ML20024H395
| ML20024H395 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 05/23/1991 |
| From: | Joyner J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| References | |
| NUDOCS 9106030253 | |
| Download: ML20024H395 (2) | |
See also: IR 05000317/1990004
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M&i' 2 3 1991
Docket Nos. 50-317
50-318
Baltimore Gas and Electric Company
ATTN: .Mr. George C. Creel
Vice President
Nuclear Energy
Calvert Cliffs Nuclear Power Plant
MD Rts 2 & 4, P,0, Box 1535
i
Lusby, Maryland 20657
Dear Mr. Creel:
Subject:
Combined Inspection Nos. 50-317/90-04 and 50-318/90-04
This refers to your letter dated March 29, 1991, in response to our letter
dated February 12, 1991,
l
Thank you for informing us of the corrective and preventive actions documented
)
in your letter. These actions will be examined during a future inspection of
-your licensed program.
Based upon our review of Attachments 1 and 2 to your letter, we do not see a
need to meet with your Emergency Planning personnel to discuss the specifics
of the EAL revisions you plan to make, unless you believe that it would be
,
beneficial for other reasons.
Please contact William J. Lazarus of this
office at (215) 337-5208, if you desire to meet with us.
Your cooperation with us is appreciated.
Sincerely,
-
Orig:rul S;gned By:
Richard R. Keimig
James H. Joyner, Chief
Facilities Radiological Safety
and Safeguards Branch
Division of Radiation Safety
and Safeguards
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OFFICIAL RECORD COPY
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Baltimore Gas and Electric Company
2
CC:
R. McLean, Administrator, Nuclear Evaluations
J. Walter, Engineering Division, Public Service Commission of Maryland
G. Adams, Licensing (CCNPP)
C. Hart, Sr., Supervisor, Security Planning & Programs
R, Beahm, Director, Security Services
K. Burger, Esquire, Maryland People's Counsel
R. Ochs, Maryland Safe Energy Coalition
,
Public Document Room (PDR)
,
local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
State of Maryland (2)
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bcc:
Region I Docket Room (with concurrences)
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Management Assistant, DRMA (w/o encl)
J. Joyner, DRSS
C. Cowgill, DRP
E. Knutson, DRP
D. Vito, DRP
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B. Summers, DRP
K. Abraham, PA0 (2)
M. Conner, DRP (SALP Reports Only)
M. Callahan, OCA
0. Mcdonald,-NRR
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R. Capra, NRR
K. Brockman, ED0
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SD3/91
0FFICIAL RECORD COPY
RL CC 90-04/04 - 0002.0.0
05/20/91
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B ALTIMORE
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GAS AND
ELECTRIC
OHARLES CENTER e P.O. BOX 1475 * BALTIMORE. MARYLAND 21203-1475
Gconot c. cacco
v,c c pa n.w.,
March 29,1991
Nvcic am E ,gno,
t mod no24ss
U. S. Nuclear Regulatory Commission
Washington, DC 20555
NITENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant
Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318
Emergency Classification and Action Level Scheme Update and
implementation Schedule
REFERENCE:
(a)
Letter from Mr. James IL Joyner (NRC) to Mr. George C. Creel
(BG&E), Review of Calvert Cliffs Nuclear Power Plant Emergency
Action Levels (EALs), dated February 12,1991
(b)
NrtC Combined Inspection Report Nos. 50-31790-04 and
Gentlemen:
Reference (a) discusses the results of Nuclear Regulatory Commission staff review of Revision 14,
Change 3 to the Emergency Classification and Action Level Scheme for Calvert Cliffs Nuclear Power
Plant. This review concluded that the Emergency Action Level (EAL) scheme has been improved,
but that additional changes are needed to meet the guidance of NUREG-0654. The letter requested
a response to staff review comments and a schedule for implementing further changes to the EAL
scheme.
It has been BG&Es consistent intent to use the guidance of NUREG-0654 in defining those
conditions which should initiate EAL declarations. We have been equally attentive in attempting to
insert that guidance into our EALs in the form of definitions that are clear-cut and straightfonvard
for application by our operating staff. To this end, we have tied EAL declarations to our Emergency
or Abnormal Operating Procedures (EOP/AOP) wherever possible. Since these do not fit identically
with the wording of NUREG-0654, we have attempted to identify equivalent conditions as nearly as
possible while still complying with the intent and spirit of NUREG-0654. We have carefully
considered your previous comments from Reference (b) in evaluating these interpretations, and have
resolved most of your noted concerns. Your most recent letter addresses some remaining items. We
have reviewed these and our comments are provided in Attachment (1).
