ML20134E482
| 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
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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)
bec w/ encl:
Region I Docket Room (with concurrences)
SeMor Operat4 ens-OfHeer (w/o e@
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DRP Section Chief
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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.
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CALVERT CLIFFS ErlFORCEMEllT C0flFEREllCE
DISCUSS 10fl ITEMS
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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
(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
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
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.
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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
'
Training Instruction flo. 5 which required that personnel
c
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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