ML20154S275

Discusses Insp on 880627-0713 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount $150,000

ML20154S275
Person / Time
Site:	Calvert Cliffs
Issue date:	09/20/1988
From:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Tiernan J BALTIMORE GAS & ELECTRIC CO.
Shared Package
ML20154S279	List: ML20154S275 ML20154S288
References
EA-88-202, NUDOCS 8810050031
Download: ML20154S275 (4)

Text

. - - - - - - _ - -

September 20, 1988 Docket Nos. 50-317; 50-318 License Nos. ORP-53; OPR-69 EA 88-202 Baltimore Gas and Electric Company ATTN: Mr. J. A. Tiernan Vice President, Nuclear Energy Calvert Citf fs Nuclear Power Plant Md. Rts. 2 and 4 Post Office Box 1535 Lusby, Maryland Gentlemen:

SUBJECT:

NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES (NRC Inspection Report No. 50-317/88-17; 50-318/88-17)

This refers to the special NRC safety inspection conducted between June 27 and July 13,1933 at Calvert Cliff: Nuclear Power Plant, Units 1 and 2, to review two operational events which occurred at your facility in June and July,1988.

The report of this inspection was sent to you on July 21, 1988. The two events, both of which were identified by members of your staff and reported to the NRC,

, involved violations of technical specification limiting conditions for opera-tion (LCO). In one case, the LCO was violated in that certain technical specification limiting safety system settings were set at values less conser-vative than required. The violations are described in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty. On August 8, 1988 l an enforcement conference was conducted with you and members of your staff to discuss the violations, their causes, and your corrective action.

l The first violation involved the inoperability of one of the emergency diesel i

generators (EDG) for Unit 2, for approximately 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> in June 1988, while the reactor was at 100% power. During survet11ance testing, Operations personnel assumed a malfunction in the diesel generator's automatic voltage regulator and they placed the voltage regulator in manual mode in order to complete the test. However, the voltage regulator was not returned to the automatic mode upon completion of the test. As a result, the violation occurred in that the diesel generator was rendered inoperable because it would not successfully power essential loads as required.

The second violation involved operation of the Unit I reactor at power in July 1988 while all the variable high level and axial offset Reactor Prc,tective System instrumentation channels were inoperable for approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> because their trip setpoints were less conservative than the limiting safety system settings described in the technical specifications. The violation occurred when operations personnel noted a 5% mismatch between nuclear instrumentation (NI) power indication at 174 and reactor coolant system (RCS)

Delta T power indication at 224, and the control room operator lowered the RCS Delta T power indication to coincide with the NI power indication. This is of particular concern because prior to taking this action, the operator was OFFICIAL RECORD COPY CP PKG CALVERT CLIFFS 9/15 - 0001.0.0 09/15/88 getoosoo31 PDR eso9:0 ADOCK0500g7 N[ , ,

l 0 l t

Baltimore Gas and Electric Company  !

not aware nor made any attempt to determine which power indication was correct.  :

This adjustment was made with the supervisor's approval but without his I realizing the magnitude of the change or the effect of this change on the l limiting safety system settings, and without formal and administrative l approval of what, in fact, constituted a temporary change to a procedure.

The NRC is particularly concerned that, in each case, operations personnel  !

made changes to safety related equipment without understanding or determining  :

the effects of these changes on the operability of the equipment, and without  ;

coordinating with, or seeking assistance from, technical support personnel. .

I Furthermore, in making these changes, which were contrary to established r

procedures, operations personnel did not exhibit a proper safety attitude in  !

l that they were not sufficiently questioning or technically inquisitive while

seeking resolution of these problems. j e

1 These events raise significant questions concerning the (1) the control of .

1 operations, anu (2) the coordination and communication that exists between i

) operations and technical support personnel. Furthermore, they provide another  !

I example of a continuing NRC concern, expressed during previous SALP i j evaluations, that your staff was, at times, slow to recognize the existence of ,

potential safety issues and was not always effective in reviewing, evaluating,  !

ard resolving potential safety problems.  !

