IR 05000317/2009003
| ML092120046 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 07/30/2009 |
| From: | Glenn Dentel Reactor Projects Branch 1 |
| To: | Spina J Constellation Generation Group |
| Dentel, G RGN-I/DRP/BR1/610-337-5233 | |
| References | |
| IR-09-003 | |
| Download: ML092120046 (36) | |
Text
July 30, 2009
SUBJECT:
CALVERT CLIFFS NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000317/2009003 AND 05000318/2009003
Dear Mr. Spina:
On June 30, 2009, 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 July 15, 2009, with you 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 of very low safety significance (Green). This finding was determined to involve a violation of NRC requirements. Additionally, a licensee-identified violation, which was determined to be of very low safety significance, is listed in this report. However, because the findings are 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 Calvert Cliffs.
In addition, if you disagree with the characterization of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region 1, and the NRC Resident Inspector at CCNPP. The information you provide will be considered in accordance with Inspection Manual Chapter (IMC) 0305. 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 T. Dentel, Chief Reactor Projects Branch 1 Division of Reactor Projects
Docket Nos.: 50-317, 50-318 License Nos.: DPR-53, DPR-69
Enclosure:
Inspection Report 05000317/2009003 and 05000318/2009003 w/Attachment: Supplemental Information
cc w/encl:
M. J. Wallace, Vice-Chairman, Constellation Generation H. B. Barron, President, CEO & CNO C. W. Fleming, Esq., Senior Counsel, Nuclear Generation J. Gaines, Director, Licensing, CCNPP L. Larragoite, Manager, Nuclear Safety and Security, CCNPP S. Gray, Program Manager, Power Plant Assessment Program, Maryland Department of Natural Resources K. Burger, Esquire, Maryland People's Counsel P. Birnie, Esquire, Co-Director, Maryland Safe Coalition M. Griffen, Maryland Department of the Environment W. Parren, President, Calvert County Board of Commissioners R. Hickok, NRC Technical Training Center S. Pattison, SLO (2)
SUMMARY OF FINDINGS
IR 05000317/2009003, 05000318/2009003; 4/1/09 - 6/30/09; Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2: Equipment Alignment.
The report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. A Green finding, which was determined to be a non-cited violation (NCV), was identified. The significance of 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.
Cornerstone: Mitigating Systems
- Green.
The inspectors identified an NCV of 10 CFR Part 50, Appendix B, Criterion XI,
Test Control, for Units 1 and 2 because Constellation did not establish an adequate test program to assure that the auxiliary feedwater (AFW) pump room emergency ventilation system would perform satisfactorily in service. Specifically, the performance evaluations used to determine the equipment performance of the emergency ventilation system did not incorporate the requirements and acceptance limits contained in the Updated Final Safety Analysis Report (UFSAR). This resulted in Constellation not recognizing that the AFW pump room emergency ventilation system did not meet the design requirements stated in the UFSAR. Constellation entered this issue into their corrective action program (CAP) for resolution as condition report (CR)-2008-002833.
The immediate corrective action included performing an operability determination to verify the operability of the Unit 1 and 2 turbine driven auxiliary feedwater (TDAFW)pumps. The planned corrective actions included the installation of larger ventilation fans to obtain the required flow rate and to create a preventive maintenance task to measure the airflow for each emergency ventilation fan.
This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affects the cornerstone objective to ensure the availability and reliability of the AFW system, which responds to initiating events to prevent undesirable consequences (i.e., core damage). The inspectors determined that the finding is of very low safety significance because it is not a design or qualification deficiency, did not represent a loss of a safety function of a system or a single train greater than its Technical Specifications (TS) allowed outage time, and did not screen as potentially risk significant due to external events. Since the performance deficiency was determined to be the result of a latent issue and does not reflect current performance, no cross-cutting aspect is assigned. (Section 1R04)
Other Findings
A violation of very low safety significance, that was identified by Constellation, has been reviewed by the inspectors. Corrective actions taken or planned by Constellation have been entered into their CAP. This violation and the corrective action tracking numbers are listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status
Calvert Cliffs Unit 1 began the inspection period at 100 percent power. On June 6, 2009, operators reduced power to 85 percent to perform main turbine valve testing. Operators returned the unit to 100 percent power on the same day. The unit remained at 100 percent power for the remainder of the inspection period.
Calvert Cliffs Unit 2 began the inspection period at 100 percent power. On June 13, 2009, operators reduced power to 85 percent to perform main turbine valve testing. Operators returned the unit to 100 percent power on the same day. 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 - Two Samples)
a. Inspection Scope
==
The inspectors reviewed the adverse weather preparation and mitigating strategies before the onset of hot weather operations and the high grid loading summer season.
