ML20217F142

Notice of Violations from Insp on 971221-980207.Violations Noted:From Sept 1996 to Sept 1997,BGE Tested Direct Line Notification Communication Link W/Contiguous State Local Govt Quarterly Instead of Monthly

ML20217F142
Person / Time
Site:	Calvert Cliffs
Issue date:	03/20/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20217F131	List: ML20217F125 ML20217F142 ML20217F148
References
50-317-97-08, 50-317-97-8, 50-318-97-08, 50-318-97-8, NUDOCS 9803310289
Download: ML20217F142 (4)

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I ENCLOSURE 1 NOTICE OF VIOLATION l

l Baltimore Gas and Electric Company Docket / License Nos. 50-317; DPR 53 Calvert Cliffs Nuclear Power Plant 50-318; DPR-69 During an NRC inspection conducted from December 31,1997, to Feoruary 9,1998, four violations of NRC requirements were identified. In accordance with the " Genera:

Statement of Policy and Procedures for NRC Enforcement Actions," NUREG 1600, the violations are listed below:

A. Technical Specification (TS) 3.1.3.3 requires, in part, two of the following three control eternent assembly (CEA) position indicating channels be operable for each shutdown and regulating CEA: (a) CEA voltage divider reed switch position indicator channel; (b) CEA " Full Out" or " Full In" reed switch position indicator channel; and, (c) CEA pulse counting position indicator channel.

Corstrary to the above, between January 4 and 5,1998, BGE failed to meet Technical Specification Limiting Condition for Operation 3.1.3.3 for Unit 1 when both the Control Element Assembly (CEA) voltage divider reed switch position )

indicator channel and the CEA " Full Out" reed switch position indicator channel l were inoperable, and no associated Action requirement existed.

This is a Severity Level IV violation (Supplement l--Reactor Operations). )

8. Criterion XI, Test Control, of Appendix B to 10 CFR Part 50 requires a test program be established to assure that all testing required to demonstrate that systems and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents.

Contrary to the above, as of January 6,1998:

1. BGE failed to establish a written test procedure to verify that the CEA reed i switch position indicator voltage divider network power supply voltage was i within the acceptance limit specified by the applicable design documents. '

2. BGE failed to establish a written test procedure to verify that the CEA voltage divider reed switch position indication channel was capable of determining the absolute CEA position within i1.75 inches as required by Technical Specification Limiting condition for Operation 3.1.3.3.

s This is a Severity Level IV viciation (Supplement l--Reactor Operations). l l

9803310289 980320 ,

PDR ADOCK 05000317 O PDR

r l-0 l Enclosure 1 2 i

l C. 10 CFR 50.54(q) requires licensees authorized to possess and operate a nuclear power reactor to follow and maintain in effect emergency plans which meet the ,

l standards in 10 CFR 47(b) and the requirements in Appendix E to 10 CFR Part 50. 4 Paragraph IV.E.9 of Appendix E to Part 50 requires all communication plans have arrangements for emergencies, ... these arrangements willinclude:

l a. Provision for communications with contiguous State / local

! governments within the plume exposure pathway Emergency Planning j Zone (EPZ). Such communications shall be tested monthly.

b. Provisions for communications by the licensee with NRC Headquarters and the appropriate NRC Regional Office Operations Center from the  ;

nuclear power reactor control room, the onsite technical support center, and the near-site emergency operations facility. Such communications shall be tested monthly, l Contrary to the above, from September,1996 to September 1997:

a. BGE tested the direct line notification communication link with the contiguous State / local governments quarterly instead of monthly,

b. BGE tested the Health Physics Network communication link with NRC l Headquarters and the Region i Operations Center quarterly instead of monthly.

This is a Severity Level IV violation (Supplement Vill-Emergency Preparedness (EP).

j D. 10 CFR 50.54(q) requires licensees authorized to possess and operate a nuclear l power reactor to follow and maintain in effect emergency plans which meet the

! standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part i 50.10 CFR 50.47(b)(9) requires the onsite emergency response plans for nuclear power reactors have adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency l condition.

! The Calvert Cliffs Nuclear Power Plant Emergency Response Plan (ERP)

Paragruph IV, Accident Assessment, of Chapter 4, Emergency Measures states, in part, Emergency Response Plan implementation Procedures (ERPIP) provide methods and techniques for determining radioactive material release source term.

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Enclosure 1 3 1

Contrary to the above, on January 15,1998, methods and techniques for assessing (

and monitoring actual or potential offsite consequences of a radiological emergency condition were not adequately implemented, during tabletop walkthroughs, in that two technicians functioning as interim Radiological Assessment Directors, assumed incorrect isotopic concentrations of the radioactive material release source term which resulted in non-conservative offsite dose projections.

This is a Severity Level IV violation. (Supplement Vill - Emergency Preparedness)

Pursuant to the provisions of 10 CFR 2.201, Baltimore Gas & Electric Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the

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l Regional Administrator, Region I, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for violations A, B, and D: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to I avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the  ;

correspondence adequately addresses the required responso, if an adequate reply is not i received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

The NRC has concluded that information regarding the reason for violation C above, the corrective actions taken and planned to correct the violation and prevent recurrence and the date when full compliance will be achieved is already adequately addressed on the docket in NRC Inspection Report 50-317&318/97-08. However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a " Reply to a Notice of Violation,"

and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region l, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).

If you contest this enfort,ement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 205550001.

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Enclosure 1 4 Because your response will be placed in the NRC PDR, to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is l necessary to provide an acceptable response, then please provide a bracketed copy of your j response that identifies the information that should be protected and a redacted copy of l your response that deletes such information if you request withholding of such material, i you must specifically identify the portions of your response that you seek to have withheld

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and provide in detail the bases for your claim of withholding (e.g., explain why the  ;

disclosure of information will create an unwarranted invasion of personal privacy or provide i the information required by 10 CFR 2.790(b) to support a request for withholding l confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

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Dated at King of Prussia, Pennsylvania this 20th day of March 1998.

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