ML20134E482

Forwards Agenda for 850814 Enforcement Conference at Region I Ofc to Ascertain Validity of Findings in Insp Repts 50-317/85-16 & 50-318/85-14 & to Review Licensee Commitments Re post-accident Sampling Sys (TMI Item II.B.3)

ML20134E482
Person / Time
Site:	Calvert Cliffs
Issue date:	08/13/1985
From:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Tiernan J BALTIMORE GAS & ELECTRIC CO.
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-TM NUDOCS 8508200281
Download: ML20134E482 (6)

See also: IR 05000317/1985016

Text

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AUG 131985

Docket Nos. 50-317

50-318

Baltimore Gas and Electric Company

ATTN: J. A. Tiernan, Manager

Nuclear Power

P.O. Box 1475

Baltimore, Maryland 21203

Gentlemen:

Enclosed is our agenda for the Enforcement Conference scheduled for 1:00

p.m. , August 14, 1985 at the NRC Region I office. If you have any

questions relative to these discussion items, please refer them to Dr.

R. Bellamy (215) 337-5200.

Sincerely,

Original Signed BYI

'

Thomas T. Martin, Director

Division of Radiation Safety

and Safeguards

Enclosure: As Stated

cc w/ encl:

A. E. Lundvall, Jr., Vice President, Supply

R. M. Douglass, Manager, Quality Assurance

L. B. Russell, Plant Superintendent

Thomas Magette, Administrator, Nuclear Evaluations

R. C. L. Olson, Principal Engineer

R. E. Denton, General Supervisor, Training and Technical Services

Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector

StateofMaryland(2)

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CALVERT CLIFFS

ENFORCEMEtlT C0tlFEREtlCE AGENDA

e

It is the express purpose of the conference to:

1. Ascertain the validity of certain findings of NRC Inspection

50-317/84-16; 50-318/85-14, performed June 24-28, 1985. The

particular findings to be verified in this conference are

listed in the attached Discussion Items.

2. Ascertain the licensee's corrective measures relative to these

findings, particularly,

What is the current post-accident sampling capability?

What is the operational status?

What are the long term corrective measures to provide assur-

ance that the capability will be maintained?

What changes in the management control system will be made to

assure that NRC required engineering or plant modifications,

that may not directly effect plant operations, will be proper-

ly prioritized and effectively completed in a timely manner?

What changes in the pre-operational testing of such modifica-

tions will be made in order to verify and validate that the

effected design or system is operational and able to perform

as intended?

What Quality Assurance and Quality Control enhancements are

planned?

3. Determine the licensee's perception of the import of the

findings, the causal factors that resulted in the conditions

noted, and corrective measures applied to prevent recurrence.

OFFICI AL RECORD COPY

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CALVERT CLIFFS ErlFORCEMEllT C0flFEREllCE

DISCUSS 10fl ITEMS

,

1. Status as of June 26, 1985 of the CE-PASS In-Line capability.

1.1 The flRC's " Order Confirming Licensee Cormiitments on

Post-TMI Related Issues" (March 16, 1983) was in refer-

ence to submittals made regarding the establishment and

implementation of post-accident sampling via in-line

analyses with the CE-PASS; and back-up to the in-line

equipment via dilated grab sample from the CE-PASS. Such

capability was declared operable on June 1,1983.

1.1.1 Licensee records do not indicate that the

system was verified to be completely operational

and able to perform as indicated in a submittal

to the flRC dated flovember 30, 1982.

1.1.2 Licensee commitments and submittals per

flVREG-0737 requirements were only in regard to

CE-PASS and did not infer or reference any

intended use of the flSSS sink /PASA method as a

back-up sampling technique upon establishment

of the CE-PASS on June 1, 1983.

1.1.3 Since installation, there have been continual

problems with the CE-PASS including leaking

valves, inoperable valves, inoperable system

components, and erroneous in-line analytical

instrument indications.

1.1.4 A fully integrated and complete test of the

system demonstrating the CE-PASS capability to

acquire samples from all sample points and

analyze such samples within the accuracies

stated for each parameter has not been per-

formed.

1.1.5 The system's ability to provide a diluted

samples for back-up analyses was never proven

due to unreliable dilution capability.

1.1.6 There was no test ever performed that demon-

strated that the in-line radioisotopic analyzer

was able to provide a factor of 2 accuracy.

1.1.7 On June 26, 1985, the applicable procedure

(ERPIP 4.4.7.6) for operation of the CE-PASS

was not conmensurate with the current system

configuration. Consequently a surveillance

procedure had to be used to operate the syste:::.

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1.1.8 On June 26, 1985, a sar.ple was not able to be

acquired from the Unit-2 hot lcg because the

sample acquisition valve was inoperable

(2-CV-5105-).

1.1.9 On June 26, 1985, valves 1-SV-6529 and

2-SV-6529 would not function and thereby

prevented sample flow through the CE-PASS.

