ML19289D652

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Responds to NRC Re Violations Noted in IE Insp Repts 50-317/78-38 & 50-318/78-34.Corrective Actions: Oversight of Mgt Controls Sys Improved to Aid Implementation of License Requirements
ML19289D652
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 02/05/1979
From: Lundvall A
BALTIMORE GAS & ELECTRIC CO.
To: Grier B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19289D651 List:
References
NUDOCS 7903140015
Download: ML19289D652 (3)


Text

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BALTIMORE G AS AND ELECTRIC COMPANY P.O. BO X 14 7 5 B A LTI M O R E. M A R YL A N D 2120 3 ARTHUR C. LUN OVALL,JR.

WCE Persiotav S u peLv February 5,1979 Office of Inspection and Enforcement Docket Nos.

50-317 U.S. Nuclear Regulatory Commission 50-318 Region I 631 Park Avenue King of Prussia, Pennsylvania 19406 Attention:

Mr. Boyce H. Grier, Director Gentlemen:

This refers to your Inspe:: tion Report 50-317/78-38; 50-318/78-34 of January 17, 1979, which transmitted two items of noncompliance noted during the inspection. Enclosure (1) to this letter constitutes a written explanation in reply to these items of noncompliance.

With respect to Item A of your Appendix A, a discussion of the measures we have taken to improve the effectiveness of our control over the implementation of our license requirements is included in our reply to this item in Enclosure (1).

Should you have further questions concerning this reply, we would be pleased to discuss them with you.

Very truly yours

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a

- _r A. E. Lundval Jr.

Vice President - Supply AEL/ RED /dds Enclosure 7 70 31Y00 il

ENCLOSURE (1)

REPLY TO NRC LETTER OF JANUARY 17, 1979; I&E INSPECTION REPORT 50-317/78-38 and 50-318/78-34 ITEM A Even though a recent series of events have occurred which reflect inattentiveness to Technical Specification requirements, we do not feel that all five instances resulted from a single weakness or oversight in our management controls systems. Therefore, it is not possible to supply a single remedy to the problem set forth by your letter; rather, several individual solutions have been or will be applied.

Immediately following the January 4,1979, Management Meeting, the Nuclear Plant Engineer - Operations (NPE-0) met with all Supervisors and work leaders of the operations unit, the Shift Supervisors and Senior Control Room Operators. This series of meetings had several purposes:

to convey the content of the I&E Managment Meeting to these supervisors, to impress upon these supervisors the necessity for absolute adherence to the Technical Specifications, and to collectively suggest solutions for problems which ~ led to the events of concern. As a result of these meetings we feel that the super-visors involved have a better understanding of their responsibilities in implementing our license requirements and will exercise an increased vigilence in doing so.

Further specific actions which have been taken or will be taken to strengthen our control over Technical Specification requirements are set forth below:

1.

Further direction to the Control Room Operators (CR0s) has been issued to reiterate their duties and responsibilities towards license requirements. We realize that past memoranda of this nature have not been totally effective. Therefore, this memoran-dum is considered as a first step only; subsequently the NPE-0 will attend regularly scheduled " retraining" sessions with the CR0s through mid-March to personally emphasize the importance of this matter and to obtain first-hand suggestions for improve-ment from the personnel directly involved.

2.

Log readings which are taken twice per shift have been moved ahead one hour to allow the Senior Control Room Operators extra time to do a more thorough review of critical logs at the end of each shift.

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REPLY TO NRC LETTER OF JANUARY 17, 1979 Page 2 3.

The problem of " hanging alarms" is being addressed both from an engineering and operational standpoint. The Engineering Depart-ment is performing a design review of chronically hanging alarms to determine if design modifications are warranted to alleviate the problem. Additionally, a weekly " preventative maintenance" routine has been incorporated to list and evaluate all alarms which are hanging during power operation.

4.

An NPE-0 Standing Instruction has been issued which requires the logging (in the Control Room log) of all periodic actions which are taken as a result of being in a Technical Specification

" Action Statement".

5.

A daily information sheet is being transmitted to the Radiation Safety and Chemistry Foremen which lists all Technical Speciff-cation " Action Statements" for this area of concern.

6.

A checklist has been added to the " Reactor Trip Recovery" procadure, A0P-14, which requires the listing of all current " Action State-ments" and their subsequent resolution prior to a change in operational modes.

We feel that the above described actions will strengthen our control over adherence to our license requirements and will substantially reduce the probability of recurrence of events of a similar nature to those described by your letter.

ITEM B CCI-200B, " Maintenance Requests", will be revised to assign final determination of post-maintenance test requirements to the Senior Control Room Operator (SCRO). The revised CCI-2008 also clarifies the responsibility of the SCRC to document the method of performing post-maintenance testing and returning equipment to normal operating status. CCI-2008 will be revised by February 16, 1979 and the new provisions will be fully implemented by March 1,1979.

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