IR 05000317/2011008

Download: ML111190104

Text

UNITED STATESNUCLEAR REGULATORY COMMISSIONREGION I475 ALLENDALE ROADKING OF PRUSSIA. PA 19406.1415ApriI 29, LOILGeorge H. Gellrich, Vice PresidentCalvert Cliffs Nuclear Power Plant, LLCConstellation Energy Nuclear Group, LLC'1650 Calvert Cliffs ParkwayLusby, Maryland 20657 -47 02

SUBJECT: CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT 2 - NRC INSPECTIONPROCEDURE 95001 SUPPLEMENTAL INSPECTION REPORT4500a318t201 1008

Dear Mr. Gellrich:

On March 18,2011, the U.S. Nuclear Regulatory Commission (NRC) staff completed asupplemental inspection in accordance with Inspection Procedure 95001, "SupplementalInspection for One or Two White Inputs in a Strategic Performance Area," at your Calvert CliffsNuclear Power Plant Unit 2. The enclosed inspection report documents the inspection results,which were discussed at the exit meeting on March 18,2011, with you and other members ofyour staff.As required by the NRC Reactor Oversight Process Action Matrix, this supplemental inspectionwas performed because a finding of White safety significance was identified in the secondquarter of 2010. This issue was documented previously in NRC Special Inspection Report0500031712010006 and 0500031812010006. The NRC staff was informed on February 11,2011 , of your staff's readiness for this inspection.The objectives of this supplemental inspection were to provide assurance that: (1) the rootcauses and the contributing causes for the risk-significant issues were understood; (2) theextent of condition and extent of cause of the issues were identified; and (3) corrective actionswere or will be sufficient to address and preclude repetition of the root and contributing causes.The inspection consisted of examination of activities conducted under your license as theyrelated to safety, compliance with the Commission's rules and regulations, and the conditions ofyour operating license.The inspectors determined that your staff performed a comprehensive evaluation of the Whitefinding. Your actions in response to the White finding resulted in a root cause analysis thatappropriately addressed the root and contributing causes, extent of condition and extent ofcause, and corrective actions.Your staff identified that a failure of the 28 emergency diesel generator (EDG) lube oil pressuremonitoring circuit caused the 28 EDG to trip shortly after it started in response to the loss ofpower to the plant's emergency busses following the dual unit trip on February 18, 2010. The28 EDG tripped due to the slow response of an engine lube oil pressure indicator and the earlytimeout of a time delay relay that were both associated with the EDG's lube oil pressuremonitoring circuit. Your statf concluded that these equipment conditions were caused by anineffective preventive maintenance program for the 28 EDG. The ineffective program was theresult of the use of an inappropriate engineering change process to delete the requirement for G. Gellrichperiodic Agastat relay replacements and the use of poor work practices and inadequateproceduraiguidance when venting, flushing and calibrating pressure indications for the EDGlube oil system.The corrective actions you completed to address these issues included revising the preventivemaintenance strategy for the associated Agastat relays; implementing additional preventivemaintenance requirements for EDG lube oil pressure sensing lines; revising procedures toimprove work controls during maintenance and calibrations performed on EDG lube oil pressureindication components; and implementing a formal plan to monitor and detect degradation oflube oil pressure monitoring circuit components, including the Agastat relays. You alsocompleted extent of condition actions to confirm similar equipment conditions did not exist onthe other EDGs. Your extent of cause reviews are in progress and are intended to assess theadequacy of the preventive maintenance strategies for the plant's most risk significant systems,review the work controls for maintenance and calibrations for pressure indication components inthose systems, and assess the adequacy of engineering change processes to ensure proposedchanges are fully evaluated and that all processes and programs affected by the change areaddressed. The results of these reviews will determine the need for more extensive reviewsand corrective actions in these areas.Based on the results of this inspection, no findings were identified.Given your acceptable performance in addressing the loss of 28 EDG event and in accordancewith thb guidance in lnspection Manual Chapter (lMC) 0305, "Operating Reactor AssessmentPrograml'the White finding will only be considered in assessing plant performance for a total offour quarters.ln accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, and your response (if any) will be available electronically for public inspection in theNRC Public Document Room or from the Publicly Available Records (PARS) component ofNRC's document system, Agencywide Documents Access and Management System (ADAMS).ADAMS is accessible from the NRC Website at http://www.nrc.qov/readinqrrm/adams.html (thePublic Electronic Reading Room).

Sincerely,lurilHGlenn T. Dentel, ChiefProjects Branch 1Division of Reactor ProjectsDocket No.: 50-318License No.: DPR-69

Enclosure:

Inspection Report 05000318/201 1008w/

Attachment:

Supplemental Informationcc:/w encl: Distribution via ListServ G. Gellrichperiodic Agastat relay replacements and the use of poor work practices and inadequateproceduraiguidance when venting, flushing and calibrating pressure indications for the EDGlube oil system.The corrective actions you completed to address these issues included revising the preventivemaintenance strategy fbr the associated Agastat relays; implementing additional preventivemaintenance requirements for EDG lube oil pressure sensing lines; revising_procedures toimprove work controls during maintenance and calibrations performed.ol EDG lube oil pressureindication components; and'implementing a formal plan to monitor and detect degradation oflube oil pressure monitoring circuit components, including the Agastat relays' You alsocompleted extent of condition actions to confirm similar equipment conditions did not exist onthe other EDGs. your extent of cause reviews are also in progress and are intended to assessthe adequacy of the preventive maintenance strategies for the plant's most risk significantsystems, reuiew the work controls for maintenance and calibrations for pressure indicationcomponents in those systems, and assess the adequacy of engineering change processes.toensure proposed changes are fully evaluated and that all processes and programs affected bythe change are addresied. The results of these reviews will determine the need for moreextensive reviews and corrective actions in these areas.Based on the results of this inspection, no findings of significance were identified.Calvert Cliffs Nuclear power Plant, LLC's comprehensive actions in response to the Whitefinding resulted in a root cause analysis that adequately addressed the root and contributingcausJs, extent of condition and extent of cause, and corrective actions. Given your acceptableperformance in addressing the loss of the 28 EDG event, the White finding will only beconsidered in assessing p-lant performance for a total of four quarters, and following issuance ofthis report that docume-nts succ"ssful completion of supplemental inspection 95001, inaccordance with the guidance in lnspection Manual Chapter (lMC) 0305, "Operating ReactorAssessment Program.ln accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, and your response (if any) will be available electronically for public inspection in theNRC public Doiument Room or from the Publicly Available Records (PARS) component oJ -NRC's document system, Agencywide Documents Access and Management System (ADA{.S)ADAMS is accessible from tne runC Website at http://www.nrc.qov/readinq-rm/adams.html (thePublic Electronic Reading Room).