This review included an assessment of Nuclear Operations Administrative Procedure NO-1-119, Seasonal Readiness. The inspectors assessed the effectiveness of Constellations preparations for hot weather and grid related stress conditions to evaluate the sites readiness for seasonal susceptibilities. Risk-significant systems affected by hot weather and grid related stresses were selected for review. The review included the service water (SRW) system, component cooling (CC) system, and the 2B emergency diesel generator (EDG). The inspectors also performed a partial walkdown of the onsite (480V) and offsite (500 kilovolt (kV)) electrical systems. The inspectors interviewed control room operators and system engineers to ensure protective measures applicable to these risk-significant systems were available. This inspection satisfied two inspection samples for review of risk-significant systems during seasonal susceptibilities and grid related stress conditions. Documents reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
1R04 Equipment Alignment
.1 Partial Walkdown (71111.04Q - Four Samples)
a. Inspection Scope
The inspectors conducted partial walkdowns to verify equipment alignment of selected risk significant systems. 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 Constellation had properly identified and resolved equipment alignment problems that could cause initiating events or potentially affect the availability of associated mitigating systems. The inspectors performed a partial walkdown of the following systems:
- No. 22 steam generator (SG) manual isolation valves due to planned maintenance on the SG surface blowdown control valves; and
CCHX inlet valve (1-CV-5160).
b. Findings
No findings of significance were identified.
.2 Complete Walkdown (71111.04S - One Sample)
a. Inspection Scope
The inspectors performed a complete system walkdown of the Unit 1 and 2 AFW pump room emergency ventilation systems to identify any discrepancies between the existing equipment lineup and the specified lineup. During the walkdown, the inspectors used system drawings and operating instructions (OIs) to verify proper equipment alignment and the operational status. The inspectors reviewed open maintenance orders (MOs) 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.
b. Findings
Introduction:
The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, for Units 1 and 2 because Constellation did not establish an adequate test program to assure that the AFW pump room emergency ventilation system would perform satisfactorily in service. Specifically, the performance evaluations used to determine the equipment performance of the safety-related AFW emergency ventilation system did not incorporate the requirements and acceptance limits contained in the UFSAR.
Description:
During a review of the AFW pump room emergency ventilation system, the inspectors had concerns about the ventilation system configuration. In response to this concern, Constellation initiated a condition report (CR-2008-002293) and measured the AFW pump room emergency ventilation flow rates to evaluate the system configuration.
The results of the tests revealed that the flow rates were less than the design requirement stated in the UFSAR. The UFSAR states, in part, that the emergency ventilation system can circulate 2,000 cubic feet per minute (CFM) of air between the mechanical equipment room at Elevation 50 of the Auxiliary Building and the AFW pump room at Elevation 120 of the Turbine Building. However, Constellation found that the flow rates for both trains of the AFW pump room emergency ventilation cooling system were significantly less than the nominal design flow rate of 2,000 CFM. The inspectors reviewed the results of the flow tests and identified that the monthly performance evaluation used to determine the equipment performance of the emergency ventilation fans did not incorporate the requirements contained in the UFSAR. The inspectors noted that the performance evaluation only checked for the fans running with some amount of air supplied to the AFW pump room with no acceptance criteria. The inspectors determined that a performance deficiency existed in that Constellation did not establish an adequate test program to assure that the safety-related AFW pump room emergency ventilation cooling system would perform satisfactorily in service.
Constellation entered this issue into their CAP as CR-2008-002833 and conducted an operability review to evaluate all the safety-related AFW pump room equipment required to support the AFW system during an emergency shutdown of the plant. Constellation performed a re-analysis of the AFW pump room heat up computer model with the degraded flow rate condition and determined that the peak room temperature would not exceed a maximum of 144.9 degrees Fahrenheit (°F) during a design-basis accident (DBA). This calculated peak room temperature was within the vendors limiting temperature condition for operation of the air-cooled bearings for the TDAFW pumps, which were the most limiting components in the AFW pump room. Constellation concluded, in consultation with the vendor, that the air-cooled bearings of the TDAFW pumps would remain operable with a maximum room temperature of up to 150°F during a DBA.
Based on the information developed during the inspection, the inspectors noted that Constellation determined that the most likely cause was an initial construction setup issue in that the ventilation fans were not designed for the expected system resistance in the ductwork. The inspectors determined that the performance deficiency was the result of a latent issue and Constellation did not have a reasonable opportunity to identify the problem since the performance evaluation only focused on the fans running with some amount of airflow and that there were no failed performance evaluations identified. The planned corrective actions for this issue included the installation of larger ventilation fans to obtain the required flow rate and to create a preventive maintenance task to measure the airflow for each emergency ventilation fan on a periodic basis.
