolidates the requirements for compression fitting work
into alingle prtcedure, its use is required for all compression fitting assembly and installation
conducted by the Maintenance group. Training on this technical procedure has been developed and
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ATTACitMENT (1)
INSPECTION REPORT NOS. 50 317(318).97 05-02
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conducted for appropriate personnel invnived with comicession fitting assembly and installation. Some
of the recomrnendations from the training sessions were incorporated into the technical procedure and
others are 6till under review. 'this training will also be conducted for any other plant personnel required
to install compression fittings on permanent plant equipment prior to them performing the work.
Compression fitting vendor instruction manuals have been incorporated into appropriate vendor technical
manuals.
III. CORRECTIVE
STEPS
TilAT
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FURT11ER
Y10LA110ES
Maintenance has identified guidelines that could potentially effect the operation of the plant. These
guidelhics are being either proceduralized or deleted.
We are currently in the process of evaluating other maintenance technical proecdures that may require
consolidction across discipline lines. In addition, we are currently evaluating methods to ensure lessons
learned from industry and plant experience are more efficiently internalized at Calvert Cliffs to prevent
similar events.1his initiative will address the ownership and follow up issues that contributed to this
event.
IV. DATE WilEN FULL COMPLIANCE WILL llE ACillEVED
Calvert Clifts is currently in compliance. No additional compression 6tting failures have occurred.
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