IR 05000317/1996010
| ML20217P993 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 08/15/1997 |
| From: | Doerflein L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| References | |
| 50-317-96-10, 50-318-96-10, NUDOCS 9708290101 | |
| Download: ML20217P993 (2) | |
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August ~ 15, 1997_ ,
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Mr. Charles _
Vice President - Nuclear Energy Bahlmore Gas and Electric Company .
Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657 4702'
SUBJECT: NRC INSPECTION REPORT NOS. 50 317/9610 AND 50 318/9610 AND NOTICE OF VIOLATION
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Dear Mr. Cruse:
This letter refers to your April 4,1997, correspondence in response to our February 27,1997 setter.
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, Original Signed by:
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Lawrence T. Doerflein, Chief Projects Branch 1 Division of Reactor Projects
t Doda . Nos. 50 317
, 50 318 {
cc:
T. Pritchett, Director, Nuclear Regulatory Matters (CCNPP) l R. McLean, Administrator, Nuclear Evaluations
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E J. Walter, Engineering Division, Public Service Commission of Maryland cc w/ copy of Licensee's Response Letter:
K. Burger, Esquire, Maryland People's Counsel R. Ochs, Maryland Safe Energy Coalition State of Maryland (2)-
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970829010'1 970915-
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OFFICIAL RECORD COPY IE:01.
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Mr. Charles Distribution w/ copy of Licensee's Response Letter:
RI EDO Coordinator S. Stewart Calvert Cliffs A. Dromerick, NRR L.- Doorflein , DRP S. Adams,DRP R. Junod, DRP M. Campion, RI Nuclear Safety Information Center (NSIC)
PUBLIC -
Regicn i Docket Room (with concurrences)
Inspection Program Branch, NRR (IPAS)
DOCDESK
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4 DOCUMENT NAME: G:\ BRANCH 1\RL961010.CC To receive a copy of this document, Indicate in the box: "C" = Copy without attachment / enclosure "E" =
C:py with attachment / enclosure "N" - No copy OFFICE- Al/DRP , l Rl/DRP ,
NAME SAdams(yt,0 gen LDoerfleinW4J DATE 08A C/97 -' 08/ t y/97 OFFICIAL RECORD COPY I _.
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CH Auns 11. Caosr. Ilattimore Gas and Electric Company Vice President Calven Cliffs Nuclear Power Plant Nuclear Energy 1650 Calvert Cliffs Parkway Lusby, Maryl .nd 20657 410 495 4455 April 4,1997 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATI'ENTION: Document Control Desk SUILIECT: Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos 50 317 & 50 318 Reply to Notice of Violations -- Inspection Report Nos. 50-317(318V96-10 REFERENCE: (a) Letter from Mr. L. T. Doerflein (NRC) to Mr. C. It Cruse (BGE), dated February 27, 1997, NRC Region I integrated Inspection Report Nos 50 317/96-10 and 50-318/96-10 and Notice of Violation in response to Reference (a), Attachments (1), (2), and (3), detail our response to the violations in the subject Nuclear Regulatory Commission Inspection Report concerning control of activities associated with spent fuel handling operations, an unloading procedure for our independent Spent Fuel Storage Installation dry shielded canisters, and corrective actions associated with a cable separation issue resolution plan.
Due to outage-related activities, this response was not submitted within 30 days as requested in
. Reference (a). An extension was discussed with the Nuclear Regulatory Commission Resident inspectors, Should you have questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours,
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CilC/CDS/bjd M# '] /fgsgt. -
Attachments: As stated J
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Document Control Desk
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April 4,1997.
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cc:; L. T. Doorflein, NRC 11. J. Miller, NRC ;
~ R. S. Fleishman, Esquire : Resident Inspector,NRC ~
J. E. Silberg, Esquire R.1, McLean, DNR A. W. Dromerick, NRC J.11. Walter, PSC Director, Project Directorate 1 1, NRC
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A'ITACllMENT (1)
NOTICE OF VIOLATION 50-317/96-10-01 AND 50-318/96-10-01 INADEQUATE PROCEDURE AND FAILURE TO FOLLOW PROCEDURES DURING SPENT FUEL HANDLING OPERATIONS Notice of Violation Nos. 50-317/96-10-01 and 50 318/9610-01 describes a single case of an inadequate procedure and two cases of failure to follow procedures associated with spent fuel handling operations.