Sincerely,IRNGlenn T. Dentel, ChiefProjects Branch 1Division of Reactor ProjectsDocket No.: 50-318License No.: DPR-69Distribution w/encl: via e-mail (see attached page)SUNSI Review Complete: LC (Reviewer's Initials)OOCUrtreHr r.rnrUEc,pRffiEftFilGfvert-Cliffs\lnspection Reports\CC lR 2011-008\cc11008 Revl.docxAfter declanns this document "An Official Agency Record" it g!l! be-released to the Public.To receive a-copy of this document, indiiate in the box: -q = Qopy without attachmenUenclosure "E" = Copy withattachmenVenclosure "N" = No coPYML111190104 G. GellrichDistribution w/encl: (via E-mail)W. Dean, RAD. Lew, DRAD. Roberts, DRPJ. Clifford, DRPC. Miller, DRSP. Wilson, DRSS. Bush-Goddard, Rl OEDOA. Klett, NRRG. Dentel, DRPR. Powell, DRPN. Perry, DRPJ. Hawkins, DRPK. Cronk, DRPN. Floyd, DRPS. Kennedy, DRP, SRIS. lbarrola, Acting RlC. Newgent, DRP, Resident OARidsNrrPMCa lvertCl iffs Resou rceRidsNrrDorlLpll -1 ResourceROPreportsResource Docket No.:License No.:Report No.:Licensee:Facility:Location:Dates:lnspectors:u.s. NUGLEAR REGULATORY COMMISSION (NRG)REGION 150-318DPR.690500031 8i201 1 008Calvert Cliffs Nuclear Power Plant, LLCCalvert Cliffs Nuclear Power Plant, Unit 2Lusby, MarylandMarch 16,2011, through March 18,2011L. Cline, Senior Project Engineer, Lead lnspectorL. Casey, Resident lnsPectorApproved by:Glenn T. Dentel, ChiefProjects Branch 1Division of Reactor ProjectsEnclosure 2

SUMMARY OF FINDINGS

lnspection Report (lR) 0500031812011008; 0311612011 - 0311812011; Calvert Cliffs NuclearPower Plant, Unit 2; Supplemental lnspection - Inspection Procedure (lP) 95001A senior project engineer and a resident inspector performed this inspection. The NRC'sprogram ior overseeing the safe operation of commercial nuclear power reactors is described inNUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

Cornerstone: Mitiqatinq SvstemsThe NRC staff performed this supplemental inspection in accordance with lP 95001,"supplemental lnspection for One or Two

White lnputs in a Strategic Performance Area," toassess Calvert Cliffs Nuclear Power Plant, LLC's (CCNPP's) evaluation of the failure of the 28emergency diesel generator (EDG) during a demand start that occurred following the dual unittrip oiCatvert CliffJ Units 1 and 2, with the concurrent loss of supplied loads, on February 18,ZOIO. The NRC staff previously characterized this issue as having low to moderate safetysignificance (White) as documented in NRC Special lR 0500031712010006 andOdOOOgtAIZCitOOOO. The inspectors concluded, based on the results of this inspection, that forthe risk significant performance issues associated with the February 18, 2010,28 EDG failure,CCNPP idlntified all root and contributing causes, appropriately addressed extent of conditionand extent of cause, and assigned appropriate corrective actions to prevent recunence'CCNP determined the cause of the 28 EDG trip was a faulted lube oil pressure monitoringcircuit. CCNPP identified the primary causes for the faulted EDG lube oil pressure monitoringcircuit to be implementation of an inappropriate change to the preventive maintenance strategyfor the Agastat relays used in the Fairbanks Morse EDG lube oil pressure monitoring circuit andinappropiiate work -controls and inadequate preventive maintenance for Fairbanks Morse EDGlube oil pressure sensing lines used in the lube oil pressure monitoring circuit. Correctiveactions ior these issues lncluded revising the preventive maintenance strategy for theassociated Agastat relays; implementation of additional preventive maintenance requirementsfor EDG luOe oit pressuie sensing lines; procedure revisions that improve work controls duringmaintenance and calibrations performed on the EDG lube oil pressure indication components;and implementation of a formal plan to monitor and detect degradation of lube oil pressuremonitoring circuit components, including the Agastat relays. CCNPP's extent of conditionactions confirmed similar equipment conditions did not exist on the other EDGs. Extent ofcause reviews will assess the'adequacy of the preventive maintenance strategies for the plant'smost risk significant systems, review the work controls for maintenance and calibrations forpressure indication components in those systems, and assess the adequacy of engineeringchange processes to ensure proposed changes are fully evaluated and that all processes andprogi"rs affected by the change are addressed. The results of these reviews will determinethe need for more extensive reviews and corrective actions in these areas.Given CCNPP's acceptable performance in addressing the performance issues revealed by theFebruary 18,2010, 28 EDG failure, the White finding associated with this issue will only beconsidered in assessing plant performance for a total of four quarters in accordance with theguidance in NRC lnspection Manual Chapter 0305, Operating Reactor Assessment Program'FindinosNo findings were identified.Enclosure

3

REPORT DETAILS

4.