Analysis:
The inspectors determined that a performance deficiency existed in that Constellation did not establish an adequate test program to assure that the safety-related AFW pump room emergency ventilation system would perform satisfactorily in service. Specifically, the performance evaluation did not contain acceptance limits, which resulted in Constellation not recognizing that the AFW pump room emergency ventilation system did not meet the design requirements stated in the UFSAR. The finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affects the cornerstone objective to ensure the availability and reliability of the AFW system, which responds to initiating events to prevent undesirable consequences (i.e., core damage). Additionally, the finding is similar to example 3.i in Appendix E of IMC 0612, in that the facility was not consistent with the UFSAR and required that an analysis be re-performed to ensure that accident analysis requirements were met. The inspectors evaluated this finding using IMC 0609 Attachment 4, Phase 1 - Initial Screening and Characterization of Findings.
The inspectors determined that the finding is of very low safety significance (Green)because it is not a design or qualification deficiency, did not represent a loss of a safety function of a system or a single train greater than its TS allowed outage time, and did not screen as potentially risk significant due to external events. Since the performance deficiency was determined to be the result of a latent issue and does not reflect current performance, no cross-cutting aspect is assigned.
Enforcement:
10 CFR Part 50, Appendix B, Criterion XI, Test Control, states, in part, a test program shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents.
Contrary to this requirement, on January 23, 2009, the inspectors identified that Constellation did not establish an adequate test program to assure that the safety-related AFW pump room emergency ventilation system would perform satisfactorily in service. Specifically, the performance evaluation did not contain acceptance limits contained in the UFSAR, which resulted in Constellation not recognizing that the AFW pump room emergency ventilation system did not meet the design requirements stated in the UFSAR. Because this violation is of very low safety significance (Green) and Constellation entered this issue into their CAP for resolution as CR-2008-002833, this violation is being treated as an NCV consistent with Section VI.A.1 of the NRC Enforcement Policy. (NCV 05000317/318/2009003-01: Inadequate Test Control associated with the Safety-Related Auxiliary Feedwater Pump Room Emergency Ventilation System)
==1R05 Fire Protection (71111.05Q - Five Samples) Fire Protection Tours
a. Inspection Scope
==
The inspectors conducted a tour of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that combustibles and ignition sources were controlled in accordance with Constellations administrative procedures; the fire detection and suppression equipment was available for use; passive fire barriers were maintained in good material condition; and compensatory measures for out-of-service, degraded, or inoperable fire protection equipment were implemented in accordance with Constellations fire plan:
- Unit 1 fan equipment pump room, fire area 14, room 225.
- Unit 2 cable spreading room, fire area 16, room 306.
- Unit 1 cable spreading room, fire area 17, room 302.
- Unit 2 east piping penetration room, fire area 11, room 310.
- 0C (station blackout) diesel generator building, fire area EDG0C, rooms SB202 and SB102.
b. Findings
No findings of significance were identified.
==1R07 Heat Sink Performance (71111.07A - One Sample)
a. Inspection Scope
==
The inspectors reviewed the thermal performance test and inspection activities for the No. 22 CCHX. The inspectors reviewed the performance data and evaluated the test acceptance criteria to ensure that the design basis requirements were satisfied. The inspectors evaluated the heat transfer capabilities based on completed flow verification tests to ensure that specific safety functions could be performed in accordance with design specifications. The inspectors also reviewed Constellations periodic maintenance methods to verify that they conformed to the guidelines delineated in Electric Power Research Institute (EPRI) Report NP-7552, Heat Exchanger Performance Monitoring Guidelines.
b. Findings
No findings of significance were identified.
1R11 Licensed Operator Requalification Program
Resident Inspector Quarterly Review (71111.11Q - One Sample)
a. Inspection Scope
On May 19, 2009, the inspectors observed a licensed operator requalification scenario to assess operator performance and the adequacy of the licensed operator-training program. The scenario involved equipment malfunctions, operator challenges, and security issues that required operators to implement the alarm response manual, OIs, abnormal operating procedures (AOPs), emergency operating procedures (EOPs), and emergency action level (EAL) criteria. The inspectors focused on high-risk operator actions performed during the implementation of AOPs and EOPs. The inspectors verified the clarity and formality of communications, the completion of appropriate operator actions in response to alarms, the performance of timely control board operations and manipulations, and that the oversight and direction provided by the shift manager were in accordance with Constellations administrative and technical procedures.
b. Findings
No findings of significance were identified.
