ML20151V963
| ML20151V963 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 09/02/1998 |
| From: | Conte R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| References | |
| 50-317-98-04, 50-317-98-4, 50-318-98-04, 50-318-98-4, EA-98-225, NUDOCS 9809150117 | |
| Download: ML20151V963 (3) | |
See also: IR 05000317/1998004
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September 2, 1998
EA 98-225
Mr. Charles H. Cruse
Vice President - Nuclear Energy
Baltimore Gas and Electric Company (BG&E) -
Calvert Cliffs Nuclear Power Plant (CCNPP) ;
1650 Calvert Cliffs Parkway I
Lusby, MD 20657-4702
SUBJECT: CALVERT CLIFFS INSPECTION REPORT NCS. 60-317/98-04
AND 50-318/98-04(REPLY)
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Dear Mr. Cruse: '
This letter refers to your July 15,1998 correspondence, in response to our notice of
violation dated June 15,1998 and our integrated inspection report dated May 1,1998.
This inspection focused on the maintenance rule baseline program (March 30,1998 to
April 3,1998) at the Calvert Cliffs Nuclear Power Plant, Lusby, Maryland. In addition, on
May 27,1998, a predecisional enforcement conference was conducted with you and
members of your staff to discuss the violations identified during the inspection, the causes,
and your corrective actions. We have reviewed this matter in accordance with NRC
Inspection Manual Procedure 92902," Maintenance." We concur with your assessment of
the root causes and corrective actions as summarized below.
The first violation involved permitting the containment spray system to remain under
10 CFR 50.65(a)(2) following a repetitive functional failure when preventative maintenance \
failed to assure that this system remained capable of performing its intended function. The p 4
cause involved an error in a computer program used to identify repetitive functional failures I
and in the lack of attention to detail by reviewing personnel. The corrective actions were j
focused on resolving the software problem and change in the maintenance rule (MR) i
program to empower and make the system managers responsible for identifying functional
failures as well as repetitive functional failures.
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The second violation permitted a number of structures, systems, and components (SSCs) <
within the scope of the Maintenance Rule (i.e., auxiliary feedwater,4KV electrical 0s
distribution, instrument air system air amplifier, hydrogen recombiner and hydrogen
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analyzer systems) to remain under 10 CFR 50.65(a)(2) when preventative maintenance l
failed to assure that these SSCs remained capable of performing their intended function.
The causes of this violation involved multiple problems in your MR review process, which
included weak understanding by system managers. For example, your program placed a
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heavy reliance on a single performance indicator that included both reliability and
- unavailability (i.e., reliability index) that made it difficult to determine the impact of a failure 3
- or unavailability on the (a)(1) status of an SSC. The corrective actions taken replaced the ;
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reliability inCsx with individual reliability and unavailability indicators and revised processes, j
i which included empowering the system managers to identify functional failures and to ,
evaluate performance criteria for their systems as required. 1
9909150117 980902
PDR ADOCK 05000317
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The third violation involved failure to establish performance measures for the emergency
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diesel generator building heating, ventilation, and air conditioning system and to effectively
l demonstrate the system remained capable of performing its intended function. The causes
were: a formal tie had not been established between the plant modification process and
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the MR program; and an oversight due to multiple ownership of responsibilities within the
MR program. The corrective actions included a revision to the plant modification procedure
(EN-1-100) as well as changes in responsibilities in your MR program.
The fourth violation involved a failure to include the portion of the emergency lighting
i located outside the control room, which is required for safe shutdown of the plant, in the
! scope of the Maintenance Rule program. The cause was an error in BG&E's original
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interpretation of the MR scoping which did not support inclusion of the entire emergency
lighting system. The corrective action revised the MR scoping document to incorporate
this portion of emergency lighting not formerly included within the MR scope. l
l The effectiveness of your corrective actions will be reviewed in a future inspection. We
appreciate your cooperation.
