ML19322A128
| ML19322A128 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 10/27/1978 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19322A120 | List: |
| References | |
| 50-317-78-24, 50-318-78-18, NUDOCS 7901030012 | |
| Download: ML19322A128 (4) | |
Text
0.
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 August 29 -
September 1 and September 18-19, 1978, it appears that certain of your activities were not conducted in full compliance with NRC regulations and the conditions of your NRC Facility License Nos. DPR-53 and DPR-69, as indicated below.
Items A and B are categorized as Infractions; Items C and D as Deficiencies.
Items A, B, and C are applicable to both Units; whereas, Item 0 is applicable to Unit 1 only.
A.
Section 6.8.1 of the Appendix A, Technical Specifications (TS) for Units 1 and 2 requires, in part, that written procedures be estab-lished, implemented and maintained for activities involving Emer-gency Plan implementation.
Contrary to this requirement, five instances of. failure to estab-lish adequate procedures were identified for activities involving Emergency Plan implementation.
Specifically:
1.
Implementation of Section V of the Site Emergency Plan (SEP) requires, in part, that specified licensee actions be taken when airborne radiciodine concentrations reach or exceed 5x10-8 microcuries/cc of air.
Contrary to this requirement, as of September 1, 1978, the Site Emergency Plan Implementing Procedure (SEPIP) A,Section V.A was inadequate in that the specified air sample volumes and analytical techniques, combined with an erroneous counting efficiency would not allow measurement of an action level of 5x10-8 microcuries of iodine /cc of air.
2.
Implementation of Section V of the SEP requires that counting instrumentation in the emergency kits be calibrated, in that,Section V.A of SEPIP A requires, in part, that airborne radio-activity levels be measured with instrumentation provided in emergency kits, using counting efficiencies posted on the included rate-meters.
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APPENDIX A 2
Contrary to these requirements, as of September 1,1978, the calibration procedures used did not provide for the calibration of the emergency kit rate-meter / detector assemblies for their intended use of evaluating airborne radioactivity; and the rate-meter / detector assemblies were not calibrated for analyzing airborne activities from charcoal cartridges or particulate filters.
3.
Implementation of Section VII.2.C and Appendix B of the SEP requires, in part, that "at least twice a year, imediately after use in emergency, the contents of the Treatment Rooms (Medical) will be inspected and replaced, replenished and/or resterilized as necessary."
Contrary to these requirements, inventory procedures and medical treatment room supply lists had not been established, as of September 19, 1978, to enable meaningful inventories to
.be conducted.
The required inspections / replacements / replenish-ments had not been conducted during 1977 or 1978, in that, on August 30, 1978, all of the intravenous solutions stored in the Controlled Area Medical Treatment Room had exceeded their posted expiration dates of June 1975 and December 1977.
Bottles of saline solutions in the included Decontamination Kits exceeded their posted expiration dates of November and December 1977.
4.
Implementation of Section V.E,1 of the SEP requires, in part,,
that implementing procedures contain measures to ensure that the number and locations of all persons, including persons engaged in farming, are known at all times such that they will be quickly warned and evacuated when necessary.
Contrary to these requirements, as of September 19, 1978, implementing procedures had not been established which contain measures that ensure that (a) the number and locations of persons engaged in farming activities on the Calvert Cliffs site are known at all times, and (b) these persons can be quickly warned and evacuated when necessary.
5.
Implementation of Sections VIII B(2) and IX of the SEP require that complete copies of the Site Emergency Plan be distributed to all offsite support agencies.
Contrary to these requirements, as of September 19, 1978, the SEP distribution procedure / list did not include, nor were copies of the Site Emergency Plan distributed to, all offsite support agencies; specifically, the local hospital, fire department and rescue services.
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APPENDIX A
'3 B.
Section 6.8.1 of Appendix A, TS for Units 1 and 2 requires, in part, that procedures be implemented for activities involving Energency Plan implementation.
Contrary to this requirement, two instances of failure to follow procedures related to SEP training were identified.
Specifically:
1.
Procedure CCI-611C established pursuant to TS 6.8.1, requires that individuals assigned emergency responsibilities by the SEP and implementing procedures receive annual SEP training in their respective areas of assigned responsibilities.
Contrary these requirements, as of September 19,1978, one or more individuals assigned emergency responsibilities in each of the following areas - Site Emergency Directors, Emergency Coordinators, Emergency Radiation Team, Fire Brigade, Emer-gency First Aid and Decontamination Team, and Emergency Secur-ity Team - had not received the required SEP training in their respective areas of responsibilities during the year 1977 nor thus far in 1978.
2.
Procedures CCI-405A and CCI-611C, established pursuant to TS 6.8.1, require, in part, that an annual review of the required SEP training be performed.
Contrary to these requirements, as of August 31, 1978, the required annual review of the SEP training conducted in 1977 had not been performed.
C.
Section 6.8.1 of Appendix A, TS for Units 1 and 2 requires, in part, that procedures be implemented for activities involving Bnergency Plan implementation.
Calvert Cliffs Procedure CCI-611C, established pursuant to TS 6.8.1, requires, in part:
that within two months of the conduct of an emergency drill, a report be submitted to the Chief Engineer, detailing actions taken based on the drill comments and recom-mendations; and that records be kept of individuals and outside agency participation in emergency drills.
Contrary to this requirement, two instances of failure to follow procedures related to emergency drill records and reports were identified. Specifically:
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APPENDIX A 4
1.
As of September 19, 1978, drill reports detailing actions taken as a result of emergency drill comments and recommenda-tions were not prepared nor submitted to the Chief Engineer for the medical emergency and site emergency drills conducted during 1977.
2.
Records of individuals participating in the 1977 emergency medical and site emergency drills were not kept.
D.
Environmental Technical Specification 2.1.1 requires that the hourly average temperature increase of the condenser cooling water not exceed 5.56 C (10*F).
Contrary to this requirement, on July 14, 1978 and July 23, 1978, the hourly average temperature increase of the condenser cooling water exceeded 10 F, in that, the hourly average increase reached 10.1 F and 10.3'F, respectively, on those days.
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