ML20198F196
| ML20198F196 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 11/07/1985 |
| From: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| To: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| NUDOCS 8511140292 | |
| Download: ML20198F196 (8) | |
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BALTIMORE GAS AND ELECTRIC CHARLES CENTER P.O. BOX 1475 BALTIMORE, MARYLAND 21203 ARTHUR E. LUNDVALL. JR.
Vice PRESIDENT November 7,1985 sumv U. S. Nuclear Regulatory Commission Office of Inspection & Enforcement Washington, DC 20555 ATTENTION: Mr. James M. Taylor, Director
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Notice of Violation & Proposed Imposition of Civil Penalties IE Inspection Reports 50-317/85-16; 50-318/85-14 &
50-317/85-18; 50-318/85-16
REFERENCE:
(a)
Letter from T. E. Murley, NRC, to A. E. Lundvall, Jr., BG&E, dated September 26,1985, Same Subject (b)
Letter from A. E. Lundvall, Jr., BG&E, to T. E. Murley, NRC, dated October 8,1985 (c)
Letter from A. E. Lundvall, Jr., BG&E, to T. T. Martin, NRC, dated September 26,1985 Gentlemen:
- This letter is being forwarded as requested by reference (a). The subject letter included a proposed imposition of civil penalties of $50,000 for the subject IE Inspection Reports.
Please find enclosed Check No. 1900579 from BG&E to the Treasurer of the United States in the amount of $50,000.
Additionally, the responses to the apparent violations addressed in reference (a) are forwarded in the enclosure to this letter.
8511140292 851107 PDR ADOCK 05000317 G
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Mr. James M. Taylor November 7,1985 Page 2 Should you have any questions regarding this matter, we would be pleased to discuss them with you.
Very truly yours, b. E. Lundvall, Jr.
A Vice President-Supply STATE OF MARYLAND :
- TO WIT:
CITY OF BALTIMORE Joseph A. Tiernan, being duly sworn states that he is Vice President of the Baltimore Gas and Electric Company, a corporation of the State of Maryland; that he provides the foregoing response for the purposes therein set forth; that the statements made are true and correct to the best of his knowledge, information, and belief; and that he was
. authorized to provide the response on behalf of said Corporation.
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h TITNESS my Hand and Notarial Seal:
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7///85 My Commission Expires:
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Enclosure AEL/LES/gla cc: D. A. Brune, Esquire G. F. Trowbridge, Esquire D. H. Jaffe, NRC T. E. Murley, NRC T. Foley, NRC
ENCLOSURE (1)
REPLY TO APPENDIX A OF NRC INSPECTION REPORT 50-317/85-16; 50-318/85-14 & 50-317/85-18; 50-318/85-16 SECTION I-ITEM A We have reviewed the circumstances that led to the apparent viciation (i.e., failure to implement and maintain the upgraded Post Accident Sampling System (PASS) capability required by NRC Confirmatory Order dated March 16, 1983). The following concerns were investigated:
NRC ITEMS I.A.1 THROUGH I.A.3 o
The system was never fully tested to verify operability.
The accuracy of the in-line analyzers (boron, pH, dissolved gases and radioiosotope) o was never demonstrated.
o Valves were not designed for system pressure, often leaked, and at times failed to operate, and in-line analyzers, when operationally tested, were inoperable or provided inaccurate results.
BG&E RESPONSE TO ITEMS I.A.1 THROUGH I.A.3 The cause of these concerns was a change in operating philosophy between the original installation of the PASS (in 1981 and 1982) and 1984. The system was originally designed and installed as a one-time use system, not as a routine or normal sample method. In 1984, it became apparent that NRC and INPO desired periodic demonstration of PASS operability. Consistent with the original scope, bench testing, and total system integrity post-installation hydrostatic tests, flushes, and necessary valve manipulations were conducted satisfactorily. PASS sample results were not compared with routine sample results because once the system was contaminated, PASS instrumentation maintenance would result in unnecessary man-rem exposure. A dilution verification was considered, but was not necessary since the ported valve transfers a known sample volume (4.7 ml) into the depressurized sample vessel. A simple volume conversion would have confirmed the dilution factor. A sample test matrix was considered; however, was not run through the system because the manufacturer, Combustion Engineering (CE), Incorporated, informed BG&E that a test of another utility's PASS for chemical interferences confirmed CE's results and these applied generically to other CE PASS's. The other maintenance problems occurred beginning in mid-1984, as the system was tested with radioactive coolant samples due to the change in operating philosophy.
