IR 05000317/1987003

Insp Repts 50-317/87-03 & 50-318/87-03 on 870224-27.No Violations Noted.Major Areas Inspected:Licensee Followup Actions to Items Identified During Previous Insp Re Licensee Implementation & Status of NUREG-0737 Items

ML20205T266
Person / Time
Site:	Calvert Cliffs
Issue date:	03/23/1987
From:	Kottan J, Pasciak W, Rabatin K, Sherbini S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20205T257	List: IR 05000317/1987003 ML20205T251
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-2.F.1, TASK-3.D.3.3, TASK-TM 50-317-87-03, 50-317-87-3, 50-318-87-03, 50-318-87-3, NUDOCS 8704070255
Download: ML20205T266 (8)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

50-317/87-03

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Report No /87-03 1 50-317 1 Docket No :

. DPR-53 -

C y License No OPR-69 Priority -

Category C

Licensee: Baltimore Gas and Electric Company

P. O. Box 1475 Baltimore, Maryland 21203

Facility Name: Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Inspection At: Lusby, Maryland Inspection Conducted: February 24-27, 1987

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~ j j i Inspectors: \j. d-

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3 / 40 /6 7

J. J. Kott'an, Radiat on Laboratory Specialist / dite MM S. SheRiTni, Ra iafion Specialist '

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/t.K. L. Rabatin, Radjation Specialist

]!20/97

/ efate Approved by: 1h 6>

W. J. PQcialG Chief, Effluents'Raciation '

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ProtecgionSection i Inspection Summary:

Inspection on February 24-27, 1987 (Report Nos. 50-317/87-03 and 50-318/87-03)

Areas Inspected: Special, announced inspection of the licensee's fcilow-up

. actions to items identified during previous inspections of the licensee's implementation and status of items identified in NUREG-0737: II.B.3, post-accident sampling of reactor coolant and containment atmosphere; II.F.1-1, noble gas effluent monitors; II.F.1-2, post-accident effluent monitoring; and III.D.3.3, inplant radioiodine measurements. The inspection involved 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br />

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on site by three regionally-based inspectors.

j Results: Of the 12 items reviewed, 11 were closed. No violations were identifie :

i' 8704070255 870401 PDR ADOCK 05000317 i G PDR i

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DETAILS Persons Contacted J. Lemons, Manager, Nuclear Operations

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• L. Larragotte, Licensing Engineer

• J. Carroll, General Supervisor, QA

• S. Hutson, Supervisor,- Plant Chemistry

*M. Bowman, General Supervisor, Technical Services

• P. Crinigan, General Supervisor, Chemistry

, *C. Mahon, Principal Engineer

• M. Kostelnik, Engineer

, *M. Snodderly, Engineer l *L. Salyards, Principal Engineer

. *W. Cartwright, Senior Engineer

• C. Main, Engineer S. Cowne, Senior Engineer C. Griffin, Training Instructor i

• Denotes those present at the exit intervie The inspectors also interviewed other licensee personnel including members of the chemistry, health physics, engineering, and training staff . Licensee Action on Previously Identified Items I

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(Closed) Violation (317/85-16-01; 318/85-14-01): Inoperability of CE-PASS i system. The CE-PASS system is no longer in service. See Paragraph 3.

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(Closed) Violation (317/85-16-02; 318/85-14-02)

CE-PASS system capa-

! bility demonstration. The CE-PASS system is no longer in service. The

current PASS system was tested by taking an RCS sample and performing dissolved hydrogen, gamma isotopic, boron and chloride analsyses. Also, i

NRC boron and chloride standards were submitted to the licensee for I analysis. Samples were taken and analyzed within the required time

! limits. Projected exposures are withing GDC 19 limits. See Paragraph 3.

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(Closed) Violation (317-85-16-03; 318/85-14-03)

Alternate method of sample processing. An alternate method for sample analysis is not

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required. This is because alternate methods of analysis are required

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only for inline instrumentation. The current PASS has no inline instrumentatio !

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(Closed) Inspector Follow-up Item (317/85-16-04; 85-14-04): Containment l air sampling and core damage assessment.

