ML022890492
| ML022890492 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 10/09/2002 |
| From: | Katz P Constellation Energy Group |
| To: | Document Control Desk, NRC Region 1 |
| References | |
| IR-02-010 | |
| Download: ML022890492 (5) | |
Text
Peter E. Katz Vice President Calvert Cliffs Nuclear Power Plant Constellation Generation Group, LLC 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 410 495-4455 410 495-3500 Fax Constellation Energy Group October 9, 2002 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
SUBJECT:
REFERENCE:
Document Control Desk Calvert Cliffs Nuclear Power Plant Unit Nos. 1 & 2; Docket Nos. 50-317 & 50-318 Response to a Notice of Violation - NRC Inspection Report 50-317/02-010; 50-318/02-010 (a)
Letter from Mr. H. J. Miller (NRC) to Mr. P. E. Katz (CCNPP), dated September 9, 2002, Final Significance Determination for a White Finding and Notice of Violation at Calvert Cliffs Nuclear Power Plant (NRC Inspection Report 50-317/02-010; 50-318/02-010)
This letter provides Calvert Cliffs Nuclear Power Plant's response to Reference (a), which identified a Notice of Violation associated with a white finding. This Notice of Violation involved a failure to adequately meet the requirements of 10 CFR 50.54(q), 10 CFR 50.47(b)(5), and 10 CFR Part 50, Appendix E, Section IV.D.3.
The response to this Notice of Violation is provided in Attachment (1).
Should you have questions regarding this matter, we will be pleased to discuss them with you.
Very truly yous PEK/TER/bjd
Attachment:
(1)
NRC Inspection Report No. 50-317(318)/02-010, Response to Violation 02-010-01 cc:
J. Petro, Esquire J. E. Silberg, Esquire Director, Project Directorate I-1, NRC D. M. Skay, NRC H. J. Miller, NRC Resident Inspector, NRC R. I. McLean, DNR
/
ATTACHMENT (1)
NRC INSPECTION REPORT NO. 50-317(318)/02-10 RESPONSE TO VIOLATION 02-010-01 Calvert Cliffs Nuclear Power Plant, Inc.
October 9, 2002
ATTACHMENT (1)
NRC INSPECTION REPORT NO. 50-317(318)/02-010 RESPONSE TO VIOLATION 02-010-01 10 CFR Part 50.54(q) requires in part, that a licensee authorized to possess and operate a nuclear power reactor shall follow and maintain in effect emergency plans that meet the standards in 10 CFR 50.47(b) and the requirements of Appendix E of this part.
10 CFR 50.47(b)(5) requires in part, that procedures have been established for notification, by the licensee, of State and local response organizations; and means to provide early notification to the populace within the plume exposure pathway Emergency Planning Zone [EPZJ have been established.
10 CFR 50, Appendix E, Section IV.D.3, states in part, that a design objective of the prompt public notification system shall be to have the capability to essentially complete the initial notification of the public within the plume exposure pathway EPZ within about 15 minutes after declaring an emergency.
The licensee shall demonstrate that State and local officials have the capability to make a public notification decision promptly on being informed by the licensee of an emergency condition.
Contrary to the above, between August 14, 2001 and November 5, 2001, the licensee was not capable of completing the initial notification of the public within the plume exposure pathway EPZ within about 15 minutes in Calvert County, Maryland. Specifically, the computer icon in the 911 Center for Calvert County used to activate the sirens had been inadvertently removed, which disabled the system and prevented it from being activated in a timely manner.
REASON FOR THE VIOLATION On Monday, November 5, 2001, the annual full cycle test of the Calvert Cliffs Public Alert &
Notification System Emergency Sirens was conducted simultaneously at noon in three counties. The test was a success in St. Mary's and Dorchester counties, but none of the sirens (0 of 49 sirens) actuated in Calvert County. The Calvert County sirens were declared inoperable. The immediate physical cause was identified as an incorrect icon (BGE Attack) on the computer screen. This icon was used in lieu of the proper one (BGE Alert) and was incorrectly programmed. There is no indication of any physical problem with the equipment.
CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED The following compensatory actions have been taken to address the direct causes of this violation and prevent future occurrences.
"* The missing "BGE Alert ALL" icon was restored to all Calvert Control computer screens by 7:00 pm on November 5, 2001.
"* The "Silent" and "Cancel" icons were retained. By 7:00 pm on November 5, 2001, all other icons were removed to reduce confusion.
"* The "BGE Alert ALL" icon was renamed "CCNPP Sirens" for clarity. Also, the "BGE Silent" icon was renamed "CCNPP Silent" and the "BGE Cancel" icon was renamed "CCNPP Cancel."
Appropriate county procedures were revised to reflect this change.
"* At 11:00 am on November 6, 2001, a system test of the Calvert Cliffs siren activation equipment at Calvert Control was completed. This test verified that all equipment was functioning properly without actual full siren activation.
"* Reviewed appropriate County Siren Activation procedures for all three affected counties.
"* Completed training within the Emergency Planning Unit on the need to document conditions adverse to quality on issue reports as illustrated by this event.
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ATTACHMENT (1Ž NRC INSPECTION REPORT NO. 50-317(318)/02-010 RESPONSE TO VIOLATION 02-010-01 "Completed training within the Plant Engineering Section on the need to document conditions adverse to quality on issue reports as illustrated by this event.
A verbal agreement was established with Calvert County representatives to communicate all maintenance, including software changes, to Calvert Cliffs Nuclear Power Plant (CCNPP) Emergency Planning personnel.
This action will improve communications related to system maintenance between CCNPP and Calvert County Control Center.
Calvert County Control Center activation procedures were changed to reflect new siren activation methods. These changes will help ensure consistent testing.
Establishment of expectations for when formal risk assessments are appropriate was considered by site management. This action was deemed unnecessary because the Project Manager or responsible organization for a modification is responsible to communicate the risks of not funding the modification to management. Management is responsible for determining what risk is acceptable as long as nuclear and personnel safety are not compromised.
Emergency Planning Section (CCNPP) has assigned one individual to be the point-of-contact or subject matter expert for sirens. A single point-of-contact will facilitate communications.
The following compensatory actions and controls have been taken to ensure clarity of expectations for both CCNPP and Calvert County personnel:
"* A Memorandum of Understanding has been established that delineates the Roles and Responsibilities for CCNPP and county personnel in all three counties.
"* An agreed upon communications protocol has been established.
"* Training with the Calvert County 911 Center operators has been completed.
"* Procedure usage has been reviewed with county personnel.
"* A protocol for Post-Maintenance Testing has been established.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS
- 1.
Additional administrative controls shall be developed and implemented to ensure clarity of expectations for both CCNPP and Calvert County personnel are maintained. These administrative controls shall address the interface between Calvert County and CCNPP, and also CCNPP internal interfaces. Standards and expectations will include, but are not limited to the following areas:
- Configuration Management
+ Communications
+ Training - Shall include Plant Engineering Section, Emergency Planning Unit, and county personnel
+ Procedure usage
+ Post-Maintenance Testing
- 2.
A methodical, documented risk analysis for all seven Nuclear Regulatory Commission cornerstones, using the general approach of a failure mode effects analysis, will be completed.
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ATTACHMENT (1)
NRC INSPECTION REPORT NO. 50-317(318)/02-010 RESPONSE TO VIOLATION 02-010-01
- 3.
An effectiveness review of the above corrective actions shall be performed. This review shall, as a minimum, review siren performance for repeat failures, and procedure compliance with all standards already in place as a result of the preceding action plan.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Calvert Cliffs Nuclear Power Plant restored compliance on November 6, 2001 when all equipment was verified to be functioning properly.
Calvert Cliffs presently complies with 10 CFR Part 50.54(q), 10 CFR 50.47(b)(5), and 10 CFR Part 50, Appendix E, Section IV.D. Compensatory actions are in place to prevent further violations. Corrective actions are planned to improve performance and bases capture the need for each action planned.
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