The notice of violation states, in part:
a. The procedures usedfor spentfuel handling were not appropriate to the circumstances in thatfuel handling was performed without verification that the fuel pool ventilation system wouldpiter all of the radioactive material released duriq a fuel handling accident through charcoal adsorbers prior to discharge to the atmosph-re, instead, due l to ventilation system imbalance, tome of theflow of air in the vicinity of the spentfuel pool was diverted to the aurillary building ventilation system. which did not include charcoaladsorbers.
b. Spentfuel handling was not accomplished in accordance withprocedure F11-340 in that the controlled copy of the procedure was not maintained in the control room. Instead, the controlled copy was maintained by the Nuclear Fuel Management Group, c. Spentfuel handling was not accomplished in accordance with procedure Fil 340 in that a briepng between the work group and control room supervisor (CRS) on the moves to be performed was not done. Instead, a briefing of the work group personnel only was conducted by nuclearfuels engineering personnel.
Part At FUEL llANDLING PERFORMED WITilOUT VERIFICATION THAT SPENT FUEL POOL VENTILATION SYSTEM WOULD FILTER ALL RADIOACTIVE MATERIALS RELEASED DURING A FUEL HANDLING ACCIDENT.
1. REASON FOR T1H' VIOLATION On January 10,1997, a Nuclear Regulatory Commission Resident inspector noted that air from the spent fuel pool (SFP) area was leaking through an open door into the Auxiliary Building while fuel was being moved in the SFP. Operations personnel were notified, the door closed, and fuel movement was sxured due to air still escaping under the door. Operations declared the system inoperable and fuel movement in the area was ceased, Calvert Cliffs Unit I and 2 share a common SFP area. Ventilation of the SFP area is accomplished by the exhaust system which draws SFP air through high efficiency particulate air (HEPA) Glters and charcoal adsorbers and discharges it into the main plant vent of Unit 1. Technical Specification 3,9,12 requires the SFP ventilation system be operable whenever irradiated fuel is in the SFP. An operable system consists of one HEPA filter bank, two charcoal adsorber banks, and two exhaust fans. The SFP ventilation system normally maintains a negative pressure in the SFP area with respect to ambient pressures and the pressure in other areas surrounding the SFP area.
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ATTACHMENT (1)
NOTICE OF VIOLATION 50-317/96-10-01 AND 50-318/9610-01 i INADEQUATE PROCEDURE AND FAILURE TO FOLLOW PROCEDURES DURING hPENT FUEL HANDLING OPERATIONS The Auxiliary Building ventilation system draws outside air through two supply fans and discharges it to the main plant vent via two exhaust fans. The flow path of this ventilation system includes a HEPA filter and radiation monitoring equipment but no charcoal adsorber banks.
On Monday, January 6,1997, the Auxiliary Building supply fans No. I1 and No.12 were tagged out of-service for replacement of their discharge dampers. This placed the Auxiliary Duilding ventilation system in a lineup with only one supply fan in operation. Historically, this lineup was not considered a problem because the Auxiliary Building is maintained at a negative pressure with respect to the atmosphere. An unknown effect of this line-up, however, was that the Auxiliary Building pressure became rnore negative than the SFP area pressure. This resulted in air leakage from the SFP area into the Auxiliary Building.
Fuel movement began on Wednesday, January 8,1997. Fuel was being moved in preparation for the Spring 1997 Unit 2 refueling outage. Fuel movement was suspended on Friday, January 10,1997 upon identification of the air leakage through a door from the SFP into the Auxiliary Building.