Sincerely,
ORIGINAL SIGNED BY:
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Richard J. Conte, Chief
Operator Licensing and
Human Performance Branch
Division of Reactor Safety
Docket / License Nos: 50-317/DPR-53
50-318/DPR-69
cc w/encis:
T. Pritchett, Director, Nuclear Regulatory Matters (CCNPP)
R. McLean, Administrator, Nuclear Evaluations
J. Walter, Engineering Division, Public Service Commission of Maryland
K. Burger, Esquire, Maryland People's Counsel
R. Ochs, Maryland Safe Energy Coalition
i State of Maryland (2)
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Distribution w/ encl: ,
Nuclear Safety Information Center (NSIC)
PUBLIC
NRC Resident inspector
Region i Docket Room (with concurrences)
D. Holody, ORA
R. Conte, DRS
J. Caruso, DRS
S. Dennis, DRS
L. Doorflein, DRP
R. Junod, DRP
K. Kennedy, RI EDO Coordinator
R. Zimmerman, ADPR, NRR l
F. Davis, OGC
A. Nicosia, OGC
J. Lieberman, OE (OEMAIL)
D. Nelson, OE
T. Walker, ORA
S. Bajwa, NRR
A. Dromerick, NRR
M. Campion, RI
Inspection Program Branch, NRR (IPAS)
R. Correia, NRR ]
R. Latta, NRR
R. Prato, NRR
J.D. Wilcox, NRR
DOCDESK
DRS File
Distribution w/ encl: (Via E-Mail)
W. Cook, DRP
J. Stewart, SRI - Calvert Cliffs
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DOCUMENT NAME: G:\OLHP\CARUSO\CC9804. REP
T3 receive a copy of this M .;,i. Indicato in the bom "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure T = No
copy /
l OFFICE . Rl/DRS o /l Rl/DRS y/ 47 gja ln l l !
l NAME JCaruso /',W RCont("7 L, .Omg4JL
DATE 09/02/9'8 <fV 09/l198 ' 9/ t /9 y *
- OFFICIAL RECORD COPY !
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CHARLES II. CRUSE Baltimore Gas and Electric Company
Vice President Calvert Cliffs Nuclear Power Plant
Nuclear Energy 1650 Calvert Cliffs Parkway
Lusby, Maryland 20657
, 410 495-4455
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July 15,1998
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
Reply to a Notice of Violation -- Notice of Violation (NRC Inspection Report
< Nos. 50-317/98-04 and 50-318/98-04)
REFERENCES: (a) Letter from Mr. J. T. Wiggins (NRC) to Mr. C. H. Cruse (BGE), dated
June 15, 1998, Notice of Violation (NRC Inspection Report
Nos. 50-317/98-04 and 50-318/98-04)
(b) Letter from Mr. J. T. Wiggins (NRC) to Mr. C. H. Cruse (BGE), dated
May 1,1998, NRC Region 1 Maintenance Rule Team Inspection Report
Nos. 50-317/98-04 and 50-318/98-04
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This letter provides Baltimore Gas and Electric Company's response to Reference (a), which identified
four violations. The violations cited have been addressed as specified in the Enclosure to Reference (a).
The responses to these violations are provided in Attachments (1) through (4). The corrective actions in
this letter were discussed at the Predecisional Enforcement Conference held in response to Reference (b).
In order to assure continued management support and oversight of the Maintenance Rule Program, I have
instituted additional monitoring and reporting. In addition to the monthly system reports, a specific
report to plant management will be made relative to the Maintenance Rule Plant Level indicators.
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July 15,1998
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Should you have questions regarding this matter, we will be pleased to discuss them with you.
