ML20211L281
| ML20211L281 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 06/06/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20211L262 | List: |
| References | |
| 50-317-86-07, 50-317-86-7, 50-318-86-07, 50-318-86-7, NUDOCS 8607020041 | |
| Download: ML20211L281 (2) | |
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APPENDIX A NOTICE OF VIOLATION Baltimore Gas and Electric Company Docket / License: 50-317;DPR-53 Calvert Cliffs Units 1 and 2 50-318;DPR-69 As a result of the inspection conducted on March 4 - April 30, 1986, and in accord-ance with the NRC Enforcement Policy (10 CFR 2 Appendix C), the following violations were identified:
A.1 10 CFR 50, Appendix B Criterion XI, " Test Control," requires that test proce-dures include provisions for assuring that all prerequisites for a given test have been met and that adequate test instrumentation is available and used.
Contrary to the above, on March 10, 1986, during the performance of STP-073-1
" Engineering Safety Features Equipment Performance Test," procedures did not assure that test prerequisites had been met in that No. 13 High Pressure Safety Injection Pump Discharge Pressure gauge 1 PT-301Z was inadequate for use, out of calibration, and used to demonstrate functional acceptance of safety systems.
This is a Severity Level V Violation (Supplement I) applicable to DPR-53.
A.2 The Baltimore Gas and Electric Quality Assurance Manual Section 18.2, " General Controls," requires that the QA Program meet the requirements of Regulatory Guide 1.30, August 11, 1972.
Regulatory Guide 1.30 " Quality Assurance Requirements for the Installation, Inspection and Testing of Instrumentation and Electric Equipment," August 1972, establishes that acceptable methods for compliance with the pertinent sections of Appendix B to 10 CFR 50 requirements are included in ANSI N45.2.4-1972, " Installation, Inspection, and Testing Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations" (also designed as IEEE Std. 336-1971).
Although subdivision 1.1 of ANSI N45.2.4-1972 states that the requirements promulgated apply during the construction phase of a nuclear power plant, RG 1.30 specifies that these requirements are also to be considered applicable for the installation, in-spection and testing of instrumentation and electric equipment during the operation phase of a nuclear power plant.
ANSI N45.2.4-1972, " Installation, Inspection and Testing Requirements for In-strumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations," Section 6, " Post Construction Verification," requires that tests be made to assure that instrumentation and control channels are properly calibrated, and that items requiring calibration be tagged or labelled on completion indicating the date of calibration and identity of person that performed the calibration.
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Appendix A 2
Contrary to the above, as of March 10, 1986, installed instrumentation at Calvert Cliffs was not being tagged or labelled indicating the date of cali-bration and identity of the person that performed the calibration.
This is a Severity Level V (Supplement I) applicable to DPR-53 and 69.
A. 3 10 CFR 50, Appendix B Criterion V, " Instructions, Procedures and Drawings;"
requires that activities affecting quality be prescribed by documented in-structions, procedures, or drawings, of a type appropriate to the circum-stances and be accomplished in accordance with these instructions, procedures, or drawings.
Contrary to the above, on March 22, 1986, a post-maintenance test of electro-matic relief valve 1-ERV-404 was accomplished by procedures not appropriate to the circumstances resulting in the inadvertent isolation of the Unit 1 shutdown cooling system.
Additionally,10 CFR 50, Appendix B, Criterion XVI, " Corrective Action," re-quires that measures be established to correct failures, malfunctions and deficiencies, and in the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Contrary to the ebove, the loss of shutdown cooling event, a significant ad-verse condition which occurred on November 1,1985, and caused by instructions inappropriate to the circumstances, recurred on March 22, 1986, due to proce-dures inappropriate to the circumstances.
Additional events leading to the loss of shutdown cooling occurred on June 2,1985, and January 4 and 7,1983, and October 12, 1983. Collectively, these events demonstrate that adequate corrective actions had not been taken to preclude repetition of loss of shut-down cooling.
This is a Severity Level IV Violation (Supplement I) applicable to.0PR-53 and 69.
Pursuant to the provisions of 10 CFR2.201, Baltimore Gas and Electric Company is hereby required to submit to this office within 30 days of the date of this Notice, a written statement or explanation in reply, including:
(1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved.
Where good cause is shown, consideration will be given to extending the response time.
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