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i Containment Air Sampling The problems caused by using one key to operate the isolation valves on the sample lines have been corrected. The solution was to provide sets of identical keys (17 keys per set) for Units 1 and These-keys are sufficient in number to operate all the valves.

1 A technical basis for selecting a suitable purge time for the sample lines has been developed. The recommended purge time is 20 minute It is based on a minimum pump flow of 0.03 SCFM. This purge time is

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estimated to be sufficient to purge the sample line and also the sample loop by five loop volumes. The 20 minute time is applicable to both Units 1 and 2 because of similarities of construction of the sampling systems, A flow indicator has not been installed on the system. Instead of use of an indicator, the licensee is using a regular surveillance schedule to ensure system operability. Part of the surveillance program involves use of a removable flow indicator to measure flow rate during testing. The licensee stated that the surveillance program provides reasonable assurance of flow through the sampling system during actual sampling. The inspector noted, however, that i there was still no assurance that flow would be obtained under i accident conditions, and that conclusions regarding core damage

based on a sample from the system could be seriously in error if

sample flow had, in fact, not occurred during sample collection.

The licensee stated that the matter will be further reviewed to determine appropriate corrective actio This item will be reviewed in a subsequent inspection (317/87-03-01; 318/87-03-01). The handling tools, lead gloves, and lead-lined apron are no longer required by procedure. The licensee stated that, although such

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equipment provided shielding, it also resulted in significantly slower job performance and therefore longer stay times in the radi-l ation areas. The decision was, therefore, made to rely on speed

] rather than shielding and manipulators to minimize exposur The licensee stated that the gas pressure in the sample at the time the syringe is used would be close to atmospheric and the syringe would therefore not be exposed to high pressures. The licensee is also using a new, gas tight syringe-to ensure against leakage of '.

radioactive gases from the syring The sample rig has been modified to eliminate the dead le , A time and motion study has been completed and the study estimates that sample collection and analysis could be performed within GDC-19 dose limits.

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4 The control panel is being used on a routine basis for sampling a -

number of points in the system. The technicians are, therefore, familiar with the general layout and operation of the panel. The licensee stated that obtaining a containment sample requires only a minor deviation from routine panel operations and that the techni-cians have been trained in this operatio Core Damage Assessment 4 The licensee core damage methodology no longer requires containment iodine activity but relies on the containment noble gas activities.

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Therefore, a representative containment iodine sample is no longer require '

7 The pressure and temperature corrections are required to enable calculation of containment activity based on containment sample analysis results. Since the sample and containment air will gen-erally be at significantly different temperatures and pressures, the correction is required. The correction is included in some of the licensee's emergency procedures. The licensee stated that other procedures will be reviewed to ensure consistenc (0 pen) Inspector Follow-up Item (317/85-16-05; 318/85-14-05): Noble gas effluent monitoring. The problems involved in measuring flow rate in the stack have not been resolved and the licensee is still using a default flow rate. The flow measurement problem involves developing a meth-odology to correct the readings of the pitot tube flow measurement probes

, installed in the vent to a reliable flow rate. Tests using traverse flow measurements as the reference flow value show that the currently used methodology for interpreting the pitot tube readings is not sufficiently accurate and reliable for use as input to the microprocessor used to calculate release rates. The licensee stated that development work is continuin (Closed) Inspector Follow-up Item (317/85-16-06; 318/85-14-06): Main steam effluent radiation monitor. The main steamline monitor is currently operational and procedures have been developed for calibrating the syste The calibration is a two phase process, an electronic calibration and a radioactive source calibration. The source calibration is not an in place calibration. It requires removal of the detector from its shield on the steam line and use of a separate calibration jig. The jig exposes the detector to three predetermined exposure rate levels. The calibration consists of ensuring that the instrument reading is within specified limits of the expected readings. The calibration procedure. is thus a calibration of the detector's exposure rate response and not of the mon-itoring system as a whole. The relationship between activity in the steam line and monitor reading has been derived by calculation and theoretical analysi:. The results of this analysis are expressed in the form of a series of curves relating the monitor reading in R/hr to activity in the steam line in uCi/cc as a function of decay time. Attenuation of low-energy gamma rays has been considered in the calculations and theoretical analyse l

