IR 05000317/1979024
| ML19312A381 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 02/07/1980 |
| From: | Bores R, Kottan J, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19309C230 | List: |
| References | |
| 50-317-79-24, 50-318-79-23, NUDOCS 8004080352 | |
| Download: ML19312A381 (8) | |
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nU U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT 9 "
50-317/79-24 Report No. 50-318/79-23 50-317 Docket No. 50-318 DPR-53 C
C License No. OPR-69 Priority '
Category
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Licensee:
Baltimore Gas and Electric Company (BG&E)
Charles Center Baltimore, Maryland 21203 Facility Name:
Calvert Cliffs Nuclear Power Plant (CC), Units 1 & 2 Inspection at:
Calvert Cliffs Site, Lusby, Maryland Inspection conducted: December 10-11, 1979 Inspectors: [
2 /7 [80 R. M. Shadbaky7 Radiation Specialist date signed
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A/? /10 J. J. Kot[n, Radiation Specialist date signed
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Approved by:
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O R. J. Boref, Chief, Environmental and date signed Special Projects Section, FF&MS Branch Inspection Summary:
Inspection on December 10-11, 1979 (Combined Report No. 50-317/79-24 and 50-318/79-23)
Areas Inspected:
Special, announced inspection of the make-up and condensate demineralizer system operations and associated nonradiological discharges at CC Units 1 and 2.
The inspection involved 28 inspector-hours onsite by two regionally based NRC inspectors.
Subsequent to the inspection an Enforcement Meeting was held on November 29,1979 at the NRC Region I Office.
Results:
One item of noncompliance was identified (Infraction - Exceeding the plant discharge limiting condition for operation for pH - paragraph 3) in this area.
Region I Form 12 (Rev. April 77)
80040 % W
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DETAILS 1.
Individuals Contacted
- L. B. Russell, Chief Engineer
- R. E. Denton, Nuclear Plant Engineer
- S. M. Davis, Performance Engineer J. Carroll, Supervisor Technical Support
- R. F. Eherts, Performance Engineer B. Perrott, Water Treatment Specialist M. Bowman, Supervisor, QA Audit Unit B. R. White, Plant Operator W. Putman, Principal Technician, Rad. Chem.
M. Quade, Operator Trainee
- denotes those present at the exit interview on December 10, 1979.
2.
General The make-up water and condensate demineralizer systems are located at elevation +12 in the service building.
These systems are part of the water treatment plant. The water demineralizers are cation, anion and mixed-bed ion-exchange resin types. Acid (H S0 ) and 2 3 caustic (NaOH) are used to regenerate the ion exchange relin.
The waste solution produced from the regeneration process is pumped to one of two neutralizing tanks located at the plant yard.
The CC Environmental Technical Specifications (ETS) require that the demineralizer regeneration-produced waste solution be neutralized to obtain a pH in the range of 6.0-9.0 prior to release into the circulating water discharge.
Inadequacies in the system design, maintenance and operations were identified by the NRC and by the licenseee throughout the operational history of the system. On repeated occasions, since the initial plant operation, these inadequacies resulted in the release of sulfuric acid, sodium hydroxide or waste solution with a pH outside the required range.
3.
System Operation The inspector examined the make-up water and condensate demineralizer systems and detennined that several of the system components, including the acid and caustic day tanks, the acid and caustic
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pumps and system piping were corroded.
The concrete slab under the day tank showed corrosion.
The licensee stated that system corrosion has resulted from minor acid or caustic leaks from the pumps, piping and tanks. The liquid leaks or spills at the water treatment plant were collected into the service water building sump which discharges to the Chesapeake Bay.
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The inspector discussed with the licensee the current system condition including industrial and environmental hazards of acid and caustic spills.
The licensee stated that the water treatment plant system is a high maintenance system because of the corrosive nature of the chemicals used and the high frequency of deminerali7er regeneration.
The licensee stated that some system maintenance was performed, however, a substantial system maintenance request was submitted to plant management on April 9,1979 and was approved on October 26, 1979. The inspector reviewed a copy of the proposed system maintenance and upgrading and noted that replacement of the corroded components, including pumps, valves, pipes, controls and concrete slab was requested.