==1R12 Maintenance Effectiveness (71111.12Q - Two Samples)
Quarterly Review
a. Inspection Scope
==
The inspectors reviewed the maintenance effectiveness of the samples listed below for the following: 1) appropriate work practices; 2) identifying and addressing common cause failures; 3) scoping in accordance with 10 CFR Part 50.65(b) of the maintenance rule; 4) characterizing reliability issues for performance; 5) trending key parameters for condition monitoring; 6) recording unavailability for performance; 7) classification and reclassification in accordance with 10 CFR Part 50.65(a)(1) or (a)(2); and 8)appropriateness of performance criteria for structures, systems, and components (SSCs)classified as (a)(2) and/or appropriateness and adequacy of goals and corrective actions for SSCs classified as (a)(1).
- No. 22 SW pump differential pressure in the action range (CR-2009-002962).
- Unit 2 wide range noble gas monitor (WRNGM) high range detector indicating erratically (CR-2009-003436).
b. Findings
No findings of significance were identified.
==1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - Six Samples)
a.
==
Inspection Scope
The inspectors reviewed the following activities to verify that Constellation performed the appropriate risk assessments for planned maintenance of out of service equipment and emergent work. For the emergent work activities performed by station personnel, the inspectors verified that Constellation promptly reassessed and managed the plant risk.
The inspectors compared the risk assessments and risk management actions with station procedure NO-1-117, Integrated Risk Management, and Constellations risk assessment tool to the requirements of 10 CFR Part 50.65(a)(4) and the recommendations of the Nuclear Management and Resources Council 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. In addition, the inspectors assessed the adequacy of Constellations identification and resolution of problems associated with maintenance risk assessments and emergent work activities.
- Emergent risk assessment due to the No. 23 condensate booster pump tripping on low suction pressure on April 2, 2009.
- Planned maintenance on the No. 22 SW pump on April 7, 2009.
- Emergent risk assessment due to the No. 11 CCHX inlet valve failure to stroke in the open position on May 28, 2009.
- Planned maintenance on the No. 11 instrument air compressor on April 29, 2009.
- Planned maintenance on the 1A EDG on May 11, 2009.
- Emergent risk assessment due to the 0C EDG turbocharger high exhaust temperature issue on June 15, 2009.
b. Findings
No findings of significance were identified.
==1R15 Operability Evaluations (71111.15 - Seven 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. The inspectors performed field walkdowns, interviewed personnel, and reviewed the following items:
- Unit 2 WRNGM reading lower than expected count rates (CR-2009-003436/FA-09-003);
- 1A EDG output breaker over-current protective relay timing setting low (CR-2009-003574);
- Unit 2 pressurizer safety valve temperature profiles are higher than the specified range (CR-2009-003660/OD-09-006);
- Unit 1 reactor protection system received spurious trip of channel B for trip unit 10 (axial shape index) (CR-2009-003950);
- 1A EDG possible failure to evaluate all loads at the maximum frequency (CR-2009-003933); and
- Unit 1 SW check valve 1-SW-103 inoperable due to a leak in the seat (CR-2009-004108).
b. Findings
Introduction:
The inspectors identified an unresolved item (URI) associated with the compensatory actions for having the WRNGM out of service.
Description:
On May 4, 2009, the Unit 2 WRNGM failed. Constellation wrote a functionality assessment to address the degraded condition of the WRNGM being out of service for greater than 7 days. The inspectors reviewed the functionality assessment and questioned the ability of operators to implement the compensatory actions stated in the assessment. Compensatory actions included taking a hand held radiation monitor measurement on the Auxiliary Building roof at a line marked 10 meters from the plant main vent. ERPIP-821, Accidental Radioactivity Release Monitoring, and Sampling Methods, gives guidance on taking the measurement and converting the radiation measurement to a release rate. The release rate is compared to the values in EAL Table A.3-1, Effluent Monitor Classification Thresholds for Effluent Monitors, and is used to calculate a dose projection which is compared to the values in EAL Table A.3-2, Dose Projection/Environment Measurement Classification Thresholds, to determine if an EAL classification threshold is met.
Using the conversion factor in ERPIP-8 and the information in the EAL Table A.3-1, the inspectors determined that the radiation levels on the auxiliary building roof may be too high for radiation protection technicians to take the hand held radiation monitor measurement. If the radiation levels were too high, then Constellation would not be able to implement the compensatory actions for the WRNGM being out of service.
This would affect the ability of the emergency response organization (ERO) to make an appropriate EAL declaration. The inspectors determined that a design basis fuel-handling incident (FHI) at the spent fuel pool (SFP) area is the accident of most concern because there are no redundant EAL initiating conditions higher than an ALERT declaration. Therefore, the ERO would have to rely upon dose projection calculations to determine if the EAL declaration would need to be escalated and/or for the appropriate EAL classification to be declared. Interim corrective actions include an installed portable monitor with remote monitoring capabilities to perform the initial dose assessment when the WRNGM is out of service.
