ML20044E178

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Notice of Violation from Insp on 930405-09.Violation Noted: Emergency Plan Requirement to Maintain Mobile Labs to Be Operable within 1 H Was Not Followed
ML20044E178
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 05/14/1993
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20044E172 List:
References
50-317-93-03, 50-317-93-3, 50-318-93-03, 50-318-93-3, NUDOCS 9305240041
Download: ML20044E178 (3)


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NOTICE OF VIOLATION Baltimore Gas and Electric Company Docket Nos. 50-317, 50-318 Calven Cliffs Nuclear Power Plant License No. DPR-53,DPR-69 During an NRC inspection conducted on April 5-9, 1993, apparent violations of NRC requirements wem identified.

In accordance with the " General Statement of Policy and l

Procedure for NRC Enforcement Actions," 10CFR Pan 2, Appendix C, those violations are listed below:

A.

10CFR50.54(q) states in pan: "A licensee authorized to possess and operate a nuclear power reactor shall follow and maintain in effect emergency plans which meet the standards in f10CFR50.47(b) and the requirements in Appendix E of this part."

10CFR50.47(b)(8) specifies the standard that " Adequate emergency facilities and l

equipment to suppon the emergency response are pmvided and maintained."

Section 5.I.G.I.b, (Page 5-6) of the licensee's Emergency Response Plan, " Facilities and Equipment," states: "Two mobile laboratory trailers, equipped with absolute (HEPA) filter ventilation systems and electric generators, can be operational in about one hour.

The larger trailer has general laboratory capabilities similar to those of the Chemistry Laboratory.

The smaller trailer is equipped with a shielded counting system and functions as a back-up counting mom."

Contrary to the above, from March 2,1992 through April 9,1993, the emergency plan requirement to maintain the mobile laboratories so that they could be operational in about one hour was not followed.

Specifically, the mobile laboratory trailers were not equipped with a shielded counting system or gas panitioner, all laboratory glassware had been removed, ion exchange column lifetimes had expired in May of 1990 and February of 1992, and several other items listed in the Emergency Response Plan inventory pmcedures (tool kit, detergent, Tygon tubing, desiccant, air sampler, etc.) were not contained within the trailers. Consequently, the mobile laboratories could not provide either general laboratory capabilities similar to those of the Chemistry Lab or a back-up counting capability.

This is a Severity Ievel IV violation (Supplement VIII).

B.

10CFR50.54(q) states in pan: "A licensee authorized to possess and operate a nuclear power reactor shall follow and maintain in effect emergency plans which meet the standards in i10CFR50.47(b).."

10CFR50.47(b)(8) specifies the standard that " Adequate emergency facilities and equipment to suppon the emergency response are provided and maintained."

Section 6.IV, (Page 6-4) of the licensee's Emergency Response Plan, " Maintaining Preparedness," states in pan:

9305240041 930514 PDR ADDCK 05000317 OFFICIAL. RECORD COPY G

PDR

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" Emergency equipment and instrumentation are inspected, inventoried and/or i

operationally checked once each quaner, after each used(sic) and/or whenever tampering is suspected."

" Equipment calibration is in accordance with Radiation-Safety Pmcedures which endorse manufactures (sic) calibration recommendations. Sufficient reserves are available to replace items removed from emergency kits for calibrationhepair."

Contrary to the above, from the second quarter of 1992 until April 8,1993, emergency plan requirements to maintain designated calibrated equipments available were not followed. Specifically, accortling to the licensee's quarterly inventory records, during the last three quaners of 1992 and the first quaner of 1943, a total of 42 instances were j

documented where radiation survey equipment was found to be missing or out of calibration. Also, as stated in the licensee's June 8,1992 Issue Repon, there were not sufficient reserves available to replace items removed from emergency kits for repair.

Funber, on April 8,1993, NRC sampling review determined that an ion chamber survey instrument was missing from the emergency locker in the Opentions Suppon Center.

This is a Severity Level IV violation (Supplement VIII).

C.

10CFR50.54(q) states in part "A licensee authorized to possess and operate a nuclear power reactor shall follow and maintain in effect emergency plans which meet the standards in 510CFR50.47(b)..."

10CFR50.47(b)(15) specifies the standard that " Radiological emergency response training i

is provided to those who may be called on to assist in an emergency."

i The Calven Cliffs Emergency Response Plan, Section 3, specif 6...

" Nuclear Energy Division Managers, while each assigned a specific emergency i

organization position in ERPIPs, are all trained as SEC (Site Emergency Coortlinator) and Corporate Spokesperson. Should circumstances dictate, Managers may sene in either role at the discretion of the recovery officer."

Contrary to the above, as of April 9,1993, required emergency plan training provisions were not followed for the Calven Cliffs Nuclear Energy Division managers.

Specifically, none of the six Nuclear Energy Division managers were currently trained as both Site Emergency Coordinator and Corporate Spokesperson.

This is a Severity Level V violation (Supplement VIII).

OFFICIAL RECORD COPY

3 Pursuant to the provisions of 10 CFR 2.201, Baltimore Gas and Electric Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, A'ITN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region I, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued to show cause why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the i

response time.

Under the authority of Section 182 of the Act,42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Dated at King of Prussia, Pennsylvania this jlHh day of May,1993 i

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