1.2 On February 22, 1935, Technical Specification 3/4.7.13

" Post-Accident Sampling" was issued.

1.2.1 Subsequently, the licensee declared the CE-PASS

inoperable on March 5,1985; reported the same

to the MRC on March 29, June 6, and July 22,

1985.

1.2.2 The March 29 and June 6, 1985 submittals

indicated that the " preplanned alternate method

of processing samples" was in. effect. Such

method was considered by the licensee to be the

NSSS sink /PASA technique.

1.2.3 Since Technical Specification 3/4.7.13 has been

issued, the CE-PASS has always been declared

inoperable.

2. Status of NSSS sink /PASA Method.

2.1 The NSSS sink /PASA method was a post-accident sampling

technique established originally to satisfy the interim

requirements for post-accident sampling capability

specified in NUREG-0578. Except as mentioned in the

Order as the system to be employed until the establish-

ment of the CE-PASS on June 1, 1983, the NSSS sink /PASA

method is not referenced in any submittals relative to

NUREG-0737 (II.B.3) pertaining to post-accident sampling.

The method was never suggested as a " preplanned alternate

method of processing specified samples". Since the

CE-PASS was declared inoperable on March 5, 1985, (and

earlier in view of the operating performance of CE-PASS),

the NSSS sink /PASA method has been considered as the

post-accident sampling capability.

2.1.1 As of June 26, 1985, no approved procedure

existed for the operation of the NSSS sink /PASA

system in the current configuration.

2.1.2 No personnel had been formally trained on the

method and system configuration.

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2.1.3 During a demonstration on June 26, 1985, the

primary coolant sample was forced out the top

of the burette due to a design and operator

error. In' later demonstrations:

2.1.3.1 On July 17, 1985, the PASA leaked

all of the primary coolant through a

hose clamp that was used to repair

the previous def frciency;

2.1.3.2 On July 18, 1985, the controlled

delivery of primary coolant sample to

the burette could not be accorrplished,

and resulted in primary coolant being

leaked from the PASA until the

technician stopped the leak by

putting his finger over the spigot.

2.1.4 As of June 28, 1985, there was never a time and

motion study performed to verify that the NSSS

sink /PASA method could be accomplished within

GDC-19 dose limits.

2.1.5 The analyses procedure (ERPIP 4.4.7.4) did not

contain provisions for analyses of hydrogen (or

total gas) or pH.

2.1.6 No remote tools or equipment are used for

sample acquisition via the NSSS sink /PASA

method; and lead-lined gloves and aprons

specified as necessary in the analysis proce-

dure (ERPIP 4.4.7.4) were not available for use

on June 26, 1985,

2.1.7 The PASA assembly is not a structurally sound

device and contains fragile glassware compo-

nents that are subject to breakage.

3. Status of Post-Accident Particulate and Radiciodine Capability.

3.1 T.S. 3/4.3.3.8 issued February 1985 specified an opera-

bility surveillance requirement for the main vent iodine

and particulate sampler. Such samplers are required to

be demonstrated operable by comparison with samples indepen-

dently drawn from the main vent at least once per month.

3.1.1 T.S. 4.3.3.8 was never implemented. The

surveillance requirement was never performed.

OFFICI AL RECORD COPY

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3.1.2 flo evaluation had ever been performed to

demonstrate that the samples collected by this

system were representative of the effluent

stream. *

3.1.3 As of June 26, 1985, personnel were not trained

in the procedure for collecting grab samples

from this system.

3.1.4 As of June 26, 1985, the licensee was unable to

demonstrate the workability of procedures for

filter removal from the sampling cask in the

Wide Range Gas Monitor; and subsequent analysis

of such filter.

4. Status of Containment High Range Radiation Monitor (CHRRM) System.

4.1 The CHRRM system is required by NUREG-0737 and subsequent

clarifications contained in RG 1.97, to be qualified to

function in an accident environment as a Category I

instrument system.

4.1.1 RAYCHEM sleeving of electrical connectors,

including internal containment penetration-to-

cable connectors is required to assure the

environmental qualification of the system.

4.1.2 On June 27, 1985, none of the four internal

penetration-to-cable connectors in Unit-1 were

provided with protective (RAYCHEM) sleeving

necessary to assure environmental qualification

of the system,

5. Status of Inplant Radioiodine Monitoring Program.

5.1 T.S. 6.15 specifies that a program be implemented to

assure the capability of accurately measuring airborne

iodine concentrations in-plant during accident con-

ditions. Such program included the training of

personnel. To this end, the licensee established

c Training Instruction flo. 5 which required that personnel

responsible

'

for accident monitoring, including

radiciodine measurements, be trained yearly.

5.1.1 As of June 28, 1985, no personnel have been

trained in this function since February 1984.

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0FFICI AL RECORD COPY

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