ML20245K402
| ML20245K402 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 08/10/1989 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| EA-89-107, NUDOCS 8908180445 | |
| Download: ML20245K402 (9) | |
Text
7 4
j$
'\\~1
- i pi BALTIMORE r
GAS AND ELECTRIC e
- i' t
CHARLES CENTER P.O. BOX 1475 BALTIMORE, MARYLAND 21203
- GEORGE C. CREEL viet Passiorm wuets*=t caov Augurt 10, 1989
' (sos) eso-44ss Director, Office of Enforcement U. S.' Nuclear Regulatory Commission Washington, DC 20555 A'ITENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos. I & 2; Docket Nos. 50-317 & 50-318 Renly to a Notice of Violation. EA 89-107
REFERENCE:
(a) Letter from Mr. W. T. Russell (NRC) to Mr. G. C. Creel (BG&E),
dated July 12, 1989, Notice of Violation and Proposed Imposition of Civil Penalties (NRC Inspection Report Nos. 50-317/89-11; 50-318/89-11)
' Gentlemen:
Pursuant to the provisions of 10 CFR 2.201, Attachment (1) is our reply to the violations delineated in Reference (a). Also, please find enclosed payment in the sum of $75,000 for the referenced civil penalty (BG&E Check No. 1025001).
This Notice of Violation involves two events:
o Temporary modifications without prior 10 CFR 50.59 evaluation or review by the Plant Operations and Safety Review Committee (POSRC),
and o
Breaches of the containment boundary during core alterations.
As we discussed with you at the May 30, 1989, enforcement conference, the broader implication of these events involves control of operations and maintenance activities, including temporary modifications, potentially affecting nuclear safety. We discussed our corrective actions for these issues at the enforcement conference as well as at meetings with you at your offices on May 10, 1989, and our offices on May 12,1989. We feel the result of these meetings was a mutual understanding of our commitment to correct these specific symptoms by formulating a broad-based action plan to correct their underlying causes.
The changes we plan to make in the area of safety tagging procedures and work control processes are going to require time and much effort. However, completion of these changes will ensure that we meet our long-term con.mitment to support safe and reliable operation of Calvert Cliffs Nuclear Power Plant. In the meantime, we have assured that safety remains our top priority by, among other actions, slowing down our $
n SM8188M SE*yj,7[-
'l 1
~/de4. 7.5;oooj o
(j.
f F
i
- f 9
Document Control Desk i
. August 10, 1989' l
Page 2 l
outage-related work on both Units. This relieves the pressure on our work force and helps ensure that our operations and maintenance schedules are not pursued at the l
expense of public health and safety.
We understand the issues involved here and we have taken prompt and effective action to prevent recurrence. We are pursuing longer-term improvements which will further enhance our performance in these areas. Our goal is not to simply meet industry l
standards; it is to bring Calvert Cliffs to the ranks of top performing plants in the nuclear industry.
Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours, I
i STATE OF MARYLAND TO WIT :
$00 nL O( OdlUrs t a /
.19 N efore me, the I hereby certify that on the
/0 d u day of M4hA b
suly)criber,7ea Notary Public of the State of Marylandl in and forD /7 6 A u 'A >
('A u d
, personally appeared George C. Creel, being duly sworn, ahd states that he is VJce President of the Baltimore Gas and Electric Company, a corporation of the State of Maryland; that he provides the foregoing response for the purposes therein set forth; that the statements made are true and correct to the best of his knowledge, information, and belief; and that he was authorized to pro. 'ide the response on behalf of said Corporation.
WITNESS my Hand and Notarial Seal:
ft M
[/ No(ary Public My Commission Expires:
13 s
GCC/JMO/dtm Attachments I
I
- y..:-
Document Control Desk
. August'. 10, 19,69 Page 3.
q.
cc:
. D. A Brune, Esquire
. J. E. Silberg, Esquire R. A.Capra, NRC S. A.McNeil, NRC W. T. Russell, NRC V. L. Pritchett, NRC T.. Magette, DNR D
w l
i+
4 A*ITACHMENT (1)
REPLY.TO A NOTICE OF VIOLATION
. JNSPECTION. REPORT - NOS.
50-317/89-11; 50-318/89-11 VIOLATION A:
FAILURE.TO MAINTAIN CONTAINMENT REFUELING INTEGRITY DURING CORE ALTER ATIONS -
1.
Admission or Denial of the Alleged Violation The violation involving two examples of failure to maintain containment integrity while core alterations were being performed, occurred as stated in the Notice of
. Violation with two' exceptions. The end times of the two events are incorrectly stated as 3:50 a.m. and 6:35 a.m., whereas the actual times should be 3:50 p.m.
and 6:35 p.m., respectively.
2.
