IR 05000317/1997002: Difference between revisions

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{{Adams
{{Adams
| number = ML20210K642
| number = ML20217Q011
| issue date = 08/11/1997
| issue date = 08/15/1997
| title = Discusses Insp Repts 50-317/97-02 & 50-318/97-02 on 970302- 0412 & 50-317/97-03 & 50-318/97-03 on 970413-0531 & Notice of Violations & Proposed Imposition of Civil Penalty in Amount of $176,000
| 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 = Miller H
| 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, 50-317-97-03, 50-317-97-2, 50-317-97-3, 50-318-97-02, 50-318-97-03, 50-318-97-2, 50-318-97-3, EA-97-192, NUDOCS 9708200004
| document report number = 50-317-97-02, 50-317-97-2, 50-318-97-02, 50-318-97-2, NUDOCS 9708290109
| package number = ML20210K648
| title reference date = 06-30-1997
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| page count = 6
| page count = 2
}}
}}


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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
        '
 
easeg ka  UNITED staffs   j s
==Dear Mr. Cruse:==
[  NUCLEAR REOULATORY COMMISSION nacioN I
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.
l 4M ALLENoAlt hoAD   :
 
l KING oF PMusstA PENNSYLVANIA 1H061415
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
- - -


e.. *      l
. August 11,1997    !
i EA 97192 i
Mr. Charles Vice President . Nuclear Energy    t Baltimore Gas and Electric Company (BGE)    !
Calvert Cliffs Nuclear Power Plant 16bs Calvert Cliffs Perkway Lusby, Maryland 20067 4702 SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES
  - $176,000 (NRC Inspection Reports Nos. 50 317/97 02 & 50 318/97-02;  ,
50 317/97 03 & 60 318/37 03)    ;
,
,
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
*
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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
(


==Dear Mr. Cruse:==
*
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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
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_
Notice of Violation Nos. 50-317/97 02 08 and 50 318/97 02-08 describe a failms to implenent
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cormtin notices as required by 10 CPR Part 50, Appendix B, Critwien 16. W notice of violation i states, la part:
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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.
:
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This letter refers to the NRC inspection conducted at the Calvert Cliffs Nuclear Power Plant
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
  '
  '
from March 2,1997 to April 12,1997 and on April 24,1997, the findings of which were provided to you during inn exit meeting on May 7,1997. The inspection report was sent to
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 on May 29,1997. During the inspection, several apparent violations were identified, including a number of violations related to the f allure to effectively control activities conducted
,
,
by a contractor diver in the Unit 2 spent fuel pool. Other apparent violations, related to .
We desamined the following reasons for the vloistion:
inadequate rediation protection controls, as well as inadequate fuel handling operations, were
'
        !'
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also identified. On June 12,1997, a Predecisional Enforcement Conference was conducted with you and members of your staff to discuss the violaticns, their causes, and your corrective !'
actions. During the conference, two examples of an additional apparent violation of
        ;
radiological protection program requirements were also discussed. Those additional apparent violations, which were identified by your staff,were reviewed by the NRC during an inspection conducted between April 13,1997 to May 31,1997, for which an exit meeting was held on June 19,1997. That inspection report was sent to you on July 1,1997.


Based on the information developed during the inspections, and the information provided
e
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<
durbg the enforcement conference, thirteen violet'ons of NRC requirements are being cited and are described in the enclosed Notice of Violation and Proposed imposition of Civil t Penalties (Notice). The three moat significant violations relate to the failure to implement appropriate radiological controls during the diving operations in the Unit 2 spent fuel 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
resulting in the potential for a diver to gain unauthorized or inadvertent access to very high r
  ' dimensions).
radiation areas that could have resulted in significant radiological exposure to the individual, t Specifically, due to insufficient controls, inadequate pre job planning and communication, ineffective surveillance of the diver, and deficient supervisory oversight of the activity, the
'         '
ind!vidual was inadvertently able to gain access to areas in which radiation levels could be .
encountated at 500 rods or more in an hour due to the proximity of spent fuel.


_
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        {
e h personnel involved in the ownt were not sumciently knowledgeable to fbily evaluate the
ED[
;
G k ob17 PDR
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.
        <g--h'( !
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Baltimore Gas and Electric Company 2 The specific violations associated with the diving activity involve (1) f ailure to ensure that the diver would not be able to gain unauthorized or inadvertent access to areas where radiation levels could be 600 tads or more in an hour; (2) f ailure to provide adequate instructions to the diver as to the nature and location of very high radiation fields and the authorized work tasks; and (3) f ailure to perform adequate surveys during and af ter the diver entered an area of the spent fuel pool that had not boon previously surveyed. .our radiological control staff,
    '
responsible for plannint; and mNitoring this activity, failed to provide control of this activity sufficient to assure thei the dives would not be unexpectedly exposed to, or inadvertently enter, very high radiatko fields within the spent fuel storage pool.


