ML20247N166
| ML20247N166 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 07/27/1989 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-89-10, IEB-85-003, IEB-85-3, NUDOCS 8908020304 | |
| Download: ML20247N166 (7) | |
Text
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BALTI M ORE GAS AND ELECTRIC CHARLES CENTER
- P. O. BOX 1475 BALTIMORE, MARYLAND 21203 l
l GEORGE C. CREEL Wet PasseDENT Nuctram Ewcnov l
(sou aso-44ss July 27,1989 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 Reply to Notice of Violation (Inspection Report Nos. 50-317,89-12; 50-318/89-12
REFERENCE:
(a) Letter from Mr. J. P. Durr (NRC) to Mr. G. C. Creel (BG&E),
dated June 16, 1989, same subject (b) Teleconference between Mr.
M.
D.
Milbradt (BG&E) and Mr.V.
L.
Pritchett (NRC), on June 30, 1989, Extension for Response to Notice of Violation Gentlemen:
As requested in Reference (a), we are providing our response to the identified violations ir. Attachment (1).
During the inspection, we agreed to provide the NRC with a description of our plans to cpgrade the motor-operated valve (MOV) program, including a proposed milestone schedule. This information is provided in Attachment (2). Since the issuance of the inspection t eport on Jene 16, 1989, Generic Letter 89-10, " Safety-Related Motor-Opciated Valve Testing and Surveillance" has been issued on June 25, 1989. Our plans to upgraJe the MOV program provided in this submittal are not intended to be used as part of our future response to the generic letter. The upgrade of the MOV program
'vss self-ioMated and indicates our strong commitrrent for providing an aggreche and on-gein MOV maintenance progratn.
An extension for seplying to the referenced Notice of Violation was granted by Mr. Clifford J.
Anderson, NRC Chief of Plants System Section, DRS, Regio i 1 until July 27, 1989. This extension was requested to provide adequate time to conduct a thorough technical revicw, p$
gpf 8900020304 890727 DR ADDCK 0500 7
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Docum:nt Control Desk July 27,1989 Page 2 1
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Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours, I
i GCC/GLB/ dim
. Attachments cc:
D. A. Brune, Esquire J. E.
Silberg, Esquire R. A.Capra, NRC S. A.McNeil,NRC W. T. Russell, NRC.
H. Eichenholz/V. L. Pritchett, NRC T. Magette, DNR '
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'l-ATTACEMENT (I)'
REPLY TO A NOTICE OF VIOLATION
' INSPECTION REPORT 50-317/89-12; 50-318/89-12 L
I I.
STATEMENT' OF VIOLATIONS A.
Violation A l
The inspector' determined there were no procedures for performing ' the following maintenance activities that can affect -the performance of safety-related equipment:
1.
No. procedural requirements exist for SMB-00 and SMB-3 safety-related MOV actuators to ' specify the frequency - of inspection or the necessary ' criteria for stem lubrication of the
- actuators
.to assure proper MOV. operation.-
The inspector identified MOVs 2-MOV-653, 654 and 655 with unlubricated stems.-
2.
Criteria. were not specified to establish safety-related MOV limit switch and bypass - switch settings for proper MOV operation.
B.
Violation B
1.
Baltimore Gas and Electric Setpoint File Manual No.14, Revision 4 '
requires that the torque switch settings for MOV 2-MOV-653.be 1.5 for both opening and closing operations - of the MOV. However, the '
- installed torque sV ch setting for MOV 2-MOV-653 was found non-conservatively s t at 1.0 for both opening and closing of the MOV.
II.
BG&E RESPONSE A.
Cptragfive Stens Taken and Results Achieved 1.
(Violations A and B) - Maintenance Orders (MOs) were initiated on
. May 5, 1989, to (1) clean and lubricate all Bulletin ' 85-03 MOV stems and (2). inspect, verify, and reset, if necessary, the torque switches in all Bulletin 85-03 MOVs. However, before any of the work was scheduled to begin, a stop work order was issued by the MOV Project. Manager on May 23, 1989 because proper control of the MOV-re'ated werk process could not be reasonably assured due to deficiencies identified with the procedures. The order affected all MOV work to be ' perfernwd on active plant components, with the exception of svork necessary for procedure development and design verification. The order was also issued concurrent with a Non-Conformance Report which identified the procedural deficiencies that programmatically exist relative to MOV work practices, and the order will be effective until the appropriate procedural
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A'ITACHMENT (1) l REPLY - TO A NOTICE OF VIOLATION l
INSPECTION REPORT 50-317/89-12; 50-318/89-12 revisions have been completed.
in the
- interim, specific step by-step instructions have been written to allow work to
, continue. to inspect and lubricate = Bulletin 85-03 MOVs.