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Very truly your's, ,
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C. H. Cruse
Vice President - Nuclear Energy
CHC/KRE/ dim
Attachments: (1) Response to NRC Inspection Report Nos. 50-317/98-04 and 50-318/98-04 --
Violation Al
(2) Response to NRC Inspection Report Nos. 50-317/98-04 and 50-318/98-04 --
Violation A2
(3) Response to NRC Inspection Report Nos. 50-317/98-04 and 50-318/98-04 --
Violation B
(4) Response to NRC Inspection Report Nos. 56117/98-04 and 50-318/98-04 --
Violation C
cc: R. S. Fleishman, Esquire Resident inspector,NRC
J. E. Silberg, Esquire R. I. McLean, DNR
S. S. Bajwa, NRC J. H. Walter, PSC
A. W. Dromerick, NRC J. T. Wiggins, NRC
H. J. Miller, NRC
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ATTACHMENT (1)
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RESPONSE TO NRC INSPECTION REPORT
NOS. 50-317/98-04 & 50-318/98-04
VIOLATION A1
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Baltimore Gas and Electric Company
Calvert Cliffs Nuclear Power Plant
July 15,1998
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ATTACHMENT (1)
RESPONSE TO NRC INSPECTION REPORT NOS. 50-317/98-04 AND 50-318/98-04
VIOLATION A1
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10 CFR 50.65(a)(1) requires, in part, the holders of an operating license shall monitor the performance
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or condition ofSSCs [ systems, structures, and components] within the scope of the monitoring program
as defined in 10 CFR 50.65(b) against licensee-established goals, in a manner sufficient to provide
reasonable assurance that such SSCs are capable offulfilling their intendedfunctions. Su~ch goals shall
be establishedcommensurate with safety. When the performance or condition ofan SSC does not meet
established goals, appropriate corrective action shall be taken.
10 CFR 50.65(a)(2) requires, in part, that monitoring as specified in 10 CFR 50.65 (a)(1) is not required
where it has been demonstrated that the performance or condition of an SSC is being effectively
controlled by performing appropriate preventive maintenance, such that the SSC remains capable of
performing its intendedfunction.
Contrary to the above, the licensee permitted a number ofSSCs within the scope ofthe Maintenance Rule .
to remain under 10 CFR 50.65(a)(2) when preventive maintenance failed to assure that these SSCs !
remained capable ofperforming their intendedfunction, as evidenced by thefollowing examples, each of
which constitutes a separate violation: '
1. On July 10, 1996, the licensee elected to place the containment spray system under
Section 50.65(a)(2). Followisg a repetitive functionalfailure, identified by the NRC, which
occurred in March 1997, the licensee incorrectly allowed this system to remain under 10 CFR
50.65(a)(2). The repetitivefunctionalfailure demonstrated that thepreventive maintenance being
performed on this system was na appropriate in that itfailed to assure that the system remained
capable ofperforming its intendedf:<nction. The system should have been placed under 10 CFR
50.65(a)(1)following Ihe repetitivefailwe.
I. ADMISSION OR DENIAL OF THE AII FGED VIOLATION j
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Baltimore Gas and Electric Company accepts the violation as stated. /
II. REASON FOR THE VIOLATION
Part of the Maintenance Rule (MR) Baseline Inspection focused on the identification of repetitive
functional failures of plant equipment within the scope of the MR. During this review, it was identified
that a repetitive functional failure of Unit 2 Containment Spray Check Valve SI-330 had occurred.
However, this system was not identified as part of the Calvert Cliffs MR Plant Level Indicators. The
failure of 2-SI-330 occurred on March 24,1995, and March 19,1997.
At Calvert Cliffs Nuclear Power Plant, repetitive functional failures are one eleme it of the MR Plant
Level Indicators. Repetitive functional failures are defined as two functional fara es occurring to the
same device type, within a 24-month period that have the same MR Cause Cod.:, taid the same failure
mode.
During the review of the methodology used to identify repetitive functiona', failures, two errors were
detected in the methodology as follows:
- When identifying repetitive functional failures, the date of occurrence should be used as a
screening criteria; however, the out-of-service date was used in the search program; and
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ATTACHMENT (1)
RESPONSE TO NRC INSPECTION REPORT NOS. 50-317/98-04 AND 50-318/98-04
VIOLATION A1
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- The search period was limited to 24 months.
