IR 05000317/2007005
| ML080380496 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 02/07/2008 |
| From: | Glenn Dentel Reactor Projects Branch 1 |
| To: | Spina J Constellation Generation Group |
| Dentel, G RGN-I/DRP/BR1/610-337-5233 | |
| References | |
| IR-07-005 | |
| Download: ML080380496 (33) | |
Text
ary 7, 2008
SUBJECT:
CALVERT CLIFFS NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000317/2007005 AND 05000318/2007005
Dear Mr. Spina:
On December 31, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Calvert Cliffs Nuclear Power Plant (CCNPP) Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on January 11, 2008, with Mr. Bauder and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
This report documents one NRC-identified finding and one self-revealing finding of very low safety significance (Green). Both of the findings were determined to involve violations of NRC requirements. However, because of the very low safety significance and because they are entered into your corrective action program (CAP), the NRC is treating these findings as non-cited violations (NCVs) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest any NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region 1; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the CCNPP.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Glenn Dentel, Chief Projects Branch 1 Division of Reactor Projects Docket Nos.: 50-317, 50-318 License Nos.: DPR-53, DPR-69 Enclosure: Inspection Report 05000317/2007005 and 05000318/2007005 w/Attachment: Supplemental Information cc w/encl:
M. J. Wallace, President, Constellation Generation J. M. Heffley, Senior Vice President and Chief Nuclear Officer President, Calvert County Board of Commissioners C. W. Fleming, Esq., Senior Counsel, Nuclear Generation Group J. Gaines, Director, Licensing Director, Nuclear Regulatory Matters R. McLean, Manager, Nuclear Programs K. Burger, Esquire, Maryland People's Counsel R. Hickok, NRC Technical Training Center S. Pattison, SLO (2)
SUMMARY OF FINDINGS
IR 05000317/2007-005, 05000318/2007-005; 10/01/2007 - 12/31/2007; Calvert Cliffs Nuclear
Power Plant, Units 1 and 2: Post-Maintenance Testing and Event Follow-up.
The report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Two Green findings were identified, both of which were determined to be NCVs. The significance for most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.
NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
- Green.
An NRC-identified NCV of Technical Specifications (TS) 5.4.1.a, Procedures, was identified because Constellation did not establish and maintain an adequate procedure to vent and flush the saltwater (SW) strainer pressure transmitters and flow controllers. This resulted in an inoperable train of service water (SRW) following maintenance on the Unit 1 11B plate heat exchanger (HX). Specifically, Operating Instruction (OI) 29, SW System, did not provide operators and instrument maintenance (IM) technicians with adequate procedural guidance on venting and flushing the SW strainer instrumentation in order to mitigate potential air intrusion following maintenance activities on the service water heat exchangers (SRWHXs).
The immediate corrective actions included instructions to extend the time that IM technicians vent and flush the SW strainer instrumentation. The planned corrective action is to review and revise procedure OI-29, as necessary, to incorporate extended venting and flushing guidance.
This finding is more than minor because it is associated with the procedure quality attribute of the Mitigating System cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of the SRW system that respond to initiating events to prevent undesirable consequences. The inspectors determined that the finding was of very low safety significance because it is not a design or qualification deficiency, does not represent a loss of a system safety function or safety function of a single train for greater than its TS allowed outage time, and does not screen as potentially risk significant due to external events. This finding has a cross-cutting aspect in the area of problem identification and resolution because Constellation did not thoroughly evaluate prior SRWHX strainer venting issues to address and fully resolve problems in a timely manner commensurate with its safety significance (P.1.c per IMC 0305). (Section 1R19)
Cornerstone: Barrier Integrity
- Green.
A self-revealing NCV of very low safety significance of License Condition 2.C.(1) to Renewed Facility Operating License DPR-69, occurred when Constellation operated Unit 2 in excess of the licensed power limit of 2700 megawatt thermal (MWTH). On December 8, 2007, during a load change following main turbine control valve testing, operators inadvertently increased the two-minute instantaneous thermal power above the licensed power limit of 2700 MWTH for approximately 15 minutes. Constellation conducted a prompt investigation and determined that operators did not adequately stop the power ascension due to distractions with the withdrawal of control element assemblies (CEAs) to the full out position and the inappropriate use of turbine load (turbine load was already at 100 percent) to maintain cold leg temperature within TS limits. Following the event, Constellation took immediate corrective action to remediate the operators controlling the evolution and entered this issue into their CAP.
The finding is more than minor because it is associated with the human performance attribute of the Barrier Integrity cornerstone and affects the cornerstone objective to provide a reasonable assurance that physical design barriers, such as fuel cladding, protect the public from radionuclide releases caused by accidents or events.
Specifically, operation above the licensed limit reduced the 2 percent uncertainty margin assumed in the accident analysis to protect the fuel cladding from damage.
