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{{Adams
{{Adams
| number = ML20140B224
| number = ML20217Q011
| issue date = 05/29/1997
| issue date = 08/15/1997
| title = Forwards Insp Repts 50-317/97-02 & 50-318/97-02 on 970302-0412 & Nov.Several Apparent Violations That Are Being Considered for Escalated Enforcement Action IAW General Statement of Policy & Procedure, Were Identified
| title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-317/97-02 & 50-318/97-02
| author name = Hehl C
| author name = Doerflein L
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| addressee name = Cruse C
| addressee name = Cruse C
Line 10: Line 10:
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-317-97-02, 50-317-97-2, 50-318-97-02, 50-318-97-2, EA-97-192, NUDOCS 9706060109
| document report number = 50-317-97-02, 50-317-97-2, 50-318-97-02, 50-318-97-2, NUDOCS 9708290109
| package number = ML20140B228
| title reference date = 06-30-1997
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| page count = 4
| page count = 2
}}
}}


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=Text=
=Text=
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August 15, 1997 Mr. Charles 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 02 AND 50 318/97 02 AND NOTICE OF VIOLATION
l l
May 29, 1997
.
EA No. 97-192
: Mr. Charles i Vice President - Nuclear Energy Baltimore Gas and Electric Company (BGE)
Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657 -4702
:
SUBJECT: NRC REGION I INTEGRATED INSPECTION REPORT NOS. 50-317/97-02   :
AND 50-318/97-02 AND NOTICE OF VIOLATION


==Dear Mr. Cruse:==
==Dear Mr. Cruse:==
This letter refers to your June 30,1997, correspondence in response to our May 29,1997, 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 cooperation.
Sincerely, Ohtginal 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:
l K. Burger, Esquire, Maryland People's Counsel    i R. Ochs, Maryland Safe Energy Coalition -    .
State of Maryland (2)    \
li!NERJR,Illlill pg g,g,PDR G  -
  "#*  OFFICIAL RECORD COPY  IE:01
- - -
,
,
This refers to the inspection conducted at the Calvert Cliffs Nuclear Power Plant from j March 2,1997 to April 12,1997 and on April 24,1997. The enclosed report presents the results of the inspection. At the conclusion of the inspection, these findings were  -
Mr. Charles Distribution w/ copy of Licensee's Response Letter:
discussed with Mr. Katz and others of your staff.
RI EDO Coordinator S. Stewart Calvert Cliffs A. Dromerick, NRR L. Doorfloin, DRP S. Adams,DRP R. Junod, DRP M. Complon, RI Nuclear Safety Information Center (NSIC)
PUBLIC Region l Dockat Room (with concurrences)
Inspection Program Branch, NRR (IPAS)
DOCDESK DOCUMENT NAME: A:\RL970202.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 0FFICE Rl/DRP .,
Al/DRP NAME SAdamse t) g LDoertlein ddd DATE 08/15/97 / 084(/97 0FFICIAL RECORD COPV


