IR 05000317/1997008

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-317/97-08 & 50-318/97-08 on 980320.Actions Taken or Planned Will Be Examined During Future Insp to Assess Overall Effectiveness

ML20249A079
Person / Time
Site:	Calvert Cliffs, 05000319
Issue date:	06/10/1998
From:	Doerflein L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Cruse C BALTIMORE GAS & ELECTRIC CO.
References
50-317-97-08, 50-317-97-8, 50-318-97-08, 50-318-97-8, NUDOCS 9806160033
Download: ML20249A079 (3)

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, Jur, ~98 l Mr. Charles l Vice President - Nuclear Energy i

Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway l Lusby, MD 20657- 4702 SUBJECT: NRC INSPECTION REPORT NOS. 50-317/97-08 AND 50-318/97-08 l AND NOTICE OF VIOLATION

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Dear Mr. Cruse:

This letter refers to your April 20,1998 correspondence, in responsa to our March 20,1998 letter.

Thank you for informing us of the corrective and preventive actions documented in your letter. We have reviewed these issues in accordance with NRC Inspection Procedures

- 92901, " Followup - Plant Operations," and 92904, " Follow-up - Plant Support." Based upon our preliminary review, we find your response to these violations appropriate. The l . specific actions taken or planned will be examined during a future inspection to assess their overall effectiveness.

We appreciate your cooperation.

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Sincerely, i

t Original Signed by:

William A. Cook for Lawrence T. Doerflain, Chief Projects Branch 1 Division of Reactor Projects l

Docket Nos. 50-317 l

50-318 3 j cc: .

T. Pritchett, Director, Nuclear Regulatory Matters (CCNPP)

R. McLean, Administrator, Nuclear Evaluations l J. Walter, Engineering Division, Public Service Commission of Maryland 9906160033 990610 PDR ADOCK 05000317 g PM 0FFICIAL RECORD COPY IE:01

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Charles 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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Charles Distribution w/ copy of Licensee's Response Letter:

B. McCabe, RI EDO Coordinator S. Bajwa, NRR A. Dromerick, NRR L. Doerflein , DRP W. Cook, DRP J. Stewart - Calvert Cliffs R.Junod,DRP M. Campion, RI Nuclear Safety information Center (NSIC)

PUBLIC Region l Docket Room (with concurrences)

Inspection Program Branch, NRR (IPAS)

DOCDESK

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DOCUMENT NAME: A:\RL970808.CC To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" =

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Copy with attachment / enclosure "N" = No copy j

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OFFICE Rl/DRP , Rl/DRP NAME WCook 4 LDoerflein(b

DATE 06/p/98 06/gy98 '

OFFICIAL RECORD COPY 1

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CHAOLES II. CHUsE Baltimore Gas and Electric Company Vice President Calvert Cliffs Nuclear Pow er Plant Nuclear Energy 1650 Calvert Cliffs Parkway i Lusby, Maryland 20657 1 410 4954455 l

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April 20,1998 l

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 Reply to a Notice of Violation: NRC Region I Integrated Inspection Report Nos. 50-317/97-08 and 50-318/97-08

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l REFERENCE: (a) Letter from Mr. L. T. Doerflein (NRC) to Mr. C. (BGE), dated l

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March 20, 1998, NRC Region i Integrated Inspection Report Nos. 50-317/97-08 and 50-317/97-08 and Notice of Violation l

l This letter provides Baltimore Gas and Electric Campany's response to Reference ! ;). Your letter identified three violations which require a response. Each of the violations cited has been Aividually addressed as specified in the Enclosure to Reference (a). Individual responses to each of these '-tions are provided in Attachments (1) througa ('4). Information contained in Reference (a) coric crung Violation 97-08-05 accurately reflects our corrective actions and our position. Therefore, no response to this violation is being submitted.

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

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l Very truly yours, C7;/// MjW CHC/JMO/ dim Attachment cc: R. S. Fleishman, Esquire Resident Inspector, NRC J. E. Silberg, Esquire R. I. McLean, DNR Director, Project Dir:ctorate I-1, NRC J.11. Walter, PSC A. W. Dromerick, NRC ' L. T. Doerflein (NRC)

H. J. Miller, NRC

'92C9 2.50 = ? 7fP

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ATTACIIMENT (1) l NRC REGION I INTEGRATED INSPECTION REPORT NOS. 50-317/97-08 AND 50-318/97-08 VIOLATION 97-08-01 Criterion XI, Test Control, ofAppendix B to 10 CFR Part 50 requires a testprogram be established to assure that all testing required to demonstrate that systems and components willperform satisfactorily in service is identified andperformed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents.