The inspectors determined that the finding was of very low safety significance because the reduction of the uncertainty margin assumed in the accident analysis was only associated with the fuel barrier integrity and did not affect the reactor coolant system (RCS) or containment barriers. This finding has a cross-cutting aspect in the area of Human Performance because Constellation did not effectively communicate expectations of procedural compliance in that the operators did not appropriately monitor plant parameters during the power increase (H.4.b per IMC 0305). (Section 4OA3)
Licensee-Identified Violations
None.
REPORT DETAILS
Summary of Plant Status
Calvert Cliffs Unit 1 began the inspection period at 100 percent reactor power. On October 2, 2007, operators reduced power to 84 percent to perform waterbox condenser cleaning. Operators returned the Unit to 100 percent power on the same day. On October 20, operators reduced power to less than 10 percent to replace the main generators stator liquid cooling (SLC) system filters. Operators returned the unit to 100 percent power on October 21, and the Unit remained at 100 percent power the remainder of the inspection period.
Calvert Cliffs Unit 2 began the inspection period at 100 percent reactor power. On December 7, operators reduced power to 84 percent to perform main turbine valve testing. Operators returned the Unit to 100 percent power on December 08. The Unit remained at 100 percent power for the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R01 Adverse Weather Protection (71111.01 - One Sample)
Adverse Weather Seasonal Preparations - Cold Weather
a. Inspection Scope
The inspectors performed a review of cold weather preparations before the onset of the cold weather season to evaluate the sites readiness for seasonal susceptibilities. This review included an assessment of Nuclear Operations Program Procedure NO-1-119, Seasonal Readiness. The inspectors assessed the effectiveness of the sites cold weather readiness program to ensure that the selected systems would remain functional and available for a plant shutdown during cold weather conditions as required by TS.
The inspectors also discussed the protective measures applicable to the systems with control room operators, the seasonal readiness coordinator, and the system engineer.
Additionally, the inspectors performed partial field walkdowns to evaluate the material condition and functionality of the freeze protection equipment (e.g., heat tracing, instrumentation, and ventilation) associated with the systems. The inspection activity represents the completion of one sample and included a review of the following risk significant systems to evaluate for the sites cold weather readiness:
- 11 refueling water tank; and
b. Findings
No findings of significance were identified.
1R04 Equipment Alignment
.1 Partial Walkdown (71111.04Q - One Sample)
a. Inspection Scope
The inspectors verified that selected equipment trains of safety-related and risk significant systems were properly aligned. The inspectors reviewed plant documents to determine the correct system and power alignments, as well as the required positions of critical valves and breakers. The inspectors verified that the Constellation had properly identified and resolved equipment alignment problems that could cause initiating events or potentially affect the availability of associated mitigating systems. The applicable documents used for this inspection are located in the Attachment. The inspectors performed a partial walkdown of the 2A EDG during maintenance on the 2B EDG.
b. Findings
No findings of significance were identified.
.2 Complete Walkdown (71111.04S - Two Samples)
a. Inspection Scope
The inspectors performed a complete system walkdown of the systems listed below to identify any discrepancies between the existing equipment lineup and the specified lineup. During the walkdown, system drawings and OIs were used to verify proper equipment alignment and operational status. The inspectors reviewed open maintenance orders (MO) on the system for any deficiencies that could affect the ability of the system to perform its safety function. Inspectors also reviewed unresolved design issues such as temporary modifications, operator workarounds, and items tracked by plant engineering to assess their collective impact on system operation. Additionally, the inspectors reviewed the condition report (CR) database to verify that equipment alignment problems were being identified and appropriately resolved. The inspectors performed a complete walkdown for the following systems:
- Unit 2 component cooling system (CC); and
- Unit 1 SW system.
b. Findings
No findings of significance were identified.
1R05 Fire Protection (71111.05Q - Seven Samples)
a. Inspection Scope
The inspectors conducted a tour of accessible portions of fire areas to assess Constellations control of transient combustible material and ignition sources, fire detection and suppression capabilities, fire barriers, and related compensatory measures when required. The inspectors assessed the material condition of fire suppression and detection equipment to determine whether any conditions or deficiencies existed that could impair the availability of the equipment. The applicable documents used for this inspection are located in the Attachment. The inspectors performed a walkdown of the following areas:
- Unit 1 component cooling room, fire area 15, room 228;
- Unit 2 component cooling room, fire area 12, room 201;
- P-13000-1 transformer, fire area - yard;
- P-13000-2 transformer, fire area - yard;
- Unit 2 switchgear room 27 foot elevation, fire area 18, room 311;
- Unit 2 switchgear room 45 foot elevation, fire area 25, room 407; and
- Unit 1 refueling water tank pump room, fire area 44, room 439.
b. Findings
No findings of significance were identified.
1R11 Licensed Operator Requalification Program
.1 Resident Inspector Quarterly Review (71111.11Q - One Sample)
a. Inspection Scope
On November 19, 2007, the inspectors observed a licensed operator requalification exam scenario to assess operator performance and the adequacy of the licensed operator training program. The scenario involved intake challenges followed by a loss of coolant accident (LOCA). The inspectors focused on high-risk operator actions performed during implementation of emergency operating procedures (EOP), entry into abnormal operating procedures, and classification of the events related to intake problems, a large break LOCA and steam leak issues. The inspectors evaluated the clarity and formality of communications, the completion of appropriate actions in response to alarms, the performance of timely control board operations and manipulations, and the oversight and direction provided by the shift manager. The lists the documents reviewed for this section.
b. Findings
No findings of significance were identified.