Additionally, our
implementation schedule is included in Attachment (2).
As discussed earlier this month with Mr. Jim Wiggins of the Region I office, BG&E Emergency
Planning personnel will discuss the specifics of the EAL revision with you at your convenience in
King of Prussia.
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Docu' ment Control Desk
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h1 arch 29,19ll
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Page 2
Should you have any further questions regarding this matter, we will be pleased to discuss them with
you.
Verj truly yours,
l
U
GCCffEF/REF/bjd
Attachments
cc:
D. A. Brune, Esquire
J. E. Silberg, Esquire
R. A. Capra, NRC
D. G. hicDonald, Jr., NRC
T. T. hiartin, NRC
L E. Nicholson, NRC
R.1. hicLean, DNR
J. H. Walter, PSC
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NITACIIMENT (I)
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llESI'ONSE TO NitC lllWlEW COM MENTS
BG&E views NOUEs 3.b,4, and Alert 9 as instances where existing EALs comply with NUREG.
0654 guidance but that revision to incorporate your comments will improve the clarity. It is our
intent to include these items in our next modification to the EALs.
BG&E considers that NOUE 6, which discusses Safety / Relief valves, is currently adequately covered
under " Equipment described in Technical Speci6 cation" and through " Abnormal coolant
Temperature / Pressure outside of Technical Specification" which would result from such a
malfune'. ion; We will, however, incorporate an additional EAL to clarify the inclusion of this
condition.
BG&E considers that NOUE 7, Loss of Onsite Power, is adequately addressed through existing
EALs. For total loss of onsite power an alert level emergency will be declared under EAL 'EOP 7,
Station Blackout implemented." For partialloss of onsite power a NOUE would be declared under
the general safety category EAL: " Equipment described in Tc;hnical Specification is degraded such
th a t ... ."
BG&E views NOUEs 14a and c as cases in which the current guidance covers the intent of NUREG.
0654 to the extent that unambiguous guidance could be provided. While we will agree to expand the
definitions of explosions and unusual aircraft activity, we note that this will introduce a greater
degree of subjectivity into our classification. Since it is clearly the NRCs position that this increased
latitude ofinterpretation better meets the needs of the public, we will agree to the changes.
BG&E views SAE 10 as an instance where the existing EAL complies with NUREG.0654 guidance.
Adopting your comments wid improve the conservative level for implementing the EAL lt is our
,
intention to include this implementing level in our next change to the EAL
BG&E considers evacuation of the Control Room and implementation of AOP-9 series procedures
discussed in SAE 18 as equivalent. We agree, however that the EAL can be modified to address the
NRCs concern.
'
BG&E has reviewed GE #5 and agrees to add specific core melt sequences as listed.
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A'ITACilMENT (2)
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IML REVISION SCIIEDUI.E
SCIIEDULED
COMPLETION
ACTIVITY
I) ATE
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Develop EAL revision responsive to NRC concerns
April,1991
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Technical review of proposed EAL revision (includes comment
May,1991
resolution)
Plant Operations and Safety Review Committee review of
-
proposed EAL revision (includes comment resolution)
June,1991
NRC review of proposed EAL revision (Region I and NRR;
-
includes comment resolution)
July August,1991
State / County review of proposed EAL revision
September,1991
-
Condect training on EAL revision
September. October,
-
1991
EAL final approval and implementation
November,1991
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B At TIMORE
GAS AND
ELECTRIC
CHARLES CENTER * P.O. BOX 1475 * BALTIMORE. MARYLAND 21203-1475
Gronot C CnttL
v.ce p.c. m .
March 29,1991
s ea .
t,a.a,
uoa , o . . s
U. S. Nuclear Regulatory Commission
Washington, DC 20555
ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant
Unit Nos.1 & 2; Docket Nos. 50-317 & 50 318
Emergency Classification and Action Level Scheme Update and
implementation Schedule
REFERENCE:
(a)
Letter from Mr. James H. Joyner (NRC) to Mr. George C. Creel
(BG&E), Review of Calvert Cliffs Nuclear Power Plant Emergency
Action Levels (EALs), dated February 12,1991
(b)
NRC Combined Inspection Report Nos. 50 317/90-04 and
50-318/90-04
Gentlemen:
,
Reference (p) discusses the results of Nuclear Regulatory Commission staff review of Revision 14,
Change 3 to the Emergency Classification and Action Level Scheme for Calvert Cliffs Nuclear Power
Plant. This revies concluded that the Emergency Action Level (EAL) scheme has been improved,
but that additional changes are needed to meet the guidance of NUREG-0654. The letter requested
a response to staff review comments and a schedule for implernenting further changes to the EAL
scheme.
