IR 05000317/1985016

Discusses Special Team Insp Repts 50-317/85-16, 50-318/85-14,50-317/85-18 & 50-318/85-16 on 850624-28 & 0715-19 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $50,000

ML20137W183
Person / Time
Site:	Calvert Cliffs
Issue date:	09/26/1985
From:	Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Lundvalle A BALTIMORE GAS & ELECTRIC CO.
Shared Package
ML20137W187	List: IR 05000317/1985016
References
RTR-NUREG-0737, RTR-NUREG-737 NUDOCS 8510040243
Download: ML20137W183 (3)

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Docket Nos. 50-317, 50-318

License Nos. DPR-53, DPR-69

EA 85-102

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Baltimore Gas and Electric Company

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ATTN: Mr. A. E. Lundvall, J Vice President, Supply P. O. Box 1475 Baltimore, Maryland 21203 Gentlemen:

Subject: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES (NRC INSPECTION NOS. 50-317/85-16; 50-318/85-14; 50-317/85-18; 50-318/85-16)

This refers to the special NRC team inspections conducted on June 24-28, 1985, i

and July 15-19, 1985, at the Calvert Cliffs Nuclear Power Plant, Units 1 and 2, to review implementation of certain items related to post-accident sampling and monitoring, as specified in NUREG-0737, " Clarification of TMI Action Plan Requirements." These items were the subject of the NRC " Order Confirming Licensee Commitments on Post-TMI Related Issues," dated March 16, 1983. The reports of these inspections were sent to you on August 8 and 7, 1985, respectively. During the inspections, violations of NRC requirements were identified, one of which involved the failure to implement and maintain the installed upgraded post-accident sampling system (PASS). The PASS was required by the Order to be implemented and maintained beginning June 1, 1983, and the requirement for the PASS to be operable was incorporated into the Technical Specifications on February 22, 198 The violations, their causes, and your corrective actions were discussed with Mr. J. Tiernan and other members of your staff during a management meeting on July 11, 1985, and at an enforcement conference with you and ,

members of your staff on August 14, 1985. Your actions to address our

immediate concerns were confirmed in my letter to you dated August 29, 198 The violation involving failure to implement and maintain the PASS is of significant concern to the NRC because (a) the system, although installed, was never fully tested to verify operability, (b) system operating procedures were inadequate, and (c) training of operating personnel was deficient in some areas and nonexistent in others. Further, although it was evident that the PASS system was not being properly maintained because of component failures, such as leaking

and inoperable valves, inoperable and inaccurate in-line analyzers, and erroneous control and instrument indicators, correction of these problems was

given low priority attention by management.

! CERTIFIED MAIL RETURN RECEIPT REQUESTED

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0FFICIAL RECORD COPY CP PKG CALVERT CLIFFS 2 - 0001. /24/85 8510040243 850926 37 ADOCK O gDR

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Baltimore Gas and Electric Company -2- j The failure to aggressively identify and correct deficiencies that existed

, in the PASS system represents an inadequate level of performance on the part of

] Baltimore Gas and Electric Company. While the NRC inspection of July 15-19, ,

. 1985 did not find similar deficiencies in management oversight with regard to j other systems at Calvert Cliffs, the duration of time that the deficiencies in j the PASS existed demonstrates the need for improvements in management control '

i and concern for systems that do not affect plant operability directly, but

which are required to be maintained operable.

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! To emphasize the importance of adequate management oversight of such systems,

! including prompt identification and correction of deficiencies, I have been authorized, after consultation with the Director, Office of Inspection

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and Enforcement, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalties in the amount of Fifty Thousand Dollars ($50,000)

, for the violations described in Section I of the enclosed Notice. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"

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10 CFR Part 2, Appendix C (1985) (Enforcement Policy), the violations described in Section I of the enclosed Notice have been categorized as a Severity Level III problem. The escalation and mitigation factors in the Enforcement Policy were considered and no adjustment has been deemed appropriat !

You are required to respond to this letter and should follow the instructions

! specified in the enclosed Notice when preparing your response. In your response,

you should document the specific actions taken and any additional actions you j plan to prevent recurrence. After reviewing your response to this Notice, l including your proposed corrective actions, the NRC will determine whether j further enforcement action is necessary to ensure compliance with regulatory requirement In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," Part 2, j Title 10, Code of Federal Regulations, a copy of this letter and its enclosure

will be placed in the NRC Public Document Room.

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The responses directed by this letter and the enclosed Notice are not subject l to the clearance procedures of the Office of Management and Budget, as required j by the Paperwork Reduction Act of 1980, PL 96-51

Sincerely, l

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{ Thomas E. Murley j Regional Administrator

i Enclosure: Notice of Violation and Proposed Imposition of Civil Penalties

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i 0FFICIAL RECORD COPY CP PKG CALVERT CLIFFS 2 - 0002. i l 09/24/85

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Baltimore Gas and Electric Company -3-i i- cc w/ encl:

R. M. Douglass, Manager, Quality Assurance

! L. B. Russell, Plant Superintendent i Thomas Magette, Administrator, Nuclear Evaluations R. C. L. Olson, Principal Engineer R. E. Denton, General Supervisor, Training and Technical Services i

bec w/ encl:

Region I Docket Room (with concurrences)

, Senior Operations Officer (w/o enc 1)

, Section Chief, DRP l POR LPOR NSIC

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NRC Resident Inspector j State of Maryland (2)

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ACRS SECY CA J.. Taylor, IE R. Vollmer, IE

J. Collins, IE

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J. Axelrad, IE

G. Klingler, IE T. Murley, RI J. Lieberman, ELD

V. Stello, DED/ROGR i Enforcement Coordinators

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RI, RII, RIII, RIV, RV F. Ingram, PA

S. Connelly, OIA i B. Hayes, OI I H. Denton, NRR I

J. Crooks, AE00 E. Jordan, IE

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