IR 05000317/1993003

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-317/93-03 & 50-318/93-03.Action Acceptable Re Justification for Elimination of Mobile Labs from Emergency Response Plan

ML20057A700
Person / Time
Site:	Calvert Cliffs
Issue date:	08/26/1993
From:	Joyner J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Denton R BALTIMORE GAS & ELECTRIC CO.
References
NUDOCS 9309150172
Download: ML20057A700 (3)

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1. JG 2 61993 Docket Nos. 50-317 50-318 l Mr. Robert ; Vice Preddent - Nuclear Energy l Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 - 4702

Dear Mr. Denton:

Subject: Combined Inspection Nos. 50-317/93-03 and 50-318/93-03 This letter refers to your June 11, 1993 response to our May 14, 1993, letter, and to the associated 10 CFR 50.59 and 10 CFR 50.54(q) reviews that you provided separately.

Our review of yourjustification for elimination of the mobile labs from the Emergency Response Plan and for removing the requirement to train all Nuclear Energy Division Mangers as both Site Emergency Coordinator and Corporate Spokesperson found these actions to be acceptable.

Thank you for informing us of all the corrective and preventive actions documented in your letter. We will be examining the implementation of these actions during future inspections.

Thank you for your cooperation.

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Sincerely, I

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originalsigned By:  ;

James H.Joyner )

James H. Joyner, Chief l Facilities Radiological Safety and Safeguards Branch Division of Radiation Safety and Safeguards

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OFFICIAL RECORD COPY G:CC9303.RL August 23,1993

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AUG 2 6 19?3 Baltimore Gas and Electric Company 2  !

cc:

G. Detter, Director, Nuclear Regulatory Matters (CCNPP)

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 Public Document Room (PDR)

local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector ,

l State of Maryland (2)

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C FFICIAL RECORD COPY G:CC9303.RL August 18, 1993

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Baltimore Gas and Electric Company 3 2 0 IE33

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bec: i l Region I Docket Room (with concurrences) l t

C. Cowgill, DRP L. Nicholson, DRP

) J. Yerokun, DRP 3'

D. Weaver, DRP  !

P. Wilson - Calvert Cliffs  !

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V. McCree, OEDO

R. Capra, NRR

D. Mcdonald, NRR

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BALTIMORE ,

GAS AND ,

ELECTRIC N. ,

1650 CALVERT CLIFFS PARKWAY . LUSBY, MARYl AND 20657-4702 l

RestAt E. DENTON viec ==rserwr June 11,1993 NgCLE AR rNERGY (4:0) 26 0+** 55 U. S. Nuclear Regulatory Commission Washington,DC 20555 ATTENTION: Document Control Desk SUBJECT: Calvert Cliffs Nuclear Power Plant

Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Inspection Report 50-317/93-03,50-318S3-03; Calvert Cliffs Nuclear Power Plant Emercency Preparedness Inspection REFERENCE

(a) Ixtter from Mr. J. H. Joyner (NRC) to Mr. R. (BG&E),

dated May 14, 1993, Calvert Cliffs Nuclear Power Plant Emergency Preparedness Inspection (50-317/93-03; 50-318/93-03)

Gentlemen:

In response to Reference (a), please find Attachments (1) through (3) detailing our response to three cited violations concerning our Emergency Preparedness program.

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

Very truly yours, j r m. e

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Attachments cc: 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 R. I. McLean, DNR J. H. Walter, PSC j.Qf a

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ATTACllMENT (I)

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REPLYTO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-317(318V93-03 ERP MOBILE LABORATORIES 1 I. DESCRIPTION OF VIOLATION ,

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Reference (a) indicates that we failed to maintain two mobile laboratory trailers in accordance with the Emergency Response Plan (ERP), Section 5.LG.1.b, thereby siolating  :

the requirements of 10 CFR 50.54(q) and 10 CFR 50.47(b)(8). Specifically, the mobile l i

laboratory trailers required by the ERP were not equipped with a shielded counting system or I

gas partitioner, laboratory glassware had been removed, ion exchange column lifetimes had -

expired in May 1990 and February 1992, and several other items listed in the ERP inventory . l procedures (tool kit, detergent, tygon tubing, desiccant, air sampler) were not contained l within the trailers. Consequently, the mobile laboratories could not provide either general i laboratory capabilities similar to those of the Chemistry Lab or a back-up counting capability. !

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II. REASON FOR VIOLATION After contending with longstanding difficulties in maintaining back-up analysis equipment in j the mobile trailers specified in the ERP, BG&E decided to transfer the capability to another i location that could better support the function. This effort was given a low priority because }

l of its low safety significance. The relocation effort was not yet complete when the inspectors t

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identified this condition.

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III. CORRECTTVE STEPS TAKEN AND RESULTS ACIIIEVED l Analysis done subsequent to relocation work demonstrated that back-up analysis capabilities .