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Alarm setpoints have been selected for the steam line monitors. The

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3setpoints are based on a calculated dose at the site boundary of 100 mrem assuming steam release from the main steam line to the environment at 100%

flow rate for a period .of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The dose calculations were performed using the methodology in the Offsite Dose Calculation Manual and the steam flow rates were obtained from the FSA (Closed) Inspector Follow-up Item (317/85-16-07; 318/85-14-07): Effluent radiation monitors procedures and training. Procedures have been devel-oped for calibration and functional testing of the wide-range gas monitor

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system. A study has also been completed of the response of the monitor system as a function of cecay time of the accident mix of isotopes. A training program has also been developed for training operators on the use of the system. The program includes annual retraining given by the training department in a formal format, plus a six-month retraining given by the chemistry department. The latter has not been incorporated as a formal requirement in the overall training progra The methodology for using the wide-range monitor readings has been incorporated into the procedures. This methodology calls for use of the wide-range gas monitor readings during the initial phase of an accident

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only. Once the emergency organization becomes functional, release rates will be estimated using methods described in the emergency procedure These methods incorporate the response factors of the wide-range gas

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(Closed) Inspector Follow-up Item (317/85-16-08; 318/85-14-08): Sample line losses. A study of the radioiodine and particle transmission losses i in the wide-range gas monitor sample lines was completed by Science

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Applications International Corporation (SAIC). The conclusions of that

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study were that the transmission losses of particles in the lines were not expected to-be large. Iodine transmission losses in the low range

.y sample lines were also not expected to be large. However, two problems were identified. One is a potential for condensation of water vapor in the sample ifnes. The results in the report were obtained assuming no

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condensation, and such condensation would invalidate the study. The licensee stated that heat tracing has been installed on the sample lines

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and should orevent condensation. The other problem identified in the report was that transmission of elemental fodine in the high range moni-tor sample lines is expected to be very low. The report recommends development of alternatives to the use of these sample lines. The licen-see stated that the problem is being studied to determine an appropriate solution. This item will be reviewed in a future inspectiori (317/87-03-02; 318/87-03-02).

(Closed) Violation (317/85-16-09;,318/85-14-09): Effluent monitor surveillance requirement. The Technical Specification requirement to perform these comparisons has been deleted. The licensee is currently relying on a surveillance program to ensure operability of the syste .

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i (Closed) Inspector Follow-up Item (317/85-16-10; 318/85-14-10): Effluent iodine sampling. A time and motion study has been completed. The study estimates the doses expected to be received during retrieval / replacement of charcoal cartridges from the wide-range gas monitor. The methodology for retrieval and handling of the samples has been more clearly developed and clarified and technicians have been trained in the retrieval and i filter replacemen (Closed) Violation (317/85-16-12; 318/85-14-12): Failure to perform

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inplant iodine sampling and analysis training as required. Review of training records indicates that the required training was given in 198 Records were complete and available. All designated personnel were pro-

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vided with the required training. See Paragraph (Closed) Inspector. Follow-up Item (317/85-16-13; 318/85-14-13): Inplant radioiodine monitoring. ERPIP 4.1.7 addresses onsite monitoring during emergencies. This procedure contains provisions for taking air samples using charcoal or silver zeolite, as applicable, and analyzing them to i determine radiciodine airborne activity. The procedure contains a cali-bration curve of air activity versus counts (in 2 minutes) for cartridges j counted with an MS-2/ SPA- . Post-Accident Sampling System, Item II. The licensee's PASS system consists of the NSSS sample sink which has been modified to permit sample collection under accident condition This system has the capability to collect reactor coolant samples at operating pressure and also at low pressure via the LPSI pump. The samples collected by this system are taken to the laboratory for chem-ical and radiochemical analyses. The sampling and analyses can be performed within the GDC-19 dose limits. An NRC safety evaluation by the Office of Nuclear Reactor Regulation concluded that the NSSS sample sink PASS systems are acceptable and meet the requirements of NUREG-0737, Item II.B.3. The licensee's old PASS system, the CE-PASS, is no longer in servic During this inspection, a capability demonstration of the licensee's PASS system was performed. The licensee sampled reactor coolant and performed dissolved hydrogen, chloride, boron, and gamma isotopic analyses on the sample. The licensee performed the sampling and analysis, using normal methods and equipment, within the required time limits. The results of the licensee's analyses were compared to the results obtained from routine samples and analyses. The results are listed in Appendix A. In addition, the inspectors submitted both chloride and boren standards to the licensee for analysis in order to verify the licensee's capability to perform these analyses. The standards were prepared by Brookhaven National Laboratory (BNL) for NRC Region I. These results are also listed in Appendix . - - - -. . ..-