After the event, a review of the Technical Speci0 cation requirements and Updated Final Safety Analysis Report (UFSAR) descriptions for the SFP ventilation system determined that all of the SFP ventilation system requirements and interactions with other ventilation systems had not been previously recognized and thus not properly tested, in the past, we performed the SFP area test with the Auxiliary Building ventilation system running normally (2 supply and 2 exhaust fans). We never performed the SFP test with only one set of Auxiliary Building fans running. Specifically, initial startup testing, the SFP area surveillance test, and subsequent special testing performed in the late 1980s h d not considered that the Auxiliary Building could be at a more negative pressure than the SFP area. These tests focused on the ability of the SFP exhaust fans to discharge enough inleakage air to maintain a negative pressure in the SFP area relative to the outside ambient pressure. Based on this focus, the most conservative plant configurations, including opening a 45' elevation roll up door to maintain areas around the SFP area with as much positive pressure as possible to allow the most inleakage, were established to adequately test the SFP exhaust fan air removal capability. It was not realized that a test of the SFP ventilation system to maintain the most negative pressure when both: 1) roll-up door is closed and 2) Auxiliary Building exhaust fan capacity greatly exceeds supply fan capacity; was also appropriate to validate the capability of the SFP ventilation system to perform its safety function.
A thorough review was performed to ensure that the opening created by the replacement of the Nos,11 end 12 Auxiliary Building supply fan discharge dampers (about one square foot) would not affect the ability of the SFP ventilation system fans to maintain a negative pressure in the SFP area relative to the outside ambient. The review determined that it would not. However, troubleshooting results, subsequent to discovery of this issue, showed that with the Auxiliary Building Nos.1I and 12 supply fan discharge dampers reinstalled, a single Auxiliary Building supply fan was insufficient to maintain the SFP area at a negative pressure with respect to the Auxiliary Building, in conclusion, the primary reason for this event was a less than adequate understanding of the SFP system interactions. This resulted in allowing conditions to exist which were adverse to the requirements
.of the Technical Specification 3.9.12, the system design basis and the UFSAR descriptions.
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ATTACilMENT (1)
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NOTICE OF VIOLATION 50-317/9010-01 AND 50-318/9610-01 INADEQUATE PROCEDURE AND FAILURE TO FOLLOW PROCEDURES DURING SPENT FUEL HANDLING OPERATIONS II. CORIECTIVE STEPS TAKEN AND RESULTS ACHIEVED Following discovery of this issue, we initiated a review of the SFP ventilation system. A troubleshooting plan was implemented during the week of January 1317,1997 to re-create the adverse conditions and bound the problem. A formal troubleshooting procedure was performed which demonstrated that with any one Auxiliary Building supply fan running, Auxiliary Building pressure was able to become more negative than the SFP area pressure. It was also found that during certain conditions, the SFP area could regain "most negative" status with a single supply fan running. All combinations of two Auxiliary Building supply fans running resulted in the SFP area being at the most negative pressure.
Based on the results of the above tests, a ventilation configuration policy was developed to prevent recurrence of this event. Subsequently, appropriate operations procedures and the surveillance test procedure (STP M 542-0) were revised to incorporate the lessons learned from the root cause investigation. These procedures were re-performed to establish a valid current test.
Licensee Event Report 317 97-001, Spent Fuel Moved with Ventilation System inoperable and Missed Surveillance," was issued on February 10,1997 concerning this event.
111. CORRECTIVE STEPS WilICII WILL BE TAKEN TO AVOID FURTIIER Y10LATIO.NS A permanent modification is being developed to add locally mounted manometers in the SFP area for case of pressure verification. As part of our preparations for moving fuel during the current Unit 2 refueling outage, we have reviewed the potential impact of the Containment Purg- System with personnel airlock interlocks defeated on the operability of the SFP area ventilation. This review has resulted in additional procedure changes to prevent unwanted interactions between the SFP and Containment Purge systems, nis issue is being reviewed for possible applicability to the Emergency Core Cooling System exhaust and Penetration Room exhaust systems.