.2 Biennial Review (71111.11B - One Sample)
a. Inspection Scope
The following inspection activities were performed using NUREG-1021, Operator Licensing Examination Standards for Power Reactors, IP 71111.11, Licensed Operator Requalification Program, and NRC IMC 0609, Appendix I, Operator Requalification Human Performance SDP, and 10 CFR 55.46, Simulator Rule as acceptance criteria.
The inspectors reviewed documentation of operating history since the last requalification program inspection. The inspectors discussed station operating events with the resident staff. Documents reviewed included NRC inspection reports, CRs, and assignment requests (ARs) that involved human performance issues of licensed operators to ensure that operational events were not indicative of possible training deficiencies.
The inspectors reviewed twelve simulator scenarios and ten job performance measures (JPMs) administered during this current exam cycle to ensure the quality of these exams met or exceeded the criteria established in the Examination Standards and 10 CFR 55.59. In addition, the inspectors did a detailed review of three of the five comprehensive written exams administered.
During the on-site inspection, the inspectors observed the administration of operating examinations to two operating crews and one staff crew. The operating examinations for each crew consisted of two crew simulator scenarios and five JPMs. The examiners observed seven training personnel administering the various components of the exam.
Conformance with Simulator Requirements Specified in 10 CFR 55.46 For the site-specific simulator, the inspectors observed simulator performance during the conduct of the examinations, and reviewed discrepancy reports to verify compliance with the requirements of 10 CFR 55.46.
The inspectors reviewed a sample of simulator tests including malfunction, transient, normal, and steady state tests. The inspectors also reviewed a sample of completed simulator deficiency reports (DRs) from the past two-year period to determine whether the described issues were effectively addressed.
Conformance with operator license conditions was verified by reviewing the following records:
- Nine medical records were reviewed to determine whether the records were complete, that restrictions noted by the doctor were reflected on the individuals license and that the exams were given within 24 months. License restrictions were compared to NRC records.
- A sample of five licensed operator reactivation records were reviewed as well as one full shift of licensed personnel watch-standing documentation for time on shift to verify currency and conformance with the requirements of 10 CFR 55.
- All remediation training records from the past two-year training cycle were reviewed. These records were associated with operators who failed cycle written exams.
Licensees Feedback System.
The inspectors interviewed instructors, training/operations management personnel, and licensed operators for feedback regarding the implementation of the licensed operator requalification program to ensure the requalification program was meeting their needs and was responsive to their noted deficiencies/recommended changes. In addition, the inspectors reviewed feedback summaries submitted by the operators.
On December 20, 2007, the inspectors conducted an in-office review of operator requalification exam results. The inspection assessed whether pass rates were consistent with the guidance of NRC IMC 0609 SDP, Appendix I. The inspectors reviewed the exam results to determine whether:
- Crew failure rate on the dynamic simulator was greater than 20%. (Failure rate was 0.0%)
- Individual failure rate on the dynamic simulator test was less than or equal to 20%. (Failure rate was 1.0%)
- Individual failure rate on the walkthrough test (JPMs) was less than or equal to 20%. (Failure rate was 4.5%)
- More than 75% of the individuals passed all portions of the exam (94% of the individuals passed all portions of the exam).
b. Findings
The inspectors review of a licensed SROs medical records revealed that an ongoing condition necessitated a medication that would require a no solo license restriction.
The SRO did not report his medical condition change in May 2003 to Constellation or the NRC. The Constellation physician assistant discovered the new medication prescribed to the SRO during a routine physical in January 2005, and determined that it was for a medical condition that required a no solo license restriction. Constellation reported the issue to the NRC and processed the required documentation to have the SROs license amended to include the no solo condition.
An Unresolved Item (URI) will track NRC evaluation of this issue until additional NRC review determines whether Constellation personnel failed to timely notify the NRC of a medical condition that resulted in an SRO license restriction and, therefore, was in violation of 10 CFR 50.74. (URI 05000317 & 05000318/2007005-01, Timely NRC notification of SRO license restriction)
1R12 Maintenance Effectiveness (71111.12Q - One Sample)
a. Inspection Scope
The inspectors reviewed the No. 11 and No. 22 containment air coolers (CACs) for the following: 1) appropriate work practices; 2) identifying and addressing common cause failures; 3) scoping in accordance with 10 CFR 50.65(b) of the maintenance rule; 4)characterizing reliability issues for performance; 5) trending key parameters for condition monitoring; 6) charging unavailability for performance; 7) classification in accordance with 10 CFR 50.65(a)(2); and 8) appropriateness of the performance criteria for the CACs classified as (a)(2). Documents reviewed are listed in the Attachment.
b. Findings
No findings of significances were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - Five Samples)
a. Inspection Scope
The inspectors reviewed the following activities to verify that station personnel performed the appropriate risk assessments prior to removing equipment for work. When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed. The inspectors compared the risk assessments and risk management actions performed by station procedure NO-1-117, Integrated Risk Management, to the requirements of 10 CFR 50.65(a)(4), the recommendations of the Nuclear Management and Resources Council 93-01, Revision 2, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, and approved station procedures. In addition, the inspectors assessed the adequacy of Constellations identification and resolution of problems associated with maintenance risk assessments and emergent work activities. Documents reviewed are listed in the Attachment.
