IR 05000317/1993014

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-317/93-14 & 50-318/93-14

ML20059K798
Person / Time
Site:	Calvert Cliffs
Issue date:	11/09/1993
From:	Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Denton R BALTIMORE GAS & ELECTRIC CO.
References
NUDOCS 9311160202
Download: ML20059K798 (2)

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NOV 9 !993

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s Docket Nos. 50-317 1 50-318 Mr. Robert Vice President - Nuclear Energy Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 - 4702  ;

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Dear Mr. Denton:

SUBJECT: INSPECTION REPORT NOS. 50-317/93-14 AND 50-318/93-14 {

This letter refers to your September 3,1993 correspondence, in response to our August 11, 1993 letter.

i 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.

Your cooperation with us is appreciated. .

Sincerely,

Oriciual asaen,n Jacque P. Durr, Chief .;

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Engineering Branch Division of Reactor Safety ,

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G. Detter, 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  ;

Public Document Room (PDR)  ;

Local Public Document Room (LPDR)

Nuclear Safety Iuformation Center (NSIC)

NRC Resident Inspector {

State of Maryland (2)

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Region I Docket Room (with concurrences)

C. Cowgill, DRP l i

L. Nicholson, DRP D. Weaver, DRP ,

i P. Wilson - Calvert Cliffs '

V. McCree, OEDO

R. Capra, NRR D. Mcdonald, NRR .

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OFFICIAL RECORD COPY A:RE317318.14-l i

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-te 4 BALTIMORE I GAS AND ELECTRIC l

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ROBERT E. DENTON vict PRtser~t September 3,1993 NUCLEAR ENERGY (4so) aso-4 4 5s U. S. Nuclear Regulatory Commission Washington, DC 20555 A'ITENTION: Document Control Desk SUBJECT: Calvert Cliffs Nuclear Pov'er Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Non-destructive Examination Notice of Violation REl'ERENCE: (a) Letter from Mr. M. W. Hodges (NRC) to Mr. R. (BG&E),

dated August 11, 1993, Notice of Violation and Enforcement Conference Results, Combined Inspection Report Nos. 50-317/93-14 and 50-318/9314 In response to Reference (a), Attachment (1) is provided.

As we discussed at the August 5,1993 Enforcement Conference, we agree that minimum compliance with the ASME Code is not enough and that we need to have more ownership of Non-destructive -

Examination onsite. We are taking steps to correct this. We will closely monitor the results of our initiatives and pertinent industry and Nuclear Regulatory Commission information. If these indicate additional actions are needed, we will take them.

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

Very truly yours, r g s

[ JSW A

RED /DWM/dwm/bjd Attachment ec: D. A. Brune, Esquire J. E. Silberg, Esquire R. A. Capra, NRC D. G. Mcdonald, Jr., NRC T. T. Martin, NRC P. R. Wilson, NRC g-) M nb ' "'

Yb R. I. McLean, DNR J. H. Walter, PSC 1JL/ ' '

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A'ITACIIMENT (1)

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NOTICE OF VIOLATION 50-318/93-14-01

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Notice of Violation 50-318S3-14-01 describes two non-conformances involving untimely or ineffective corrective actions, violating 10 CFR Part 50, Appendix B, Criterion XVI, Corrective ;

Actions. In the first, Non-destructive Examination (NDE) personnel exceeded overtime limits of i Technical Specification 6.8.1.g without prior written authorizatica. This occurred after  !

implementation of corrective actions resulting from a previous similn violation. The second non- '

conformance involved magnetic particle procedure deficiencies identified in 1989 not having been j corrected by May 1993.

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I. OVERTIME.

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A. DESCRil" TION AND CAUSE OF EVENTS.

Nuclear Regulatory Commission Inspection Report 50-317/93-02 and 50-318/93-02 documented instances in which Project Management personnel testing a new Spent !

Fuel Pool area crane last December exceeded the overtime limits of Technical Specification 6.8.1.g without prior written authorization per Calvert Cliffs Instruction {

(CCI)-159, which implements Generic Letter 82-12 overtime requirements. Our review of this item concluded that the problem was confined to the project ;

organization based on other procedural compliance issues related to the Spent Fuel Pool crane testing and the lack of obvious overtime problems found in a review of the ,

Operations and Maintenance areas.

During the recent Unit 2 outage, from March to June, NDE inspectors worked overtime in excess ot the Technical Specification 6.8.1.g limits without proper authorization. The excessive overtime was the result ofinadequate planning with the result that not enough inspectors were available during periods of high activity. The lack of proper authorization resulte.d from a lack of understanding and inadequate management of CCI-159 by supervisors and workers. Contributing to the authorization problem was the fact that NDE management is located offsite. Non-destructive Examination inspectors routinely received overtime authorization from the Shift Supervisor since NDE management was not routinely available onsite.