I Accordingly, a need exists for bettar control of operations at Calvert Cliffs,

) and better coordination both within the operations department and among the i departments to assure the reactors are operated safely in accordance with the  !

l the technical specifications, To emphasize these needs, I have been [

q authorized, after consultation with the Director, Office of Enforcement, and i 1 the Deputy Executive Director for Regional Operations, to issue the enclosed [

j Notice of Violation and Proposed Imposition of Civil Penalty in the amount of f

, One Hundred Fif ty Thousand Dollars (5150,000) for the violations described in [

j the enclosed Notice. In accordance with the "General Statement of Policy and

Procedure for NRC Enforcement Actions," 10 CFR Part 2. Appendix C (1988) [

t (Enforcement Policy), the violations described in the enclosed Notice have been  !

individually categorized at Severity Level !!!. l 4  ;

I Although the base civil penalty amount for a Severity Level III violation is [

l 550,000, the base civil penalty amount has been increased by 50?4 to 575,000 L in each case. With respect to the first violation, the penalty was increased

! by 50'4 because of your recent poor performance in the area of control of ,

, surveillance tests. For example, deficiencies in this area have caused (1) an  !

event in 1937 in which all four sensor channels of the recirculation actuation [

systems were inoperable for 15 minutes due to improper isolation of all four  !

4 switches during preparations for a surveillance test, sad (2) problems encountered !

4 during testing of Auxiliary Feedwater pumps which resulted in a Confirmatory i j Action Letter being issued on November 2, 1937. With respect to the second [

violation, the penalty was increased by 50*. because your staff should have known

1 of the reduced ex-core NI signals resulting from the lower leakage two year core  !

1 design. A similar situation had previously occurred at Unit 2 following the  :

1937 refueling and although your staff had been notified of the potential for  !

1 I

0FFICIAL RECORD COPY CP PKG CALVERT CLIFFS 9/15 - 0002.0.0 l 09/15/83 l 1

l 1 1

, Baltimore Gas and Electric Company T-this type of problem by the NSS$ gendor, they failed to adequately disseminate and use this information.

The other escalation and mitigat',on factors were considered and no further adjustment was considered apprcpriate.

You are required to respor,d to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your 1

response, you should document the specific actions taken and any additional l actions you plan to 9revent recurrence. After reviewing you response to this l Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliaace with NRC regulatory requirements.

In r.ccordance with Section 2.790 of the NRC's "Rules of Practice " Part 2 Title 10, Code of Federal Regulations, a copy of this letter and its enclosure veil be place in the NRC Public Document Room.

i The responses directed by this letter and the enclosed Notice are not subject j to the clearance procedures of the Office of Management and Budget as requ9eed j by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.

I

Sincerely, i

1

] 0r1~' 31 S1: nod By j

IILL*14 7. T.USOILL j William T. Russell l Regional Administrator J

Enclosure:

Notice of Violation and Proposed Imposition of Civil Penalty cc w/ encl:

M. Bowman, General Supervisor, Technical Services Engineering l T. Magette. Administrator, Nuclear Evaluations Public Document Room (POR) local public Document Room (LPOR) a Nuclear Safety Information Center (NSIC) i NRC Resident Inspector I

State of Maryland (2) l 1

I i

k l

0FFICIAL RECORD COPY CP PKG CALVERT CLIFFS 9/15 - 0003.0.0 09/15/S8 i

)

Baltimore Gas and Electric On" y bec w/ enc 1:

Region I Docket Room (witt, .a urrences)

Management Assistant, ORMA (w/o enc 1)

ORP Section Chief Robert J. Bores, ORSS SECY J. Taylor OEDRO J. Lieberman, OE J. Luehman, OE W. Russell, R!

0. Holody, RI L. Chandler, OGC Enforcement Directors, RII-!!!

Enforcement Officers, RIV-V T. Murley, NRR F. Ingram, PA J. Bradburne, CA '

E. Jordan, AE00 B. Hayes, OI S. Connelly, OIA P. Robinson, OE F. Miraglia, NRR

0. Nussbaumer, OGP/SP OE File (3 copies = ltrhd)

E00 Rdg File DCS

8. Clayton, E00 RI:E0 R RP RI:0RP RI HolodyAlb/tm/ms Tj RI:RC pp t -Viggins V Gutierrez)(

8/f,,/88 8/Ip/88 8 p/89 8/O/88 8/ /8 RI:RA R OGC OE

{ an( Russell {t) f M o[ia Chandler Lieberman

_8./- 88 h/ /88 '8 88 8/ /88 8/ /88 /

E0 - -4 - -

y p

~_

._ p 0FFICIAL REC RD COPY CP PKG CALVERT CLIFFS 9/15 - 0004.0.0 09/15/88

\u9 n v e

<lM