ML20065R722

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Responds to Violations Noted in Insp Repts 50-317/90-27 & 50-318/90-27.Corrective Actions:Plant Log Instruction Revised to State Specific Requirements for Tracking Tech Spec Special Rept Action Statements
ML20065R722
Person / Time
Site: Calvert Cliffs  
Issue date: 12/07/1990
From: Creel G
BALTIMORE GAS & ELECTRIC CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9012190149
Download: ML20065R722 (3)


Text

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i BALTIMORE

_ OAS AND ELECTRIC CHARLES CENTER

  • P.O. BOX 1475

. GcoRot C. CRttL.

December 7,1990 VICE PM(SiOENT NVCttan ENEROT (3 01) 800-4 e SS r

U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:

Document Control Desk i

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50 318 NRC Inspection Report Nos. 50 317/90-27 and 50-318/90-27 i

Gentlemen:-

The subject Inspection Report cover letter expressed concern that we " appeared to take no actions.

as required by the Techmcal Specifications regarding three inoperable effluent monitors." Our actual deficiency was limited solely to reporting of actions taken. 'All other actions were properly

_ g taken; p'

Our response to the Notice of Violation regarding the omission ofinformation from the Semi-annual l

Radioactive Effluent Report is provided in Attachment (1). As discussed with members of your staff, 1

the response is provided 30 days after receipt of the Inspection Report.

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

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Very trulyyours, n

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GCC/JV/bjd

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- Attachment cci D. A. Brune, Esquire J. E. Silberg, Esquire R. A. Capra, NRC D. O. Mcdonald, Jr., NRC T. T. Martin,.NRC L E. Nicholson, NRC R. I. McLean, DNR

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IEC l-l9012190149 901207ADOCK 05000317 2

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A'ITACIIMENT (l)

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RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS,50 317/90 27: 50-318/90 27 STATEMENT OF V101 ATION

" Sections 3.3.3.9 (Radioactive Gaseous Efnuent Monitoring Instrumentation) and 3.3.3.10 (Radioactive Liquid Effluent Monitoring Instrumentation) of the Technical SpeciGeations require, in part, in the event the monitoring instrument becomes inoperable, that the licensee '.. exert best efforts to return the instruments to OPERABLE status within 30 days and, if unsuccessful, explain in the next Semiannual Radioactive Effluent Release Report why the inoperability was not corrected in a timely manner.'

Contrary to the above requirements, the licensee did not report or explain la the Semiannual Effluent Release Reports why inoperable ef0uent monitors (1) Unit 2 Steam Generator Blowdown Effluent Monitor (inoperable smcc August 1989), (2) Liquid Radwaste Effluent Monitor (inoperable since March 1990), and (3) Waste Gas IIoldup System Monitor (inoperable since March 1990) were not repaired in'a timely manner "

I;ACKGROUND On August 26 and 27,1989, the Unit 1 and Unit 2, respectively, Steam Generator Blowdown (SGBD) effluent Radiation Monitoring Systems (RMSs) were declared inoperable. The Unit 1 SGBD RMSs were returned to service on February 26,1990.

On' March 12,1990, the combined Units 1 and 2 Liquid Radwaste and Waste Gas Italdup System RMS? were declared inoperable. (LER 50 317/90-10).

In each case, the apprcpriate ACTION Statements o' Tennical Specifications 3.3.3.9 and 3.3.3.10 were entered and the compensatory actions taken. How ver, required entries were not made in the subsequent Semiannual Radioactive Effluent Release (SARER) Report.

j The causes of the Violation were:

The expiration of the Technical Specification 30 day ACTION requirement for making appropriate entries in the SARER Report was not tracked in the Control P.com Operators (CRO) logs.

Therefore, the administrative procedure for notifying the responsible organization was not initiated.

Neither the Compliance Unit or the Chemistry Section followed up on the information

- available to them to verify that the SARER Report requirements were met.

l CORH ECTIVE STEPS Til AT IIAVE ilEEN TAKEN:

A review of both Unit's CRO logs for the past six months determined the problem was isolated to SARER Report entries related to the SGBD, Liquid Radwaste, and Waste Gas lloldup System

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RMSs. No other Special Reports required by Technical Specification ACTION Statements were missed.'

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_ A supplement to the SARER Report was issued on October 26,1990. This supplement explained

- why the inoperability was not corrected in a timely manner, as required by Technical Specifications 3.3.3.9 and 3.3.3.10.

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61TACilMENT (1)

ItESPONSE TO NOTICE OF VIOLATION jb'SPECriON REPOllT NOS. 50-317/90-27: 50-318/90 27 Refresher training was conducted for all appropriate Compliance Unit personnel on Special Reports and the Administrative Procedures which govern Special Reports.

Operators have received clarification of requirements for CRO log tracking of Technical Specification Special Report ACrlON Staicments.

COllRECrlVE STEPS TilAT Wil.1,11E TAKEN TO AVOID FUltTilElt VIOL ATIONS:

In order to prevent recurrence,we will:

Revise the Plant Logs instruction to clearly state the specific requirement for tracking Technical Specification Special Report ACTION statements in CRO logs ; and Incorporate measures for Chemistry to review the status of equiprnent which may require inclusion in the SARER Report as part of their report preparation.

Finally, the Compliance Unit is reviewing our administrative and supporting implementing procedures to ensure that appropriate initiating mechanistri.re present for all Special Reports required by Technical Specifications.

D ATE WilEN FULI, COMPI,l ANCE WAS AClllEVED:

Full compliance was achieved October 26, 1990, when the SARER Report supplement was submitted with the information required by Technical Specifications 3.3.3.9 and 3.3.3.10.

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