Management was therefore not involved in, nor aware of, the excessive overtime use.

II. CORRECTIVE STEPS TAKEN AND RESULTS ACIIIEVED.

Following our discovery of the problems with overtime in NDE, we reviewed use of overtime onsite and found other instances in which overtime controls had not met expectations. The Plant General Manager discussed this concern at the daily planning meeting, issued a memo on the subject to site supervisors, and established an interim monitoring process. The Superintendent of Operations directed Shift Supervisors not to approve overtime extensions unless they are required for safe operation and all efforts to contact line supervisors have been exhausted.

Appropriate personnel actions have been taken.

C. CORRECTIVE STEPS WIIICII WILL IIE TAKEN TO AVOID FURTilER VIOLATIONS.

Calvert Cliffs Instruction-159 will be revised to clarify expectations regarding the use and approval of overtime. We will conduct training on management's expectations and the procedure resisions. We will review possible improvements to our self-assessment program.

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ATTACIIMENT U)

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NOTICE OF VIOLATION 50-318/93-14-01 I

II. PROCEDUR ES.

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A. DESCRIPTION AND CAUSE OF EVENTS.

The magnetic particle procedures were written before the late 1980's and were -

originally intended for use in either ASME Section XI and non-ASME Section XI l applications. They therefore lacked certain Code-required detail, relying instead on +

skill-of-the-craft. This lack of detail was identified by the Authorized Nuclear '

Inservice Inspector in late 1988 and a program was initiated to revise technical '

control, liquid penetrant, visual inspection, and magnetic particle procedures. The procedurc changes were scheduled and prioritized. As of July 1993, 39 of 42 '

identified procedures had been revised.

We initially scheduled the procedure revisions to be completed by the end of 1989. '

Higher priority items, including the plant shutdown to repair pressurizer leaks, intervened and, although there was a steady stream of NDE procedure changes, it -

took several years longer than originally planned to get to the magnetic particle ;

procedures, which had received a lower priority than other NDE procedures. The j decision to delay the procedure revisions was made within the NDE organization and '

were not being tracked onsite by the corrective action system. Because the procedure deficiencies were not viewed as items which would result in any ,

performance problems, they were given a low priority and frequently postponed.

H. CORRECTIVE STEPS TAKEN AND RESULTS ACIllEVED.  !

An upgraded magnetic particle procedure for Section XI work was approved  :

July 15,1993. Prior to completion of the Unit 2 outage, we reviewed the performance of affected Insenice Inspection NDE inspections and identified ,

examinations to be repeated during the current Insenice Inspection interval. None of these involve operability concerns as all rework can be performed later in this~

interval.

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CORRECTIVE STEPS WIIICII M1LL DE TAKEN TO AVOID FURTIIER l VIOLATIONS.

All remaining NDE procedure revisiores will be completed prior to their next use in Section XI work. As part of our Procedure Upgrade Project, we are reviewing other i procedures utilized by offsite support organizations which impact Calvert Cliffs operation.  !

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l III. NON-DESTRUCTIVE EXAMINATION PROGRAM.

A. DESCRIPTION AND CAUSE OF EVENTS.

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Collectively, these two problems indicate programmatic weaknesses in the .

management of our NDE program. As a result of earlier administrative problems, we had previously reviewed the NDE program for possible enhancements. The NDE organization is part of the Fossil Support Services Department in the Fossil Energy Division. It provides services at Calvert Cliffs but does not report functionally to i

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NITACIIMENT (1)

NOTICE OF VIOLATION 50-318/93-14-01 Calvert Cliffs management. While some NDE personnel are located onsite, no -

senior personnel, vested with appropriate authority to administer, manage, and monitor the NDE program at Calvert Cliffs, are located onsite. No procedure clearly identifies NDE interfaces and responsibilities.

II. CORRECTIVE STEPS TAKEN AND RESULTS ACIIIEVED.

Self-assessments of the NDE program have been completed. Additionally, corrective action tracking systems put into place subsequent to the NDE procedure problem will assist in making similar concerns more sisible to onsite and offsite supervision and management.

C. CORRECTIVE STEPS WlIICII WILL BE TAKEN TO AVOID FURTIIER VIOLATIONS.

A senior NDE representative will be assigned onsite and will report to tht site Technical Support organization. A Special Processes Directive is being developed which will clearly define ownership and accountability for the NDE program at Calvert Cliffs. An NDE Corrective Action Plan has been developed which provides specific actions to improve and monitor performance.

IV. DATE WIIEN FULL COMPLIANCE WILL IIE ACIIIEVED.

Full compliance was achieved when management implemented enhanced overtime controls and the new ASME Section XI magnetic particle procedure was approved on July 15,1993.

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