ML19337B013
| ML19337B013 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 08/05/1980 |
| From: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19337A991 | List: |
| References | |
| NUDOCS 8010010201 | |
| Download: ML19337B013 (3) | |
Text
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B ALTIMORE G AS AND ELECTRIC COMPANY P.O. B O X 14 7 5 B ALTIMOR E. M A R YL AN D 21203 AmtHum E. LuNovALL,JR.
v.cs P.c,oca, Su pes, August 5, 1980 U.S. Nuclear Regulatory Commission Docket Nos.
50-317 Region I 50-318 631 Park Avenue King of Prussia, PA 19406 ATTN: Mr. B. H. Grier, Director Gentlemen:
As a result of the telephone conversation held between your Messrs.
Brunner and McCabe and myself on July 17, 1980, we have reviewed our reply to certain items contained in your inspection reports 50-317/
80-01; 50-318/80-01 and 50-317/80-02; 50-318/80-02.
The results of this review and, where appropriate, further corrective action we have taken is detailed in enclosure '1) to this letter.
Should you have further questions regarding this matter, we would be pleased to discuss them with you.
Very truly yours',
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I A. E. Lundvall, Jr.
Vice President-Supply i
AEL/ RED /gla Enclosure 8010010 20'1
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ENCLOSURE (1)
RESULTS OF THE REEVALUATION OF CORRECTIVE ACTIONS ASSOCIATED WITH NRC INSPECTION REPORTS
,50-317/80-01; 50-318/80-01 and 50-317/80-02; 50-318/80-02 INSPECTION REPORT 50-317/80-01; 50-318/80-01, Item B As described in our reply to the subject inspection report, this item of noncompliance was based on a difference of interpretation as to the types of situations which constitute a " loss of safety function". Our i
longstanding interpretation, as implemented by the Shift Supervisors, keyed the reporti.ig requirement set forth by Technical Specification 6.9.1.8.f to exceeding the individual LC0 related " action statements".
Based on our recent conversations with your staff, we have reconsidered this interpretation and have taken further corrective action regarding this item. Specifically, the Shift Suoervisors have been instructed to regard Technical Specification 6.9.1.8.f separately from action statements and to strictly categorize the simultaneous loss of redundant, safety-related equipment as requiring a prompt report (even in situations which satisfy the associated action statements).
I INSPECTION REPORT 50-317/80-01; 50-318/80-01, Item C In deference to your staff s position regarding this item, we will review all violations of the Technical Specifications noted in this item of your report. This review will be completed by August 15, 1980.
In the future, similar violations will be reviewed by the POSRC.
INSPECTION REPORT 50-317/80-02; 50-318/80-02, Item A.1.a Your staff has expressed concern regarding a statement in this reply which they interpret as an endorsement to deviate from written procedures.
A further explanation of this statement is warranted.
Stating that we do not expect plant personnel to follow incorrect pro-cedures was not intended to endorse deviation from procedures nor should it indicate complacency with procedure errors. All plant procedures have an associated mechanism for implementing changes and revisions. Those procedures which are routinely used can be changed "on the spot" (so plant management and a follow-up ) review by the POSRC.
long as the intent is not altered with the approval of two members of Personnel frequently use this mechanism to correct minor pmcedure errors before the procedures are used. Such actions are proper and are expected to be followed when procedure errors are recognized.
In order to respond to your concern in this area, the Manager-Nuclear Power has directed a memorandum to all department level general supervisors /
suoervisors at the site reiterating the importance of strict adherence to procedures and of timely corrective actions regarding procedure changes l
and revisions as the need is recognized.
[
.,. o ; -
ENCLOSURE (1)
RESULTS OF THE REEVALUATION OF CORRECTIVE ACTIONS ASSOCIATED WITH NRC INSPECTION REPORTS 50-317/80-01: 50-318/80-01 and 50-317/80-02; 50-318/80-02 INSPECTION REPORT 50-317/80-02; 50-318/80-02, Item A.1.b(1)
The procedure, SEPIP A, which is the subject of this item, as it existed at the time of the incident, was written in a rather general fomat to cover all levels of radiological " emergencies", even though the lowest levels of initiating events should not rigorously be defined as an "emer-gency". Hence, relatively minor radiation instrument increases could lead to the implementation of a single checklist which generically extended to encompass even the most serious radiological indidents affecting the general public.
It is now recognized that the implementation of a procedure with such a broad scope is not desirable since it allows tco great a latitude for judgmental decision as to which items are "not applicable" to the situation at hand. On March 13, 1980, Revision 10 to the Site Emergency Plan Implementation Procedures was issued. This revision substantially altered the format of SEPIP A.
Separate check-lists are now provided for a Plant or Local Emergency and for a Site or General Emergency. This improvement should preclude future confusica as to the applicability of the various actions prescribed for each classi-fication.