*
a
%
CnAn.as 11. Caost  Baltimon Oas ard Electric Company
  % PruWnt    Calmt Cliffs Nuclear Power Plant fN  Nuclear Energy  16$0CalvertClifT Parkwsy
      . 1,95by. Marylard 20557 410 495 4455  j i
i June 30,1997 U. S. Nuclear Regu! story Commission Washington,DC 20$$$
NITENTION:  Document Contml Desk SUBJECT:  Calvert CliffsNuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50 317 & $0 318
  ]Lenly to a Nottee ofViolation Inungstlodoort Not3n 117(312V97 02 _
REFERENCE:  (a) Letter imm Mr.1. T. Doerflein (NRC) to Mr. C. (BGE). dated p  May 29, 1997. NRC Region 1 Integrated Inspection Report Nos. 50-317/97 02 and 50 318/97 02 and Notice of Violation in response to Reference (a), Attachment (1) details our response to the violations in the subject Nuclear Regulatory Commission Inspection Repott coace ning corrective actions associated with our Motor.
Operated Valvo Program.
Should you have questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours, I
    '
    , (4%
for Charles Vice President Nuclear Energy CliC/SJR/bjd Attachment cc: R. S. Fleishman, E 1ulto  Resident inspector,NRC J. B. Silberg. Esquire  R.1. McLean, DNR  *
A. W. Dromerick, NRC  J.11.Waltet PSC
. Director, Project Directorate I 1, NRC L. T. Doerflein, NRC 11. J. Miller, NRC
(
*
.
.
ATTACIORENT (1)
'
'
Based on the results of this inspection, the NRC has determined that a violation of NRC requirements occurred. This violation is cited in the enclosed Notice of Violation (Notice)
NO11CE OF VIOLATION 9041'h97434g AND $641697 4348 O
        '
FAILURE 10 IMP 12 MENT CORREC11VE ACTIONS As REQUIRED BY le CFR PART Sg. APPENDIX 5. CRITERION 16
and the circumstances surrounding the issue are described in detail in Section E1.4 of the enclosed inspection report. The violation concerns inadequate corrective actions following identification of degraded conditions for one of the Unit 1 power operated relief valve block
_-
,
_
Notice of Violation Nos. 50-317/97 02 08 and 50 318/97 02-08 describe a failms to implenent
;
cormtin notices as required by 10 CPR Part 50, Appendix B, Critwien 16. W notice of violation i states, la part:
'
10 CFR 30, 4pendia B, Cr.. rien XVI, 'Cormeln Action," repires that nwaren be established to astwe that conditions adwese to petity, such at fellwn, maV- 2:=,
dqficiencies, deviations, dyrctin material and optoment and ::-: :-. :a are pronptly identyled and oormted, br the once ofsignfloant condition adwrge to paltry, the nearwes shall answe that the cause qfthe condition is determinedmedcornettu action taken to preclude repetition.
:
'
Conernry to the abon, in April 19% 4ter ' pairs topower operated nilqf valw block vain l-MOY403, correctin actions wn not taken to)\dly evaluate the apaNitty of this vain to
?  )bnetton sender design 4aris conditions he itsprior degradedsinte. Also, oorreottw actions wre
). not taken then lofully evaluate the operabiliQ' ingtdioatione due to potential degraded conditions for the otherpower operatedreligf wrin Nock valves (1-M0Y.403 and2 MOV403 and 405).
 
I. - REASON BOR TIRE YtollTION
' Calvert Cilffs Nuclear Pour Plant failed to meet the requirwnents of 10 CFR Part 50, Appendix B, Criterion 16 in that:  -
J t
We did not fully evaluete the operability impact of enlarging the wedge guide grooves of 1 MOV-40L
  '
  '
valves.
We did not fully evaluate the impact of rubbing and interfmence found in 1.MOV-403 on its past operability or the operability of the other power operated relief valve (PORV) block valus.


>
,
You are required to respond to the enclosed Notice and should follow the instructions
We desamined the following reasons for the vloistion:
        !
specified in the Notice when preparing your response. in your response, you should q document the specific actions taken and include any additional actions you plan to prevent recurrence. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. After reviewing your response to the Notice, including your proposed corrective actions and the results of future g inspections, the NRC will determine whether further NRC enforcement action is necessary Ya, to ensure compliance with NRC regulatory requirements.


I in addition, several apparent violations were identified that are being considered for So escalated enforcement action in accordance with the " General Statement of Policy and Y Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600. As described below, the apparent violations involve the series of problems identified during
e
'84 fuel handling operations, and control of high radiation area access including the failure to I jg effectively control diving activities in the Unit 2 spent fuel storage pool.
<
  % controlling procedure for the Motor Operated Valve (MOV) Program did not require a MI evaluation that compared MOV oritial characteristlos to eithw the "as found" condition (i.e., an evalution of the impsot of rubbles and laterfence found in 1 MOV 403) ce the "as leR" condition (l.c., an enluation of the impact of the changes made to the valw's internal
  ' dimensions).


