ML20045B572

Responds to NRC 930514 Ltr Re Violations Noted in EP Insp Repts 50-317/93-03 & 50-318/93-03.C/As:closer Supervisory Attention Will Be Paid to Establishing Priority of Resolution of Er Plan Related Equipment Problems

ML20045B572
Person / Time
Site:	Calvert Cliffs
Issue date:	06/11/1993
From:	Denton R BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9306180083
Download: ML20045B572 (4)

Text

,

' BALTIMORE GAS AND ,

l ELECTRIC --

1650 CALVERT CUFFS PARKWAY LUSBY, MARYLAND 20657-4702 RootRT E DENTON vice eResic. tut June 11,1993 NUCLE AR cNERG f f aiO) 360 44 55 '

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 Inspection Report 50-317S3-03,50-318S3-03; Calvert Cliffs Nuclear Power Plant Emercency Preparedness inspection

REFERENCE:

(a) letter from Mr. J. H. Joyner (NRC) to Mr. R. E. Denton (BG&E),

dated May 14,1993, Calvert Cliffs Nuclear Power Plant Emergency Preparedness inspection (50-317S3-03; 50-31893-03)

Gentlemen:

In response to Reference (a), please find Attachments (1) through (3) detailing our response to three cited violations concerning our Emergency Preparedness program.

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

Very truly yours, N x 4

[_ -W RED /WDM/bjd (

Attachments i

cc: D. A. Brune, Esquire l' J. E. Silberg, Esquire R. A. Capra, NRC l D. G. Mcdonald, Jr., NRC 1 T. T. Martin, NRC '

P. R. Wilson, NRC R.1. McLean, DNR ,

J. H. Walter, PSC l 1

" ftBS l 930618'0083 930611 'l '

l PDR ADOCK 05000317 ~

O PDR , ,

I

A'ITACIIMENT (1)

REPIX TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-317(318)/93-03 >

ERP MOlllLE LAllORATORIES I. 1)ESCRIPTION OF VIDIATION Reference (a) indicates that we failed to maintain two mobile laboratory trailers in accordance with the Emergency Response Plan (ERP), Section 5.1.G.1.b, thereby violating the requirements of 10 CFR 50.54(q) and 10 CFR 50.47(b)(8). Specifically, the mobile laboratory trailers required by the ERP were not equipped with a shicided counting system or gas partitioner, laboratory glassware had been removed, ion exchange column lifetimes had expired in May 1990 and February 1992, and several other items listed in the ERP inventory procedures (tool kit, detergent, tygon tubing, desiccant, air sampler) 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.

11. REASON FOR VIOLATION After contending with longstanding difficulties in maintaining back-up analysis equipment in the mobile trailers specified in the ERP, BG&E decided to transfer the capability to another k> cation that could better support the function. This effort was given a low priority because of its low safety significance. The relocation effort was not yet complete when the inspectors identified this condition.

Ill. CORRECTIVE STEPS TAKEN AND RESULTS ACillEVEI)

Analysis donc subsequent to relocation work demonstrated that back-up analysis capabilities are not required. The provision for Mobile Laboratory Trailers was deleted from the ERP on June 7,1993 following approval of a 50.54(q) cvaluation showing that the change would not reduce the effectiveness of the Plan.

IV. COR RECTIVE ACTIONS WillCII WILL llE TAKEN TO AVOID FURTilER VIOLATIONS Closer supenisory attention will be paid to establishing the priority of resolution of ERP- ,

related equipment problems. Existing corrective action systems are satisfactory to track resolution of non-conformances such as this.

V. D ATE WIIEN FULL COMPit LANCE WILL llE ACIllEVED Full compliance was achieved on June 7,1993 with approval of the ERP revision.

1

A1TACilMENT (2)

REPLY TO NOTICE OF VIOLATION INSPECflON REPORT NOS. 50-317(318)/93-03 ERP INSTRUMENT CALIllRATION AND INVENTORY I. DESCRIPTION OF VIOLATION Reference (a) indicates that we failed to maintain emergency equipment inventories and calibration in accordance with ERP Section 6.IV, thereby violating 10 CFR 50.54(q) and 10 CFR 50.47(b)(8). Specifically, according to our quarterly inventory records, during the last three quarters of 1992 and the first quarter of 1993, a total of 42 instances were documented where radiation survey equipment was found to be missing or out-of-calbration.

Also, as stated in our June 8,1992 Issue Report, there were not sufficient reserves available to replace items removed from emergency kits for repair. Further on April 8,1993, NRC review determined that an ion chamber survey instrument was missing from the emergency kicker in the Operations Support Center.

II. REASON FOR VIDIATION This violation resulted from failure to fully resolve issues identified by BG&E in June 1992 and January 1993. Closer follow-up would have showed that corrective measures taken were not effective in resolving the problem. A recent root cause analysis uncovered several training and procedural issues which when combined led to the cited condition.

Ill. CORRECIIVE STEPS TAKEN AND RESULTS ACIIIEVED )

A detailed instruction has been written on how to accomplish the calibration PM. The system for tracking instrument calibration duc dates has also been incorporated directly in -

the instruction. Training has been conducted to enhance procedural knowledge and compliance in this area. A pool of instruments is being established that will allow replacement of those out for calibration and repairs.

IV. CORRECflVE ACflONS WillCII Wil.L IIE TAKEN TO AVOID FURTilER VIOLATIONS No further action is required.

V. DATE WIIEN FULL COM PLI ANCE WILL llE ACllllNED Full compliance will be achieved upon establishment of the instrument pool. The estimated completion date is October 1,1993. 4 l

4 i

1 1

1

ATTAClIMENT (31 REPIX TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-317(3181/93-03 ERP TRAINING OF NUCLEAR ENERGY DIVISION MANAGERS

1. DESCRIPTION OF VIOLATION Reference (a) indicates that all Nuclear Energy Division (NED) Managers were not trained as both Site Emergency Coordinator (SEC) and Corporate Spokesperson in accordance with ERP, Section 3, thereby violating 10 CFR 50.5 f(q) and 10 CFR 50.47(b)(15). Specifically, none of the six NED managers were trained as both SEC and Corporate Spokesperson.

II. REASON FOR VIOLATION The violation occurred because ERPIP-904, Training, does not contain a requirement to review ERP commitments before changes are made to training for individuals listed in the Emergency Response Organization (ERO).

III. CORRECTIVE STEPS TAKEN AND RESULTS ACillEVED The referenced requirement was originally incorporated in the ERP to provide flexibility in filling key ERO positions. At the time, there were only three NED managers. Subsequent reorganization increased the number of managers to six. Additionally, the practice of training the next lower level of supenision for key ERO positions has resulted in the availability of more qualified people to fill the same number of positions. The ERP requirement does not reflect the best use of our resources in this area. The requirement to train all NED Managers as both SEC and Corporate Spokesperson was therefore deleted from the ERP on June 7,1993, following approval of a 10 CFR 50.54(q) evaluation showing that the change would not reduce the effectiveness of the plan. 1 IV. CORRECTIVE ACTIONS WillCil WILL IIE TAKEN TO AVOID FURTilER VIOLATIONS A revision will be made to ERPIP-904, Training, to include a requirement to review ERP commitments before changes are made to training for individuals listed in the ERO.

V. DATE WilEN FULL COMPLIANCE WILL llE ACIIIEVED Full compliance will be achieved by September 14,1993.

1 l

)

I 1

,