Since the inspection was completed, many corrective actions have been taken. These corrective actions were forwarded in Enclosure (1) of reference (b), and related to findings 317/85-16-01; 318/85-14-01 through 317/85-16-03; 318/85-14-03.
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ENCLOSURE (1)
REPLY TO APPENDIX A OF NRC INSPECTION REPORT 50-317/8 16; 50-318/85-14 & 50-317/85-18; 50-318/85-16 l
NRC ITEM I.A.4 I
Modifications to the initial design of the PASS were not reflected in system o
emergency operating procedures.
BG&E RESPONSE TO LA.4 As was evident in Licensee Event Report 84-03, having two procedures (RCP-1-407 for operation at power and Emergency Response Plan Implementing Procedure (ERPIP) 4.4.7.6 for emergency operating during plant shutdown) provided the opportunity for incorrect usage. The ERPIP did not contain, nor is it appropriate to include precautions for system operation at power in non-emergency cor.ditions. Since the PASS would be operated routinely under non-emergency conditions, it was decided to retain RCP-1-407 as the system operating procedure. The ERPIP was being considered for cancellation, thus RCP-1-407 alone was maintained current with the PASS configuration. ER mP cancellation or revision was contingent on satisfactory PASS performance so that the differences between pre-and post-accident operation could be identified. In the event of an emergency, RCP-1-407 would have been used for system operation with reference to the ERPIP for radiological considerations. Reference (b), response to finding 317/85 03; 318/85-14-03, includes the actions taken to eliminate procedure differences.
NRC ITEM I.A.5 Personnel responsible for operation of the system in accident conditions were not o
adequately trained.
BG&E RESPONSE TO I.A.5 Liquid Monitoring Team personnel were trained in classroom and in-plant walk-through sessions on a semi-annual basis.
Initial classroom training was held in mid-1983.
Classroom and walk-through sessions began in February 1984 and have continued at six month intervals. Actual system operation, including drawing appropriate samples was not accomplished due to system unavailability. However, since June 1985, all members of the Liquid Monitoring Team have been trained on the system, including practice in drawing samples in accordance with current emergency operating procedures.
In addition, the instructor for PASS topics was individually trained by the PASS equipment vendor.
As procedures have been revised, retraining of team members has been accomplished.
In the future, semi-annual training sessions will continue to include changes to either the system design or operating procedures.
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ENCLOSURE (1)
REPLY TO APPENDIX A OF NRC INSPECTION REPORT 50-317/85-16; 50-318/85-14 & 50-317/85-18: 50-318/85-16 NRC ITEM LB.1 o
The alternate method, when tested on three occasions between June 27 and July 18,1985, did not perform its intended function.
BG&E RESPONSE TO LB.1 During the three occasions mentioned in the Inspection Reports, various parts of the alternate method did fail due to hardware problems and/or technician errors, which resulted in system failure. The system, however, did perform its function on other occasions both before and after these three instances.
This sampling technique represents a proven and viable method of obtaining and analyzing post accident samples.
There has been intensive technician training performed on the sampling method as well as minor modifications to the hardware layout. In addition, a shielded degassing and sampling station will be constructed in the Chemistry Laboratory for this evolution.
Piping modifications will be made to return the drains on the NSSS sample sink to the Reactor Coolant Drain Tank. All modifications should be completed by the end of the 1985 Unit 2 refueling outage, currently scheduled to end in December 1985.
NRC ITEM I.B.2 o
No procedures existed for the implementation of the alternate method in the present configuration.
BG&E RESPONSE TO LB.2 The review process for the emergency operating procedure did not facilitate timely revision. Steps taken to correct this deficiency include revising ERPIP 4.4.7.4 to reflect the present system configuration. To avoid further procedural change complications, provisions have been made in ERPIP 5.0 to allow for on-the-spot changes to ERPIPs. The results achieved from these actions are an up-to-date procedure that reflects the existing system configuration. Full compliance is considered to have been achieved September 25,1985.
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ENCLOSURE (1) 1 REPLY TO APPENDIX A OF NRC INSPECTION REPORT 50-317/85-16; 50-318/85-14 & 50-317/85-18; 50-318/85-16 NRC ITEM I.B.3 i
o Personnel were not formally trained in the use of the alternate method.