The fuel handling problems included the poor material condition of the fuel handling equipment, operation of the refueling equipment contrary to the Technical Specification 060003 h !,hh lh 0FFICIAl. RECORD COPY  IE:01
.
e h personnel involved in the ownt were not sumciently knowledgeable to fbily evaluate the
;
impact that the "as-found" or the "as-leR" condition of I MOV.403 could have on its opwebility or the opusbility of otbet PORY block valves.


A        '
  .
  .
.
j Charles requirements, failure to use engineering drawings during troubleshooting, and the failure to follow fuel handling procedures.


On April 3,1997, your staff failed to effectively control diving activities in the Unit 2 spent fuel storage pool and as a result, a diver moved from a comprehensively surveyed area at the south end of the pool to unsurveyed areas at the north end of the pool. The diver sustained an unplanned exposure. Although no exposure in excess of regulatory limits is believed to have occurred, we are concerned that sufficient measures were not employed to provide positive contrnt of this activity which involved very high levels of radiation.
- , - .~ ,- -.--
 
i*.
A*ITACHMENT (1)
 
NOTICE OF VIOLATION $041787 02-08 AND 5041g47-02 03 O
FAILURE TO IMPLEMENT CORRECTIVE ACTIONS AS REQtHRED 11Y
_
10 CFR PART $0. APPENDIX B. CRITERION 16 Badgramm4 Near the end of the Unit 1 1994 Refbeling Outage (RTO), the block valve (1 MOVU O3 ) for PORY l ER%402 was discovered to be leaking. De leak was not expected since the velve had just been overhauled. We determined the luk rate, approximately eight gallons per hour, did not affect the valve's operability. An issue report was generated to invwtigate the leak during tlw 1996 RFO.


Specifically, due to insufficient controls, including inadequate pre-job planning and communication, and lack of positive surveillance, the individual inadvertently came in close proximity to radiation fields in excess of 500 rads per hour.
The valve was disassembled and inspected during the 1996 RFO. Rubbing was found in the guide groove of the valve wedge. The rubbing was caused when the disk contacted a weld at the end of the valve's closing stroke. De contact caused the wedge to become cocked in the seat and resulted in the valveleaking.


During the inspection period, we also noted a failure to control access to the Unit 2 containment, a high radiation area, via the emergency airlock, and a failure to properly document the problem in the corrective action system. Additionally, on May 1,1997, a worker performed maintenance for over one hour in a locked high radiation area inside the Unit 2 containment without any dosimetry. Subsequently, on May 4, two workers inadvertently gained access to a high radiation area during the construction of scaffolding in the Unit 2 auxilian :uilding. Although the last two problems occurred outside the inspection period, those issues, in conjunction with the loss of control of the diver, were considered to reflect an apparent breakdown in the applied radiation protection program, specifically the control of high radiation area access at Calvert Cliffs.
Valve Opwation and Test Equipment System (VOTT.S) testing at the start of the Unit 1 1996 RFO had shown an unexpected increase in disk pullout force. $1nce no unexpected increase in disk pull out force was seen in the other Unit I and 2 PORY block valves, the results of the VOTES tests supported our determination of the cause for the leak in 1 MOW 403.


Accordingly, no Notice of Violation is presently being issued for these inspection findings.
To cornet the leak, the 1 MOW 403 wedge wu lapped, the wedge's guide grooves were enlarged, and excess base metal was removed. Enlarging the guide grooves and removing additional base metal were performed per the vendor technical manual. We failed to evaluate how changing the valve's internal A dirnensions would Impact the valve's operability. De "as.left" VOT1?S test did show that the disk pullout force was within expected values.


In addition, please be advised that the number and characterization of apparent violations described in the enclosed inspection report may change as a result of further NRC review.
He System Engineer evaluated the valve repair. Ilowever, the evaluation was not ooordinated between the System Engineer and the Component Engineer. nc System Engineer evaluated the "as found" and
"as-left" conditions of the valve. De System Engineer concluded the rubbing was limited to the seating portion of the stroke and did not affect the valve's ability to stroke shut. De Component Engineer was awwe that the valve had bwn repaired but only evaluated the "as found" and *as left" VOTES test results. De VOTES test ruults for the Unit I and 2 PORY block valves did not Indicate generic concerns. Neither the System Engineer nor the Component Engineer considered the full impact that machining the guide grooves might have on the valve's ability to function under design basis differential pressure conditions. A full evaluation would have considered the impact of changing the valve's internal dlmensions.


