IR 05000318/1987013

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-318/87-13

ML20236K896
Person / Time
Site:	Calvert Cliffs
Issue date:	08/04/1987
From:	Johnston W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Tiernan J BALTIMORE GAS & ELECTRIC CO.
References
NUDOCS 8708100037
Download: ML20236K896 (1)

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, AUG 4 1987 i l

Docket No.;50-318 License No. DPR-69 l

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Baltimore Gas andeElectric Company ATTN: Mr. J. A. Tiernan Vice President s

fiaclear Energy P.O. Box 1475 Baltimore, Maryland 21203 Gentlemen:

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Subject: Inspection No. 50-318/87-13

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l This refers to your letter dated July 15, 1987, in response to our letter dated June 16, 198 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 progra Your cooperation with us is appreciate

Sincerely, l

Original SiCned ??'

Lee & Bettenhausea William V. Johnston, Acting Director Division of Reactor Safety cc:

Public Document Room (PDR)

Nuclear Safety Information Center (NSIC) ]

State of Maryland l bec:

Ppgion I Docket Room (w/ concurrences)

RI:DRS RI:DRS RI:DRS l h rone/mlb pBlumberg hausen 8/el/87 8/4 /87 8/f/87

0FFICIAL RECORD COPY RL CC1 87-13 - 0001. l 08/01/87 l 8708100037 870004 l PDR G

ADOCK 05000310 PDR h ;

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B ALTIMORE i GAS AND ELECTRIC CHARLES CENTER P. O. BOX 1475 BALTIMORE, MARYLAND 21203 JOSEPH A.TIERNAN VICE PRESIDENT NUCLEAR ENERGY l

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July 15,1987 l

U. S. Nuclear Regulatory Commission Docket No. 50-318 Region I )

631 Park Avenue License No. DPR-69 l King of Prussia, PA 19406 ATTENTION: Mr. W. V. Johnston, Acting Director Division of Reactor Safety Gentlemen:

This refers to Inspection Report 50-317/87-12, 50-318/87-13; which transmitted one item of apparent non-compliance with NRC requirement!.. Enclosure (1) to this letter is in reply to the item noted in Appendix A of your letter dated June 16, 198 Should you have any further questions regarding this matter, we will be pleased to discuss them with yo Very truly yours, Y

j JAT/LSL/dlm i

Enclosure cc: D. A. Brune, Esquire J. E. Silberg, Esquire R. A,Capra, NRC  ;

S. A.McNeil, NRC W. T. Russell, NRC T. Foley/D. C. Trimble, NRC I

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I l ENCLOSURE (1)

REPLYTO APPENDIX A OFNRCINSPECTION REPORT 50-317/87-12; 50-318/87-13 I

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A PPARENT FAILURE TO PREVENT IN A DVERTENT OPER ATION OF EOUIPM ENT We' have, reviewed tha circura$tances that led to the apparent violation of 10 CFR 50, l Appendii B, Criteric:t XIV, Inspection, Test and Operating Status," referred to by the subject fospection report. This was caused by a failure to follow Calvert Cliffs Instruction 1i2G, Safety Tagging, which states that " . Red Danger Tags . . . when

! attached to operating devices, denote that the device is not to be operated or removed

. ." Contrary to this procedure, a danger tagged drain valve was removed from the Auxiliary Feedwater Chemical Addition piping without clearing the tag and modifying the tagout in accordance with CCI-ll2 Prior to the scheduled work taking place, a maintenance lead person conducted a system walkdown with the tagging authority to clearly identify the scope of the work. The appropriate system isolation boundaries were identified and established. The drain valve (#CA330, #23 AFW Pump Chemical Addition . Header Drain), which was subsequently removed with the danger tag, was originally tagged open to allow the system water to drain from the pipes and to prevent repressurization of this system's section of piping, All required guidance provided in CCI-l12G was followed with the exception of l the requirement to remove a danger tag (with authorization from the tagging authority)

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prior to removing an associated componen l Both the Quality Control (QC) Inspector and the senior welder associated with the above work were aware that a tagged valve should never be removed from a system or reposi-tioned without authorization from the tagging authority. . In addition, an informal survey was later conducted among mechanics and welders. 'lhese people were presented with a hypothetical maintenance situation involving work on a tagged component. In all cases, each individual stated that prior to any work being performed, the tagging authority would have to be contacted. Therefore, we feel that our safety tagging procedures and associated training are adequate, and that this was an isolated incident and not indicative of a programmatic weaknes Accordingl/, the corrective actions cited below have been implemented to ensure that imilar violathni will not occur in the futur Formal counselings were administered to the three individuals directly involved with th3 ' above work: The welding helper (who removed the danger tagged valve),

the sen ob welder (lead man), and the QC Inspecto Th event Cas revieved svith mechanical maintenance and modification workers and QC Inspecteri. They were reminded by their supervisors of the requirements to never operate, remove, or change the status of a danger tagged component until the tar is cleared by the proper tagging authority. The personnel and plant safety reasons for the above requirements were emphasize <

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