BG&E RESPONSE TO I.B.3 Emergency PASS operation of alternate sample methods had not been included in earlier Liquid Monitoring Team training sessions due to the absence of a verified and validated emergency procedure as described in the response to item I.B.2. However, during August 1985, Liquid Monitoring Team members were trained to obtain liquid samples using both the primary and alternate sampling methods. This training consisted of both walk-through and practical sample-drawing exercises, the latter performed in full anti-contamination clothing. Team members have also been trained on related emergency operating procedure revisions implemented after August.
NRC ITEM I.B.4 o
~ No evaluation was performed to determine if such operation of the alternate method could be performed within the dose limits of 10 CFR 50, Appendix A, General Design Criterion 19.
BG&E RESPONSE TO ITEM I.B.4 The concern was investigated in light of existing NSSS Reactor Coolant Sample (RCS) sink configuration and versions of pertinent ERPIPs used at the time of the inspection. A time and motion study was conducted in 1981 on the interim sampling system (i.e., the NSSS sink while PASS was being designed and installed) which demonstrated compliance with dose limits in 10 CFR 20 per NUREG-0578, of three rem whole body and 18.75 rem for extremities. These limits are more restrictive than the dose limits of 10 CFR 50, Appendix A, General Design Criterion 19.
Since 1981, modifications had been made to the PASS alternate sampling system and associated ERPIPs without any upgraded dose evaluation being performed.
Shortly af ter the subject inspection, a consultant was contracted to perform an evaluation of the present alternate system configuration against current criterion which pointed out a potential extremity exposure problem. This has been confirmed by BG&E staff engineers.
Apparently, system modifications rendered the original dose study invalid. Consequently, the NSSS sink is being modified to include new sampling methods and system / personnel shielding to reduce extremity exposures. A new time and motion study with respect to radiation exposure will be conducted. The expected completion date for these items is December 1985.
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ENCLOSURE (1)
REPLY TO APPENDIX A OF NRC INSPECTION REPORT 50-317/85-16; 50-318/85-14 & 50-317/85-18; 50-318/85-16 NRC ITEM II.A o
As of June 26, 1985, although the in-containment high radiation monitors were installed in Unit 1, the installation was inadequate in that protective sleeving, required to assure environmental qualifications of the in-containment electrical penetration-to-cable connectors (two for each monitoring device) had not been installed.
BG&E RESPONSE TO ITEM II.A We have investigated this item of apparent noncompliance with NRC requirements. The environmental qualification status of the connectors on the containment high range radiation monitors is consistent with the regulatory requirements in effect at the time e.:ch maintenance action was completed on the equipment as stated in reference (b).
Accordingly, it is requested that this apparent noncompliance be reconsidered.
NRC ITEM II.B o
From February 22,1985, (the date on which this Technical Specification became effective) to June 28, 1985, samples were not drawn independently from the main vent at least one per month to verify operability of the main vent iodine and particulate sampler.
BG&E RESPONSE TO II.B Samples were not drawn independently from the main vent at least once per month to verify operability of the main vent iodine and particulate sampler. The samples were not drawn due to a misinterpretation of the Technical Specification requirements by the responsible organization. To avoid recurrence of this, an independent audit of all future Technical Specification changes will be performed within two weeks of their implementation. This will provide an independent check on all Technical Specification implementation activities. Full compliance with this requirement has been achieved.
This item was documented in Licensee Event Report 50-317/85-03.
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F ENCLOSURE (1)
REPLY TO APPENDIX A OF NRC INSPECTION REPORT 50-317/85-16; 50-318/85-14 & 50-317/85-18; 50-318/85-16 NRC ITEM II.C The training program for personnel, as defined by Training Instruction No. 5, was o
not implemented in that the last training to be performed in this area was conducted in February 1984.
BG&E RESPONSE TO II.C Training which satisfies the requirements of Technical Specification 6.15 and Calvert Cliffs Training Instruction 5 was fully documented in February 1984, and at the time of the inspection, was scheduled for August 1985. Partial records exist for Monitoring Team lodine monitoring training in a field exercise in August-September 1984. These records were disallowed by the inspection team, due to the incomplete status of the associated training of monitoring personnel. This does not constitute a violation of training instructions. Emergency response yearly retraining may be scheduled at any time during the calendar year, an example of which is provided in reference (b). It is requested that this apparent noncompliance be reconsidered.
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