4OA4 Supplemental Inspection

.01 lnspection ScopeThe NRC staff performed this supplemental inspection in accordance with lP 95001 toassess Calvert Cliffs Nuclear Power Plant, LLC's (CCNPP's) evaluation of a White1nding that affected the Mitigating Systems cornerstone in the Reactor Safety strategicperformance area.The objectives for this inspection were to:r Provide assurance that the root and contributing causes of risk-significant issueswere understood;r Provide assurance that the extent of condition and extent of cause of risk-significant issues were identified; andr Provide assurance that CCNPP's corrective actions for risk-significant issueswere or will be sufficient to address the root and contributing causes and topreclude rePetition.Calvert Cliffs Unit 2 entered the Regulatory Response Column of the NRC's ActionMatrix in the second quarter of 2010 as a result of one inspection finding of low tomoderate safety significance (White). The finding was specifically associated with thefailure of the Zfi eOC during a demand start that occurred following a dual unit trip ofCatvert Cliffs Units 1 and 2 with the concurrent loss of supplied loads on February 18,2010. The initiator for the event was water intrusion from the roof into the auxiliarybuilding switchgear room that caused a fault in the switch gear cabinets that cascadedinto trifs of both Unit 1 and 2 because of relay failures. The 28 EDG received a validstart signal due to under voltage on the 24 4kilovolt (kV) bus; the engine started andbegan to accept load, but then tripped. The cause of the EDG trip was a faulted lowlubl oil pressure monitoring circuit. Sufficient oil pressure had not developed in the lubeoil sensing lines and prevented the pressure switches from resetting at the nominal time;additionally, one of the circuits' time delay relays (T3A) timed out early_and armed thelow lube oil pressure trip prematurely. This resulted in the trip of the 28 EDG. Thefinding was characterized as having a White safety significance based.on the results of aPhase 3 risk analysis with an exposure time of 323 days that resulted in a totalcalculated conditibnal core damage frequency of 7.1E-6. The finding and details of thepreliminary risk assessment analysis are discussed in NRC Special lnspection ReportbSOOOetZ72010006 and 05000318/201006. The risk significance determination for thefinding was finalized by an August 3, 2010, NRC letter to CCNPP. This letter alsoissued Notice of Violation EA-10-080 that was associated with this finding.CCNPP staff informed the NRC staff on February 11,2011, that they were ready for thesupplemental inspection. ln preparation for the inspection, CCNPPLcerformed acaiegory 1 root cause analysis report (RCAR), Condition Report (CR)-2010-007157'Failure of tne 28 EDG during the Dual Unit Trip, Revision 2, to identify the equipmentand organizational causes that led to the White finding.Enclosure 4The inspectors reviewed CCNPP's RCAR and other evaluations conducted to supportthe RCAR. The inspectors reviewed corrective actions that were taken or planned toaddress the identified causes. The inspectors also discussed with CCNPP personneltoensure that the root and contributing causes and the contribution of safety culturecomponents were understood, and that the corrective actions taken or planned wereappropriate to address the causes and preclude repetition..02 EEluatjsl of the Inspection Requirements02.01 Problem ldentificationa. lP 95001 requires that the inspection staff determine that the licensee's evaluation of theissue documents who identified the issue (i.e., licensee-identified, self-revealing, orNRC-identified) and the conditions under which the issue was identified.CCNPP determined that the 28 EDG trip was caused by a lube oil pressure monitoringcircuit relay (T3A) timing out earlier than normal and "sticky lubrication oil" that caused28 EDG indicated engine lube pressure to be less than the relay setpoint when the T3Arelay timed out. In accordance with NRC Inspection Manual Chapter 0612 definitions forlicensee-identified, self-revealing, or NRC-identified, CCNPP's RCAR identified theseequipment issues as self-revealing.The NRC completed a specialteam inspection to review CCNPP's response, causeevaluation and corrective actions for the dual unit trip. The results of this inspectionwere documented in NRC Special Inspection Report 05000317/2010006 and005000318/2010006. The special inspection team determined that the failed T3A relaywas installed for 13.5 years, 3.5 years beyond the manufacturers recommended servicelife.In 2001, CCNPP had approved extending the service life for these relays based on theimplementation of an Agastat relay performance monitoring program that was notformally implemented. The special inspection team determined that this resulted in an"age-related" failure of the T3A relay that caused the 28 EDG trip on February 18,2010,and that this was a performance deficiency.The NRC issued an NRC-identified Notice of Violation (NOV) for Technical Specification5.4.1, which specifies that written procedures shall be established for activities listed inRegulatory Guide 1.33 Appendix A, including a replacement schedule for componentswith a specified service life. ln accordance with NRC lnspection Manual Chapter 0612definitions for licensee-identified, self-revealing, or NRC-identified, CCNPP's RCARidentified this performance deficiency as NRC-identified.The inspectors determined that CCNPP's RCAR for the event appropriately documentedwho identified the equipment issues and the performance deficiencies for this event andunder what conditions the equipment issues and performance deficiencies wereidentified.b. lP 95001 requires that the inspection staff determine that the licensee's evaluation of theissue documents how long the issue existed and prior opportunities for identification.Enclosure c.5CCNPP's evaluation was unable to determine exactly how long the two conditions - thesticky lubrication oil and the degraded Agastat relay - had existed to a degree that theyimpacted the ability of the 28 EDG to perform its safety function. As a result, the risksignificance determination for the 2B EDG failure was based upon the last knownsalisfactory calibration results for the lube oil pressure monitoring circuit that wascompfeted on May 13,2008.CCNPP's evaluation determined that programs and processes in place during the periodof time that led up to the 28 EDG trip were not capable of identifying that the lubricatingoil in the system pressure sensing lines and the Agastat relay were degrading so thatactions could be taken before the operability of the EDGs was impacted' CCNPPidentified that, without performing additional monitoring of lube oil pressures and Agastatrelay performance, only a cold fast EDG start could identify degradation of lube oilpressure monitoring circuit components. However, cold fast test starts werediscontinued at Calvert Cliffs in September 1994, in accordance with a November 2,1gg3, Calvert Cliff's license amendment request to eliminate the requirement to performcold fast test starts.CCNPP determined that this request was submitted based on NRC genericcorrespondence (Generic Letter 84-15) that suggested, due to the wear and tear causedby cold fast EDG starts, licensees should evaluate the need to perform them. CCNPPaiso determined that the NRC approved the request on February 24,1994; but that, atthat time, CCNPP did not recognlze the need for or implement the additional monitoringnecessary to identify degradation of the lube oil pressure monitoring circuit components.CCNPP developed corrective actions to evaluate the testing and preventive_maintenance programs for the EDGs. To address this identified gap in EDG systemtesting, CCNPP froceduralized additional monitoring for the Fairbanks Morse EDG lubeoil pre-isure monitoring circuit components in order to detect degradation during themonthly EDG surveillance testing. CCNPP will also conduct an extent of conditionreview for the plant's most risk significant systems to identify potential vulnerabilities inthe testing programs for these systems as well. The evaluations were scheduled to becompletel in May 2011. The results of this review will determine the need for additionalevaluation and corrective actions in this area.The inspectors determined that, based on the information available, the RCAR for the 28EDG trip appropriatety documented how long the performance deficiency existed andprior opportunities foiidentification. CCNPP also implemented appropriate changes toin" f"irbrnks Morse EDG preventive maintenance and testing programs and initiated anextent of condition review to evaluate the need for adjustments in this area for other risksignificant systems. The inspectors reviewed the proceduralized monitoring program forth-e Fairbanis Morse EDG lube oil pressure monitoring circuit components andconcluded that the new procedure should identify circuit degradation in time to allowcorrective action to be completed before EDG operability is impacted.lp 95001 requires that the inspection staff determine that the licensee's evaluationdocuments the plant specific risk consequences, as applicable, and complianceconcerns associated with the issue(s).Enclosure 6The NRC determined this issue was a White finding, as documented in NRC Speciallnspection Report 0500031712010006 and 0500031812010006, and CCNPP's RCARalso acknowledged that the finding associated with this issue had White safetysignificance. CCNPP's RCAR documented that the consequences of the issue included:complicating the operator's response to the February 18, 2410, dual unit trip; additionalmaintenance testing and repair costs and out of service time for mitigating systemsequipment in order to correct the condition and fully identify the extent of condition andcause; and an increase in Unit 2's baseline core damage frequency by a factor of 3.68.CCNPP also reviewed potential consequences for the failure had it occurred during adifferent initiating event, and determined that had the plant experienced a complete lossof offsite power with the 28 EDG failure and with the same equipment out of service formaintenance as on February 18,2010, Unit 2 would have met the criteria for an Alertemergency declaration. Therefore, on the day of the event, the potential existed for oneadditional equipment fault to place each Calvert Cliffs Unit in a plant condition thatrequired an emergency declaration.CCNPP also acknowledged the violation of Technical Specification 5.4.1 that requiredmaintenance of written procedures for preventive maintenance items. CCNPP provideda response to the NRC Notice of Violation issued on August 3,2010, in a letter datedSeptember 2,2010. CCNPP acknowledged the White finding and violation, discussedthe causes, corrective actions to prevent recurrence, and stated that full compliancewould be achieved on January 15, 2011.The inspectors concluded that CCNPP appropriately documented the risk consequencesand compliance concerns associated with the issue. The inspectors also confirmed,through the review of corrective actions completed, that full compliance with regulationswas restored on January 13,2011.d. FindinosNo findings were identified.02.02 Root

Cause.