A predecisional enforcement conference to discuss these apparent violations has been scheduled for June 12,1997 at 10:00 a.m. The decision to hold a predecisional enforcement conference does not mean that the NRC has determined that a violation has occurred or that enforcement action will be taken. This conference is being held to obtain information to enable the NRC to make an enforcement decision, such as a common understanding of the facts, root causes, missed opportunities to identify the apparent violation sooner, corrective actions, significance of the issues and the need for lasting and effective corrective action. In particular, we expect you to address the apparent lack of effective management oversight in both fuel handling and high radiation area access control, including the May 1 and May 4 high radiation area access problems, as well as the effectiveness of your corrective action processes in identifying and correcting problems in these areas, in addition, the conference is an opportunity for you to point out any errors in our inspection report and for you to provide any information concerning your perspectives on 1) the severity of the violations, 2) the application of the factors that the NRC considers when it determines the amount of a civil penalty that may be assessed in accordance with Section VI.B.2 of the Enforcement Policy, and 3) any other application of the Enforcement Policy to this case, including the exercise of discretion in accordance with Section Vll.
During May 1997, a Performanoe Prodletion Model(PPM) was run on I MOV 403 to verify the valve's satisfactory performance with its guide grooves enlarged. %c PPM determined that the valve in its curmut configuration would operate under design requirements.


You will be advised by separate correspondence of the results of our deliberations on these matters. No response regarding these apparent violations is required at this time.
II. CORRECTWE STEPS TAWN AND RRULTS_ACHIEi1D Responsibility for the verifying satisfactory performance of MOVs has been assigned to 2 CV Component Engin**t.     '


I P
  .
  .
I I Charles >
.
l In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its en::losures, and your response will be placed in the NRC Public Document Room (PDR).
ATTACIIMENT (1)
O NOTICE OF VIOLATION S0 31747 02 08 AND 50-31197-0248
,
O FA11NRE TO IMPIEMENT CORRECT!YE ACTIONS AS REQUIRED BY 10 CFR PART 50. APPENDIX D. CRITERION 16 From a review of maintenance orders of all the PORY block valves, we concluded:
A. He internal dbnensions of no other PORY block valyc had been changed; and B. Internal inspections, VOTES tests, and Motor Power Monitor tests show that one other PORV block valve had rubbing or interference. Cornetive maintenanoc was performed on that valve.
 
III. CORIIFMIVE STEPS W111Cll WII .T. IlE TAKEN To AY.DID FURTilER HO1AT10ES Training will be given to increase the knowledge level of selected site penonnel on MOVs:
A. Additional representatives from Engineering will attend PPM training.
 
D. Overview training will be given to ensure affected organizations understand the effects of maintenance and modifications on the operability of MOVs.
 
-
The controlling procedure for the MOV Program will be revised to require the MOV Component O Engineer to verify that perfortaanoe of MOVs is satisfactory and require an evaluation when valve internal dimensions which impact the design basis are changed.


'
IV. DATE WIIEN Full CSMPLIANCE WII.T. BE AcirfFVED ne PPM training is curnntly scheduled to be completed by Augu-t 1997.
 
The ovesview training will be completed prior to the 1998 RFO.


Sincerely, fs Original Signed by:
De controlling procedure for the MOV Program procedure will be revised by December 15,1997.
Larry Nicholson for  ,
Charles W. Hehl, Director i
Division of Reactor Projects i
Docket / License Nos: 50-317/DPR-53    )
[  50-318/DPR-69    '
Enclosures:
      )
1. Notice of Violation    '
2. NRC Region I integrated Inspection Report Nos. 50-317/97-02 and 50-318/97-02 cc w/encls:
,
T. Pritchett, Director, Nuclear Regulatory Matters (CCNPP)
! R. McLean, Administrator, Nuclear Evaluations l- J. Walter, Engineering Division, Public Service Commission of Maryland l
K. Burger, Esquire, Maryland People's Counsel R. Ochs, Maryland Safe Energy Coalition State of Maryland (2)
i
      !
      :
      !
      !
l


l l
b       '
l l
i
       '
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_..