This item is unresolved pending further review and investigation of the re-analysis such that the inspectors can determine if there is a performance deficiency associated with this issue. The inspectors need to review Constellations conversion factor used in ERPIP-821 and the conversion factor used in any re-analysis to determine if Constellation has adequate methods and equipment in place for assessing and monitoring a design basis FHI at the SFP area when the WRNGM is out of service. (URI 05000317/318/2009003-02, Wide Range Noble Gas Monitor Compensatory Actions)
==1R18 Plant Modifications (71111.18 - Two Samples)
a. Inspection Scope
==
The inspectors reviewed the plant modifications listed below to verify that the modifications did not affect the safety functions of systems that are important to safety.
The inspectors verified that the system design and licensing bases did not degrade due to the modifications to ensure that the system maintained its availability, reliability, and functional capability. The inspectors conducted walkdowns of accessible portions of the modifications to verify that the proper configuration control was maintained to ensure that the plant was not placed in an unsafe condition and that the modifications were implemented in accordance with Constellation procedures.
- A temporary modification to isolate instrument air (1-IA-1302) to valve (1-CV-5163) in order to fail it in its safe position (open) (EC-20080288-00).
- A permanent modification to change the fan sheaves and motors for the AFW pump room emergency ventilation fans (EC-20090055-00).
b. Findings
No findings of significance were identified.
==1R19 Post-Maintenance Testing (71111.19 - Seven Samples)
a. Inspection Scope
==
The inspectors reviewed the post-maintenance tests for the maintenance activities 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 was 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.
- Replaced the engineering safety feature actuation signal under voltage sensor on channel ZD for bus 11 (MO #1200204937).
- No. 23 and 24 containment air coolers inlet valve relay inspection and tests (MO
- 2200604196).
- Adjusted the control flow damper for No. 12 emergency core cooling system (ECCS)pump room exhaust fan (MO #1200803754).
- Overhauled the No. 22 SW pump (MO #2200801890).
- Adjusted the mechanical stops and packing for No. 11 CCHX SW inlet control valve (1-CV-5160) (WO #C90463613).
- 0C EDG overhaul inspection and troubleshooting of the turbocharger exhaust temperature element (WO #C90467246).
b. Findings
No findings of significance were identified.
==1R22 Surveillance Testing (71111.22 - Five 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.
- Unit 1 ECCS pump room ventilation system monthly test (STP-O-11-1).
- Unit 1 functional testing of the No. 11 4kV bus protective relays (FTE-59).
- Unit 1 safety injection system valve operability test (STP-O-65Q-1).
- Unit 2 SW pump and check valve quarterly operability inservice test (STP-O-73A-2).
b. Findings
No findings of significance were identified.
Cornerstone: Emergency Preparedness (EP)
1EP6 Drill Evaluation (71114.06 - One Sample)
a. Inspection Scope
The inspectors observed an EP drill on May 19, 2009. This EP drill focused on equipment failures, operator challenges, and security issues that could typically exist during a complicated plant trip. The inspectors observed the ERO performance onsite and at the Joint Information Center/Emergency Operations Facility. The inspectors verified that the classification, notification, and protective action recommendations were accurate and timely. Additionally, the inspectors assessed the ability of Constellations evaluators to address operator performance deficiencies identified during the exercise.
Additionally, the inspectors conducted a review of the emergency response plan and associated implementation procedures for a fuel handling incident in the SFP area and containment.
b. Findings
Introduction.
The inspectors identified a URI associated with the emergency response plan implementing procedures (ERPIPs) for a FHI in the Containment Building.
Description.
In January 2001, Constellation submitted a license amendment request to modify the conditions of containment closure during core alterations/fuel handling for Units 1 and 2. A new containment outage door assembly was installed on the outside of the equipment hatch opening to provide for a quicker closure, improve safety when the door is open, and allow more flexibility when staging material in the Containment Building during an outage. In support of this amendment request, Constellation conducted an analysis of the design basis FHI. Constellation concluded that since the existing safety analysis assumed the radioactive release is unfiltered via the personnel air lock to the plant main vent, the analysis will also apply to the containment outage door and is not changed if both the personnel airlock and the containment outage door are open at the same time. In conjunction with the NRCs approval of the amendment request in March 2001, Constellation updated Chapter 14.18 of the UFSAR to include the assumption that the containment outage door/equipment hatch will remain open for the duration of the FHI in Containment. Thus, the radioactivity release point could be through the containment outage door and/or through the plant main vent. In a review of associated ERPIPs for a FHI in containment, the inspectors questioned the measures in place to account for a potential release path through the containment outage door.
