ML19322A115

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Notice of Violation from Insp on 781010-13
ML19322A115
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 11/09/1978
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19322A107 List:
References
50-317-78-28, 50-318-78-25, NUDOCS 7901020449
Download: ML19322A115 (2)


Text

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Q,'

APPENDIX A NOTICE OF VIOLATION Baltimore Gas and Electric Company Docket Nos. 50-317 50-318 Based on the results of an NRC inspection conducted on October 10-13, 1978, it appears that several of your activities were not conducted in full compliance with conditions of your NRC Facility License Nos. DPR-53 and DPR-69 as indicated below. These items are categorized as deficiencies.

A.

Technical Specification 6.8.3 requires in part:

" Temporary changes to procedures...may be made provided...the change is documented, reviewed by the POSRC and approved by the Chief Engineer within 14 days of implementation."

Contrary to the above, as of October 13, 1978, a temporary change (78-56),issuedJune 28, 1978, to 0I 20, Revision 2, May 10, 1978, Fire Protection System, had not been reviewed by the POSRC and ap-proved by the Chief Engineer; and, a temporary change to 018E, Revision 6, November 3,1977, MSIV Hydraulics had not been documented, and, therefore, was not reviewed by the POSRC and approved by the Chief Engineer.

B.

10 CFR 50, Appendix B, Criterion VI states in part:

" Measures shall be established to control the issuance of documents such as

... procedures... including changes thereto, which prescribe all activities affecting quality. These measures shall assure that documents, including changes, are reviewed for adequacy...and are distributed to and used at locations where the prescribed activity is performed...."

Quality Assurance Procedure (QAP) 1, Revision 16, November 2.1977, Procedure Control, paragraph 4.2.1 in reference to Plant, Section and Unit Procedures, states in part:

"These procedures shall be prepared according to control procedures which provide requirements for... review... revision, control, issue and distribution..."

Calvert Cliffs Operation Manual (CCOM) 300B, Change 6, August P.,

1978, requires in part that full copies of operating procedures instructions be maintained at the Unit 1 and Unit 2 Control Room Operation Desks. _ QAP 31, Revision 2, April 3,1978, paragraph 5.1 requires in part that procedures shall comply with applicable subsection 5.0 and 6.0 of ANSI N18.7-1972. ANSI N18.7-1972, paragraph 5.4 states in part:

"...To ensure procedures in current use provide best possible instructions to operators systematic review is required...." CCOM 3008, Chango 6, August 2,1978, paragraph X states in part:

Documentation of periodic review of the CCOM shall be affixed to the cover sheet of the original of each affected procedure...."

79010204N

App:ndix A 2

Contrary to the above, as of October 13, 1978, certain operating procedures were not properly controlled nor properly reviewed for adequacy as follows:

Table 1 to OI 8E, Revision 6, November 3,1977, MSIV Hydraulics, was not in the copies of this procedure at the Unit 1 and Unit 2 Control Room Operation Desks; OP-6, Revision 9, May 10, 1978, Start-Up Checkoff List, contained nonconservative limits with respect to Technical Specification (TS) for Safety Injection Tanks Nitrogen Cover Pressure and M41 mum Refueling Water Tank Temperature.

In both cases, a: iicable pages had been revised subsequent to the issuance of these TS limits; One section of OP-3, Revision 9, November 30, 1977, reflected a nonconservative TS Cold leg Temperature limit for Departure from Nucleate Boiling considerations while an attached figure did identify the appropriate limit; and, Documentation of periodic review did not exist on the original to the affected procedures (OP-6 and OP-3) nor was it evident that other operating instructions (0I 2A, 3 and 8E) had been reviewed on a periodic basis.

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