The licensee stated that the proposed system maintenance and upgrading ard currently being reviewed by BG&E engineers in Bal timore.
The inspector stated that this area is considered unresolved (317/79-24-01; 318/79-23-01), pending completion of all the required system maintenance and modifications to ensure that potential for acid / caustic spills or leaks is minimized (paragraph 7.0).
The inspector examined the neutralizing tanks (No.11 and 12) and
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determined that the tanks were not provided with high tank level alarms; nor with catch basins to contain tank leaks or overflows and to prevent the release of unneutralized waste solution to the Chesapeake Bay.
Tank No.12 was not provided with hard-piping for dilution and fire hoses were used to dilute the tank contents.
The inspector observed signs of what appeared to be residues from spills, leaks or tank overflows in the area surrounding tanks No.
11 and 12.
The licensee stated that no leaks had occurred from tank No.11 since the tank lining was installed and the source of the observed salt on the ground was mainly from a tank No.12 overflow which had occurred on November 29, 1979.
That tank overflow resulted in the release of 8,400 gallons of caustic solution (pH 12.1) to the yard drain which was subsequently discharged to the Chesapeake Bay.
The inspector determined, through review of licensee's records and interview of licensee's personnel, that this uncontrolled discharge of caustic solution had occurred as a result of operator inattention to the tank level indicator at the water treatment plant in the service building. The inspector stated
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failure to adhere.to ETS Section 2.2, pH Limiting Condition for Operation (LCO),was an item of noncompliance (317/79-24-02; 318/79-23-02).
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4.
Managenent Controls The inspector reviewed the licensee's management controls as related to the operation of the plant water treatment system including the neutralization of the demineralizer regeneration waste solution.
Areas reviewed included the following:
a.
Assignment of Responsibility The inspector determined, through discussions with the licensee management and interview of personnel, that the water treatment system operations are assigned to the plant service building operators and the outside operators.
These individuals are usually the most junior members on the plant operation staff.
The licensee stated that during 1978, one of the plant operators was assigned the responsibility of operating the water treat-ment plant on a routine basis.
This individual will become the water treatment plant specialist and with responsibility to maintain compliance with the ETS in this area.
The service building and the outside operators report to the senior plant operator.
The neutralizing tank operation was coordinated by the service building and the outside operator.
The inspector discussed with the licensee the apparent lack of communication between the service building operator and the outside operators, particularly during shift change periods.
The licensee stated that both the neutralizing tanks and the water treatment plant locations were provided with a paging system which was used by the water treatment plant and the outside operators. The licensee stated that communications between the outside and water treatment plant operators during shift changes will be evaluated.
The inspector stated that until this area is evaluated and actions are taken to ensure adequate communication during shift change, this item is considered unresolved (317/79-24-03; 318/79-23-03).
b.
Procedures The inspector reviewed the licensee's procedures for operation of the waste neutralizing system (0I-23D), demineralized water system (0I-238), and condensate demineralizer system (0I-11C).
The inspector noted that several revisions of these procedures were made by the licensee in an attempt to upgrade these procedures.
The inspector discussed with the licensee the procedural changes needed upon completion of the pending water treatment plant modifications.
The licensee stated that all the new modifications which could impact on the water treatment system operation will be included in a new revision of the (
procedures.
This area is considered unresolved pending review i
of these procedures (317/79-24-04; 318/79-23-04).
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c.
Training The inspector reviewed a sample of the training records for individuals involved in the operation of the water treatment system. The inspector determined that individuals involved in the operation of the water treatment system are the most junior operators and had minimal training. The licensee stated that this area will be evaluated and training will be upgraded.
d.
Audi ts The inspector reviewed the licensee's audits of the water treatment plant operation including those performed during June 1979 and September 1977.
The inspector determined that the licensee's audits in this area were shallow in nature and were inadequate to identify problems and correct the repeated noncompliance items related to the waste neutralization and discharge.
