ML19350C075

Responds to NRC 810115 Ltr Re Violations Noted in IE Insp Repts 50-317/80-16 & 50-318/80-15.Corrective Actions:Oxygen Analyzer Portion of Gas Analyzing Sys Returned to Svc in Dec 1980

ML19350C075
Person / Time
Site:	Calvert Cliffs
Issue date:	02/09/1981
From:	Lundvall A BALTIMORE GAS & ELECTRIC CO.
To:	Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19350C073	List: ML19350C075
References
NUDOCS 8103300358
Download: ML19350C075 (4)

Text

-

BALTIMORE GAS AND ELECTRIC -

CHARLES CENTER . P.O. BOX 1475 BALTIMORE, MARYLAND 21203 ARTHum E. LUNOVALL. Jm.

vice Pacs ocar SU P88LY February 9, 1981 U.S. Nuclear Regulatory Commission Region'I 631 Park Avenue King of Prussia, PA 19406 ATTENTION: Eldon J. Brunner, Chief Reactor Operations and Nuclear Support Branch Gentlemen:

This refers to your Inspection Report 50-317/80-16; 50-318/80-15, which transmitted several items of apparent noncompliance with NRC requirements. Enclosure (1) to this letter is a written statement in reply to the items set forth in your letter of January 15, 1981. Additionally, each item of this enclosure addresses the management control programs associated with the affected area and steps we have-taken, when appropriate, to improve the effectiveness of such controls.

Should you have any questions regarding this reply, we will be pleased to discuss them with you.

Very truly yours,

/

,i /,

/ s J f l}{ & G6? b*$ l-l-A. E. Lundvall, Jr. '

'Vice President Supply AEL/ RED /gla Enclos'ure (1) 81033 cog

ENCLOSURE (1)

REPLY TO APPENDIX A 0F NRC INSPECTION -

REPORT 50-317/80-16; 50-318/80-15 Item A Liquid releases from the Calvert Cliffs Nuclear Power Plant (except those from soapy and laboratory drains) are routinely processed through the reactor coolant waste evaporators and/or waste ion exchangers. During the fourth quarter of 1979, two incidents of saltwater introduction into the miscellaneous waste system caused higher than normal activity in several plant releases. The high salt concentrations into the waste ion exchangera caused reverse ion exchange.(i.e., release of previously removed activity) and high activity releases.

In fact, six liquid releases surrounding the two episodes, of the 41 reactor coolant waste monitor tanks released this quarter, accounted for over 50% of the 4.54 curies.

Several plant maintenance techniques have been modifie'd to prevent recurrence of this type of incident. The effectiveness of these efforts was exemplified by the low activity releases during 1980. Based on the successful minimization of the 1980 releases, we consider that we are presently in compliance with the requirements of Environmental Technical Specification 2.3.A.5.

The radwaste management system is currently under review by the Electric Engineering Department. Aspects of volume reduction / solidification and temporary on site storage are being studied. The economy of the results will be evaluated, with appropriate radwaste system changes incorporated and the FSAR updated.

Item B The inappropriateness of the Shift Supervisor's action was discussed with him and the on-shift Senior Control Room Operator by the General Supervisor-Operations and Plant Superintendent

, upon the latter's arrival in the Control Room at approximately 5:30 p.m. Additionally, in his Notes and' Instructions dated October 10, 1980, the General Supervisor-Operations brought this event to the attention of all licensed personnel.with emphasis on the failure.to sound the emergency alarm and make appropriate announcements.

4

ENCLOSURE (1)

REPLY TO APPENDIX A 0F NRC INSPECTION REPORT 50-317/80-16; 50-318/80-15 With regard to the adequacy of existing management controls, the Site Emergency Plan Implementing Procedure (SEPIP) in effect during the event and the current Emergency Response Plan Implementing Procedures (ERPIP's) have been reviewed.

Both procedures specifically direct that emergency alarms and PA announcements be made following classification of an event. It is, therefore, concluded that this item resu?.ted from an error in judgment on the part of a single individual and that management controls in this area are adequate.

Item C A request for an amendment to Technical Specification 6.3.1 has been drafted and approved by the Plant Operations and Safety Review Commitee and the Off-Site Safety and Review Committee.

This proposed amendment will alter the existing Technical Specification such that the formal educational requirements of ANSI 18.1-19 71 would not necessarily eliminate candidates for a supervisory position. Other factors, such as experience and training could be used to demonstrate suitability, if properly controlled and documented. The proposed amendment will be submitted to the NRC by February 28, 1981.

In order to strengthen our management controls in this area and to prevent future deficiencies of this nature, a memorandum has been initiated by the Manager-Nuclear Power and directed to the managers of all departments who approve the promotions of personnel under the purview of Technical Specification 6.3.1.

This memorandum cautions the affected managers that the require-ments of the standards to which we are committed must be observed when considering candidates for promotion.

Item D The Shift Supervisor who failed to report the unit trip was personnaly counselled by the General Supervisor-Operations regarding his error. In addition, this failure to comply with the prompt notification requirements was brought to the attention of all licensed operations personnel in the General Supervisor-Operations Notes and Instructions dated November 4, 1980.

1 l

L

ENCLOSURE (1)

REPLY TO APPENDIX A OF NRC INSPECTION REPORT 50-317/80-16; 50-318/80-15 This item resulted from an oversight on the part of the Shift Supervisor who was directly involved in supervising the investigation of the loss of condenser vacuum and the subsequent reactor trip recovery. Calvert Cliffs Instruction 118, Reporting Requirements, specifically directs that a prompt notification be made following a manual actuation of the Reactor Protective System. It is, therefore, concluded that this item resulted from the oversight on the part of a single individual and that sufficient manage-ment' controls exist in this area.

Item E The oxygen analyzer portion of the gas analyzing system was returned to service in December 1980.

To improve the effectiveness of the management control program, the requirements of 10 CTR 50.59 will be reviewed with all Nuclear Power Department affected unit supervisors and section heads. In addition, the Quality Assurance Department will add to its audit program a mechanism that will compare out-of-service equipment against the requirements of 10 CFR 50.59. This program will be instituted by April 1,1981.