The lessons learned from this event will be submitted to Operations Training for consideration of incorporation into a training lesson plan. Additional procedure changes will be made based on these lessons learned. This information is also being given to the Plant Risk Assessment Unit for consideration and appropriate incorporation into our plant risk model.
IV. DATE WilEN FULL COMPLIANCE WILL BE ACIIIEVED Full compliance was achieved on January 10,1997, when fuel movement was secured.
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ATTACIIMENT (1)
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NOTICE OF VIOLATION 50-317/96-10-01 AND 50-318/96-10-01 INADEQUATE PROCEDURE AND FAILURE TO FOLLOW PROCEDURES DURING SPENT FUEL HANDLING OPERATIONS Part H. CONTROLLED COPY OF FUEL HANDLING PROCEDURE.
1. REASON FOR THE VIOLATION At the time of this event, Fuel Handlin;; Procedure FH 340, " Component Movement in the Auxiliary Duilding," required that a controlled copy of the procedure be maintained in the Control Room when core components were being moved in the SFP. During fuel movement on January 810,1997, this requirement was not met due to personnel error on the part of the Nuclear Fuel Management personnel responsible for conducting the fuel movement. The controlled copy of the procedure had at one time been stored in the Control Room, but at some point, that copy of the procedure was removed. Nuclear Fuel Management engineers believed it was still there, but did not ensure that it was there by positive verification, resulting in non-compliance with the procedure. The requirement was contained within the administrative controls (Applicability / Scope) section of the procedure, which was not conducive to prompting the engineers to verify its presence each time fuel movement in the pool resumed. Because the procedure had routinely been kept in the Control Room, engineers over time did not display a questioning attitude by verifying its continued presence in the Control Room.
Subsequent review determined that this requirement should not have been included in Fil 340. This procedure is of recent vintage and was adapted from a previous procedure (Fil-17, " Fuel Movement within Spent Fuel Pools"). Fuel Handling Procedure Fil 17 was divided into Fil-340 and Operating Instruction OI 25A," Spent Fuel Handling Machine." Part of the intent of dividing FH 17 into FH 340 and OI 25A was to put the procedure steps needed by the Control Room operators into OI 25A.
Controlled copies of Operating Instructions are kept continually in the Control Room. Since no steps directing operation of plant equipment associated with moving fuel are contained within FH-340 it did not need to be kept in the Control Room. The requirement to keep FH-340 in the Control Room was erroneously left in Fil 340 after it was broken out of Fil-17.
11. COMCIIVE STEPS TAKEN AND_ RESULTS ACIHEVED Upon discovery of the procedure violation, plant management reiterated its expectation of strict procedure compliance with the personnel involved. Prior to resumption of fuel movement in the SFP, a multi disciplined team was assembled to review fuel handling practices in the SFP area. This team consisted of a licensed Senior Reactor Operator, the System Engineer for the SFP ventilation system, and an Engineer from Nuclear Fuel Management. This team determined that FH-340 should be revised to climinate the requirement to place a copy of FH-340 in the Control Room. This change was made on February 26,1997.
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ATTACllMENT (1)
NOTICE OF VIOLATION 50-317/96-10-01 AND 50-318/96-10-01 INADEQUATE PROCEDURE AND FAILURE TO FOLLOW PROCEDURES DURING SPENT FUEL IIANDLING OPERATIONS III. CORRECTIVE STFPS WlIICII WILL BE TAKEN TO AVOID FURTIIER
.YlOLATIONS The above mentioned multi. discipline team reviewing fuel handling practices in the SFP area is evaluating other similar events in the 19931997 time frame and will recommend additional actions as appropriate.
We will conduct a formal root cause analysis concerning this event and implement any additional corrective actions from the root cause analysis.
IV. DATE_WIIEN FULL COMPLIANCE WILL HE ACllIEVED Full compliance was achieved on January 10,1997, when fuel movement was secured.