Extent of Condition. and Extent of Cause Evaluationa. lP 95001 requires that the inspection staff determine that the licensee evaluated theissue using a systematic methodology to identify the root and contributing causes.The initial root cause for the dual unit trip was reviewed by the special inspection team, that reviewed CCNPP's response to the February 18, 2010, dual unit trip. In response tothe issues identified by the NRC inspectors during that inspection, CCNPP initiated anew root cause evaluation. The final RCAR for CR-2010-007157, which addressed theissues identified during the special inspection, was approved by management onJanuary 19,2011. CCNPP used the following systematic methods to complete itsevaluation: failure modes and effects analysis; events and causal factor charting; andManagement Oversight and Risk Tree (MORT) methodology. The techniques usedwere applied in accordance with CCNPP procedure CNG-CA-1.01-1004, Root CauseAnalysis, and the CCNPP handbook, CNG-CA-1.01-GL002, Causal Analysis Handbook.The inspectors reviewed the RCAR, the CCNPP procedure and handbook. Theinspectors also discussed the events and causal factors chart and the MORTEnclosure b.7methodology results with the members of the RCAR team. The inspectors' reviewconfirmed that the results of the evaluation were based on rigorous application of thesesystematic evaluation methods.lP 95001 requires that the inspection staff determine that the licensee's RCAR wasconducted to a level of detail commensurate with the significance of the issue.CCNPP's RCAR used systematic evaluation methods to identify the technical causes forthe 28 EDG failure, but also appropriately used the MORT methodology to identify theorganizational root and contributing causes that led to the technical causes resulting inthe 28 EDG demand failure. The RCAR identified inadequacies in the preventivemaintenance program and the work control process. Breakdowns in the correctiveaction program (CAP), engineering change processing and inconsistent application ofstandards and expectations for CCNPP's use and adherence to procedures andprocesses, in particular related to maintenance work practices, also contributed to thefailures on a lower level. CCNPP also reviewed programmatic weaknesses in the lssueResponse Team (lRT) process that led to the root cause evaluation weaknessesidentified by the special inspection team.CCNPP determined that the cause of the Agastat relay failure was a March 2001decision to extend the service life of the Agastat E7000 series relays, which were usedin the EDG lube oil pressure monitoring circuit, beyond the manufacturer specified 10year service life. At that time, in the interest of efficiency, CCNPP implemented thechange to the preventive maintenance program during a minor revision to E-406, theElectrical Design Standard. The minor revision was completed using the configurationdocument change (CDC) process in accordance with EN-1-101 , Design Change andModification lmplementation. The change relocated certain information from the E-406drawing 61406SEC234SH0001 to vendor technical manual 15167-001 and, at the sametime, eliminated the requirement to replace the Agastat relay every 10 years.The CDC process did not ensure that the impact of this change on the preventivemaintenance program for the Agastat relays was fully evaluated. ln addition, using theCDC process did not ensure that this change received an appropriate level ofindependent review. As a result, the 10 year replacement requirement was eliminatedbased upon the implementation of an informal monitoring program not documented ortracked by the preventive maintenance program. Therefore, when the componentengineer who performed the informal monitoring was moved to a new position inNovember 2002, the monitoring was no longer performed.The CDC process is no longer used at Calvert Cliffs. All engineering change proposalsare now processed through a single screening process defined in CCNPP proceduresCM-1.01-1003, Design Engineering and Configuration Control, and CNG-FES-O07,Preparation of Design Inputs and Change lmpact Screen. CCNPP corrective actionsconfirmed that, had this process been used in 2001, it would have ensured thatappropriate evaluations and reviews were completed before implementation of thechange.CCNPP determined that the cause of the entrapped air and contamination in the lube oilsensing lines was a lack of procedural guidance for pressure switch calibrations andsensing line flushing and refilling. The lack of guidance relative to testing medium,connection points for the calibration procedures, and the lack of periodic maintenanceEnclosure c.Itasks to inspect, drain and refill the sensing lines, caused the build-up of entrapped airand contaminants that slowed the response time of the 28 EDG lube oil pressureindication. This slow response in indicated lube oil pressure caused the 28 EDG to tripduring start-up on February 18,2010, after the T3A relay timed out early and armed thelube oil pressure trip circuit.The inspectors discussed the events and casualfactors chart, and the MORTmethodology results with the members of the RCAR team. The inspectors concludedthat the results of the evaluation were based on rigorous application of these systematicevaluation methods and were conducted to the appropriate level of detail that ensuredorganizational weaknesses were identified and corrected.lP 95001 requires that the inspection staff determine that the licensee's RCAR includeda consideration of prior occurrences of the issue and knowledge of operatingexperience.CCNPP's cause evaluation identified low level industry external operating experienceitems dealing with air entrapment in EDG lube oil pressure sensing lines and stickylubrication oil in EDG lube oil pressure sensing lines, but did not identify externaloperating experience related to the specific Agastat relay failure. CCNPP concludedthat the applicable low level items were missed opportunities, but also determined thatthe CCNPP operating experience program, as defined by procedure CNG-CA-1.01-1010, Use of Operating Experience, did not require actions to be taken in response tothese items.CCNPP's evaluation also identified a self-assessment of the CCNPP relay program,performed in September 2005, in response to a significant external operating experienceitem (as defined by Attachment 1 of CNG-CA-1.01-1004) that described the results of anindustry review of relay related failures that contributed to automatic and manual scrams,The results of the self-assessment were of interest to this cause analysis because,although the external operating experience item that prompted the self-assessment didnot directly relate to the issues associated with the February 19,2010, 28 EDG trip, theassessment recommended creation of a relay component health report and theassignment of a component engineer to track relay performance. CCNPP determinedthat these recommendations were not implemented because they were not entered intothe site's CAP for tracking. CCNPP concluded that, had these two recommendationsbeen implemented, CCNPP may have identified the existing weakness in the testing andpreventive maintenance program for Agastat relays before it resulted in the 28 EDG tripon February 19,2010. To identify improvements in this area, CCNPP initiated CR-2010-012114 to review their performance relative to the self-assessment and operatingexperience programs and how these two programs interface with the CAP.CCNPP's review of internal operating experience identified one auxiliary feedwatersystem relay failure in 2009 that caused excessive time delay (CR-2009-002150). lt isimportant to note that the relay that failed was not an Agastat relay. However, theapparent cause of the excessive time delay was determined to be age-relateddegradation because the subject relay had been installed for over 10 years. At the timeof that failure, CCNPP determined that the failure mechanism did not have the potentialto affect other systems. Had the cause analysis for this failure determined that allsystems with time delay relays installed could have been affected, the degradedcondition of the 28 EDG relay may have been identified. Corrective actions for thisEnclosure d.Iissue included training for the site's root