Reasons for the Violation -
The root cause of the events have been identified as inadequate control of work processes, specifically; o
insufficient ' evaluation of the effects of work activities on containment integrity.
The potential effects of a
depressurized and drained containment' air cooler on containment integrity were not fully evaluated.
o Lack of sensitivity to containment closure requirements by Tagging
. Authority personnel and Operations / Maintenance Coordination (OMC) personnel. These groups failed to fully assess the consequences of tagouts and unscheduled work which could potentially affect containment integrity.
o Ineffective communication _ of the first event = in that oncoming operating shifts were not. made fully aware of the reasons and implications of the firs: event nor the purpose of the corrective actions associated with the first event.
o Safety tagging weaknesses in that our safety tagging program was geared towards accommodating the maintenance organization in a production-oriented manner and not predoniinately towards accomplishment of activities in accordance with the principals of nuclear safety (maintaining the plant in a safe configuration).
o Weak coordination of outage scheduling and maintenance activities in that we allowed unscheduled work to be performed without a thorough review of the effect on containment integrity in conjunction with other ongoing work.
There were no systematic controls to prevent ongoing work activities from overtaking established plant conditions. - - _ - -
1 l-ATTACHMENT J1)
REPLY TO A NOTICE OF VIOLATION JNSPECTION REPORT NOS.
50-317/89-11; 50-318/89-1I 3.
Corrective Stens That Have Been Taken and the Results Achieved We have implemented extensive corrective actions to address each of the five maior causes discussed previously. These corrective actions are as follows:
o Insufficient Evaluation of the Effects of Work Activity on Containment Integrity.
Immediately following the first event we took action to administratively control containment boundary valves with yellow caution tags to preclude inadvertent operation. After the second event the requirement for yellow tags was changed to a requirement for red danger tags. Red danger tags denote that the device is not to be operated or removed, nor its status changed in any manner until properly restored by a Safety Tagger. Red danger tags are currently the method by which we control the status of containment boundary valves during core alteration periods. We plan to tag equipment, including Control Room handswitches, required to maintain containment integrity with new uniquely colored tags. The new tags (green and black) are currently on order.
Specific instruction was added to the Surveillance Test Procedure for verification of containment integrity requiring the closure of containment air cooler (CAC) manual isolation valves for each CAC with depressurized service water piping.
Containment penetration maintenance is now severely restricted during periods when containment integrity is in effect. All proposed penetration maintenance during these time periods now requires review by an SRO. SROs have specific instructions to allow little or no containment penetration maintenance during these time periods. No local leak rate testing is allowed inside containment while refueling integrity is in effect.
Tagout and Maintenance Order (MO) review requirements were upgraded by performing a 100% audit of tagging records and the effects that existing tagouts had on the requirements of existing piant conditions; requiring two licensed operator reviews of MOs prior to starting work; and, requiring an SRO review of all tagouts for impact on containment refueling integrity.
Evaluation of the workload and staffing requirements of the Tagging Authority and shift operations to safely support the outage schedule has been performed. Enhancements will be made, where necessary.
o Lack of Sensitivity to Containment Refueling Integrity. Requirements A plant status board has been placed in the safety tagging area to inform TaEging Authority personnel of containment integrity requirements and other plant conditions. The Tagging Authority has also been added to the 2
~y; p w.,
z u
- ATTACHMENT (I)
[
h REPLY) "IO.. ' A' NOTICE OF YlOLATION JNSPECTION REPORT NOS.
50-317/89-11; 50-318/89-11 3
I distribution' of General Supervisor ' - Operations Notes and Instructions.
The GS-NO Notes and Instructions communicate informal notes or instructions-to shift personnel from the GS-NO. This' will add more consistency to the flow of information from Nuclear Operations supervision to these groups.
Physical walkdowns of tagging boundaries by the job supervisor independently, or with Tagging Authority personnel, is now required with limited exceptions.
Tagouts tied to scheduled work must be reviewed and issued no earlier than two days before actual work is scheduled to begin. This will prevent tagouts from being issued far in advance of scheduled work, thus giving the Tagging Authority and Control Roon; a higher level of awareness of the status of plant maintenance activity actually in progress, o<
Insufficient Communication of First Event The details of both events and the required actions to prevent recurrence have been communicated to site supervision and reviewed with all Nuclear Operations supervisors.
Nuclear Operat ons supervision is now more i
sensitized to the need for prompt communication' of significant information.
Face-to-face pre-shift briefings between operating -
- crews, Tagging Authority, and OMC personnel are now required to discuss plant conditions, work in-progress, and tagouts.
A set of laminated drawings to record tagout boundaries has been developed.
These drawings will provide a continuous current status of plant tagout boundaries. The drawings are maintained by the Tagging Authority office and are available to the - Shift Supervisors for consultation.