- Planned maintenance to transfer all electrical buses to P-13000-2 and de-energize P-13000-1 due to the 500 kV black bus outage (October 2, 2007).
- Planned maintenance to align the alternate 13kV transformer to the 11 service bus after relay calibrations and to support revenue metering testing (October 10, 2007).
- Emergent work on the No. 21 condensate pump breaker malfunction (October 18, 2007).
- Planned down power of Unit 1 due to SLC maintenance on the main rectifier filters (October 20, 2007).
- Planned maintenance on the 23 auxiliary feedwater (AFW) pump and the 2B EDG (December 5, 2007).
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations (71111.15 - Two Samples)
a. Inspection Scope
The inspectors reviewed operability evaluations and/or CRs to verify that the identified conditions did not adversely affect safety system operability or plant safety. The evaluations were reviewed using criteria specified in NRC Regulatory Issue Summary 2005-20, Revision to Guidance formerly contained in NRC Generic Letter 91-18, Information to Licensees Regarding two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability and Inspection Manual Part 9900, Operability Determinations and Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety. In addition, where a component was inoperable, the inspectors verified the TS limiting condition for operation implications were properly addressed. Documents reviewed are listed in the
.
The inspectors performed field walkdowns, interviewed personnel, and reviewed the following items:
- No. 21 shutdown cooling (SDC) HX CC outlet control valve 2-CV-3828 failure (IRE-025-472/OD-07-012); and
- No. 22 AFW pump steam admission valve stroke time test failure (IRE-027-435).
b. Findings
No findings of significance were identified.
1R17 Permanent Plant Modifications (71111.17A - Two Samples)
a. Inspection Scope
The inspectors reviewed two risk-significant permanent plant modification packages.
The inspectors verified that: 1) the design bases, licensing bases, and performance capability of risk-significant structures, systems, and components (SSCs) were not adversely affected or degraded through the modifications; and 2) the modifications performed during increased risk configurations did not place the plant in an unsafe condition. The inspectors also reviewed field change notices that were issued during the installation to confirm that the problems associated with the installation were adequately resolved. Additionally, the inspectors reviewed the affected procedures, drawings, design basis documents, and Updated Final Safety Analysis Report (UFSAR) sections to verify that the affected documents were appropriately updated. The risk-significant permanent plant modification are as follows:
- Implementation of the RCS vacuum fill modification; and
- SW flow instrumentation relocation modification.
b. Findings
No findings of significance were identified.
1R19 Post-Maintenance Testing (71111.19 - Five Samples)
a. Inspection Scope
The inspectors reviewed the post-maintenance tests listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure were consistent with information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data, to verify that the test results adequately demonstrated restoration of the affected safety functions. Documents reviewed are listed in the Attachment.
- No. 11B SRWHX basket strainer differential pressure indicator cleaning of the 11B SRWHX plenum (MO #1200503094).
- No. 12 low pressure safety injection pump motor inspections and relay testing (MO #1200700537 and MO #1200700538).
- 1200703914).
- 2A EDG two-year overhaul inspections (MO #220700773).
- 2B EDG speed control issues during slow speed start for monthly surveillance testing (MO #2200705551).
b. Findings
Introduction:
An NRC-identified finding of very low safety significance (Green)associated with an NCV of TS 5.4.1.a, Procedures, for Units 1 and 2 was identified because Constellation did not establish and maintain an adequate procedure to vent and flush the SW strainer pressure transmitters and flow controllers.
Description:
On July 23, 2007, IM technicians performed a vent and flush of the SW instrumentation transmitters twice before returning the 11B SRWHX back to service following maintenance activities. Approximately ten hours later, operators declared the 11B SRWHX inoperable when the SW strainer pressure transmitter (1-PDIS-5210A)prevented the automatic flush of the 11B SW strainer. The malfunction of the pressure transmitter affected the flushing valve in that debris accumulated in the strainer and caused a reduction in saltwater flow to the SRWHX. Constellation initiated a CR (IRE-024-194) and concluded that this was most likely due to air intrusion in the sensing line of the transmitter following cleaning of the 11B SRWHX. Following a review of the corrective actions and the event, the inspectors identified that the procedure used to perform the evolution did not provide operators and technicians with adequate procedural guidance on venting and flushing the SW instrumentation. The inspectors observed the technicians perform this evolution as a skill of craft or trained proficiency with a one-page line-up to open and shut valves with no time duration for the vent and flush of the instrumentation.