This event occurred during the fourth of five dives into the Unit 2 refueling cavity and spent fuel pool in April 1997 to inspect and repair malfunctioning fuel transfer equipment. During the fourth dive, the diver lef t the previously surveyed and approved dive location at the south end of the Unit 2 spent fuel pool, and moved into an unapproved, unsurveyed area ln the north end of the pool. in doing so, the diver entered areas exhibiting significantly higher radiation fields, where he received an unplanned radiation exposure, and could have been occupationally exposed in excess of regulatory limits.
i*.
A*ITACHMENT (1)


The fundamental controls provided to ensure that the diver could not gain unauthorized or inadvertent access to very high radiation fields were inadequate. Even though the diver was equipped with a tether, the individual monitoring the tether did not question the excessive amount of restraint fSat was let out as the diver traversed to the unsurveyed north end of the pool. While the diver was provided with multiple personal dosimetry devices that were remotely monitored by the radiation protection technicie7s, he was not continuously monitored by a television camera, as he had been during previous dives. Instead, the radiation protection personnel were expected to provide continuous coverage via a viewing glass placed on the surface of the pool. However, such coverage was flawed in that bubbles from the divera breathing air and to some degree, the refueling bridge, obscured direct observation. Also, the individual responsible for maintaining direct visual contact, by your own admission at the enforcement conference, became distracted from his responsibilities. As a result, the radiation protection personnel failed to observe the diver move away from the approved location.
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.


Further, when the dosimetry readouts indicated that the diver was being exposed to higher than expected fields, rather than confirming his whereabouts, the diver was inappropriately directed to reenter the area to locate the source of the radiation, h addition, the prejob briefing with the diver and dive support personnel was ineffective in that a late change in the scope of the work directly resulted in the diver's misunderstanding of the work scope. Also, the radiation survey briefing at the job site did not identify to the diver the radiological hazard associated with the fresh irradiated fuelin'the north end of the pool in that the diver was provided with a survey map of the south end of the pool, which he interpreted as representing the entire pool. Moreover, the diver was unaware that he was restricted from performing any activities at the north end of the spent fuel pool since the area was not surveyed.
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.
.
Baltimore Gas and Electric Company 3 Af ter the fourth dive was completed, but prior to processing the diver's dosimetry, a decision was made to initiate a fifth dive, using another diver to complete the repair / inspection.


Without his dosimetry first being processed to determine the exposure obtained during the fourth dive, the diver from the fourth dive was allowed to re enter the spent fuel storage pool work area to support the other diver. Although he re entered the radiological controlled area and worked in areas with low radiation dose rates, a comprehensive dose assessment had not been performed to determine whether the unauthorized entry into the unsurveyed area resulted in the diver receiving a dose in excess of the limits of 10 CFR Part 20. Preliminary calculations performed by your staff, indicated that the diver's right extremity (right knuckles) may have entered radiation fields of 155 to 310 rem /hr and the whole body (right arm) may have entered radiation fields ranging from 45 to 90 rem /hr.
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.


Although subsequent detailed dose assessments for the diver indicated that no apparent radiation exposure in excess of NRC limits likely occurred, this was nonetheless a significant event given the serious consequences that could result from the diver being in close proximity to irradiated fuel. Weaknesses in the establishment and implementation of the type of radiological controls necessary to assure safety in the vicinity of very high radiation areas resulted in a substantici potential for an exposure in excess of regulatory limits at the f acility.
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.


In summary, the NRC considers that the event resulted from a serious lack of attention toward licensed responsibilities. The event involved a serious breakdown in controls that were to be provided for the diving evolutions. Significant deficiencies in communications, coordination, and management oversight and decision making, also existed. As a result, a substantial and unnecessary occupational exposure nearly occurred. Therefore, the violations in Section I, which involve a very significant regulatory concern, have been classified in the aggregate as a Severity Leveill problem in accordance with Section IV of the " General Statement of Policy and Procedure for NRC Enforcement Actions " (Enforcement Policy), NUREG 1600.
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.