The licensee stated that since the water treatment system is a nonsafety related system, minimal effort was devoted to audits in this area, however, as a result of the repeated items of noncompliance in this area a comprehensive audit of the water treatment plant operation including waste neutralization and discharges will be conducted.
5.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations.
Unresolved items disclosed during this inspection are discussed in paragraphs 3, 4a and 4b.
6.
Exit Interview The inspector met with the licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on December 11, 1979 at the CC 1 & 2 site.
The inspector summarized the purpose and the scope of the inspection and finding _
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7.
Enforcement Meeting a.
Persons Attending NRC Attendees J. M. Allan, Deputy Director, RI G. H. Smith, Chief FF&MS Branch, RI H. B. Kister, Acting Chief, RO&NS Branch, RI D. F. Johnson, Reactor Inspector, RI R. E. Architzel, Reactor Inspector, RI M. M. Shanbaky, Radiation Specialist, RI Baltimore Gas and Electric Company Attendees A. E. Lundvall, Jr. Vice President - Supply J. N. Bullock, Manager, Electric Generation L. B. Russell, Chief Engineer R. E. Denton, Nuclear Plant Engineer b.
General On November 29, 1979, the make-up demineralizer neutralizer tank overflowed resulting in the discharge of about 8,400 gallons of caustic water with a pH of about 12.1 through the yard drain to the Chesapeake Bay.
This condition exceeded the Environmental Technical Specifications, Appendix B.
The unplanned release of caustic water with a pH outside the Environmental Technical Specifications had occurred on at least 18 occasions since 1974.
These releases occurred as a result of operator error, equipment malfunction, tank leakage, and/or the failure to follow established procedures.
These releases demonstrated a weakness in the licensee's management control system and represent a matter of environmental concern.
c.
Areas Discussed and Licensee's Management Committments The repeated discharges of waste water outside the required pH range along with the several modes of failure to adhere to the regulatory requirements of Section 2.2 of the ETS, including inadequate system maintenance and design and inadequate management controls were discussed with the licensee's management.
The following commitments were made by the licensee's management.
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(1) Neutralizing Tanks The licensee stated that neutralizing tanks Nos.11 and 12 will be provided with curbing adequate to contain any tank leaks.
Tank No.12 will be modified to a permanent tank fixture and will be provided with a liner and hard piping required for all modes of operations including tank dilution. Both tanks will be provided with high level alanns with annunciators in the control room. The licensee stated that in addition to these tank modifications, a study to detennine the adequacy of the tank mixing system will be performed.
The tank modifications and proposed study will be completed by February 1980.
(2) Water Treatment Plant The licensee stated that a study to upgrade the water treatment plant including the replacement of all corroded plant components, including metering pumps, valves, pipes, controls, day tanks, and the concrete slab under the day tanks, was submitted to BG&E corporate offices for engineering review in November 1979.
The engineering of the proposed study will be completed by the Summer of 1980 and the completion of all required maintenance will be accomplished by the end of 1980. The licensee stated that with regard to the service building sump modifications, the sump will be discharged through the neutralizing tanks as of December 20, 1979.
This will ensure that any caustic or acid spills / leaks at the service building will be neutralized prior to discharge.
(3) Administrative Controls The licensee stated that the regeneration waste neutralizing procedures now includes a checklist for recording the tank level on an hourly basis.
In addition, a valve check-up list and a usage permit fonn will be used as part of the waste neutralizing system operations procedures effective March 1980.
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The training of auxiliary operators will be reviewed and an additional level of supervision will be added to review and approve tank discharges. An overall audit of the water treatment system operations including the neutralizing tanks operations will be performed during March 1980. This audit will encompass the waste neutralizing procedures, water treatment plant operation procedures, water treatment system maintenance, system calibrations, qualifications and training of system operators and system operating records.
At the conclusion of this enforcement meeting with the NRC Region I management informed the licensee that all actions taken by the licensee, to prevent the repeated items of noncompliance in this area, including those provided during this enforcement meeting will be examined during a subsequent inspection.
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