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are not required. The provision for Mobile Laboratory Trailers was deleted from the ERP i on June 7,1993 following approval of a 50.54(q) evaluation showing that the change would  !

not reduce the effectiveness of the Plan.  ;

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IV. CORRECTIVE ACTIONS WIIICII WILL BE TAKEN TO AVOID FURTIIER VIOLATIONS i

Closer supervisory attention will be paid to establishing the priority of resolution of ERP- i related equipment problems. Existing corrective action systems are satisfactory to track i resolution of non-conformances such as this. l V. DATE WIIEN ITLL COMPLIANCE MTLL BE ACHIEVED Full compliance was achieved on June 7,1993 with approval of the ERP resision.

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A'ITACII51ENT (2)

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REPLY TO NOTICE OF VIOLATION l INSPECTION REPORT NOS. 50 317(318)/93-03  ;

ERP INSTRUMENT CALIBRATION AND INVENTORY L DESCRIPTION OF VIOLATION l Reference (a) indicates that we failed to maintain emergency equipment inventories and ,

calibration in accordance with ERP Section 6.IV, thereby violating 10 CFR 50.54(q) and  !

t 10 CFR 50.47(b)(8). Specifically, according to our quarterly inventory records, during the last three quarters of 1992 and the first quarter of 1993, a total of 42 instances were documented where radiation survey equipment was found to be missing or out-of-calibration.

Also, as stated in our June 8,19921ssue Report, there were not sufficient reserves available  ;

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to replace items removed from emergency kits for repair. Further on April 8,1993, NRC review determined that an ion chamber survey instrument was missing from the emergency -

locker in the Operations Support Center. l

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IL REASON FOR VIOLATION

This violation resulted from failure to fully resolve issues identified by BG&E in June 1992

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and January 1993. Closer follow-up would have showed that corrective measures taken were not effective in resolving the problem. A recent root cause analysis uncovered several +

training and proceduralissues which when combined led to the cited condition, l

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III. CORRECT 1VE STEPS TAKEN AND RESULTS ACillEVED i A detailed instruction has been written on how to accomplish the calibration PM. The .

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system for tracking instrument calibration due dates has also been incorporated directly in the instruction. Training has been conducted to enhance procedural knowledge and compliance in this area. A pool of instruments is being established that will allow l replacement of those out for calibration and repairs.

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IV. CORRECTIVE ACTIONS WlIICII MTLL BE TAKEN TO AVOID FURTIIER V101ATIONS  !

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No further action is required.

V. D ATE %1 TEN FULL COMPLIANCE WILL BE ACIIIEVED j l

Full compliance will be achieved upon establishment of the instrument pool The estimated completion date is October 1,1993.

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ATTACIIMENT (3)

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REPLYTO NOTICE OFVIOLATION

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INSPECTION REPORT NOS. 50-317(318)/93-03

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ERP TRAINING OF NUCLEAR ENERGY DIVISION MANAGERS ]

I. DESCRIPTION OF VIOLATION j ( -l l Reference (a) indicates that all Nuclear Energy Division (NED) Managers were not trained 1 l

- as both Site Emergency Coordinator (SEC) and Corporate Spokesperson in accordance with ERP, Section 3, thereby violating 10 CFR 50.54(q) and 10 CFR 50.47(b)(15). Specifically,  !

none of the six NED managers were trained as both SEC and Corporate Spokesperson. l l

II. REASON FOR VIOLATION 1

The violation occurred because ERPIP-904, Training, does not contain a requirement to  !

review ERP commitments before changes are made to training for individuals listed in the !

Emergency Response Organization (ERO). l l

l III. CORRECTIVE STEPS TAKEN AND RESULTS ACIHEVED .:

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The referenced requirement was originally incorporated in the ERP to provide flexibility in [

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filling key ERO positions. At the time, there were only three NED managers. Subsequent  ;

reorganization increased the number of managers to six. Additionally, the practice of l training the next lower level of supervision for key ERO positions has resulted in the l availability of more qualified people to fill the same number of positions. The ERP l

requirement does not reflect the best use of our resources in this area. The requirement to i 4 train all NED Managers as both SEC and Corporate Spokesperson was therefore deleted from the ERP on June 7,1993, following approval of a 10 CFR 50.54(q) evaluation showing

that the change would not reduce the effectiveness of the plan.  !

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IV. CORRECTIVE ACTIONS %1IICH MTLL BE TAKEN -TO AVOID FURTIIER l

VIOLATIONS

.A revision will be made to ERPIP-904, Training, to include a requirement to review ERP f commitments before changes are made to training for individuals listed in the ERO. j

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- V. DATE M1.JEN FULL COMPLIANCE WILL BE ACIHEVED l Full compliance will be achieved by September 14,1993.

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