The inspectors also identified that numerous air intrusion problems occurred in the past where SW instrumentation transmitters read lower than expected following maintenance that included subsequent venting activities. However, the corrective actions associated with these issues focused on performing additional venting and flushing and did not evaluate whether the initial vent or flush provided an adequate duration of time such that it could remove the air from the instrument lines.
Constellation entered this issue into their CAP for resolution as IRE-024-194 and IRE-027-939. Immediate corrective actions following the July 23, 2007, event included instructions to extend the time that technicians vent and flush the SW strainer instrumentation. The planned corrective action going forward is to review and revise procedure OI-29, as necessary, to incorporate extended venting and flushing guidance.
The performance deficiency is that Constellation did not establish and maintain an adequate procedure to vent and flush the SW strainer pressure transmitters. This resulted in an inoperable train of SRW subsystem following maintenance on the 11B SRWHX. This issue was considered an NRC-identified finding because Constellation was not previously aware that OI-29 was inadequate.
Analysis:
This finding is more than minor because it is associated with the procedure quality attribute of the Mitigating System cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of the SRW system that respond to initiating events to prevent undesirable consequences. Specifically, the inadequate vent and flush of the SW strainer instrumentation rendered one-train of SRW unavailable. The inspectors evaluated the significance of this finding using Phase 1 of the IMC 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations. The inspectors determined that the finding was of very low safety significance because it is not a design or qualification deficiency, does not represent a loss of a system safety function or safety function of a single train for greater than its TS AOT, and does not screen as potentially risk significant due to external events. This finding has a cross-cutting aspect in the area of problem identification and resolution because Constellation did not thoroughly evaluate prior SRWHX strainer venting issues to address and fully resolve problems in a timely manner commensurate with its safety significance (P.1.c of IMC 0305).
Enforcement:
TS 5.4.1.a, Procedures, requires that written procedures shall be established, implemented, and maintained for activities specified in Regulatory Guide 1.33, Appendix A, Revision 2. Regulatory Guide 1.33, Appendix A, item 3, states, in part, that instructions for filling and venting should be prepared, as appropriate for the service water system. Contrary to these requirements, prior to July 23, 2007, Constellation did not establish and maintain an adequate procedure to vent and flush the SW strainer pressure transmitters. Specifically, OI-29, SW System, did not provide operations and IM technicians with adequate procedural guidance on venting and flushing the SW strainer instrumentation in order to mitigate potential air intrusion following maintenance activities on the SRWHXs. Because this issue is of very low safety significance (Green) and Constellation entered this issue into their CAP as IRE-024-194 and IRE-027-939, this violation is being treated as an NCV consistent with Section VI.A.1 of the NRC Enforcement Policy. (NCV 05000317 and 05000318/2007005-02: Inadequate vent procedure for the SW strainer pressure transmitters)
1R22 Surveillance Testing (71111.22 - Four Samples)
a. Inspection Scope
The inspectors observed and/or reviewed the surveillance tests listed below associated with selected risk-significant SSCs to determine whether the testing adequately demonstrated the ability to perform its intended safety function. The inspectors also verified that proper test conditions were established as specified in the procedures, no equipment preconditioning activities occurred, and that acceptance criteria had been satisfied. The documents reviewed during this inspection are listed in the Attachment.
- STP-O-65G-2, component cooling valve quarterly test
- STP-O-73C-2, component cooling pump quarterly test
- STP-O-73A-2, SW pump and valve operability in-service test
- STP-O-8A-1, test of 1A diesel generator and 11 4kV bus loss of coolant incident sequencer.
b. Findings
No findings of significance were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation (71114.06 - One Sample)
a. Inspection Scope
The inspectors observed portions of a site emergency response drill exercise conducted on December 18, 2007, to assess licensed operators and site emergency response in the area of emergency preparedness. This training exercise focused on equipment failures and operator challenges that would typically exist during a significant event that resulted in emergency classification being reported to state and local officials. The inspectors also observed and evaluated the required procedural transitions and associated event classifications.
b. Findings
No findings of significance were identified.
1EP7 Force-On-Force Exercise Evaluation (71114.07 - One Sample)
a. Inspection Scope
On November 7, 2007, the inspectors observed drill players in response to a site emergency preparedness drill conducted in conjunction with a Force-on-Force exercise, documented in inspection report 05000317/318-2007201. The inspectors observed utilization of the security related procedures including classification of the scenario within time requirements. The inspectors also observed portions of the post drill critique to determine whether the evaluators identified observed deficiencies.
b. Findings
No findings of significance were identified.
RADIATION SAFETY
Cornerstone: Public Radiation Safety
2PS2 Radioactive Materials Processing and Shipping (71122.02 - Six Samples)
a. Inspection Scope
The inspectors reviewed the solid radioactive waste system description in the UFSAR and the recent radiological effluent release reports for information on the types and amounts of radioactive waste disposed, and reviewed the scope of Constellations audit program to verify that it meets the requirements of 10 CFR 20.1101C.