The definition for repetitive functional failures includes "date of occurfence." Neither the originator nor
the reviewer identified the difference between the equipment out-of-service date and the date of
occurrence. This error was caused by a lack of attention to detail by both the originator and reviewer.
Use of a 24-month time frame also contributed to the error in not identifying the repetitive functional
failure. The causes of this error are that the person performing the search did not recognize the error in
using 24 months vice 25, and the search program development was not independently reviewed.
III. CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACIHEVED
The software for identifying repetitive functional failures has been revised to use the date of discovery of
a functional failure. Validation testing has been performed on the new software to verify that it correctly
identifies all repetitive functional failures. The results of the validation testing have been documented
and independently reviewed. The site MR Program was revised to include the System Manager in the
identification of functional failures as well as repetitive functional failures.
IV. CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER
VIOLATIONS
No additional corrective actions are necessary beyond those already taken.
V. DATE WHEN FULL COMPLIANCE WILL BE ACIHEVED
Full compliance was achieved on May 27,1998, with the issuance of the procedure Managing System
Performance (MN-1-112), Revision 3.
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RESPONSE TO NRC INSPECTION REPORT
NOS. 50-317/98-04 & 50-318/98-04
VIOLATION A2
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Baltimore Gas and EIcetric Company
Calvert Cliffs Nuclear Power Plant
July 15,1998
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ATTACHMENT (2)
RESPONSE TO N'RC INSPECTION REPORT NOS. 50-317/98-04 AND 50-318/98-04
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VIOLATION A2 l
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10 CFR 50.65(a)(1) requires, in part, the holders of an operating license shall monitor the performance
or condition ofSSCs within the scope of the monitoringprogram as defwed in 10 CFR 50.65(b) against ,
l licensee-established goals, in a manner suficient to provide reasonable assurance that such SSCs are '
l capable offulfilling their intendedfunctions. Such goals shall be established commensurite with safety.
When the performance or condition of an SSC does not meet established goals, appropriate corrective
action shallbe taken.
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10 CFR 50.65(a)(2) requires, in part, that monitoring as specified in 10 CFR 50.65 (a)(1) is not required
where it has been demonstrated that the performance or condition of an SSC is being effectively
controlled by performing appropriate preventive maintenance, such that the SSC remains capable of
performing its intendedfunction.
l Contrary to the above, the licensee permitted a number ofSSCs within the scope ofthe Maintenance Rule
to remain under 10 CFR 50.65(a)(2) when preventive maintenance failed to assure that these SSCs I
- remained capable ofperforming their intendedfunction, as evidenced by thefollowing examples, each of
which constitutes a separate violation:
2. On July 10,1996, the licensee elected to place the 4KV electrical distribution bus, instrument air
system air amphfier, hydrogen recombiner, hydrogen analper and auxiliaryfeed water systems
under Section 50.65(a)(2). Following repetitivefunctionalfailures and/cr excess unavailability
l times, the licensee incorrectly allowed the systems to remain under 10 CFR 50.65(a)(2) for
excessiveperiods oftime rangingfrom three months to 1.5 years. The repetitivefunctionalfalhares
and/or excess unavailability times demonstrated that the preventive maintenance beingperformed
on these systems was not appropriate in that itfailed to assure that the systems remained capable l
ofperforming their intendedfunctions. The systems should have been placed under 10 CFR j
50.65(a)(1) in a timely manner commensurate with safety following the repetitive functional l
failures and/or excess unavailability times. j
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I. ADMISSION OR DENIAL OF THE AII EGED VIOLATION
Baltimore Gas and Electric company accepts the violation as stated.