It has been BG&Es consistent intent to use the guidance of NUREG-0654 in defining those
conditions which should initiate EAL declarations. We have been equally attentive in attempting to
insert that guidance into our EALs in the form of definitions that are clear cut and straightforward
for application by our operating staff. To this end, we have tied EAL declarations to our Emergency
or Abnormal Operating Procedure' (EOP/ AOl') wherever possible. Since these do not fit identically
with the wording of NUREG-0654, we have attempted to identify equivalent conditions as nearly as
possible while still complying with tne intent and spirit of NUREG-0654. We have carefully
considered your previcus comments from Reference (b)in evaluating these interpretations, and have
resolved most of your noted concerns. Your most recent letter addresses some remaining items. We
have reviewed these and our comments are provided in Attachment (1). Additionally, our
implementation schedule is included in Attachment (2).
As discussed earlier this month with Mr. Jim Wiggins of the Region I office, BG&E Emergency
Planning personnel will discuss the specifics of the EAL revision with you at your convenience in
King of Prussia.
.
.
.
.
-
_ . _ _ _ _ . _ . _ . . . _ _ - - . - _
.-_
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l
-i
Document Control Desk
.
h! arch 29,1991
Page 2
Should you have any further questions regarding this matter, we will be pleased to discuss them with
you.
Very truly yours,
'
.
,/
m
GCCffEF/REF/bjd
y
Attachments
cc:
D. A. Brune, Esquire
J. E. Silberg, Esquire
R. A. Capra, NRC
D. G. hicDonald, Jr., NRC
T. T. Af artin, NRC
L E. Nicholson, NRC
R. I. hicLean, DNR
J. H. Walter, PSC
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_ . . _..__ _ _
4
4
.
~
ATI'ACllM ENT (1)
.
11ESI'ONSE TO NitC REVIEW COMMENTS
BG&E views NOUEs 3.b,4, and Alert 9 as instances where existing EAl2 comply with NUREG.
0654 guidance but that revision to incorporate your comments will improve the clarity. It is our
intent to include these iterrs in our next modification to the EALt
BG&E considers that NOUE 6, which discusses Safety / Relief valves, is currently adequately covered
under " Equipment described in TecLnical Specification" and through " Abnormal coolant
Temperature / Pressure outside of Tec!.nical Specification" which would result from wch a
malfunction. We will, however, incorporate an additional EAL to clarify the inclusion of this
condition.
BG&E considers that NOUE 7. Loss of Oasite Power, is adequately addressed through existing
EALs. For total loss of onsite power an alert level emergency will be declared under EAL "EOP-7,
Station Blackout implemented." For partial loss of onsite power a NOUE would be declared under
the general safety category EAL: " Equipment described in Technical Specification is degraded such
tha t ... ."
BG&E views NOUEs 14a and c as cases in which the current guidance covers the intent of NUREG.
0654 to the extent that unambiguous guidance could be provided. While we will agree to expand the
definitions of explosions and unusual aircraft activity, we note that this will introduce a greater
degree of subjectivity into our classification. Since it is clearly the NRCs position that this increased
+
latitude ofinterpretation better meets the needs of the public, we will agree to the changes.
BG&E views SAE 10 as an instance where the existing EAL complies with NUREG.0654 guidance.
Adopting your comments will improve the conservative level for implementing the EAL It is our
intention to include this implementing levelin our next change to the EAL.
BG&E considers evacuation of the Control Room and implementation of AGP-9 series procedures
discussed in SAE 18 as equivalent. We agree, however that the EAL can be modified to address the
NRCs concern.
BG&E has reviewed GE #5 and agrees to add specific core melt sequences as listed.
I
1
. .
_
,
-
.-
-
.-
,
-, --
.- - - -
-
_
_ _ _ _ - _ _ _
_.
._
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'
flTACllMl:NT (2)
.
,
.
'
JAljEVISION SCIIEDUI.E
SCllEDULED
COMI'LET!ON
ACTIVriX
DATE
Develop EAL revision responsive to NRC concerns
April,1991
-
Technical review of proposed EAL revision (includes comment
May,1991
-
resolution)
Plant Operations and Safety Review Committee review of
-
proposed EAL revision (includes comment resolution)
June,1991
-
NRC review of proposed EAL revision (Region I and NRR;
includes comment resolution)
July August,1991
State / County review of proposed EAL revision
September,1991
-
-
Conduct training on EAL revision
September-October,
1991
-
EAL final approval and implementation
November,1991
s
i
1
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