The inspectors walked down the liquid and solid radioactive waste processing systems to verify and assess that the current system configuration and operation agree with the descriptions contained in the UFSAR and in the Process Control Program. The inspectors reviewed the status of any radioactive waste process equipment that is not operational and/or is abandoned in place and verified that the changes were reviewed and documented in accordance with 10 CFR 50.59, as appropriate. The inspectors reviewed current processes for transferring radioactive waste resin and sludge discharges into shipping/disposal containers to determine if appropriate waste stream mixing and/or sampling procedures, and methodology for waste concentration averaging provide representative samples of the waste product for the purposes of waste classification as specified in 10 CFR 61.55 for waste disposal.
Waste Characterization & Classification The inspectors reviewed the radiochemical sample analysis results for Constellations radioactive waste streams; reviewed Constellations use of scaling factors and calculations used to account for difficult-to-measure radionuclides; and verified that Constellations program assures compliance with 10 CFR 61.55 and 10 CFR 61.56 as required by Appendix G of 10 CFR Part 20. The inspectors reviewed Constellations program to ensure that the waste stream composition data accounts for changing operational parameters and thus remains valid between the annual or biennial sample analysis updates.
Shipment Preparations The inspectors observed shipment packaging, surveying, labeling, marking, placarding, vehicle checks, emergency instructions, disposal manifest, shipping papers provided to the driver. The inspectors verified that the requirements of any applicable transport cask Certificate of Compliance have been met. The inspectors verified that Constellation was authorized to receive the shipment packages; and, observed radiation workers during the conduct of radioactive waste processing and radioactive material shipment preparation activities. The inspectors assessed whether shippers were knowledgeable of the shipping regulations and of sufficient skill to accomplish the package preparation requirements for public transport with respect to NRC Bulletin 79-19 and 49 CFR Part 172 Subpart H, and verified that Constellations training program provides training to personnel responsible for the conduct of radioactive waste processing and radioactive material shipment preparation activities.
Shipping Records The inspectors sampled non-excepted package shipment records and reviewed these records for compliance with NRC and Department of Transportation requirements.
Problem Identification and Resolution The inspectors reviewed licensee event reports, special reports, audits, State agency reports, and self-assessments related to the radioactive material and transportation programs performed since the last inspection to determine that identified problems were entered into the CAP for resolution. The inspectors also reviewed corrective action reports written against the radioactive material and shipping programs since the previous inspection.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES (OA)
4OA1 Performance Indicator (PI) Verification (71151 - Ten Samples)
.1 Mitigating System
a. Inspection Scope
The inspectors reviewed Constellations PI program to evaluate, collect and report information on Mitigating Systems Performance Index (MSPI). The MSPI systems were reviewed for the period of January 1, 2007, through December 31, 2007. The inspectors used the guidance provided in Nuclear Energy Institute (NEI) 99-02, Revision 5, Regulatory Assessment PI Guideline to assess the accuracy of Constellations collection and reporting of PI data. The inspectors reviewed system unavailability data, monitored component demands, demand failure data, and the consolidated data entry MSPI derivation reports for both unavailability index and unreliability index. Additionally, the inspectors reviewed out-of-service logs, operating logs, and the maintenance rule database to determine the accuracy and completeness of the reported unavailability data. This inspection activity represents the completion of ten samples for Unit 1 and Unit 2.
b. Findings
No findings of significance were identified.
.2 Physical Protection
a. Inspection Scope
The inspectors reviewed Constellations PI data for gathering, processing, evaluating, and submitting data for the Fitness-for-Duty, Personnel Screening, and Protected Area Security Equipment PIs for the period May 2006 through April 2007. The inspectors verified that the PIs had been properly reported as specified in NEI 99-02. The review included Constellations tracking and trending reports, personnel interviews, and security event reports for the PI data collected since the last security baseline inspection. The inspectors noted from Constellations submittal that there were no reported failures to properly implement the requirements of 10 CFR 73 and 10 CFR 26 during the reporting period.
The security PIs were inspected during the annual security baseline inspection and the documentation was inadvertently omitted from the security baseline inspection report issued previously in 2007.
b. Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems (71152 - Two Samples)
.1 Reviews of Items Entered Into the CAP
a. Inspection Scope
The inspectors performed a daily screening of items entered into Constellations CAP as required by IP 71152, Identification and Resolution of Problems. The review facilitated the identification of potentially repetitive equipment failures or specific human performance issues for follow-up inspection. This was accomplished by reviewing the description of each new CR and attending screening meetings.
b. Findings
No findings of significance were identified.
.2 Annual Sample: Unit 1 No. 11 CAC Motor Failure
a. Inspection Scope
The inspectors completed an in-depth review of Constellations evaluation and corrective actions associated with a December 16, 2006 failure of the Unit 1 No. 11 CAC motor.
The inspectors verified that Constellation adequately addressed and fully understood the issue. The corrective actions were reviewed to ensure that the full extent of the issue was identified, an appropriate evaluation was performed and appropriate corrective actions were specified, prioritized and implemented. The inspectors evaluated these actions against the requirements of Constellations CAP and 10 CFR Part 50, Appendix B. Additionally, Constellations personnel were interviewed with respect to the effectiveness of the implementation of these corrective measures.
b. Assessment and Findings No findings of significance were identified.