Specifically, the potential release through the containment outage door may be unaccounted for until field monitoring is conducted later during the event. The inspectors noted that the initial dose projection is used to support initial EAL declarations and to make protective action recommendations if warranted by projected radiological conditions at the sites boundary.
This item is unresolved pending further review and investigation of stated methods used to obtain an initial dose assessment during a FHI with the containment outage door open such that the inspectors can determine if there is a performance deficiency associated with this issue. The inspectors need to complete the review of Constellations evaluation to determine if the stated methods, systems, and equipment for assessing and monitoring the potential release through the containment outage door are adequate.
(URI 05000317/318/2009003-03, Initial Dose Assessment with the Containment Outage Door Opened)
RADIATION SAFETY
Cornerstone: Public Radiation Safety
2PS2 Radioactive Material Processing and Transportation
a. Inspection Scope
(71122.02 -Six Samples)
During the period of June 15 to 19, 2009, the inspectors conducted the following activities to verify that CCNPPs radioactive material processing and transportation program complies with federal regulations. The inspectors reviewed shipment documentation and observed work activities.
Inspection Planning and System Walkdown
The inspectors reviewed the CCNPP UFSAR description of the radioactive waste processing system. The inspectors reviewed the most recent radiological release report for information on the type and amount of radioactive waste disposed.
The inspectors verified that the scope of CCNPPs audit program meets the requirements of NRC regulations. The inspectors walked down the radioactive material processing system to ensure it was as described in the UFSAR and in the process control plan. The inspectors also reviewed the reactor coolant waste evaporator equipment to verify if administrative controls were in place, which require that all preventative maintenance be performed prior to placing the equipment in use.
On-Site Inspection
The inspectors reviewed the current processes for transferring radioactive waste into shipping/disposal containers to determine if appropriate waste stream mixing and sampling procedures and methodology for waste concentration averaging provided representative samples of the waste product for the purpose of waste classification.
The inspectors reviewed documentation for five radioactive shipments, the associated waste stream 10 CFR Part 61 analysis results, and the scaling factors used to calculate the activities for hard to detect isotopes. The inspectors reviewed CCNPPs program to ensure that waste stream composition data accounts for changing operational parameters and thus remains valid between the annual or biennial sample analyses.
The inspectors noted that each resin liner is sampled separately and therefore is well within the sampling requirements.
The inspectors reviewed the radioactive shipment documentation for compliance with NRC and Department of Transportation requirements. The inspectors reviewed the packaging and preparation for shipment of a reactor coolant pump motor. The inspector also reviewed the paperwork and had discussions with the driver. The inspectors observed radiation workers and questioned the radiation workers to determine if they were knowledgeable of shipping regulations.
Problem Identification and Resolution
The inspectors reviewed quality assurance audits, self-assessments, and six CRs related to the radioactive material processing and transportation program performed since the last inspection. The inspectors also reviewed the corrective action evaluations written against the associated CRs.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES (OA)
4OA1 Performance Indicator (PI) Verification
Barrier Integrity (71151 - Four Samples)
a. Inspection Scope
The inspectors reviewed Constellations reactor coolant system (RCS) activity and RCS leakage PIs for Units 1 and 2. The inspectors reviewed the PIs for the period of April 2008 through March 2009. The inspectors used the guidance provided in NEI 99-02, Regulatory Assessment PI Guideline, to assess the accuracy of PI data collected and reported. The inspectors reviewed RCS chemistry sample analyses, control room logs of daily measurements for RCS gross leakage and compared that information to data reported by the PI. Additionally, the inspectors observed surveillance activities that determined the RCS identified leakage rate, and chemistry personnel taking and analyzing an RCS sample.
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 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 review focused on repetitive equipment and corrective maintenance issues but also considered the results of daily inspector corrective action screenings. The review included issues documented in system health reports, corrective MOs, assessment reports, temporary modifications, and maintenance rule assessments. The inspectors review considered the six-month period of January to June 2009, although some examples expanded beyond those dates when the scope of the trend warranted. The inspectors also discussed trends and potential trends with appropriate station personnel.
b. Findings and Observations
No findings or observations of significance were identified. Although the inspectors identified several trends or potential trends during the semi-annual review, plant personnel were aware of these and had initiated corrective actions as necessary.
.3 Annual Sample: SW System Valves and Actuators
a. Inspection Scope
This inspection was conducted to assess Constellations evaluation and resolution of challenges associated with the degradation of several butterfly valves and associated actuators in the SW cooling system. Specifically, valves in the SW systems of both units had been subject to corrosion, stem leakage and actuator failures that resulted in failures of inservice testing (IST) time requirements and, in some cases, failure of the valve to operate as required.