.
TOTA P.05
.
      .
Charles Distribution w/encis:
        --
W. Axelson, DRA      J D. Screnci, PAO      l R. Zimmerman, ADPR, NRR    l J. Goldberg, OGC      l J. Lieberman, OE (OEMAIL)    l D. Holody, EO, RI      l Nuclear Safety Information Center (NSIC)    !
PUBLIC      l NRC Resident inspector Region i Docket Room (with concurrences)
R. Correia, NRR F. Talbot, NRR L. Cunningham, NRR D. Barss, NRR L. Doerflein, DRP      i J. White, DRS T. Moslak, DRP'
R. Junod, DRP Distribution w/ encl: (VIA E-MAIL)    !
W. Dean, OEDO (WMD)
l S. Stewart - Calvert Cliffs    j S. Bajwa, NRR      ,
A. Dromerick, NRR G. Vissing, NRR M. Campion, RI Inspection Program Branch, NRR (IPAS)
DOCDESK
:
DOCUMENT NAME: G:\ BRANCH 1\CC9702.lR
; To r:ceive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" =
Copy with attachment / enclosure "N" = No copy OFFICE Rl/DRP n, FK/QRS , Rl/DRP l, Rl/DRP/ h  '
. NAME SStewart ,y$ b j$its  LDoerflein blT4/ CHehlg "
DATE 05/27/97 ll #' 05/ /97 05/21/97 05 0 /97 l    OFFICIAL RECORD COPY
.
l I
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    . .
}}
}}

Latest revision as of 00:28, 18 December 2021

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-317/97-02 & 50-318/97-02
ML20217Q011
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 08/15/1997
From: Doerflein L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Cruse C
BALTIMORE GAS & ELECTRIC CO.
References
50-317-97-02, 50-317-97-2, 50-318-97-02, 50-318-97-2, NUDOCS 9708290109
Download: ML20217Q011 (2)
v • d • e


Text

o

.-

August 15, 1997 Mr. Charles 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 02 AND 50 318/97 02 AND NOTICE OF VIOLATION

Dear Mr. Cruse:

This letter refers to your June 30,1997, correspondence in response to our May 29,1997, 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 cooperation.

Sincerely, Ohtginal 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:

l K. Burger, Esquire, Maryland People's Counsel i R. Ochs, Maryland Safe Energy Coalition - .

State of Maryland (2) \

li!NERJR,Illlill pg g,g,PDR G -

"#* OFFICIAL RECORD COPY IE:01

- - -

,

Mr. Charles Distribution w/ copy of Licensee's Response Letter:

RI EDO Coordinator S. Stewart Calvert Cliffs A. Dromerick, NRR L. Doorfloin, DRP S. Adams,DRP R. Junod, DRP M. Complon, RI Nuclear Safety Information Center (NSIC)

PUBLIC Region l Dockat Room (with concurrences)

Inspection Program Branch, NRR (IPAS)

DOCDESK DOCUMENT NAME: A:\RL970202.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 0FFICE Rl/DRP .,

Al/DRP NAME SAdamse t) g LDoertlein ddd DATE 08/15/97 / 084(/97 0FFICIAL RECORD COPV

a

%

CnAn.as 11. Caost Baltimon Oas ard Electric Company

% PruWnt Calmt Cliffs Nuclear Power Plant fN Nuclear Energy 16$0CalvertClifT Parkwsy

. 1,95by. Marylard 20557 410 495 4455 j i

i June 30,1997 U. S. Nuclear Regu! story Commission Washington,DC 20$$$

NITENTION: Document Contml Desk SUBJECT: Calvert CliffsNuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50 317 & $0 318

]Lenly to a Nottee ofViolation Inungstlodoort Not3n 117(312V97 02 _

REFERENCE: (a) Letter imm Mr.1. T. Doerflein (NRC) to Mr. C. (BGE). dated p May 29, 1997. NRC Region 1 Integrated Inspection Report Nos. 50-317/97 02 and 50 318/97 02 and Notice of Violation in response to Reference (a), Attachment (1) details our response to the violations in the subject Nuclear Regulatory Commission Inspection Repott coace ning corrective actions associated with our Motor.