B.
Corrective Steos Which Will be Taken to Avoid Further Violations.
1.
(Violation A,
Item 1) - Calvert Cliffs Preventive Maintenance Procedures for Bulletin 85-03 MOVs will be revised to include a refueling periodicity for inspection requirements, including specific instructions for ste m lubrication.
Calvert Cliffs Procedure " Electrical 2.
(Violation A.
Item 2)
Motor-Operated Valve Test Procedure" (FTE-47) does establish criteria for setting limit switch position on Bulletin 85-03 MOVs.
. Although the criteria are not quantifiable. and depend upon the judgment of the technician attending the valve, safe operation and differential pressure testing have proven the established criteria to be adequate. However, we do recognize the necessity for establishing and maintaining quantifiable criteria for use by the technician for consis:ency in MOV set-up and by Engineering for -
trending and analysis. In order to establish c uantifiable limit a
switch setpoints, we have taken action to purchase MOV signature analysis equipment and to train members of the plant and engineering departments to form a core of trained MOV specialists who will routinely perform maintenance on MOVs.
Calvert Cliffs'Bulletin 85-03 MOVs use a two-nole limit
- ;.ch and, therefore, the torque bypass switch settings cependent upon the position indication switch settings as mentioned in the Inspection Report. Under criteria in Bulletin 85-03, BG&E has functionally proven the bypass settings are adequate to allow MOV operation under maximum differential pressure conditions. Again, these bypass settings are not quantifiable and cannot be varied to more desirable settings without disrupting position indication. We recognize the desirability of being able to quantify and vary, if needed, the bypass switch settings on the Bulletin ' 85-03 MOVs.
Coinciding with :he aforementioned purchase of and training on the signature an stysis equipment, we will begin a generic replacement program converting from two-pole to four-pole limit switch configuration. These two items will give Calvert Cliffs the necessary tools and equipment to fully control limit and bypass switch settings for Bulletin 85-03 MOVs.
3.
(Violation B)
Procedure revisions and shop training of technician-level personnel specifically addressing ti;e setting of torque switches will be implemented. The procedure revisions will clarify the proper use of the Sefpoint Log to ensure the requ! red ATTACIIMENT (I)
REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT 50-317/89-12; 50-318/E9-12 MOV torque switch settings are maintained. The ' training will facilitate procedural compliance by all personnel responsible for setting torque switches.
C.
Date When Full Comnliance Will be Achieved 1.
(Violation A, Item 1) - Corrective actions to clean and lubricate the valve stems of Bulletin 85-03 MOVs will be completed prior to entering MODE 4 on each respective Unit. Revision of preventive maintenance procedures for Bulletin 85-03 MOVs will be completed by December 31. 1989.
2.
(Violation A,
Item 2) - We will take d ivery of the signature analysis equipment by December 31, 1989. Training on the equipment will commence by January 31, 1990. Implementation of quantifiable limit switch setpoints for all safety-related MOVs will be complete by July 31, 1992. Implementation for the four-pole limit switch installation will also be completed for all safety-related MOVs by July 31, 1992.
3.
(Violation B) - The torque switch settings of Bulletin 85-03 MOVs will be inspected and adjusted, as necessary, prior to entering MODE 4 on the each respective Unit. Procedure revisions and shop training of technician-level personnel addressing the setting of torque switches will be completed by January 31, 1990, l
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^*a ATTACHMENT (2)
UPGR ADED MOV PROGRAM
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A plan was initiated in March 1989 to implement' an upgraded.MOV program, This new program not only l encompasses the - Bulletin 85-03 MOVs, but' includes all MOVs in the plant..The proposed ' schedule to. implement the new' MOV ' program is attached for your
' information. The program includes:
o Design Basis Verification o
Training' and' Maintenance.
.o
-Diagnostic. Equipment Procurement
- i.
o Quality Control-Surveillance and Audits si 1
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,.4 ATTACHMENT (2)
UPGRADED MOV PROGRAM
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