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7 l The licensee experienced difficulty in performing the chloride standard analyses because the standard used for calibration was in error. The use of an i.tproperly prepared standard was not identified by the licen-see because the licensee had yet to implement Procedure CP 103, Chemistry

Quality Assurance Program, for the ion chromatograph. This procedure provides for the use of separate calibration and' control standards as well as the use of control charts and multipoint calibrations. Had this program been in place, the improperly prepared standard would have been identified. The licensee stated that Procedure CP 103 would be imple-mented for the ion chromatograph. The inspector stated that this would be reviewed during a subsequent inspectio (317/87-03-03; 318/87-03-03) Training The inspector reviewed the licensee's chemistry training program relative to the licensee's post-accident sampling systems. The 1985, 1986, and j proposed 1987 chemistry technical continuing training schedules were reviewed. Training for the post-accident sampling systems is given every six months. Detailed outlines of the chemistry technical contin-uing training program were also reviewe Reactor coolant, containment

atmosphere, and plant effluent post-accident sampling systems were included in the outline. In addition, formal classroom training based on lesson plans C-16A-3-1, RCS Sampling, Hydrogen Analyzing and WRNGM l Subsystems for Post-Accident Sampling, and C-217-4.1.8-0, Chemistry Team Specific Procedure Training, was reviewed. The training was given in

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April and May, 1986 and included all designated chemistry technician A review of written examinations for the above training indicated that exams appeared to test lesson plan objectives and grading appeared to be fair and consistent.

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The inspector reviewed lesson plan ER-2-6, SPEC PRO, which covered emer-gency response training for the onsite monitoring team. This training which was given in August and September, 1986 included hands-on demon-stration for inplant iodine sampling and analysis. All onsite monitors designated in the licensee's emergency plan and implementing procedures received the required trainin No violations were identified in this are . Exit Meeting The inspectors met with licensee personnel denoted in Paragraph 1 of this report on February 27, 1987. The purpose, scope and findings of the inspection were discussed.

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APPENDIX COMPARIS0N OF CHEMICAL AND RADI0 CHEMICAL TEST RESULTS Parameter Concentration Measured Concentration Difference Comparison Criteria Boron 880 ppm 770 ppm - 110 ppm i 50 ppm over the (Actual sample) range 50-1000 ppm Boron 985 i 10 ppm 1000 1 0 ppm + 15 ppm Same as above (NRC standards) 2980150 ppm 2988 1 2 ppm + 8 ppm 487 i 6 ppm 50112 ppm + 14 ppm Chloride -

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10% over the range (Actual sample) 0.5 to 20 ppm i 50 ppb < 500 ppb Chloride 20.0 1 0.9 ppb 23.0 1 1.4 ppb + 3.0 ppb Same as above (NRC standards) 805 1 22 ppb 861 1 ? ppb + 56 ppb 374 1 12 ppb 447 i ? ppb + 73 ppb

• 410 i ? ppb + 36 ppb Dissolved H (Actualsamhle) 18 cc/kg 19.1 cc/kg + 1.1 cc/kg i 5 cc/kg below 50 cc/kg Gamma Isotopic Analysis (Actual sample)

Total Iodines 2.66E-1 pCi/ml 1.69E-1 pCi/ml - 0.97E-1 i a factor of 2 0 Reanalysis after recalibratio See Paragraph 3.

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