The inspectors reviewed Constellations CRs, apparent cause evaluations, and root cause reports associated with the valve failures. The inspectors also interviewed plant personnel, and reviewed performance data including IST test results, weekly valve cycling records and operator logs to evaluate the performance of the components prior to and after corrective actions were taken to address degrading valve performance. This review was done to evaluate the effectiveness of Constellations actions and determine if Constellation had promptly corrected adverse conditions when identified. In addition, the inspectors walked down SW system valves in Unit 1 and Unit 2 to assess the material condition of the valves, and observe the modifications performed on the valves as part of the corrective actions previously completed. Finally, the inspectors reviewed the long-term actions planned by Constellation to address remaining deficiencies.
b. Findings and Observations
No findings of significance were identified. The inspectors concluded that Constellation appropriately evaluated the cause of the degrading performance of the SW system valves and actuators, both individually and collectively, and several corrective actions were taken to address degrading valve performance. The inspectors noted that Constellation identified that most of the operational challenges occurred on the valves where the actuators were mounted under the valve. The inspectors found that Constellation had taken appropriate short term corrective actions to prevent this configuration from impacting valve performance and had plans to rotate those valves and actuators to an upright orientation.
The inspectors also confirmed that Constellation was adequately monitoring and trending relevant valve parameters and had taken corrective action to address degrading valve/actuator performance when negative performance trends were identified.
Constellations evaluation identified that loose packing on newly installed titanium valves had contributed to the degradation of valves stems and actuators. They determined that this was caused by insufficient procedural guidance related to supplying appropriate torque values for the packing gland followers. These procedural deficiencies were corrected through procedure changes and training. The inspectors determined that several Constellation work processes should have addressed this problem prior to valve degradation. These processes included requirements in Constellations design control process, work order process, and appropriate use of the CAP when torque deficiencies were identified in the field. Prior to the failure of valve 1-CV-5208 in 2008, Constellation had installed 15 titanium valves in the SW system beginning in 2005 but procedural deficiencies were not identified until after the valve failed (documented in IR 2008-004 as an NCV).
4OA3 Followup of Events and Notices of Enforcement Discretion (71153 - Two Samples)
.1 (Closed) Licensee Event Report (LER) 05000317/2008002-00, Pressurizer Safety Valve
Setpoint High Lift Due to Low Torque and Misalignment
During scheduled testing at an offsite vendor facility on July 25, 2008, Constellation identified that one of the two-pressurizer safety valves as-found lift setting measured higher than the value allowed by TS. Constellation personnel had removed the valve from service during the previous refueling outage and sent the valve to a testing lab to determine the as-found lift setpoint and to refurbish the internals. The vendor technician initially concluded that the high lift was due to low torque of an inlet nozzle and indications of internal valve misalignment. However, a subsequent apparent cause evaluation determined that the apparent cause was due to excessive drift and Constellation revised the LER to update the cause of the event. The inspectors reviewed this LER and documented the findings of the revised LER in Section 4OA3.2 of this report. This LER is closed.
.2 (Closed) LER 05000317/2008002-01, Pressurizer Safety Valve Setpoint High Due to
Excessive Drift
On July 25, 2008, during as-found testing, Constellation identified that one of the two pressurizer safety valves lift setting was 50 pounds per square inch higher than the value allowed by TS. Constellation personnel removed the valve from service during the previous refueling outage and sent it to a testing lab to refurbish the valve and determine the as-found lift setpoint. Constellation concluded that because the lift point exceeded the TS limit, Unit 1 had operated during the previous operating cycle with an inoperable valve for longer than the allowed TS action time and, therefore, had violated the TS.
An examination of the valve determined that there was some misalignment of the valve internals and the valve nozzle was not at the required torque setting. Additionally, the inspection found that there was some degradation of the valve internal components. As a result of the inspection, Constellation concluded that the most likely cause of the high lift setpoint was drift of the setpoint due to the degraded internal components.
Additionally, Constellation evaluated the operability of the valves currently installed in Units 1 and 2. Based on in this review, Constellation concluded that all the valves were set up and installed correctly and that they were operable. Finally, Constellation determined that although the valve setpoint was above the allowed TS limit, it still was capable of performing its safety function.
The inspectors reviewed Constellations actions associated with this event report. The inspectors also reviewed the setpoint test data prior to installation into the system, the test procedure for adequacy, and the vendors assessment of the issue. In addition, the inspectors evaluated the performance history of these safety valves and found that the performance of the valve was generally good and the appropriate maintenance and testing had been performed. Therefore, the inspectors did not identify a performance deficiency associated with this event. However, the failure to meet TS limiting condition of operation (LCO) 3.4.10 was a violation as discussed in Section 4OA7 of this report.