In accordance with the Enforcement Policy, a base civil penalty in the amount of $88,000 lo considered for a Severity Level ll violation or problem. Also, since this is a Severity Level ll problem, the NRC considered whether credit was warranted for / dent /// cat /on and Correct /ve Act/on in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy. Credit for identification is not warranted because there were several missed opportunities during the dive to identify these problems, particularly when dosimetry first alarmed, when the technician lost visual contact of the diver because of the bubbling, and when the diver asked a technician for more line and was not questioned. Credit for corrective actions is also not warranted because the immediate corrective actions after the fourth dive were deficient in that another diver was allowed to enter the pool without having obtained a thorough understanding of the cause of the earlier "near miss". Giv'en the potential for substantial personnel exposures that could result from being in such close proximity to the irradiated fuel, a root cause analysis should have been performed before commencing the fifth dive, as you acknowledged at the enforcement conference. Additionally, even though you took action to change your radiological controlled area dive operations and formalize your job coverage standard into a radiation safety procedure, you did not adequately assess the full scope and root causes of the breakdown that occurred. For example, you did not determine the extent to which production pressure was a f actor in causing the event. Further, during the enforcement conference, you did not appear to understand all potential contributors to the event, such as the cause of the inattentiveness of the lodividual assigned to observe the diver.
II. CORRECTWE STEPS TAWN AND RRULTS_ACHIEi1D Responsibility for the verifying satisfactory performance of MOVs has been assigned to 2 CV Component Engin**t.     '


l
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.
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.
Baltimore Gas and Electric Company  4  ,
Therefore, to emphasize the seriousness of this event, and the importance of appropriate management control and oversight of such activities, I have been authorized, after consultation with the Director, Of fice of Enforcement, to issue the encloseJ Notice of Violation and Proposed imposition of Civil Penalty (Notice)in the amount of $176,000 f or the violations in Section 1.


The remaining violations being cited are described in Sections ll and 111 of the enclosed Notice and are classified at Severity LevelIV. A number of these vlotations were identified by your staff and while a civil penalty is not being proposed for these violations, they are indicative of further programmatic weaknesses in radiological controls and protection, maintenance of refueling equipment, and conduct of refueling activities.
D. Overview training will be given to ensure affected organizations understand the effects of maintenance and modifications on the operability of MOVs.


Two other apparent violations listed in Inspr.9 tion Report 97 02, which you identified, involving (1) the f ailure to verify that each exhaust fan maintains the spent fuel storage pool at a measurable negative pressure relative to the outside atmosphere during system operation, and (2) the refueling machine's main holst 3,000 pound overload limit being bypassed during portions of fuelmovement within the reactor pressure vessel, are not being cited because they meet the criterla in Section Vll.B.1 of the enforcement policy regarding the exercise of discretion. Further, another apparent vlotation ininspection Report 97 02, involving drawings not being used to prepare either the troubleshooting form or contingency plans during assessment and repair of the stuck refueling transfer carriage,is being withdrawn because of information you provided at the conference where it was stated that drawings were used in a parallel assessment of the event.
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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.


You are required to respond to this letter and should folicw the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements, in accordance with 10 CFR 2.700 of the NRC's " Rules of Practice," a copy of this letter,its enclosure, and your response will be placed in the NRC Public Document Room (PDR).
IV. DATE WIIEN Full CSMPLIANCE WII.T. BE AcirfFVED ne PPM training is curnntly scheduled to be completed by Augu-t 1997.


Sincerely,
The ovesview training will be completed prior to the 1998 RFO.
[ $6 Hubert J. Miller '
Regional Administrator Docket Nos. 50 317, 50 318 License Nos. DPR 53, DPR 69 Enclosure: Notice of Violation and Propoced Imposition of Civil Penalties


. _ _ - . - . . . . - - . . - .---  .-.-- .-. .  -  .
De controlling procedure for the MOV Program procedure will be revised by December 15,1997.
        .-- _ _ . . - . - - . . - . - . . -
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'  Baltimore Oas and Electric Company  5    *
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cc w/ encl:
T. Pritchett, Director, Nuclear Regulatory Matters (CCNPP)      ,
            '
4  R. McLean, Administrator, Nuclear Evaluations J. Walter, Engineering Division, Public Service Commission of Maryland K. Burger, Esquire, Maryland People's Counsel        ,
R. Ochs, Maryland Safe Energy Coalition        !
State of Maryland (2)
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AThadani, DEDE JLloberman, OE HMiller, RI FDavis, OGC SCollins, NRR RZimmerman, NRR Enforcement Coordinators Al, Ril, Rill, RIV BBeecher, GPA/PA GCaputo, 01 PLohaus, OSP      i'
HBell, OlG Dross, AEOD TReis, OE OE:EA (Also by E Mail)
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Latest revision as of 23:28, 17 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

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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

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

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, (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

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ATTACIORENT (1)

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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

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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:

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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.

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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: -

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

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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.

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We desamined the following reasons for the vloistion:

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% 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).

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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.

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A*ITACHMENT (1)

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

FAILURE TO IMPLEMENT CORRECTIVE ACTIONS AS REQtHRED 11Y

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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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