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A'ITACilMENT (1) l
NOTICE OF VIOLATION 50-317/96-10-01 AND 50-318/9610-01 INADEQUATE PROCEDURE AND FAILURE TO FOLLOW PROCEDURES I DURING SPENT FUEL IIANDLING OPERATIONS Part C. OPERATIONS INCLUSION IN PRE-EVOLUTION BRIEFINGS. ,
I. REASON FOR THE VIOLATION Procedure Fil.340 also required that the Control Room Supervisor (CRS) be included in the pre-
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evolution brief. . While Control Room personnel were aware that fuel movement was underway, (they had placed the SFP ventilation system charcoal adsorbers in service and were informed when fuel handling operations had started or stopped) the CRS had not reviewed the fuel handling precautions and -
procedures and had not been briefed concerning actions required in the event of a fuel handling incident.
This missed requirement was the result of lack of attention to detail on the part of Nuclear Fuel Management personnel.
With the onset of the Operations Work Control Center, detailed briefs concerning fuel movement activities were conducted with Operations Work Control persomal as opposed to Control Room personnel (CRS) as had been the case in the past. The fuel handling procedure requirement was incorrectly interpreted by the engineers as being met by the briefs that were performed with the fuel handling crew and the Operations Work Control Center. The intent of briefing the CRS on details concerning actions required in the event of a fuel handling incident was lost. 'Ihe change from interfacing directly with the Control Room to interfacing with the Operations Work Control Center was not reflected in the procedure, and inattention to detail led to the non-compliance with this procedural administrative requirement.
II. CORRECTIVE STEPS TAKEN AND RESULTS ACIHEVED We revised procedure Fil.340 to further clarify which Control Room Supervisor is to be briefed on fuel movement prior to the resumption of SFP movement. Awareness training on the briefmg requirements was given to all Nuclear Fuel Management personnel.
Plant management has reiterated its expectation of strict procedure compliance with the personnel involved.
III. CORRECTIVE STEPS WIHCH WILL 11E TAKEN TO AVOID FURTHFR yl0LATIONS Procedural compliance is one of our core values at Calvert Cliffs. The requirement for procedure compliance is reinforced on a continuous basis throughout our organization, llowever, based on several recent cases ofless than adequate procedural compliance, we have established a team to assess this issue at Calvert Clifts. This team has been tasked with identification of the underlying causal factors that lead to procedural non-compliances and recommending methods to improve performance in this area.
Additional procedure enhancements are scheduled to ensure proper CRS briefings are conducted for other fuel handling operations.
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ATTACitMENT (1) 4
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NOTICE OF VIOLATION 50417/96-10-01 AND 50 318/9610-01 l INADEQUATE PROCEDURE AND FAILURE TO FOLLOW PROCEDURES l DURING SPENT FUEL HANDLING OPERATIONS We will conduct a formal root cause analysis concerning this event and impleme6 any additional corrective actions from the root cause analysis.
IV. DATE WIIEN FULL CO}iPLIANCE WIIL BE ACHIEVED Full compliance wa. achieved on January 10,1997, when fuel movement was secured.
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A'ITACliMENT (2)
NOTICE OF VIOLATION 50-317/96-10-02 AND 50-318/9610-02 FAILURE TO DEVELOP DOCUMENTATION TO SUPPORT DRY FUEL STORAGE CASK UNLOADING Notice of Violation Nos. 50 317/96-10-02 and 50 318/9610-02 states, in part, that; Calvert Clifs Nuclear Power Plant Techn!cd Procedure ISFSI-02. Rev 3, " Independent Spent Fuel Storage Installation (ISFSI) Unioading." was not appropriate in that it did not contain instructions to prevent over pressurisation of the dry shleided canister during reflood operations, prior to unloading.
I. REASOLEOR_Yl0LATION On October 9,1996, the Nuclear Regulatory Commission, Office of Nuclear Material Safety and Safeguards, Spent Fuel Project Office performed an inspection of Calvert Cliffs independent Spent Fuel Storage Installation (ISFSI) activities. One of the issues that came to light based on the inspector's previous inspection experiences at other facilitates was that the reflood steps in the ISFSI Unloading Procedure (ISFSI 02) has the potential to overpressurize the DSC from a steam flash transient.