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II. REASON FOR THE VIOLATION
The causes of this violation are as follows:
A. The site Maintenance Rule Coordinator (MRC) failed to generate an Issue Report to classify
l SSCs as (a)(1) due to repetitive functional failures. The MRC is responsible for evaluating the
! results and designating SSCs as (a)(1).
l B. The process used to capture functional failures for updating MR performance indicator ,
i delayed identification of (a)(1) performance. The original process develor .1 %r MR
implementation relied exclusively on the performance indicators ~ for < 2)(1)/(a)(2)
i determinations. System Managers were not expected to identify SSCs for (a)(1) status by any
other means then their system level performance indicators.
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ATTACHMENT (2)
RESPONSE TO NRC INSPECTION REPORT NOS. 50-317/98-04 AND 50-318/98-04
l VIOLATION A2
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The process for capturing failures relied on a maintenance order review by the Reliability
Engineering Unit following close-out of the maintenance order. In many instances, a
maintenance order would remain open for extended periods, which would delay including the
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failures in the performance indicators.
C. System Managers did not understand the relationship between system performance and system
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level performance indicators. The initial performance indicators developed for the MR used a >
l single indicator that included both reliability and unavailability. With this indicator, it was
difficult to determine the impact of a failure or unavailability on the (a)(1)/(a)(2) status of an
SSC.
D. The (a)(1) classification process relied on the publishing of the quarterly performance
indicators to make the (aXI)/(aX2) determination. As stated earlier, it was difficult to
determine the impact of failures or unavailability on the Reliability Index. The MR process
used at the time, directed the System Managers to evaluate their systems for (a)(1) based on the
performance indicators, not their assessment of system performance.
III. CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED
All SSCs identified as remaining in (aX2) status when they should have been considered (aXI) were
placed in (aXI) prior to the NRC inspection of our MR Program. As part of the replacement of the
Reliability Index with individual reliability and unavailability indicators, all scoped SSCs were reviewed
for(a)(1) status.
Two SSCs, the Main Steam Safety Valves and the Pressurizer Heater Sleeves, were designated (a)(1)
during the 1998 Refueling Outage while the process changes were being made. In both cases, the
System Manager designated the SSC as (aX1) within one week of the event that challenged the system
performance criteria. Once System Mangers were made aware of the new expectations, they were easily
able to implement the changes.
The MR implementation pmcedure, MN-1-112, has been revised to provide System Managers with
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additional guidance for failure and unavailability review. System Managers are now instructed to
evaluate their systems for (a)(1) anytime an event occurs that may challenge the performance criteria.
Failures are now identified by the System Manager for inclusion in the next quarterly performance
indicator report. All repetitive functional failures have been reviewed.
He Reliability Index has been replaced with separate reliability and unavailability indicators. In
addition, the requirement to write an Issue Report when a performance criteria is exceeded has been
reinforced with all System Managers.
IV CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER
VIOLATIONS
No additional corrective actions are necessary beyond those already taken.
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A'ITACHMENT (2)
RESPONSE TO NRC INSPECTION REPORT NOS. 50-317/98-04 AND 50-318/98-04
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VIOLATION A2
V. DATE WHEN FULL COMPLIANCE WII T. BE ACHIEVED'
Full compliance was achieved on July 10, 1998, with the completion of the review of all current
repetitive functional failures. .
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ATTACHMENT (3)
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RESPONSE TO NRC INSPECfION REPORT
NOS. 50-317/98-04 & 50-318/98-04
VIOLATION B
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Baltimore Gas and Electric Company
Calvert Cliffs Nuclear Power PInnt l
July 15,1998 ,
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ATTACHMENT (3)
RESPONSE TO NRC INSPECTION REPORT NOS. 50-317/98-04 AND 50-31P/98-04
VIOLATION B
10 CFR 50.6S(a)(1) requires, in part, that holders ofan operating license 'shall monitor the performance
or condition of SSCs, within the scope of the monitoring program, as defined by 10 CFR$0.6S(b),
l against licensee-established goals, in a manner sufficient to provide rreasonable assurance that such
SSCs are capable offulfilling their intendedfunctions. Such goals shall be established commensurate
with safety and, where practical, take into account industry-wide operating experience. When the
performance or condition ofa SSC does not meet established goals, appropriate corrective action shall
be taken.