cause evaluators and, on a temporary basisuntil training of onsite evaluators was completed, the use of root cause experts outsideof CCNPP to ensure completeness and thoroughness of evaluations.The inspectors reviewed the internal and external operating experience items thatCCNPP identified as prior occurrences and missed opportunities and determined thatthe identified items, of which the most significant were discussed above, did not involvesituations where CCNPP would have been required to take actions that would haveprevented the 28 EDG failure on February 18,2010. In addition, the inspectorsdetermined that the corrective actions CCNPP put in place to address the weaknessesthat were identified in this area, would improve the depth of internal cause evaluationsand the screening and processing of both internal and external operating experienceitems.The inspectors concluded that CCNPP's RCAR included appropriate consideration ofprior occurrences of the problem and knowledge of prior operating experience, and howthe handling of these items may have impacted the outcome of the February 19,2010,28 EDG failure.lP 95001 requires that the inspection staff determine that the licensee's RCARaddresses the extent of condition and extent of cause of the issue(s).CCNPP's evaluation considered the extent of condition associated with the thickened oilin the 28 EDG sensing lines and age-related degradation for Agastat relays installed incritical applications. For extent of cause, CCNPP assessed the adequacy of thepreventive maintenance strategies for the plant's most risk significant systems (systemstracked by the mitigating systems performance index (MSPI)), reviewed the workcontrols for maintenance and calibrations for pressure indication components in thosesame systems, and assessed the adequacy of engineering change processes to ensureproposed changes were fully evaluated and that all processes and programs affected bythe change were addressed.After the event, CCNPP flushed the lube oil sensing lines on the 28 EDG and the othertwo Fairbanks Morse EDGs (2A and 1B). Additionally, CCNPP determined that thesensing lines of several other systems could also be susceptible to similar clogging andneed flushing and/or fill and vent procedures to mitigate this potential. CCNPP did notlimit its review to lube oil systems, but included an assessment of pressure indicationsfor salt water and borated water systems as well. CCNPP initiated corrective actions toevaluate the need for flushing and/or fill and vent procedures for each susceptiblesystem.To address age-related degradation of Agastat relays, CCNPP replaced the T3A relayfor the 28 EDG and calibrated or replaced all Agastat relays in the control logic for thethree Fairbanks Morse EDGs. Relays were replaced if they were older than 10 years(from the date of manufacture) or could not meet the drift or contact resistance criteria inthe calibration procedure. For extent of condition, CCNPP reviewed the maintenancehistory for Agastat relays used in other safety-related and critical applications at the siteto identify relays that were beyond their 10 year replacement frequency or that exhibitedexcessive drift or contact resistance. CCNPP identified 55 critical relays that were olderthan 10 years and six of these relays also exhibited excessive drift. Operationsperformed an operability assessment for these six relays and determined that all theEnclosure 10relays and the systems that they supported remained operable. CCNPP developed areplacement plan for these relays that prioritized the replacements based on risksignificance and whether or not a failure of the relay would be immediately detectable.All of the relays whose failure could have impacted the ability of a safety-related systemto perform its design function have been replaced. CCNPP plans to replace all of therelays identified as being susceptible to a failure similar to the 28 EDG T3A failure by theend of 2011.To rule out the existence of a manufacturing defect that could affect operation of morethan one of the Agastat relays currently installed at Calvert Cliffs, CCNPP inspected theinternals of 12 relays removed from service as part of the relay replacement plan. Theretays were inspected for indications similar to what was identified during the contractorperformed failure modes and effects analysis on the 28 EDG T3A relay. One of therelays inspected was purchased under the same purchase order as the failed relay andits serial number indicated that it was the next relay off the assembly line after the onethat had failed. None of the 12 relays inspected presented conditions similar to whatwas found during the failure modes and effects analysis for the 28 T3A failed relay. Thisresult provided CCNPP high confidence that any manufacturing defects that may haveresulted in the 28 EDG T3A relay failure were limited to that relay'To address extent of cause relative to the adequacy of the site's preventive maintenanceprograms, CCNPP initiated a review of the testing methods for the sites most risksignificant systems (as defined by the MSPI) to identify portions of those systems thatwere not adequately tested by the current testing methodology. The review will includebenchmarking with other utilities and the results of this review will determine the need foradditional evaluation and corrective actions in this area. CCNPP also reviewed all of thesite's preventive maintenance program templates to verify that none of the templatestook credit for monitoring as a substitute for a fixed replacement strategy, as had beendone for Agastat relays. Finally, site calibration procedures for components associatedwith the site's most risk significant systems were reviewed to confirm that testconnection points and testing medium were adequately specified'ln 2001, CCNPP inappropriately used the CDC process in accordance with EN-1-101 ,Design Change and Modification lmplementation, to eliminate the requirement to replaceAgastat E7000 series relays every 10 years. The CDC process is no longer used atCalvert Cliffs, all engineering change proposals are now processed through a singlescreening process defined in CCNPP procedures CM-1.01-1003, Design Engineeringand Configuration Control, and CNG-FES-O07, Preparation of Design lnputs andChange lmpact Screen. To address the extent of this cause, CCNPP reviewed 104 ofthe 386 CDC engineering changes that were performed between 2Q01 and 2003 toverify that the changes implemented using this process were appropriately processed asa CDC. CCNPP did not identify other instances where significant changes notappropriate for processing using the CDC process were approved using the CDCprocess. CCNPP also reviewed current engineering change procedures, CM-1.01-1003and CNG-FES-QQ7 to confirm that the current process would ensure that a changesimilar to the one implemented in 2001 would receive the appropriate level of review.The inspectors reviewed a sample of CCNPP's assessments for risk significant systempreventive maintenance strategies and CCNPP's review of the need for flushing and/orfill and vent procedures for salt water systems. The inspectors reviewed thereplacement plan and related operability evaluations for safety-related Agastat relays inEnclosure 11critical applications that were older than 10 years and the inspection results for the 12Agastat relays removed from service to determine if a common failure mode waspresent. The inspectors also discussed the CDC process used to remove the Agastatrelay 10-year replacement requirement and the current engineering change process,which CCNPP determined would have ensured the appropriate evaluations and reviewswere completed, with design and system engineering personnel. Based on thesereviews and interviews, the inspectors concluded that CCNPP's RCAR adequatelyaddressed the extent of condition and the extent of cause for the performancedeficiencies identified as a result of the 28 EDG failure.lP 95001 requires that the inspection staff determine that the licensee's root cause,extent of condition, and extent of cause evaluations appropriately considered the safetyculture components as described in Inspection Manual Chapter 0305.CCNPP conducted a safety culture component assessment in accordance with siteprocedure CNG-CA-1