The inspectors determined that the corrective actions associated with the failure of the Unit 1 No. 11 CAC motor complied with Constellations procedures. The inspectors concluded that the apparent cause addressed the failure mechanism and considered the extent of condition of the remaining seven CACs.
.3 Semi-Annual Review
a. Inspection Scope
The inspectors performed a semi-annual review to identify trends that might indicate the existence of a more significant safety issue. The inspectors reviewed CCNPP Units 1 and 2 PI monthly reports, CRs, system health reports, quality assurance audits, self-assessment reports, maintenance reports, and NRC inspection reports and interviewed key personnel to evaluate if any adverse trends existed.
b. Assessment and Observations No findings of significance were identified.
The inspectors noted an adverse trend related to an increase in the number of performance issues related to inadequate procedures. This trend included both NRC and Constellation identified issues within the last four quarters of which three concerned the lack of appropriate acceptance criteria in surveillance procedures. This adverse trend of inadequate procedures was not previously identified by Constellation.
Constellation entered this issue into their CAP as IRE-028-619.
4OA3 Event Followup (71153 - Two Samples)
.1 Operating Above the Licensed Power Limit
a. Inspection Scope
On December 8, 2007, during a load change to return Unit 2 from 84 percent reactor power to 100 percent reactor power following main turbine control valve testing, operators inadvertently increased the two-minute instantaneous thermal power above the licensed power limit of 2700 MWTH. The maximum power level attained was 2741 MWTH. The total time above the licensed limit was approximately 15 minutes. The inspectors conducted a follow-up inspection to gain an understanding of the event and to assess the appropriateness of operator actions. The inspectors interviewed the shift manager and reviewed Constellation procedures, the prompt investigation, the control room logs, and related supporting documentation.
b. Findings
Introduction:
A self-revealing NCV of very low safety significance (Green) of License Condition 2.C.(1) to Renewed Facility Operating License DPR-69, occurred when Constellation operated Unit 2 in excess of the licensed power limit of 2700 MWTH.
Description:
On December 8, 2007, during a load change to return Unit 2 from 84 percent reactor power to 100 percent reactor power following main turbine control valve testing, operators inadvertently increased the two-minute instantaneous thermal power above the licensed power limit of 2700 MWTH. The maximum power level attained was 2741 MWTH. The total time above the licensed limit was approximately 15 minutes.
Constellation conducted a prompt investigation and determined that operators did not adequately stop the power ascension due to distractions with the withdrawal of CEAs to the full out position and the inappropriate use of turbine load (turbine load was already at 100 percent) to maintain cold leg temperature within TS limits. Following the event, Constellation took immediate corrective action to remediate the licensed operators controlling the evolution and entered this issue into their CAP (IRE-027-571).
The inspectors determined that operation in excess of 2700 MWTH for approximately 15 minutes was a violation of Constellations license condition. Based on the cause of the event (human error) and the duration of the transient, the inspectors concluded that the power excursion above 2700 MWTH was not due to normal fluctuations of plant parameters while operating at or near the licensed power limit. The inspectors determined that operators did not adequately monitor plant parameters as required by OI-2B, CVCS Boration, Dilution and Makeup Operations, and take appropriate action to stop the power increase which resulted in exceeding the licensed thermal power limit.
The performance deficiency is that Constellation operated Unit 2 in excess of its licensed power limit of 2700 MWTH.
Analysis:
The finding is more than minor because it is associated with the human performance attribute of the Barrier Integrity cornerstone and affects the cornerstone objective to provide a reasonable assurance that physical design barriers, such as fuel cladding, protect the public from radionuclide releases caused by accidents or events.
Specifically, operation above the licensed limit reduced the 2 percent uncertainty margin assumed in the accident analysis to protect the fuel cladding from damage. In accordance with NRC IMC 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, the inspectors conducted a Phase 1 SDP screening. The inspectors determined that the finding was of very low safety significance (Green) because the reduction of the uncertainty margin assumed in the accident analysis was only associated with the fuel barrier integrity and did not affect the reactor coolant system or containment barriers. This finding has a cross-cutting aspect in the area of Human Performance because Constellation did not effectively communicate expectations of procedural compliance in that the operators did not appropriately monitor plant parameters during the power increase (H.4.b per IMC 0305).