10 CFR SO.6S(a)(2), requires, in part, that the monitoring as specified in 10 CFR S0.6S(a)(1) is not
required where it has been demonstrated that the performance or condition of a SSC is being effectively
controlled by performing appropriate preventive maintenance, such that the SSC remains capable of
l performing its intendedfunction.
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Contrary to 10 CFR 50.6S(a)(2), as ofJuly 10,1996, the time that the licensee elected to not monitor the
performance or condition of the emergency diesel generator building heating, ventilation and air
conditioning system against establishedgoals pursuant to the requirements ofSection (a)(1), the licensee
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failed to demonstrate that the performance or condition ofSSCs within the scope of10 CFR 50.65 had
been efectively controlled byperforming appropriate preventive maintenance. Specifically, the licensee
hadfailed to establish performance measuresfor the system and was therefore unable to efectively
demonstrate the system remained capable ofperforming its intendedfunction. l
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I. ADMISSION OR DENIAL OF THE ATLFGED VIOLATION
Baltimore Gas and Electric Company accepts the violation as stated. l
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H. REASON FOR THE VIOLATION
The Emergency Diesel Generator (EDG) Heating, Ventilation, and Air Conditioning (HVAC) System
was added as part of a plant modification to install additional EDGs. This project was completed and
became operational in the spring of 1997. This system was not part of the plant design when the original
MR scoping work was completed. As part of the scoping process, informal methods were established to l
periodically review site documents for changes that would require an update to the MR scoping
document. This included changes to Emergency Operating Procedures, Quality List, and plant-
modifications. The EDG HVAC_Syst_em was included in the scope of the,MR as part of. Revision 3 to the '
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MR scope document, which was issued _SeptemWr~30,1997._ At this time, the MR scoping document
was controlled'brthiFEif~e Cycle Management Unit, which only had responsibility to maintain the
scoping document. The Reliability Engineering Unit was responsible for developing performance
criteria for risk-significant SSCs. Reliability Engineering developed performance criteria for one of the
new EDGs (No. IA) using the Reliability Index that included the HVAC System. The other diesel
generator (No.0C) was monitored by separate unavailability and reliability indicators for the EDG.
Separate indicators were not developed for the new EDG HVAC System.
There are two causes for our failure to develop specific SSC level performance indicators for this system.
A formal tie was not established with the modification _ process t.o review modifications during close-out
for chaliges to the MR Program._Wjth a formal process in place, the MR scoping document would have
l been updatedTo5n n afier the EDG HVAC System had been placed in service. The second cause involves
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ATTACHMENT (3)
RESPONSE TO NRC INSPECTION REPORT NOS. 50-317/98-04 AND 50-318/98-04
VIOLATION B
multiple ownership of responsibilities with the MR Program. Life Cycl'c Management maintained the
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sc5pe~d6cQniinr EiidTliibilitjrEngineering~developidVrformance indicators. No one had
responsibility to ensure that the performance indicators developed were in alignment with the MR
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scoping document. -
III. CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED
The MR scoping document was revised to explicitly define the functions of concern for the EDG HVAC ,
System. This was done as part of our MR scoping document review of all SSCs. In addition,
performance criteria were developed and published in the first quarter 1998 MR performance indicator
i report. As a result of the performance indicator development, the EDG HVAC System has been
l classified as (a)(2) under the MR Program.
A change has been made to the site modification procedure (EN-1-100) to include notification of the
MRC in the cl6se-out process. TliisifiV61vera-formal revi6Hfihe modification to capture any changes
to the MR Program. In addition, ownership offie MRscoping document ha= haan givenlo_theliRC. It
is now the responsibility of the MRC, working with the System Managers, to ensure that all SSCs have
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adequate performance indicat 3rs established.