Contrary to the above, as ofJanuary 6,1998:

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BGEfailed to establish a written test procedure to verify that the [ control element assembly]

(CEA) reed switch position indicator voltage divider network power supply voltage was within the acceptance limit specified by the applicable design documents.

2. BGEfailed to establish a written testprocedure to verify that the CEA voltage divider reedswitch position indication channel was capable of determining the absolute CEA position within 1.75 inches as required by Technical Specification Limiting Conditionfor Operation [LCO} 3.1.3.3.

L ADMISSION OR DENIAL OF THE ALLEGED VIOLATLOR Baltimore Gas and Electric Company accepts the violation noted.

IL REASONS FOR THE VIOLATION Each refueling outage, we perform the following procedures:

+ Maintenance Procedure I-23, "Ce . trol Element Drive System Alignment" to verify control element assembly (CEA) reed switch position indicator voltage divider network power supply voltage;

+ Maintenance Procedure I-14," Control Element Drive System Reed Switch Zeroing" to calibrate the Reed Switch Position Transmitters to zero which verifies the * 1.75 inches criteria; and

+ Post Startup Test Procedure (PSTP)-13," Control Element Drive Mechanism Performance Testing" to verify that the pulse counting (i.e., primary) position indicator channel computer digital display, the secondary CEA reed switch position indication system, and the secondary CEA digital display system are within 4.5 inches of each other.

However, because we did not routinely verify CEA reed switch position indicator voltage divider neiwork power supply voltage, we were not aware that it had drifted to the point that we no longer met the * 4.5 inches acceptance criteria of PSTP-13.

IIL CORRECTIVE STEPS TIIAT IIAVE BEEN TAKEN AND RESULTS ACHIEVED S~ surveillance Test Procedure M-211, " Secondary CEA Position Display Out of Sequence And Deviation Alarm Functional Check," has been revised to verify, on a monthly basis, CEA reed switch position indicator voltage divider ne; work power supply voltage. Maintenance Procedure I-23," Control Element Driace System Alignment" was revised to change the power supply voltage setting to increase the accuracy of the indicator system.

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ATTACIIMENT (1)

NRC REGION 1 INTEGRATED INSPECTION REPORT NOS. 50-317/07-08 AND 50-318/97-08 VIOLATION 97-08-01 IV. CORRECTIVE STEPS TIIAT WILL BE TAKEN TO AVOID FURTIIER VIOLATIONS To avoid further violations of this nature, no further actions are required.

V. DATE WIIEN FULL COMPLIANCE WILL BE ACIIIEVED Full compliance was achieved when Surveillance Test Procedure M-211, " Secondary CEA Position Display Out of Sequence And Deviation Alarm Functional Check" and Maintenance Procedure I-23,

" Control Element Drive System Alignment" were revised.

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, ATTACIIMENT (2)

NRC REGION 1 INTEGRATED INSPECTION REPORT NOS. f0-317/97-08 AND 50-318/97-08 VIOLATION 97-08-02 Technical Specification (15) 3.1.3.3 requires, in part, two of the following three control element assembly (CEA) position indicating channels be operable for each shutdown and regulating CEA:

(a) CEA voltage divider reed sy'rch position indicator channel; (b) CEA " Full Out" or " Full In " reed switchposition indicator channa; and, (c) CEA pulse countingposition indicator channel.

Contrary to the above, between January 4 and 5,1998, BGE [ Baltimore Gas and Electric Company} !

failed to meet TechnicalSpecification Limiting Conditionfor Operation 3.1.3.3for Unit 1 when both the Control Element Assembly (CEA) voltage divider reed switch position indicator channel and the CEA

" Full Out" reed switch position indicator channel were inoperable, and no associated Action requirement existed.

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L ADMISSION OR DENIAL OF THE ATLFGED VIOLATION Baltimore Gas and Electric Company accepts the violation.

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II. REASONS FOR THE VIOLATION During the last half of 1997, there had been approximately sixteen separate problems with the control element assembly (CEA) pulse counting (i.e., primary) position indicator channel system. The frequency of problems predisposed the operators to conclude that a rod position discrepancy between the primary

CEA position indication ant the secondary (i.e., CEA voltage divider reed switch position indicator channel] indication was a problem with the primary CEA indication system.

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IIL CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED  ;

A root cause analysis of the event has been performed.

All primary CEA position indication system computer cards have been replaced. For Unit 1, the

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replacements were done in late January 1998 and, for Unit 2, they were done in early March 1998. There 1 have been no problems with the primary CEA position indication system since then.