4OA5 Other Activities
.1 Quarterly Resident Inspector Observations of Security Personnel and Activities
a. Inspection Scope
During the inspection period, the inspectors conducted observations of security force personnel and activities to ensure that the activities were consistent with Constellations security procedures and regulatory requirements relating to nuclear plant security.
These observations took place during both normal and off-normal plant working hours.
These quarterly resident inspectors observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors normal plant status reviews and inspection activities.
b. Findings
No findings of significance were identified.
.2 Independent Spent Fuel Storage Installation (ISFSI) Radiological Controls and Activities
a. Inspection Scope
The inspectors evaluated the effectiveness of Constellations processes and procedures for controlling radiological activities at the ISFSI. The inspectors reviewed the As Low As Reasonably Achievable plans and radiation work permits (RWPs) used for ISFSI activities. The inspectors walked down the ISFSI area and interviewed Constellation personnel. The inspectors verified the condition of postings and dose rates and reviewed a printout of the RWP entries for the ISFSI to verify that dose per entry was within prescribed procedure limits. Additionally, the inspectors reviewed surveys from the most recent transfer of a dry cask to the ISFSI storage pad. The inspectors also reviewed six CRs related to this inspection activity.
b. Findings
No findings of significance were identified.
Enclosure
.3 (Closed) URI 05000317/318/2009002-00 Auxiliary Feedwater Pump Emergency
Ventilation Low Flow
The inspectors opened a URI in NRC IR 05000317/318/2009002 to review the inputs and assumptions used in an evaluation to determine if the degraded flow rate condition adversely affected the Mitigating System cornerstone objective to ensure the availability, reliability, and capability of the TDAFW pumps. This item was resolved as a Green NCV of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, and documented in this report in Section 1R04. This URI is closed.
In addition, this URI was inadvertently listed as URI 05000317/318/2009002-03 in IR 2009-002. The revised tracking number is URI 05000317/318/2009002-00.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On July 15, 2009, the resident inspectors presented the inspection results to Mr. James Spina and other members of licensee staff who acknowledged the findings. The inspectors asked Constellation whether any of the material examined during the inspection should be considered proprietary. There was no proprietary information identified.
4OA7 Licensee-Identified Violations
The following violation of very low safety significance (Green) was identified by Constellation and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy, for being dispositioned as an NCV.
CCNPP TS LCO 3.4.10, Pressurizer Safety Valves, states, in part, that two pressurizer safety valves shall be operable. Contrary to this, from March 2006 to March 2008 one of the two pressurizer safety valves installed in Unit 1 was set above the TS limit and, therefore, was inoperable. Constellation identified the deficiency following the refueling outage while testing the valve as part of the relief valve-testing program. Constellation entered this issue in their CAP under IRE-033-089. This violation was of very low safety significance because the valve would have opened for the events credited to mitigate incidents in the Phase 2 notebooks such that it satisfied the bounding maximum vessel pressure calculations.
ATTACHMENTS:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Constellation Personnel
- J. Spina, Site Vice President
- D. Trepanier, Plant General Manager
- R. Cable, Radwaste Shipping Technician
- B. Dansberger, Radiation Protection Supervisor
- S. Dean, Manager, Operations
- M. Flaherty, Manager, Engineering Services
- J. Gaines, Director, Licensing
- K. Gould, General Supervisor, Radiation Protection
- A. Henni, Senior Design Engineer
- L. Larragoite, Manager, Nuclear Safety and Security
- J. Lenhart, Radiation Protection Supervisor
- C. Neyman, Licensing Engineer
- J. Pruitt, Radwaste Shipping Technician
- S. Saunder, General Supervisor, Chemistry
- A. Simpson, Principle Engineer, Licensing
- J. Wynn, Senior System Engineer
- J. York, Supervisor Radiation Protection
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened
- 05000317/318/2009003-02 URI
Wide Range Noble Gas Monitor Compensatory Actions (Section 1R15)
- 05000317/318/2009003-03 URI
Initial Dose Assessment with the Containment
Outage Door Opened (Section 1EP6)
Opened and Closed
- 05000317/318/2009003-01 NCV
Inadequate Test Control Associated with the
Auxiliary Feedwater Pump Room Emergency
Ventilation System (Section 1R04)
Closed
Pressurizer Safety Valve Setpoint High Lift Due
To Low Torque Misalignment (Section 4OA3.1)
Pressurizer Safety Valve Setpoint High
Due to Excessive Drift. (Section 4OA3.2)
- 05000317/318/2009002-00 URI
Auxiliary Feedwater Pump Emergency Ventilation
Low Flow (Section 4OA5.3)