On December 4,1996, the Nuclear Regulatory Commission, Office of Nuclear Material Safety and Safeguards, Spent Fuel Project Office performed an inspection of the Calvert Cliffs 10 CFR 72.48 activities and followed-up on the above issue from the October 9,1996 inspection. Between the inspecticns on October 9 and December 4,1996, we changed the ISFSI 02 procedure to require that a calculation be performed to determine the maximum flow rate of water into the DSC to maintain the internal pressure below 10 psig. Ilowever, the inspector was concerned that there was no calculation to support the procedure.
Before our Independent Spent Fuel Storage Installation (ISFSI) site went operational in 1993, an unloading procedure was written as required by regulation. It was developed with information provided by the ISFSI vendor, and was similar to unloading procedures developed at other ISFSI sites designed by Baltimore Gas and Electric Company's vendor. A underlying cause of the violation was the fact that the knowledge base existing at the time for unloading procedures did not support the development of a more refined procedure. While industry experience with ISFSI loading has resulted in more mature loading procedures, the same is not true for ISFSI unloading procedures.
A second underlying cause is the fact that communication of and internalization ofindustry experience is weaker for ISFSI issues than for other aspects of nuclear power plant operations. There has not been a good broad-based industry communications network for ISFSI issues. Issues relative to ISFSI unloading procedures were not effectively communicated to utilities with ISFSI sites.
A third underlying cause was a lack of effective communications from the vendor concerning ISFSI issues. He vendor has not consistently communicated improvements and lessons learned concerning its
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ATTACilMENT (2)
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NOTICE OF VIOLATION 50-317/9610-02 AND 50-313/9610-02 FAILURE 10 DEVELOP DOCUMENTATION TO SUPPORT DRY FUEL STORAGE CASK UNLOADING
!!. CORRECTIVE STEPS TAKEN AND_ RESULTS ACIIIEVED We initiated a detailed calculation to bound the reflood rate of the DSC assuming design bases fuel temperatures. The results of the calculation wili be incorporated into the ISFSI 02 procedure and will be complete prior to the start of the next ISFSI loading. There is very little likelihood that a DSC will need to be unloaded prior to the next loading. l l
111. CORRECTIVE STEPS WillCII WILL HE TAKEN TO AVOID FURTIIEll l Y10LAIl0NS We will t'acilitate more effective industry use of existing communication tools. We are aggressively looking for opportunities to share ISFSI related information with other ISFSI utilities, and will encourage other utilitics to do the same. We are currently soliciting utility interest in formation of an ISFSI users group that could meet to exchange experience concerning ISFSI equipment, procedures, and audit results. We have infonned the vendor of our expectations concerning effective communication ofISFSI related information to utilities who 1. ave installed their products.
We will conduct a formal root cause analysis concerning this event and implement any additional corrective actions from the root cause analysis.
IV. DATE WIIEN _ FULL COMPLIANCE _WILL HE ACIIIEVEQ Full compliance will be achieved when the detailed calculation to bot'nd the DSC reflood rate is implemented e ' 'he ISFSI-02 procedure is changed. This is scheduled to be completed by June 13, 1997. In any cwat the ISFSI-02 procedure will be changed prior to the next ISFSI loading. There is very little likeiihood that a DSC will need to be unloaded prior to the next ISFSI loading.
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- ATTACIIMENT (3)
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NOTICE OF VIOLATION $0-317/9610-04 AND 50-318/96-10-04 INCOMPLETE CORRECTIVE ACTIONS FOR ELECTRICAL SEPARATION BARRIERS Notice of Violation Nos. 50-317/96-10-04 and 50-318/96-10-04 states a violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, ne notice of violation states, in part, that; As ofDecember 1,1996 corrective action as spectfled in BGE response letter to NRC violation 30 317/89 27 03, was not taken in that: (1) design documents, including cable and raceng drawings. were not revised to reflect the as-built configurations for Unit 2, and (2) fourteen eramples were identifled where the as built configurations did not meet design criteria and were inadequate to preclude the challenge to electricalseparation resultingfrom damaged or missing marinite separation barriers.