===.01 -1O04, "Root Cause

Analysis.

" The evaluation identifiedweaknesses, as defined in procedure CNG-CA-1 .01-1004, in the human performance,problem identification and resolution, and management performance cross cutting areas.Specifically, the weaknesses were associated with the following safety culturecomponents: work control, self-assessments and accountability, continuous learning,organizational change, and safety policies.The inspectors reviewed CCNPP's safety culture component assessment and confirmedthat the evaluation was performed in accordance with CCNPP's procedure. Theinspectors also confirmed that CCNPP appropriately assigned corrective actions forweaknesses it had identified. The inspectors determined, based on these reviews, thatCCNPP's RCAR properly considered weaknesses in safety culture components thatwere highlighted by the February 18,2010, 28 EDG failure.f. FindinqsNo findings were identified.02.03 Corrective Actionsa. lP 95001 requires that the inspection staff determine that: (1) the licensee specifiedappropriate corrective actions for each root and/or contributing cause, or (2) anevaluation that states no actions are necessary is adequate.CCNPP immediately initiated corrective actions required to restore the 28 EDG tooperable status. These actions included flushing the lube oil pressure sensing lines,replacing the 28 EDG failed T3A relay and performing a successful cold fast start of the28 EDG. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the 28 EDG failure, in accordance with technicalspecifications, CCNPP also confirmed that a common cause failure condition did notexist for the other two Fairbanks Morse EDGs.To address the lube oil sensing line blockage that delayed the reset of the low lube oilpressure switches, CCNPP created periodic maintenance tasks to inspect, drain, andrefillthe sensing lines on all three Fairbanks Morse EDGs. CCNPP also revised thecalibration procedures for the lube oil pressure switches to specify the testing mediumand connection point for the pressure source.Enclosure===

12To address the failed Agastat relay, CCNPP developed new as-found acceptancecriteria for the replacement of all safety-related and critical non safety-related Agastatrelays. Procedure E-10, Testing and Adjustment of Agastat Relays, Rev. 00301 , whichwas eliminated around the time the 10 year replacement intervalwas eliminated in 2001,was reinstated and revised to specify the replacement criteria for critical safety-relatedrelays. The new criteria stated that if during relay calibration the relay was identified tobe greater than 8 years old (from the date of manufacture), or if the as-found calibrationresults for the relay exceeded the acceptance criteria for contact resistance or drift, therelay should be replaced.As a starting point for relay replacements, CCNPP developed a relay replacement planfor all critical safety-related relays greater than 10 years old and for all non-criticalsafety-related and critical non safety-related relays greater than 18 years old. Thereplacement plan ranked each relay in terms of risk significance, relay performanceduring recent calibrations and whether or not a failure of the relay would be immediatelydetectable.To ensure timely replacement of the subject Agastat relays in the future, in addition toreinstating the age based replacement criteria, CCNPP developed and implemented arelay monitoring program that included additional replacement criteria based on thetrending of relay calibration results. These new criteria, that would be used to determinethe need for replacement of safety-related and critical non safety-related Agastat relays,were developed based on CCNPP's review of all available historical Agastat relaycalibration data. This new monitoring program, and its implementation, was described inthefollowing procedures: CNG-AM-1.01-1005, Engineering Rolesand Responsibilities,EN-1-136, CCNPP Relay Reliability Process, CNG-AM-1.01-1004, Equipment ReliabilityReporting, E-10, Testing and Adjustment of Agastat Relays, and CSU-2, Agastat RelayPerformance Monitoring.To address the fact that the combined effect of the blockage in the lube oil sensing linesand the T3A relay drift on the ability of 28 EDG to successfully respond to a demandstart could not be detected during periodic pre-lubricated surveillance testing, CCNPPimplemented a test method to detect and monitor changes in the operating margin forthe low lube oil pressure monitoring circuits for the Fairbanks Morse EDGs. CCNPP willmonitor degradation by timing the actuation for one of the lube oil pressure switches oneach Fairbanks Morse EDG during monthly surveillance testing. CCNPP alsoimplemented a relay monitoring program that included a relay component engineerreview and a relay component health report, which will trend performance for all safety-related and nonsafety-related Agastat relays based on calibration results. To provideadditional margin to the low lube oil pressure trip setpoint, CCNPP increased the timedelay setting of the T3A relay for all of the Fairbanks Morse EDGs.To address CCNPP's inappropriate use of the CDC process to eliminate the requirementto replace Agastat E7000 series relays every 10 years, CCNPP reviewed currentengineering change procedures, CM-1.01-1003 and CNG-FES-OO7, to confirm that noadditional corrective actions were required because the current processes ensured thata change similar to the one implemented in 2001 would receive the appropriate level ofreview.Enclosure b.13The inspectors reviewed CCNPP's corrective actions for each root and contributingcause as specified by the RCAR. The inspectors reviewed completed work orders forthe replacement of the failed Agastat relay, and the filling and venting of lube oil sensinglines for all EDGs. The inspectors also reviewed the evaluation that CCNPP performedto increase the time delay relay for the lube oil pressure trip circuit and identified noconcerns. The inspectors reviewed new periodic maintenance tasks that CCNPPcreated for the lube oil sensing lines and CCNPP's revisions to the Agastat relaycalibration procedures. The inspectors walked down CCNPP's new venting and fillingprocedures for the Fairbanks Morse EDG lube oil systems with the system engineer anda maintenance department representative. The walk down confirmed the adequacy ofthese procedures. The inspectors also interviewed the relay component engineer,reviewed the relay system health report and procedures E-10, "Testing and Adjustmentof Agastat Relays," Rev. 00301 and CSU-02, "Agastat Relay Performance Monitoring,"Rev. 0 to verify that a relay monitoring program was in place and that as-foundacceptance criteria for relay replacement were established. Based on these reviews andinterviews, the inspectors concluded that the proposed and completed corrective actionsassigned to address the root and contributing causes for the 28 EDG failure wereappropriate.lP 95001 requires that the inspection staff determine that the licensee prioritizedcorrective actions with consideration of risk significance and regulatory compliance.CCNPP took immediate corrective actions to restore the 28 EDG's operability bydraining and refilling the lube oil sensing lines, replacing the failed T3A Agastat relay,and performing a successful cold fast start for the 28 EDG. In accordance with