Enforcement:
License Condition 2.C.(1) to Renewed Facility Operating License DPR-69, specifies that the Constellation is authorized to operate the facility at reactor steady-state core power levels not in excess of 2700 megawatts thermal. Contrary to this requirement, on December 8, 2007, while returning to 100 percent power following main turbine valve testing, Constellation operated in excess of the licensed limit for approximately 15 minutes. Because this violation is of very low safety significance (Green) and Constellation entered the issue into their CAP (IRE-027-571), this violation is being treated as an NCV consistent with Section VI.A.1 of the NRC Enforcement Policy. (NCV 05000318/2007005-03: Reactor Operation Above Licensed Power Limit)
.2 Down Power of Unit 1 Due to SLC Filter Replacement
a. Inspection Scope
On October 20, 2007, operators reduced power to less than 10 percent to replace the Unit 1 SLC system filters. The filter replacement was due to the rectifier and main filter differential pressure trends. Following the replacement of the filters, operators restored the unit to 100 percent power on October 21, 2007. The inspectors observed and assessed the planned down-power, and evaluated the performance of the licensed operators. The inspectors also reviewed control room procedures and operator logs to determine if operators performed appropriate actions in accordance with their training and established station procedures. The Attachment lists the documents reviewed for this event.
b. Findings
No findings of significance were identified.
4OA5 Other Activities
.1 (Closed) URI 05000318/2007004-04, Unit 2 Pressurizer Safety Valve Low Lift Setting
An unresolved item (URI) was opened in NRC Inspection Report 05000318/2007004 for a potential performance deficiency associated with the setting of the pressurizer safety valves (PSVs). Constellations apparent cause evaluation completed in March 2007 determined that the PSV low set point was due to degraded threads on the bonnet and compression screw. The as-found condition of the compression screw failed a go/no go gauge test of the threads. The apparent cause concluded that this condition was not detected because the PSV was refurbished and tested in 2003 prior to incorporating the gauge test into the vendor repair procedure. However, when questioned by the inspectors, Constellation determined that the gauge test was actually incorporated in the vendor maintenance procedure in 2001. Constellation wrote condition report IRE-025-193 to investigate this discrepancy.
The inspectors conducted a follow-up inspection to assess Constellations resolution of this issue. Upon further review and discussions with the vendor, Constellation determined that the degraded threads on the bonnet and compression screw did not cause the low lift setting. As a result, the inspectors determined that the gauge test most likely would not have identified the degraded conditions that led to the low lift setting of the PSV. Therefore, the inspectors concluded that there was no performance deficiency associated with the use of the gauge test and the subsequent setting of the PSVs. This URI is closed.
.2 (Closed) URI 05000318/2006005-05, EOP-0 Issues Identified Following November 16,
2006 Trip An URI was opened in NRC Inspection Report 05000318/2006005 for a potential performance deficiency associated with the adequacy of steps in EOP-0, Post-Trip Immediate Actions. During the November 16, 2006, reactor trip event, one pressurizer power operated relief valve (PORV), which opened to control RCS pressure, remained opened for longer than expected (about 90 seconds) due to a mechanical stem problem.
The inspectors noted that the PORV had closed prior to the operators having an opportunity to consider closing the PORV block valve to terminate the unwanted pressure reduction. The inspectors reviewed whether EOP-0 provided adequate steps for operator to take action for a stuck open PORV.
The inspectors conducted a follow-up inspection to resolve concerns with this issue.
Constellation completed an assessment of this issue and determined that EOP-0 should be clarified concerning what conditions constitute and open or closed PORV such that appropriate operator actions can be taken. In addition, Constellation determined that the EOP-0, Section H, Perform Diagnostic Actions, was adequate based on the diagnostic table used to aid the operators in determining the recommended course of action along with other available information. The inspectors reviewed Constellations assessment and corrective actions associated with this issue and determined that there was no performance deficiency. This URI is closed.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On January 11, 2008, the resident inspectors presented the inspection results to Mr. Bauder and other members of your staff who acknowledged the findings. The inspectors asked Constellation whether any of the material examined during the inspection should be considered proprietary. No proprietary information was identified.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Constellation Personnel
- J. Spina, Site Vice President
- D. Bauder, Plant General Manager
- P. Beavers, Engineering Supervisor
- K. Burroughs, Chemistry Supervisor
- J. Branyan, Surveillance Test Coordinator
- S. Dean, Operations Manager
- M. Flaherty, Engineering Manager
- P. Furio, Licensing Supervisor
- J. Gaines, Licensing Director
- J. Gines, Principal Consultant
- K. Gould, Radiation Protection Manager
- G. Gwiazdowski, Director, Nuclear Security
- S. Henry, Engineering Supervisor
- W. Holston, Training Manager
- J. Lenhart, Radiation Protection Supervisor
- R. Pace, General Supervisor Operations Training
- B. Pomphrey, Assistant General Supervisor
- T. Riti, General Supervisor Operations
- A. Simpson, Senior Licensing Engineer
- C. Walker, Simulator Tester
- J. York, Supervisor Radiation Protection
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Open
Opened and Closed
- 05000317&318/2007005-02 NCV Inadequate Vent Procedure for the SW Strainer Pressure Transmitters (Section 1R19)
- 05000318/2007005-03 NCV Reactor Operation Above Licensed Power Limit (Section 4OA3)
Closed
- 05000318/2007004-03 URI Unit 2 Pressurizer Safety Valve Low Lift Setting (Section 4OA5)
- 05000318/2006005-04 URI EOP-0 Issues Identified Following the November
16, 2006 Trip (Section 4OA5)
Discussed
None