1. REASON FOR VIOLATION in 1989, Nucicar Regulatory Commission inspection Report 50-317/89-27 05 documented violations regarding the Calvert Cliffs electrical cable separation con 0guration requirements. A project was implemented to correct the deviations and actions were implemented to prevent the deviations from occurring again. His violation was closed in inspection Report 95 08 (October 16, 1995). The closure was based on a review of the status of corrective actions, walkdown inspection results, and tours of various areas of the plant to inspect a sample of cable tray installations.
During .,uclear Regulatory Commission Inspection 96-08, the Resident inspector identiDed three examples where electrical separation barriers in the 45 foot electrical penetration rooms did not appear to meet the plants electrical separation criteria. These deficiencies involved missing or broken marinite board separation covers. Follow-up inspections by Cr.lvert Cliffs personnel and the Resident Inspector identiGed deviations and discrepancies between the Geld and drawings. Each of these deviations and discrepancies fell into three general categories: (1) issues involving missing. broken, or cracked marinite board; (2) issues concerning electrical separation barrier / drawing fidelity; and (3) issues questioning the adequacy of certain specific plant cable separation configurations, in each case we concluded that no equipment operability concerns existed.
Our evaluation of this issue indicates that some corrective actions implemented to 8ddress the 1989 violation had not been incorporated into plant drawings as intended. Additionally, corrective actions that addressed the 1989 violation did not go far enough to: (1) ensure that the design documents reDected the as built con 0gurations; and (2) minimize the potential for personnel to challenge the plant's compliance to the Updated Final Safety Analysis Report (UFSAR) electrical separation criteria during normal plant activities.
The electrical separation problems found in the plant were caused by 6 combination of inadequate ownership of the plants electrical separation requirements and an apparent insensitivity of plant personnel to the UFSAR requirements for cable separation. No one was assigned specine responsibility for overseeing the effectiveness of activities which impacted cable separation design con 0gurations. As a consequence, the inadequate field practices which caused electrical separation barrier degradation to occur were not always promptly identified and corrected. Some marinite barriers were found cracked
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and some were found not restored properly following work activities.
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ATTACilMENT (3)
NOTICE OF VIOLATION 50 317/96-10-04 AND 50-318/%10-04
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INCOMPLETE CORRECTIVE ACTIONS FOR r
ELECTRICAL SEPARATION HARRIERS
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He failure to update the cable and raceway drawings was caused by personnel error. We failed to adequately document and track the completion of the drawing change requests (DCRs) submitting the marked up Unit 2 Auxiliary Building electrical cable and raceway drawings.
The project to ensure that our facility electrical separation configuration was in accordance with our configuration requirements was implemented between 1990 and 1994. This work was split up into the following plant areas: Unit 1 Containment, Unit 1 Auxiliary Building, Unit ! Cable Spreading Room, Unit 2 Containment, Unit 2 Auxiliary Building, and Unit 2 Cable Spreading Room. As each area was completed, the associated plant drawings showing electrical separation requirements were marked up to reDect the electrical separation work that was performed to disposition any non conforming conditions. +
The marked-up drawings were submitted via DCRs to revise the affected controlled drawings.
Interviews with site personnel indicate that the DCRs were submitted for all plant areas as required during the project implementation.
A recent review of these controlled drawings revealed that all areas except the Unit 2 Auxiliary Building reDected the DCRs. A search was condeted to determine if the DCRs for Unit 2 Auxiliary Building were submitted or may have been mispleed or overlooked. No documentation has been found to determine what happened to the drawing matups for the Unit 2 Auxiliary Building. During recent walkdowns, we determined that, in some instances, the Units 1 and 2 Auxiliary Building drawings were not marked-up to reflect the electrical separation barriers that existed. if the pre existing barrier condition conformed to the separation criteria, the existing cable and raceway drawings were not marked up to reDeet their existence in all cases.