technicalspecifications, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the 28 EDG failure, CCNPP also confirmed that acommon cause failure condition did not exist by confirming cold fast start capability forthe other two Fairbanks Morse EDGs. Technical specification compliance for theemergency power system limiting condition for operation was restored on February 23,2010, when the 28 EDG was declared operable.To address the identified root causes and restore regulatory compliance relative to theperformance deficiencies identified by the White finding and NOV, CCNPP completed itsfinal revision to the root cause evaluation on January 19, 2011. CCNPP implementedcorrective actions to address the causes of the White finding based on the results of thisevaluation. CCNPP developed periodic maintenance tasks to inspect, drain and refill thesensing lines on the Fairbanks Morse EDGs; revised the calibration procedures for theEDG lube oil pressure switches to provide specific guidance for testing medium and testequipment connection points; and implemented a testing method to detect and monitorfor degradation of the components in the Fairbanks Morse EDG lube oil pressuremonitoring circuits not previously testing during cold fast EDG starts. CCNPP alsodeveloped and implemented a relay monitoring program and developed as-foundacceptance criteria that controlled the replacement of all critical safety-related andcritical non safety-related Agastat relays. Regulatory compliance was restored onJanuary 13,2011, after CCNPP developed and implemented a performance monitoringprogram for the Agastat relays.At the time of the supplemental inspection, all of the corrective actions described abovewere fully completed with the exception of the extent of condition Agastat relayreplacements. The remaining relay replacements were scheduled based on CCNPP'srelay replacement plan.Enclosure c.14The inspectors reviewed CCNPP's relay replacement plan for the safety-related andcritical relays in service that had exceeded the specifiedl0 year replacementrequirement. CCNPP has replaced allAgastat relays whose failure could cause asafety-related system to be inoperable. CCNPP's replacement plan ranked each of theremaining relays in terms of risk significance, relay performance during recentcalibrations and whether or not a failure of the subject relay was immediately detectable.The remaining relays were scheduled for replacement during upcoming maintenancewindows. CCNPP developed operability determinations for each in-service relay thathad exceeded the 10 year age requirement and had previously exhibited excessive driftduring testing. The inspectors reviewed these operability determinations and verifiedthat they were adequate and that the relays remained operable. CCNPP is scheduled tofinish the planned relay replacements before the end oI2O11.The inspectors reviewed CCNPP procedure CNG-CA-1.01-1004, Root Cause Analysis,concerning guidance on prioritization and scheduling of corrective actions. Theprocedure required CCNPP to prioritize corrective actions with a due date based on risksignificance. lt also required that compensatory actions be provided if permanentacltions could not be performed in a timely manner. The inspectors compared CCNPP'sprioritization of corrective actions for the 28 EDG trip, as described above, to thisguidance. Based on this review, the review of the relay replacement plan, and theoperability determinations performed for relays that had exceeded both age and driftreplacem-ent criteria, the inspectors determined that CCNPP's implementation ofcorrective actions was appropriately prioritized with consideration of risk significance andregulatory compliance.lP 95001 requires that the inspection staff determine that the licensee established aschedule for implementing and completing the corrective actions.CCNPP took immediate corrective actions to restore the 28 EDG's operability bydraining and refilling the lube oil sensing lines, replacing the failed T3A Agastat relay,and performing a successful cold fast start for the 28 EDG. CCNPP also confirmed thata common cause failure condition did not exist by confirming cold fast start capability forthe other two Fairbanks Morse EDGs.At the time of the inspection CCNPP had completed several corrective actions toaddress the causes of the White finding based on the results of the RCAR. CCNPPdeveloped periodic maintenance tasks to inspect, drain and refill the sensing lines on theFairbanks Morse EDGs; revised the calibration procedures for the EDG lube oil pressureswitches to provide specific guidance for testing medium and test equipment connectionpoints; and implemented a testing method to detect and monitor for degradation of thecomponents in the Fairbanks Morse EDG lube oil pressure monitoring circuits notpreviously testing during cold fast EDG starts. CCNPP also developed and implemented'a relay monitoring program and developed as-found acceptance criteria that controlledthe replacement of all tritical safety-related and critical non safety-related Agastat relays'CCNpP has several assigned corrective actions that have not yet been fully completedbut are in progress. The three most significant remaining corrective actions include:replacement of att Agastat relays that exceed the newly established replacement criteriarequirements; a review of preventive maintenance strategies for a sample of safety-related system components to ensure the strategies complied with Regulatory GuideEnclosure d.151.33, Quality Assurance Program Requirements; and a review of testing procedures forthe Calvert Cliffs site's most risk significant systems, to determine if testing measureswould detect operating margin degradation before it impacted the systems capability toperform its safety function.The inspectors determined that none of these remaining corrective actions were requiredto prevent recurrence of the significant condition adverse to quality that was identified bythe February 18, 2010, 28 EDG failure. As previously discussed, all Agastat relays thatwere greater than 10 years old, whose failure could prevent a safety-related system fromperforming its designed safety function, were replaced and the relay monitoring programdesigned to control and track relay replacements was developed and implemented. Thereviews of the preventive maintenance strategies and testing methods for risk significantsystems, which are intended to verify that the programmatic or organizational conditionsthat resulted in the February 18, 2010, 28 EDG failure do not exist elsewhere at CalvertCliffs, are in progress. The results of these reviews will determine whether actions arerequired to address the extent of cause in these areas.The inspectors' reviews confirmed that regulatory compliance was restored onJanuary 13,2011, and in accordance with CCNPP's current schedule for completion forthe corrective action items discussed above and other less significant corrective actionsfor the 28 EDG trip on February 18,2Q10, all corrective actions will be completed beforethe end of 2011.Based on this assessment and that all remaining corrective actions for the White findingare scheduled for completion before the end of 2Q11, the inspectors concluded thatCCNPP established an acceptable schedule for corrective action completion that metCCNPP's corrective action timeliness requirements as provided in CCNPP procedureCNG-CA-1

