ML20034G098
| ML20034G098 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 02/25/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20034G097 | List: |
| References | |
| 50-317-93-02, 50-317-93-2, 50-318-93-02, 50-318-93-2, NUDOCS 9303090063 | |
| Download: ML20034G098 (2) | |
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APPENDIX A Notice of Violation Baltimore Gas and Electric Company Docket / License Nos. 50-317; DPR-53 Calvert Cliffs Nuclear Power Plant 50-318; DPR-69 l
During an NRC inspection conducted from January 3,1993 through February 6,1993, I
violations of NRC requirements were identified. In accordance with the General Statement of Policy and Procedure for NRC Enforcement Actions, " 10 CFR Part 2, Appendix C, the l
following violations were identified.
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l 1.
Technical Specification 6.8.1.g requires that the amount of overtime worked by plant j
staff members performing safety related functions must be limited in accordance with j
the NRC Policy Statement on Working Hours (Generic Letter 82-12).
I Generic Letter 82-12 states, in part, that an individual should not be permitted to l
work more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any seven day period (excluding shift turnover time)
J without prior approval.
Calvert Cliffs Instruction (CCI)-159, "Use of Overtime, step III.A.I.d states that an individual should not be permitted to work more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any seven day i
I period. CCI-159 step III.b states that deviations from this guideline shall be preapproved in writing by the Plant General Manager or the individual's l
Superintendent or General Supervisor.
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Contrary to the above, during spent fuel handling crane testing between January 4 -
1 19, 1993, two test coordinators, two vendor technical representatives, and one 1
i electrician exceeded 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of work in a seven day period without proper i
authorization.
This is a Ceverity Level IV violation (Supplement I).
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1 2.
Technical Specification 6.8.1.a requires that written procedures shall be established, j
implemented, and maintained covering the applicable procedures recommended in l
Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
a Regulatory Guide 1.33 requires administrative procedures for procedure adherence i
and temporary change me' hod and for procedure review and approval.
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I Contrary to the above, between January 4 - 19,1993, spent fuel handling crane testing was not conducted in accordance with written procedures as evidenced in the q
following examples:
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a.
Three engineering test procedure (ETP) changes were screened by a procedure 3
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i screener who was not certified in accordance with PR-1-102, " Certification of Qualified Reviewers and Procedure Screeners." The use of an uncertified j
procedure screener was contrary to the requirements of PR-1-101, j
" Preparation and Control of Calvert Cliffs Technical Procedures."
i b.
During ETP 92-129, load testing for the crane continued even though the procedure could not be performed as written due to the physical configuration f
of the spent fuel pool area. The continued testing of the crane was contrary to the requirements of Calvert Cliffs Instruction (CCI) 132, " Requirements for i
j Implementation, Use, and Record Keeping of ETPs," which requires that the f
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test coordinator shall stop the test and affected plant equipment shall be placed l
in the condition as directed by the shift supervisor when the test cannot be l
performed as written.
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j c.
During ETP 92-131, a method other than that specified in the procedure was l
jl used to set the load cell on the main hook. The use of an unapproved method i
of setting the load cell was contrary to the requirements of the ETP and CCI 132.
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d.
Several test personnel, including a vendor technical representative, the crane j
operators, and a test coordinator, involved in the testing did not attend a pre-j evolution briefing as required by the ETPs, CCI 132, and CCI 140, " Conduct l
of Operations," which requires that all personnel involved in an evolution, i
i even those with minimal involvement, shall attend the pre-evolution brief.
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Any persons not attending the brief that need to become involved in the evolution shall be properly briefed prior to beginning any involvement in the j
evolution.
This is a Severity Level IV violation (Supplement I).
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Pursuant to the provisions of 10 CFR 2.201, Baltimore Gas and Electric Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory l
Commission, ATTN: Document Control Desk, Washington, D.C. 20555, with a copy to the l
Regional Administrator, Region I, and a copy to the NRC Resident Inspector, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation:
(1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the
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corrective steps that have been taken and the results achieved, (3) the corrective steps that i
will be taken to avoid further violations, and (4) the date when full compliance will be l
achieved. Where good cause is shown, consideration will be given to extending the response t
time.
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