ML20137K693

Advises That C-E post-accident Sampling Sys & NSSS Remain Unacceptable,Per 850926 Notice of Violation & Proposed Imposition of Civil Penalties,Unless Individual Deficiencies Completely Corrected.Response Due in 20 Days

ML20137K693
Person / Time
Site:	Calvert Cliffs
Issue date:	01/16/1986
From:	Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Lundvall A BALTIMORE GAS & ELECTRIC CO.
References
EA-85-102, NUDOCS 8601240186
Download: ML20137K693 (3)

Text

i JAN 161986 i

Docket Nos. 50-317; 50-318 License Nos. OPR-53; DPR-69 EA 85-102 Baltimore Gas and Electric Company ATTN: Mr. A. E. Lundvall, Jr.

Vice President, Supply P. O. Box 1475 Baltimore, Maryland 21203 Gentlemen:

Subject:

Response to Notice of Violation and Proposed Imposition of Civil Penalties (

Reference:

EA 85-102)

References:

(a) Notice of Violation and Proposed Imposition of Civil Penalties-Letter from T. E. Murley, NRC to A. E. Lundvall, BG&E, dated September 26, 1985 (b) Letter from A. E. Lundvall, BG&E, to T. E. Murley, NRC, dated October 8, 1985 (c) Letter from L. B. Russell, BG&E, to T. E. Murley, NRC, dated October 25, 1985 (d) Letter from A. E. Lundvall, BG&E, to J. M. Taylor, NRC, dated November 7, 1985 On September 26, 1985, a Notice of Violation and Proposed Imposition of Civil Penalties was sent to you which described violations of Post Accident Sampling System (PASS) requirements at Calvert Cliffs. The civil penalties were assessed for the two violations described in Section I of the Notice. These viniations ennsisted of failure to functionally implement and maintain the upgraded Combustion Engineering (CE) PASS as required by an NPC Order, and failure to maintain the preplanned alternative system (Nuclear Steam Supply System) (NSSS) operational, which was required by the Technical Specifications since the CE-PASS was not operable.

In your November 7, 1985 response to the Notice, you (a) provide a check for

$50,000 in full payment of the proposed civil penalties, (b) provide a description of the corrective actions taken or planned for the violations, and (c) request reconsideration of two of the three violations for which civil penalties were not proposed, as set forth in Section II of the Notice.

Although we have reviewed your November 7 response, as well as two other letters from BG&E dated October 8, 1985 and October 25, 1985 concerning the deficiencies in the CE-PASS and NSSS, we are uncertain of the current status of both of these systems. In the October 25, 1985 letter, you state that the CE-PASS has shown to be maintenance intensive and an unreliable system, that installed instrument inaccuracies of ten cause the analytical results to be outside suggested tolerances up to a factor of three, and that neither the 0FFICIAL RECORD COPY 1HOLODYl/8/86 - 0001.0.0 i 01/14/86 I 16 8601240186 86 317 b PDR ADOCK O PDR Q &

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Baltimore Gas and Electric Company 2 in-line analyzer nor the diluted grab sample and associated analyses can be considered a viable method for post-accident sampling and analyses. Further, you indicated that you were making modifications to the NSSS and intended to request NRR approval of the NSSS as the method of taking and analyzing a reactor coolant accident sample. Although this implies that you no longer intend to utilize the CE-PASS your November 7 response, while providing corrective actions for the specific deficiencies set forth in the NRC Notice regarding the CE-PASS, does not address the deficiencies described in your October 25, 1985 letter nor does it provide the BG&E position regarding the use of the CE-PASS as the primary system for taking and analyzing a reactor coolant sample.

In addition, the preplanned alternative method using the NSSS is not considered operational, as set forth in the Notice, until the method could be performed within the dose limits of 10 CFR 50, Appendix A, General Design Criteria (GDC)

19. In your November 7 response, you indicated that the NSSS is being modified to reduce extremity exposures to acceptable levels, and a time and motion study with respect to radiation exposure was to be completed in December, 1985 to verify that the NSSS could satisfy GDC 19.

Accordingly, within 20 days of the date of this letter, please inform this office in writing of the operability status of both the CE-PASS and the NSSS.

If you consider the CE-PASS operable, describe the actions taken to resolve the deficiencies identified in your October 9,1985 letter. If you consider the NSSS operable, provide a copy of your time and motion study to verify that the NSSS satisfies GDC 19. Unless the individual deficiencies hav. been completely corrected in at least one of these systems, the NRC considers both the CE-PASS and NSSS inoperable relative to post-accident sampling.

With respect to your request for reconsideration of two of the three violations for which civil penalties were not assessed, we are reviewing the additional information in support of this request sent to J. White of my staff by A Marinn and P. Crinigan of your staff in December, 1985 and January,1986.

Our response to this request will be addressed under separate correspondence upon completion of our review.

The response directed by this letter is not subject to the clearance procedures of the Office of Management and Budget, as required by the Paperwork Reduction Act of 1980, PL 96-511.

Sincerely, Or M bri Cit * # *'t Thomas E. Murley Regional Administ'rator cc: See Next Page 0FFICIAL RECORD COPY 1HOLODYl/8/86 - 0002.0.0 01/14/86

E Baltimore Gas and Electric Company 3 R. M. Douglass, Manager, Quality Assurance L. B. Russell, Plant Superintendent Thomas Magette, Administrator, Nuclear Evaluations R. C. L. Olson, Principal Engineer J. A. Tiernan, Manager, Nuclear Power R. E. Denton, General Supervisor, Training and Technical Services Public Document Room (PDR)

Local Public Document Room (LPOR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of Maryland (2) bec:

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