Failure to update drawings to reDect the "as-built" configuration of electrical separation barriers in the Auxiliary Building complicated our ability to ensure control of the plants electrical separation barrier configuration in that building. Plant personnel did not have accurate cable raceway drawings detailing the plant's electrical separation configurations. This could have potentially resulted in the plant being returned to an unapproved or non conforming con 0guration liowever, plant walkdowns performed as part of current corrective actions found only one instance where this may have occurred. Based on this, we believe that the drawing status was not a significant causal factor in the failure to maintain electrical separation barriers.
II, CORRECTIVE STEPS TAKEN AND RNULTS ACIIIEVED A system engineer has been assigned responsibility for " electrical separation" and has commenced regular walkdowns of systems which are affected by electrical separation requirements. lie is the poir.t of contact for issue reports documenting electrical separation deficiencies. Assignment of an " electrical separation" owner has helped ensure a good understanding for the scope of the current program and provided more assurance that causes and generic implications for electrical separation problems are being consistently addressed.
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NITACliMENT (3)
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NOTICE OF VIOLATION 50-317/9610-04 AND 50-318/9610-04 INCOMPLETE CORRECTIVE ACTIONS FOR ELECTRICAL SEPARATION HARRIERS As previously stated, during the walkdowns established to recreate the Unit 2 Auxiliary flullding marked up drawings, we determined that the Units 1 and 2 Auxiliary Ilullding drawings were not marked up to reDect electrical separation barriers that previously existed but were not redected on the drawings. Ilased on this we expanded the walkdown scope.
Walkdowns were conducted to verify, mark up, and resubmit all Unit I and 2 Auxiliary Building area drawings to accurately reflect electrical cable tray and raceway separation barriers. All marked-up drawings from the Unit I and 2 Auxiliary 13uilding area walkdowns have been submitted for engineering review and incorporation into the co? trolled drawing file at this time. We plan to complete the drawing updates for these walkdowns by May 23,1997.
Walkdowns were also conducted in the Unit 2 Containment to ensure no problems existed. The Unit 2 Containment area drawings were found to accurately reDect all separation barrier criteria.
It has been determined that our current processes of drawing and controlled document changes will prevent recunence of similar failures to update drawings in a timely fashion. Our new process requires that drawing and controlled document changes are updated via our engineering and corrective action computer tracking processes. These processes require that configuration document changes are statused and cor. trolled from the time they are issued until they are complete.
The current process, which became, effective in 1995, has enhanced our ability to prioritize drawing changes and monitor and control drawing change backlogs. All submitted changes are quickly statused in our computer tracking system. to ensure that no drawing change's will be missed.
III. CORRECTIVE STEPS WIIICil WILL HE TAKEN TO AVOID FURTIIER c.
VIOLATIONS The system engineer assigned responsibility for electrical separation barriers will provide training to appropriate plant personnel. This training will include a review of electrical separation requirements, problems that have been experienced, and the need to protect the plant's electrical separation design configuration.
Following this training, as human performance issues are identified with regards to electrical separation, the system engineer will generate an issue report for appropriate organizations to address, in accordance with our existing corrective action process, these organization (s) will determine causes and implement corrective actions for ensuring their work practices protect electrical separation barriers and/or their knowledge level ensures identification of pre-existing problems.
We expect training to be completed by August 30, at which time we also expect to be in full compliance bned on having:
=> Provided the training necessary to identify separation issues;
=> Reinforced the work standards necessary to prevent separation issues; Page 3
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ATTACilMENT (3) l NOTICE OF VIOLATION 50-317/9610-04 AND 50 318/9610-04 INCOMPLLTE CORRECTIVE ACTIONS FOR ELECTRICAL SEPARATION BARRIEIIS
=> Established a feedback loop (system engineer oversight) that morJtors long term efTectiveness;
=> Established expectations for necessary action when effectiveness is identified as declining; and
=> Addressed the immediate deficiencies identified in the violation.
IV. DATE_ ellen FULL COh!PLIANCE WILL BE ACIIIEVED j We expect to be in full compliance by August 30,1997.
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