Control Room personnel shall be informed of the reasons for changes to STrs that could affect the safe operation of the plant.
o Safety Tagging Weaknesses Stricter tagging controls have been established, including weekly reviews of outstanding tagouts; strengthening control over supplementary tagout clearances; and, emphasis to tagging personnel that they are expected to deny tagging for poor job scopes and plans.
The Tagging Authority Supervisor position has been upgraded from a Senior Control Room Operator to a Shift Supervisor-level position. This person now reports directly to the Supervisor - OMC.
-3
7_
y w
ATTACHMENT '(If y
1 REPLY TO % NOTICE. OF : VIOLATION -
l
. INSPECTION - REPORT. - NOS.
50-317/89-11; 50-318/89-11 0
o' Weak. Coordination of Outage' Scheduling and Maintenance
. Containment ' refueling integrity windows are. now established,. verified by procedure, and ' maintained by conservative tagging methods regardless of K
whether core alterations are in progress.-
To gain firmer control ~ of - outage. ' work ' activities, we have significantly reduced the amount of maintenance activity and ' the number of maintenance personnel since. April 1989. These ~ reducations are meant to slow down outage work so that 'it can. be better controlled. and coordinated. The D
reductions do not effect the routine maintenance of equipment.
4.
Corrective Steos That Will be Taken to Avoid Further Violations Additional corrective. actions that are currently in progress or under evaluation
-include the following, o
Tagging Authority personnel changes shall be minimized during refueling
' outage - periods to provide stability, continuity, and a - good " memory bank" to the group.
o-
-An evaluation of. the organizational structure, staffing, and experience necessary ' to. support and control outage activities is planned. This will assure that the appropriate resources are available to better control and coordinate outage scheduling and maintenance' activities in the future. The
. estimated completion date of this evaluation and ' implementation of the necessary actions is June 30,1990.
o An evaluation of. the adequacy of our MODE 6 checklist is complete.
Changes to this checklist will be completed by December 31, 1989.
O An evaluation into the increased use of QC in operations has been completed. Nuclear Operations now receives approximately -40 man / hours per week QC observation. The person performing the observations is an SRO.
5.
Date When Full Comoliance Was Achieved We were in full compliance with the requirements of Technical Specification 3.9.4 on April 19, 1989, during the same day as, and following the second event.,
-9
- w ATTACHMENT (1)
REPLY TO A NOTICE OF VIOLATION
.INSPECIlON ' REPORT NOS. ' 50-317/89-11; 50-318/89-11 VIOLATION B:
PLANT MODIFICATION LACKING REQUIRED SAFETY EVALUATIONS 1.
Admission or Denial of Alleced Violation The violation occurred as - stated.
2.
Reason for Violation-The root cause of the violation has been identified as the following:
The. control procedure that administered our temporary modification process did not properly implement the requirements of Technical Specification 6.5.1.6.d.
It states that all proposed changes - or modifications to plant systems or equipment that affect nuclear safety 'shall be reviewed by the POSRC. We had concluded that. equipment that "affects nuclear safety" was the same as " safety-related" equipment.. This. interpretation led us-to develop a temporary modification procedure that required a formal, documented safety analysis and POSRC review only when those modifications involved any system, subsystem or component designated ' by the Q-List or Equipment Database as safety-related or,quipment that contains radioactive substances.
3.
Corrective Actions Taken and Results Achieved immediate Corrective Actions o
A General. Supervisor Nuclear Operations,
" Note and Instruction" requiring a prior review of all temporary modifications by the POSRC was issued.
o Screening criteria for temporary modifications was developed requiring the Design Engineering Section to review all temporary modifications prior to installation.
These - criteria are used to determine which temporary modifications should require prior POSRC review. The POSRC validated the screening criteria for four months by reviewing all temporary modifications prior to installation.
4.~
Corrective Actions That Will be Taken The temporary modification control procedure, Calvert Cliffs Instruction (CCl) -
117, will be revised by September 30, 1989, to require prior POSRC review of all temporary modifications that affect nuclear safety, it will require that appropriate engineering personnel address nuclear safety via a documented response to specified criteria. The criteria will assist us in determining if a proposed temporary modification affects nuclear safety. __
.+~.3 y y. ilQ k-ATTACHMENT (1)
REPLY TO A NOTICE ' OF VIOLATION
,. INSPECTION REPORT NOS.
50-317/89-11; 50-318/89-11 g
4 i :-
The Performance Improvement Plan includes a task _ that will address safety 4
assessment of maintenance activities. Completion. of this task may require further enhancements to the temporary modification control procedure.
5.
Date When Comoliance was Achieved Compliance.was achieved when the requirement for prior POSRC review of all temporary modifications was implemented on March 21, 1989.
1 q
..