Operated Valvo Program.

Should you have questions regarding this matter, we will be pleased to discuss them with you.

Very truly yours, I

'

, (4%

for Charles Vice President Nuclear Energy CliC/SJR/bjd Attachment cc: R. S. Fleishman, E 1ulto Resident inspector,NRC J. B. Silberg. Esquire R.1. McLean, DNR *

A. W. Dromerick, NRC J.11.Waltet PSC

. Director, Project Directorate I 1, NRC L. T. Doerflein, NRC 11. J. Miller, NRC

(

.

.

ATTACIORENT (1)

'

NO11CE OF VIOLATION 9041'h97434g AND $641697 4348 O

FAILURE 10 IMP 12 MENT CORREC11VE ACTIONS As REQUIRED BY le CFR PART Sg. APPENDIX 5. CRITERION 16

_-

_

Notice of Violation Nos. 50-317/97 02 08 and 50 318/97 02-08 describe a failms to implenent

cormtin notices as required by 10 CPR Part 50, Appendix B, Critwien 16. W notice of violation i states, la part:

'

10 CFR 30, 4pendia B, Cr.. rien XVI, 'Cormeln Action," repires that nwaren be established to astwe that conditions adwese to petity, such at fellwn, maV- 2:=,

dqficiencies, deviations, dyrctin material and optoment and ::-: :-. :a are pronptly identyled and oormted, br the once ofsignfloant condition adwrge to paltry, the nearwes shall answe that the cause qfthe condition is determinedmedcornettu action taken to preclude repetition.

'

Conernry to the abon, in April 19% 4ter ' pairs topower operated nilqf valw block vain l-MOY403, correctin actions wn not taken to)\dly evaluate the apaNitty of this vain to

? )bnetton sender design 4aris conditions he itsprior degradedsinte. Also, oorreottw actions wre

). not taken then lofully evaluate the operabiliQ' ingtdioatione due to potential degraded conditions for the otherpower operatedreligf wrin Nock valves (1-M0Y.403 and2 MOV403 and 405).

I. - REASON BOR TIRE YtollTION

' Calvert Cilffs Nuclear Pour Plant failed to meet the requirwnents of 10 CFR Part 50, Appendix B, Criterion 16 in that: -

J t

We did not fully evaluete the operability impact of enlarging the wedge guide grooves of 1 MOV-40L

'

We did not fully evaluate the impact of rubbing and interfmence found in 1.MOV-403 on its past operability or the operability of the other power operated relief valve (PORV) block valus.

,

We desamined the following reasons for the vloistion:

e

<

% controlling procedure for the Motor Operated Valve (MOV) Program did not require a MI evaluation that compared MOV oritial characteristlos to eithw the "as found" condition (i.e., an evalution of the impsot of rubbles and laterfence found in 1 MOV 403) ce the "as leR" condition (l.c., an enluation of the impact of the changes made to the valw's internal

' dimensions).

.

e h personnel involved in the ownt were not sumciently knowledgeable to fbily evaluate the

impact that the "as-found" or the "as-leR" condition of I MOV.403 could have on its opwebility or the opusbility of otbet PORY block valves.

A '

.

- , - .~ ,- -.--

i*.