Each Operations shift has been trained on the event both in classroom and the simulator. At the simulator sessions, the General Supervisor of Nuclear Plant Operations gave his expectations of how Operators should respond to situations like this one. Training stressed conservative decision-making and requesting technical support when necessary.

IV. CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS To avoid further violations of this nature, no further actioni, are required, llowever, to provide earlier notification of problems, Design Engineering is investigating the possibility of tighter.ing the alarm limits for voltage drift on the voltage divider position indication power supply.

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NRC REGION 1 INTEGRATED INSPECTION REPORT NOS. 50-317/97-08 AND 50-318/97-08 VIOLATION 97-08-02 V. DATE WHEN FUIL COMPLIANCE WIIL BE ACHIEVED Since the esponse to Violation 97-08 01 is related to this violation, full compliance was achieved when Surveillance Test Procedure M-211, " Secondary CEA Position Display Out of Sequence And Deviation Alarm Functional Check" and Maintenance Pro:edure I-23, " Control Element Drive System Alignment" were revised and the primary CEA position indication system computer cards were replaced.

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ATTACHMENT (3)

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NRC REGION 1 INTEGRATED INSPECTION REPORT NOS. 50-317/97-08 AND 50-318/97-08 VIOLATION 97-08-06 10 CFR 50.S4(q) requires licensees autirorized to possess and operate a nuclearpower reactor tofollow and maintain in effect emergency plans which meet the standards in 10 CFR 50.47(b) and the

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requirements in Appendix E to 10 CFR Part 50. 10 CFR 50.47(b)(9) requires the onsite emergency \

responseplansfor nuclearpower reactors have adequate methods, systems, and equipmentfor assessing and monitoring actual orpotential offsite consequences ofa radiological emergency condition. ,

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The Calvert Chffs Nuclear Power Plant Emergency Response Plan (ERP) Paragraphia, Accident \

Assessment, of Chapter 4, Emergency Measures states, in part, Emergency Response Plan implementation Procedures (ERPIP) provide methods and techniques for determining radioactive materialrelease source term.

Contrary to the above, on January 15, 1998, methods and techniques for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition were not adequately implemented, during tabletop walkthroughs, in that two techniciansfunctioning as interim Radiological Assessment Directors, assumed incorrect isotopic concentrations of the radioactive material release source term which resulted in non-conservative offsite dose projections.

I. ADMISSION OR DENIAL OF THE AT TIGED VIOLATION

Baltimore Gas and Electric Company accepts the violation.

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i II. REASONS FOR THE VIOLATION The reasons for this violation are as follows:

+ Emergency Response Plan Implementation Procedure (ERPIP)-107, " Interim Radiological Assessment" was not sufHciently detailed to address the actions assessed by the NRC inspectors;

+ Training for technicians serving in the Interim Radiological Assessment Director (IRAD) position has focused on higher probability accident scenarios such as those at the Alert level emergency; and,

+ Pronciency expectations for lower probability situations (Site and General Emergency) that require the technicians to make core damage estimates in severe accidents without the Technical Support Center and Emergency Operations Facility support have not been delineated, conveyed to the technicians in training, nor tested and evaluated.

IIL CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED The procedure used by the on-shift Chemistry Technicians, ERPIP-107, " Interim Radiological l Assessment," has been reviewed and is currently going through the revision process.

In response to the findings of the Nuclear Regulatory Com:nission inspection, a training package was developed for the on-shift Chemistry Technicians to clarify expectations regarding the identincation of ,

the accident type (which determines the isotopic concentrations). The training was completed for all '

1 RAD quali6ed personnel on February 3,1998. l l

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ATTACIIMENT (3)

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l NRC REGION 1 INTEGRATED INSPECTION REPORT NOS. 50-317/97-08 AND 50-318/97-08 VIOLATION 97-08-06 )

Additionally, a dose assessment scenario has been assigned to each qualified IRAD. The scenario includes determination of the accident type using the current ERPIP-107. The four scenarios, completed to date, have shown no problem with accident identification.

IV. CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS

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To avoid further violations of this nature, no further actions are required. However, to strengthen IRAD performance, the following additional steps will be taken:

A. The procedure used by the on-shift Chemistry Technicians, ERPIP-107, " Interim Radiological l Assessment," is being revised to simplify its use and provide more detail on using instruments to determine magnitude of core damage.

B. Chemistry Technicians that are qualified for Interim Radiological Assessment will be provided training on the revised ERPIP-107 functions prior to its implementation and proficiency evaluations on its use thereafter.  ;

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l V. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED )

Full compliance was achieved on February 3,1998 when the on-shift Chemistry Technicians were trained on the expectations regarding identification of the accident type.

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