IR 05000317/1998004

Discusses Insp Repts 50-317/98-04 & 50-318/98-04 & Forwards Notice of Violation Re Failure to Include Portion of Emergency Lighting Located Outside Control Room

ML20249B053
Person / Time
Site:	Calvert Cliffs
Issue date:	06/15/1998
From:	Wiggins J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Cruse C BALTIMORE GAS & ELECTRIC CO.
Shared Package
ML20249B054	List: IR 05000317/1998004 ML20249B057
References
50-317-98-04, 50-317-98-4, 50-318-98-04, 50-318-98-4, EA-98-225, NUDOCS 9806220019
Download: ML20249B053 (4)

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June 15, 1998

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EA 98 e' 25 Mr. Charles Vice President - Nuclear Energy Baltimore Gas and Electric Company (BGE).

Calvert Cliffs Nuclear Power Plant (CCNPP)

1650 Calvert Cliffs Parkway Lusby, MD 20657-4702 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NOS. 50-317/98-04 AND 50-318/98-04)

Dear Mr. Cruse:

This letter refers to the NRC inspection conducted at the Calvert Cliffs Nuclear Power Plant, for which the exit meeting was held on April 3,1998. The inspection report was sent to you on May 1,1998. Based on the inspection, four apparent violations of NRC requirements were identified. On, May 27,1998 a predecisional enforcement conference was conducted with you and members of your staff to discuss the apparent violations identified during the inspection, the causes, and your corrective actions. Attachments 1 and 2 are copies of NRC and licensee slides used at the conference.

The purpose of the conference , in part was to determine whether a program breakdown occurred. The concern resulted when the team found: (1) It took 3 to 6 months on an average to identify exceeding performance criteria using BGE's Maintenance Rule program procedure processes; (2) The reliability index together with other aspects of the BGE's Maintenance Rule program did not allow for timely review of structure, system, and component functional failures (FFs) and repeat FFs when (a)(2) performance criteria was exceeded; (3) Past corrective action was recommended, but was not fully acted on until October 1997. Self assessme% performed in May 1996 and October 1997 recommended that the reliability index shou;d be abandoned in favor of separate reliability and availability indicators; and (4) At the time of the inspection, the reliability index was still used for establishing performance criteria for most electrical systems cnd some mechanical systems.

We have no information to refute your position at the conference that a program breakdown did not occur. Your basis was that corrective action timeliness and quality was equivalent for equipment that remained in (a)(2) status but should have been placed in (a)(1) status. You also indicated that these actions were consistent with safety vgnificance and evident by improved plant performance, reduced trips and transients, and reduced challenges to safety systems, in addition, you indicated your efforts were aimed at extensive and complete rebeselining of your program to ensure long term success and correction of allidentified Maintenance Rule program weaknesses. Please inform us if we have any misunderstanding in this regard.

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Mr. Charles l Based on our review of the inspection findings and information provided during the conference, four violations are being cited and are described in the enclosed Notice of Violation (Notice): (1) BGE permitted the containment spray system to remain under 10 CFR

! 50.65(a)(2) following a repetitive functional failure when preventati/e maintenance failed to assure that this system remained capable of performing its intended function; (2) BGE permitted a number of structures, systems, and components (SSCs) within the scope of the Maintenance Rule to remain under 10 CFR 50.65(a)(2) when preventative maintenance failed to assure that these SSCs remained capable of performing their intended function; (3) BGE failed to establish performance measures for the emergency diesel generator building heating, ventilation, and air conditioning system and was therefore unable to effectively demonstrate the system remained capable of performing its intended function; and (4) BGE failed to include the portion of the emergency lighting located outside the control room, which is required for safe shutdown of the plant, in the scope of the Maintenance Rule program. The violations have been categorized at Severity Level IV in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," (Enforcement Policy), NUREG-1600, revison 1.

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 plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actior.s and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.

Further, these findings demonstrated that managem-u had not taken effective action to assure adequate implementation of new requirements at the facility. At the conference, you acknowledged program deficiencies and noted that implementation of the Maintenance Rule program did not meet your expectations. Accordingly, in your response to the violations, we request that you address current or additional measures that will ensure sustained organizational attention to the effectiveness of the maintenance rule implementation at your facility.

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Mr. Charles in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, l its enclosure, and your response will be placed in the NRC Public Document Room (PDR).

Sincerely, James T. Wiggins, Director Division of Reactor Safety

. Docket / License Nos.: 50-317/DPR-53 50-318/DPR-69 Enclosure: Notice of Violation Attachments:

.1 NRC Slide Presentation 2. BGE Slide Presentation cc w/encis:

T. Pritchett, 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 State of Maryland (2)

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. Mr. Charles