A*ITACHMENT (1)

NOTICE OF VIOLATION $041787 02-08 AND 5041g47-02 03 O

FAILURE TO IMPLEMENT CORRECTIVE ACTIONS AS REQtHRED 11Y

_

10 CFR PART $0. APPENDIX B. CRITERION 16 Badgramm4 Near the end of the Unit 1 1994 Refbeling Outage (RTO), the block valve (1 MOVU O3 ) for PORY l ER%402 was discovered to be leaking. De leak was not expected since the velve had just been overhauled. We determined the luk rate, approximately eight gallons per hour, did not affect the valve's operability. An issue report was generated to invwtigate the leak during tlw 1996 RFO.

The valve was disassembled and inspected during the 1996 RFO. Rubbing was found in the guide groove of the valve wedge. The rubbing was caused when the disk contacted a weld at the end of the valve's closing stroke. De contact caused the wedge to become cocked in the seat and resulted in the valveleaking.

Valve Opwation and Test Equipment System (VOTT.S) testing at the start of the Unit 1 1996 RFO had shown an unexpected increase in disk pullout force. $1nce no unexpected increase in disk pull out force was seen in the other Unit I and 2 PORY block valves, the results of the VOTES tests supported our determination of the cause for the leak in 1 MOW 403.

To cornet the leak, the 1 MOW 403 wedge wu lapped, the wedge's guide grooves were enlarged, and excess base metal was removed. Enlarging the guide grooves and removing additional base metal were performed per the vendor technical manual. We failed to evaluate how changing the valve's internal A dirnensions would Impact the valve's operability. De "as.left" VOT1?S test did show that the disk pullout force was within expected values.

He System Engineer evaluated the valve repair. Ilowever, the evaluation was not ooordinated between the System Engineer and the Component Engineer. nc System Engineer evaluated the "as found" and

"as-left" conditions of the valve. De System Engineer concluded the rubbing was limited to the seating portion of the stroke and did not affect the valve's ability to stroke shut. De Component Engineer was awwe that the valve had bwn repaired but only evaluated the "as found" and *as left" VOTES test results. De VOTES test ruults for the Unit I and 2 PORY block valves did not Indicate generic concerns. Neither the System Engineer nor the Component Engineer considered the full impact that machining the guide grooves might have on the valve's ability to function under design basis differential pressure conditions. A full evaluation would have considered the impact of changing the valve's internal dlmensions.

During May 1997, a Performanoe Prodletion Model(PPM) was run on I MOV 403 to verify the valve's satisfactory performance with its guide grooves enlarged. %c PPM determined that the valve in its curmut configuration would operate under design requirements.

II. CORRECTWE STEPS TAWN AND RRULTS_ACHIEi1D Responsibility for the verifying satisfactory performance of MOVs has been assigned to 2 CV Component Engin**t. '

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ATTACIIMENT (1)

O NOTICE OF VIOLATION S0 31747 02 08 AND 50-31197-0248

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O FA11NRE TO IMPIEMENT CORRECT!YE ACTIONS AS REQUIRED BY 10 CFR PART 50. APPENDIX D. CRITERION 16 From a review of maintenance orders of all the PORY block valves, we concluded:

A. He internal dbnensions of no other PORY block valyc had been changed; and B. Internal inspections, VOTES tests, and Motor Power Monitor tests show that one other PORV block valve had rubbing or interference. Cornetive maintenanoc was performed on that valve.

III. CORIIFMIVE STEPS W111Cll WII .T. IlE TAKEN To AY.DID FURTilER HO1AT10ES Training will be given to increase the knowledge level of selected site penonnel on MOVs:

A. Additional representatives from Engineering will attend PPM training.

D. Overview training will be given to ensure affected organizations understand the effects of maintenance and modifications on the operability of MOVs.

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The controlling procedure for the MOV Program will be revised to require the MOV Component O Engineer to verify that perfortaanoe of MOVs is satisfactory and require an evaluation when valve internal dimensions which impact the design basis are changed.

IV. DATE WIIEN Full CSMPLIANCE WII.T. BE AcirfFVED ne PPM training is curnntly scheduled to be completed by Augu-t 1997.

The ovesview training will be completed prior to the 1998 RFO.

De controlling procedure for the MOV Program procedure will be revised by December 15,1997.

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TOTA P.05

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