IV. CORRECTIVE STEPS THAT WILI BE TAKEN TO AVOID FURTHER
VIOLATIONS
No additional corrective actions are necessary beyond those already taken.
V. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
Full compliance was achieved on_May 12,1998 with the issuance of the new EDG HVAC performance
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criteria.
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ATTACHMENT (4)
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RESPONSE TO NRC INSPECTION REPORT
NOS. 50-317/98-04 & 50-318/98-04
VIOLATION C
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Baltimore Gas and Electric Company
Calvert Cliffs Nuclear Power Plant
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ATTACIIMENT (4)
RESPONSE TO NRC INSPECTION REPORT NOS. 50-317/98-04 AND 50-318/98-04
VIOLATION C
l 10 CFR 50.65(a)(1) requires, in part, that the holders of an operating license shall monitor the
performance or condition of SSCs within the scope of the rule as defined by 10 CFR 50.65(b) against
licensee-established goals, in a manner sufficient to provide reasonable assurance that such SSCs are
capable offulfilling their intendedfunctions. Such goals shall be established commensurale with safety.
When the performance or condition of an SSC does not meet established goals, appropriate corrective
action shallbe taken.
10 CFR 50.65(b)(1) requires, in part, that the holders of an operating license shall include within the
scope of the monitoring program specified in 10 CFR 50.65(a)(1), safety-related SSCs that are relied
upon to remainfunctional during andfollowing design basis events to ensure the integrity of the reactor
coolant pressure boundary, the capability to shut down the reactor and maintain it in a safe shutdown
condition, and the capability to prevent or mitigate the consequences of accidents that could result in
potential offsite exposure comparable to the 10 CFR Part 100 guidelines. The scope shall also include.
non-safety related structures, systems, or components that are relied upon to mitigate accidents or
transients, or are used in the plant emergency operating procedures, or whose failure could prevent
safety-related structures, systems, and componentsfromfulfilling their safety-relatedfunction, or whose
failure could cause a reactor scram or actuation ofa safety-relatedsystem.
Contrary to the above, as of July 1997, the licensee hadfailed to include within the scope of the
Maintenance Rule program the portion of the emergency lighting system located outside the control
room, which is requiredfor safe shutdown ofthe plant.
I. ADMISSION OR DENIAL OF THE ALI FGED VIOLATION
Baltimore Gas and Electric Company accepts the violation as stated.
II. REASON FOR THE VIOLATION
Baltimore Gas and Electric Company's interpretation of the MR scoping criteria did not support
inclusion of the entire Emergency Lighting System. We included the safety-related portions based on the
MR scoping criteria, but did not originally feel the 10 CFR Part 50, Appendix R, ponion outside the
Control Room proviled a significant contribution to successful completion of emergency operating
procedure activities. In addition, alternative means are available for illumination in plant areas. (hand-
carried flashlights) A review of several NRC baseline inspections and Regulatory Guide 1.160,
Revision 2, indicated that our conclusions differed from the NRC's.
III. CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACIHEVED
Baltimore Gas and Electric Company made the decision in June 1997 to include additional portions of
the Emergency Lighting System within the scope of the MR. The revised MR scoping document was
issued on September 30,1997 to incorporate this change.
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During the MR scoping document review and new performance indicator development, a broader
interpretation of the MR scoping criteria was used. Additionally, if there is any question as to whether
an SSC should be in the scope of the MR, the decision will be referred to the MR Expert Panel for
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resolution.
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ATTACIIMENT (4)
RESPONSE TO NRC INSPECTION REPORT NOS. 50-317/98-04 AND 50-318/98-04
VIOLATION C j
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IV. CORRECTIVE STEPS THAT WILL BE TAKEN '
TO AVOI$ FURTHER
VIOLATIONS ,
No additional corrective actions are necessary beyond those already taken. h
V. DATE WHEN FUIL COMPLIANCE WILL BE ACHIEVED l
Full compliance was achieved on September 30,1997, with the inclusion of emergency lights in the
scope of the MR.
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