05000317/FIN-2009003-00
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Finding | |
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| Title | Wide Range Noble Gas Monitor Compensatory Actions |
| Description | The inspectors identified an unresolved item (URI) associated with the compensatory actions for having the WRNGM out of service. On May 4, 2009, the Unit 2 WRNGM failed. Constellation wrote a functionality assessment to address the degraded condition of the WRNGM being out of service for greater than 7 days. The inspectors reviewed the functionality assessment and questioned the ability of operators to implement the compensatory actions stated in the assessment. Compensatory actions included taking a hand held radiation monitor measurement on the Auxiliary Building roof at a line marked 10 meters from the plant main vent. ERPIP-821, Accidental Radioactivity Release Monitoring, and Sampling Methods, gives guidance on taking the measurement and converting the radiation measurement to a release rate. The release rate is compared to the values in EAL Table A.3-1, Effluent Monitor Classification Thresholds for Effluent Monitors, and is used to calculate a dose projection which is compared to the values in EAL Table A.3-2, Dose Projection/Environment Measurement Classification Thresholds, to determine if an EAL classification threshold is met. Using the conversion factor in ERPIP-821 Attachment 1 and the information in the EAL Table A.3-1, the inspectors determined that the radiation levels on the auxiliary building roof may be too high for radiation protection technicians to take the hand held radiation monitor measurement. If the radiation levels were too high, then Constellation would not be able to implement the compensatory actions for the WRNGM being out of service. This would affect the ability of the emergency response organization (ERO) to make an appropriate EAL declaration. The inspectors determined that a design basis fuel-handling incident (FHI) at the spent fuel pool (SFP) area is the accident of most concern because there are no redundant EAL initiating conditions higher than an ALERT declaration. Therefore, the ERO would have to rely upon dose projection calculations to determine if the EAL declaration would need to be escalated and/or for the appropriate EAL classification to be declared. Interim corrective actions include an installed portable monitor with remote monitoring capabilities to perform the initial dose assessment when the WRNGM is out of service. This item is unresolved pending further review and investigation of the re-analysis such that the inspectors can determine if there is a performance deficiency associated with this issue. The inspectors need to review Constellations conversion factor used in ERPIP-821 and the conversion factor used in any re-analysis to determine if Constellation has adequate methods and equipment in place for assessing and monitoring a design basis FHI at the SFP area when the WRNGM is out of service |
| Site: | Calvert Cliffs  |
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| Report | IR 05000317/2009003 Section 1R15 |
| Date counted | Jun 30, 2009 (2009Q2) |
| Type: | URI: |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.15 |
| Inspectors (proximate) | D Silk M Davis K Young D Johnson S Barr G Dentel N Perry R Rolph J Hawkinsg Dentels Kennedy R Rolph K Mangan M Davis |
| INPO aspect | |
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Finding - Calvert Cliffs - IR 05000317/2009003 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Calvert Cliffs) @ 2009Q2
Self-Identified List (Calvert Cliffs)
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