===.01 -1 004, Root Cause

Analysis.

lP 95001 requires that the inspection staff determine that the licensee developedquantitative and/or qualitative measures of success for determining the effectiveness ofthe corrective actions to preclude repetition.The root cause analysis for CR-2010-007157, documented performance of the followingitems to review the effectiveness of the corrective actions assigned to precluderepetition. Specifically, upon documented completion of all corrective action items forCR-2010-007157, the following items were assigned to be performed (Each item belowwas tracked by a separate corrective action item in the CCNPP CAP):. Confirm that EDG Agastat relay changes to the preventive maintenance strategy,testing methods, and replacement criteria were completed ;. Conduct a self-assessment of relay trending and maintenance results to evaluatethe impact of Agastat relay trending on Agastat relay failure rates and themaintenance procedure impact on the identification of the need for relayreplacement; and. Complete an effectiveness review in accordance with CNG-CA-1.01-1004, RootCause Analysis, after all corrective actions and corrective actions to preventrecurrence have been completed to ensure the causes of the 28 EDG failurewere identified and corrected. Specific items to be confirmed during the courseof this review included: no Fairbanks Morse EDG trips due to low lube oilpressure, site wide preventive maintenance strategies meet the requirements ofEnclosure===

e.16Regulatory Guide 1.33 with respect to replacement and inspection, and that aneffective relay monitoring program has been implemented.The effectiveness review in accordance with CCNPP procedure CNG-CA-1.01-1004specified in the last item listed above required the following items to be completed:Confirm all corrective actions and corrective actions to prevent recurrence werecomplete and met effectiveness review criteria as defined in the RCAR;Confirm the corrective actions and corrective actions to prevent recurrence wereimplemented as originally planned and were not modified, nor additional actionsadded without management review committee approval;Conduct interviews with affected personnelto confirm that the original problemno longer exists;Confirm that there have not been condition reports or key site performanceindicator results that identify recent occurrences of this issue or an issuesufficiently similar in cause or consequence that indicates the problem still exists;andConfirm the corrective actions and corrective actions to prevent recurrence arestill useful (i.e., procedure change works).Upon completion of the review, CCNPP procedure CNG-CA-1.01-1004 required that thereviewer fully document the basis for the conclusions for each item and initiate CRs foreffectiveness issues identified by the review.The inspectors reviewed the effectiveness review corrective action items as documentedin the RCAR and the effectiveness review process described in CCNPP procedureCNG-CA-1.01-1004 and determined that quantitative and qualitative measures ofsuccess had been developed for determining the effectiveness of the corrective actionsto preclude repetition of the issues identified by the February 18,2010, 28 EDG trip.lP 95001 requires that the inspection staff determine that the licensee's planned or takencorrective actions adequately address a NOV that was the basis for the supplementalinspection, if applicable.The NRC issued an NOV of Technical Specification 5.4.1 to CCNPP on August 3,2010.CCNPP provided the NRC a written response to the NOV on September 2,2Q10.CCNPP's response described: (1) corrective steps that have been taken and the resultsachieved; (2) corrective steps which will be taken; (3) the date when full compliance willbe achieved; and (4) the reasons for the violation. During this inspection, the inspectorsconfirmed that CCNPP's RCAR and its planned and completed corrective actionsaddressed the NOV and the associated performance deficiencies. The inspectors alsoconfirmed that CCNPP restored full compliance with NRC requirements on January 13,2011, when it developed and implemented a performance monitoring program forAgastat relays that complied with section 9.b of Appendix A to Regulatory Guide 1.33, asrequired by Calvert Cliffs Unit 2 Technical Specification 5.4.FindinqsNo findings were identified.Enclosure 1740A6 Exit MeetinqOn March 18, 2011, the inspectors presented the inspection results to Mr. GeorgeGellrich, Site Vice President, and other members of his staff, who acknowledged theinspection results. The inspectors asked if any of the material examined during theinspection should be considered proprietary. CCNPP did not identify any proprietaryinformation.Reoulatorv Performance MeetinqFollowing the March 18,2011, exit meeting, the NRC discussed with CCNPP itsperformance at Calvert Cliffs Nuclear Power Plant, Unit 2 in accordance with IMC 0305,Section 10.01.a. The meeting was attended by the Region I Division of ReactorProjects, Branch 1, Branch Chief, and other NRC staff and the CCNPP Site VicePresident and other CCNPP staff. During this meeting, the NRC and CCNPP discussedthe issues related to the White finding that resulted in Calvert Cliffs Nuclear Power Plant,Unit 2 being placed in the Regulatory Response Column of the Action Matrix. Thisdiscussion included the causes, corrective actions, extent of condition and extent ofcause for the issues identified as a result of the February 18,2010, 28 EDG failure.ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

G. Gellrich, Site Vice President

T. Trepanier, Plant General Manager

P. Amos, Performance lmprovement

H. Beasley, Principle Engineer

D. Lauver, Director Licensing

S. Loeper, Principle Engineer

C. Neyman, Licensing Engineer

T. Riti, General Supervisor, System Engineering

LIST OF ITEMS

OPENED. CLOSED. AND DISCUSSEDClosed:0500031 8/201 0006-02vtoInadequate Preventive Maintenance Results in theFailure of the 28 Emergency Diesel Generator

LIST OF DOCUMENTS REVIEWED

RooUApparent Cause AnalvsesCR-20'10-007157, Failure of the 28 EDG During the Dual Unit Trip, Rev. 2ProceduresCSU-02, Agastat Relay Performance Monitoring, Rev. 0E-10, Testing and Adjustment of Agastat Relays, Rev. 00301CNG-AM-1.01-1018, Preventive Maintenance Program, Rev. 00600FTI-338, Calibration Checl</ Calibration of Allen-Bradley Pressure Switches, Rev. 00101FTE-59, Periodic Maintenance, Calibration and Functional Testing of Protective Relays,Rev.00600CNG-CA-1.01-1 004, Root Cause AnalysisCNG-CA-1.01 -GL002, Causal Analysis HandbookMiscellaneousRelay Component Health Report, Units 1 &2,101112010-12131120101C041lV40711X1, CCNPPP Protective Relay Setting Sheet for Auxiliary Feedwater lsolationValves 1CV4071 and 1CV4071A2C0412V40711X1, CCNPPP Protective Relay Setting Sheet for Auxiliary Feedwater lsolationValve 2CV40712C0412V40701X1, CCNPPP Protective Relay Setting Sheet for Auxiliary Feedwater lsolationValve 2CV40701C0411V40701X1, CCNPPP Protective Relay Setting Sheet for Auxiliary Feedwater lsolationValves 1CV4070 and 1CV4070A1C62DIT2A, CCNPPP Protective Relay Setting Sheet for

EDG 18T2A Relay2C61D/T3A, CCNPPP Protective Relay Setting Sheet for

EDG 28 T3A RelayAttachment

A-2Replacement Plan for SR Agastat E7000 Relays Past Service Life, signed 314111PES-25180, CCNPPP Procurement Engineering Specification for Agastat Relays andAssociated Hardware, Rev. 19Fairbanks Morse Pre Lubrication White PaperPS-33, Shelf Life Evaluations, Rev. 7ES20010067, Delete Requirement in E-406 to Change out Agastats Prior to 10 Years, Rev. 0Letter from Calvert Cliffs Nuclear Power Plant to U.S. Nuclear Regulatory Commission, datedNovember 2. 1993, License Amendment Request: Emergency Diesel Generator TestingLetter from U.S. Nuclear Regulatory Commission to Calvert Cliffs Nuclear Power Plant, datedFebruary 24, 1994, Request For Additional Information Regarding Emergency DieselGenerator Technical Specification Surveillance Testing Requirements - Calvert Cliffs NuclearPower Plant Unit Nos. 1 and2 (TAC Nos. M88168 and M88169)Letter from U.S. Nuclear Regulatory Commission to Calvert Cliffs Nuclear Power Plant, datedSeptember 27, 1994,lssuance of Amendments for Calvert Cliffs Nuclear Power Plant UnitNo. 1 (TAC No. M88168) and Unit 2 (TAC No. M88169)Work Ordersc91213077Condition Reports2011-029572011-013232010-124552010-12785Condition Reports Generated2011-33242011-2645c909367962010-12687201 0-1 1 5382010-044792009-072772011-31792011-2957c910599242011-033242010-115442010-11545201

1-3353201 1 -3358ADAMSCAPCCNPPcDcEDGIMCIPIRIRTKVMORTMSPINOVNRCPARSRCAR

LIST OF ACRONYMS

Agency-wide Documents Access and Management SystemCorrective Action ProgramCalvert Cliffs Nuclear Power PlantConfiguration Document ChangeEmergency Diesel GeneratorInspection Manual ChapterInspection Procedurelnspection Reportlssue Response TeamKilovoltManagement Oversight and Risk TreeMitigating Systems Performance lndexNotice of ViolationNuclear Regulatory CommissionPublicly Available RecordsRoot Cause Analysis ReportAttachment