ML20135E551

Notice of Violation from Insp on 961130-970118.Violations Noted:Procedures Used for Spent Fuel Handling Not Appropriate to Circumstances Causing Ventilation Sys Imbalance

ML20135E551
Person / Time
Site:	Calvert Cliffs
Issue date:	02/27/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20135E550	List: ML20135E547 ML20135E551 ML20135E554
References
50-317-96-10, 50-318-96-10, NUDOCS 9703070135
Download: ML20135E551 (3)

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i ENCLOSURE 1 i

i NOTICE OF VIOLATION Baltimore Gas and Electric Company Docket / License Nos. 50-317i DPR-53 Calvert Cliffs Nuclear Power Plant 50-318; DPR-69 During an NRC inspection conducted from December 1,1996 to January 18,1997, three -

violations of NRC requirements.were identified. In accordance with NUREG-1600, l " General Statement of Policy and Procedures for NRC Enforcement Actions,", the

violations are listed below

A. 10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality be prescribed by documented procedures, of a type appropriate to the circumstances and be accomplished in accordance with these procedures. BGE accomplished spent fuel handling evolutions in accordance with procedures FH-340, " Component Movement in the Auxiliary Building", OI-25A, " Spent Fuel Handling Machine", and Ol-22D, " Fuel Handling Area Ventilation System." Calvert Cliffs Updated Safety Analysis Report, Section 9.8 stated that the limitations placed on the spent fuel pool ventilation system ensure that in the event of a fuel handling accident, all of

- the radioactive material released will be filtered through the HEPA filters and charcoal adsorber prior to discharge to the atmosphere. FH-340, Step 2.1.B stated that the controlled copy of the fuel handling procedure would be maintained in the control room when core components are being moved in the spent fuel pool.

Procedure FH-340, Attachment FH-340-1, " Spent Fuel Pool Component . i Movement," stated that the control room supervisor (CRS) would be briefed on the moves to be performed.

Contrary to the above, on January 8,9, and 10,1997, during spent fuel movements in the Calvert Cliffs spent fuel pool; L

a. The procedures used for spent fuel handling were not appropriate to the ,

circumstances in that fuel handling was performed without verification that the fuel pool ventilation systam would filter all of the radioactive material released during a fuel handling accident through charcoal adscrbers prior to discharge to the atmosphere, instead, due to ventilation sy.dem imbalance, some of the flow of air in the vicinity of the spent fuel pool was diverted to the auxiliary building ventilation system, which did not include charcoal adsorbers. i t

b. Spent fuel handling was not accomplished in accordance with procedure FH-340 in that the controlled copy of the procedure was not maintained in the control room. Instead, the controlled copy was maintained by the Nuclear Fuel Management Group.

c. Spent fuel handling was not accomplished in accordance with procedure  :

FH-340 in that a briefing between the work group and control room i supervisor (CRS) on the moves to be performed was not done, instead, a ,

briefing of the work group personnel only was conducted by nuclear fuels engineering personnel.

9703070135 970227 PDR ADOCK 05000317

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Enclosure 1 2 This is a Severity Level IV violation (Supplement 1).

B. Material License No. SNM-2505, Condition 14, requires dry shielded cask unloading operations will occur under the specifications of the Calvert Cliffs Nuclear Power l Plant operating license. The conditions of the Calvert Cliffs operating license l include 10 CFR Part 50, Appendix B, Criterion V, vn hich states that activities affecting quality be prescribed by documented procedures of a type appropriate to l

the circumstances.

l Contrary to the above, Calvert Cliffs Nuclear Power Plant Technical Procedure ISFSI-02, Rev 3, " Independent Spent Fuel Storage Installation (ISFSI) Unloading," was not appropriate in that it did not contain instructions to prevent over pres::urization of the dry shielded canister during reflood operations, prior to unloading.

i This is a Severity Level IV violation (Supplement 1).

C. 10 CFR 50, Appendix B, Criterion XVI, " Corrective Action" requires measures be established to assure that conditions adverse to quality are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures j shad assure that corrective action is taken to preclude repetition. The BGE response i letter to NRC violation 50-317/89-27 05 stated, in part, that the BGE " Electrical l Separation issue Resolution Plan" contained elements to ensure completion of objectives including the following: (1) ensure that the design documents reflect the as-built configurations; and (2) ensure that the as-built versus as-designed configurations co.Mnue to meet the criteria on a long-term bas:s.

i Contrary to the above, as of December 1,1996 corrective action as specified in BGE response letter to NRC violation 50-317/89-27-05, was not taken in that:

(1) design documents, including cable and raceway drawings, were not revised to reflect the as-built configurations for Unit 2, and (2) fourteen examples were identified where the as-built configurations did not meet design criteria and were inadequate to preclude the challenge to electrical separation resulting from damaged or missing marinite separation barriers. l This is a Severity Level IV violation (Supplement 1).

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Enclosure 1 3 I l Pursuant to the provisions of 10 CFR 2.201, Baltimore Gas & Electric Company is hereby l required to submit a written statement or explanation to the U.S. Nuclear Regulatory i Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the l Regional Administrator, Region 1, and a copy to the NRC Resident inspector, within 30 i

! days of the date of the letter transmitting this Notice. This reply should be clearly marked .t l as a " Reply to a Notice of Violation" and should includa for each violation: (1) the reason for the violation, or if contested, the basis for disputing the violation; (2) corrective action

( taken and the results achieved; (3) corrective action to be taken to avoid further violations: I and (4) the date when full compliance will be achieved. Where good cause is shown, consideration may be given to extending your response time. ,

Dated at King of Prussia, Pennsylvania this 27th day of February,1997 I

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