IR 05000317/2017003
| ML17306A054 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 10/31/2017 |
| From: | Anthony Dimitriadis Reactor Projects Branch 1 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2017003 | |
| Download: ML17306A054 (22) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION I
2100 RENAISSANCE BLVD., Suite 100 KING OF PRUSSIA, PA 19406-2713 October 31, 2017 Mr. Bryan Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 SUBJECT: CALVERT CLIFFS NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000317/2017003 AND 05000318/2017003
Dear Mr. Hanson:
On September 30, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2. On October 11, 2017, the NRC inspectors discussed the results of this inspection with Mr. Mark Flaherty, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspectors did not identify any finding or violation of more than minor significance.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Anthony Dimitriadis, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Nos. 50-317 and 50-318 License Nos. DPR-53 and DPR-69
Enclosure:
Inspection Report 05000317/2017003 and 05000318/2017003 w/Attachment: Supplementary Information
REGION I==
Docket Nos. 50-317 and 50-318 License Nos. DPR-53 and DPR-69 Report Nos. 05000317/2017003 and 05000318/2017003 Licensee: Exelon Generation Company, LLC (Exelon)
Facility: Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Location: Lusby, MD Dates: July 1, 2017, through September 30, 2017 Inspectors: R. Clagg, Senior Resident Inspector C. Roettgen, Resident Inspector M. Hardgrove, Project Engineer J. Hawkins, Senior Resident Inspector R. Vadella, Emergency Response Coordinator Approved by: Anthony Dimitriadis, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure
SUMMARY
Inspection Report 05000317/2017003, 05000318/2017003; 7/01/2017 - 9/30/2017; Calvert
Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2; Routine Integrated Inspection Report.
This report covers a three-month period of inspection by resident inspectors and announced baseline inspections performed by regional inspectors. No findings were identified. The Nuclear Regulatory Commissions (NRC) program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,
Revision 6.
REPORT DETAILS
Summary of Plant Status
Unit 1 began the inspection period at 100 percent power. On September 28, 2017, operators reduced power to 80 percent for main turbine valve testing. On September 29, the unit was restored to 100 percent power. The unit remained at or near 100 percent power for the remainder of the inspection period.
Unit 2 began the inspection period at 100 percent power. On August 2, 2017, operators reduced power to 65 percent for 22 steam generator feedwater pump repairs and restored the unit to 100 percent power the same day. On September 10, operators reduced power to 83 percent power for man turbine valve testing and restored the unit to 100 percent power the same day. The unit remained at or near 100 percent power for the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
External Flooding
a. Inspection Scope
During the week of August 8, 2017, the inspectors performed an inspection of the intake structure for Units 1 and 2. The inspectors reviewed technical specification (TS),procedures, design documents, and Updated Final Safety Analysis Report (UFSAR),
Chapter 2.4.2.4, which depicted the design flood levels and protection areas containing safety-related equipment to identify areas that may be affected by external flooding. The inspectors conducted a general site walkdown of all external areas of the plant, including the intake structure, the emergency diesel generator (EDG) rooms, and west road relay houses to ensure that Exelon Generation Company, LLC (Exelon) erected flood protection measures in accordance with design specifications. Where applicable, the inspectors determined installed flood seal service life and verified that adequate procedures existed for inspecting the installed seals. The inspectors also reviewed operating procedures for mitigating external flooding during severe weather and confirmed that, overall, Exelon had established adequate measures to protect against external flooding events and, more specifically, that credited operator actions were adequate. Documents reviewed for each section of this inspection report are listed in the Attachment.
b. Findings
No findings were identified.
1R04 Equipment Alignment
Partial System Walkdowns (71111.04Q - 4 samples)
a. Inspection Scope
The inspectors performed partial walkdowns of the systems listed below. The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable procedures, system diagrams, the UFSAR, TSs, work orders (WO), action requests (AR), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted the systems performance of its intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify that system components and support equipment were properly aligned and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether staff had properly identified equipment issues and entered them into the corrective action program (CAP) for resolution with the appropriate significance characterization.
- Unit 2, 22 emergency core cooling system (ECCS) train during 21 ECCS train out of service due to 2-SW-5171 (21 ECCS air cooler control valve (CV)) failed to open on stroke time, July 6, 2017
- 21 and 22 containment air coolers and containment spray pumps during 23 containment air cooler out of service, July 28, 2017
- 11 and 12 containment air coolers and containment spray pumps during 13 containment air cooler out of service, August 7, 2017
b. Findings
No findings were identified.
1R05 Fire Protection
Resident Inspector Quarterly Walkdowns (71111.05Q - 4 samples)
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 Exelon controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.
- Unit 2, 27 Switchgear Room, Fire Area 18, August 8, 2017
- Unit 2, Purge Air Room, Fire Area 18A, August 8, 2017
- Unit 2, 45 Switchgear Room, Fire Area 25, August 8, 2017
- Outside Yard Area and Buildings, includes Fire Pump House, Fire Area 21, August 11, 2017
b. Findings
No findings were identified.
1R07 Heat Sink Performance
a. Inspection Scope
The inspectors reviewed the 21 and 22 component cooling heat exchangers (HX)readiness and availability to perform their safety functions. The inspectors reviewed the design basis for the component and verified Exelons commitments to NRC Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment.
The inspectors observed actual performance tests for the HXs and/or reviewed the results of previous inspections. The inspectors discussed the results of the most recent inspection with engineering staff and reviewed pictures of the as-found and as-left conditions. The inspectors verified that Exelon initiated appropriate corrective actions for identified deficiencies. The inspectors also verified that the number of tubes plugged within the HX did not exceed the maximum amount allowed.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
.1 Quarterly Review of Licensed Operator Requalification Testing and Training
a. Inspection Scope
The inspectors observed licensed operator simulator training on August 22, 2017, which involved a steam generator tube rupture, stuck open steam generator safety valve, and a failed reactor coolant pump seal, resulting in a site area emergency declaration. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager and the TS action statements entered by the shift technical advisor.
Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.
b. Findings
No findings were identified.
.2 Quarterly Review of Licensed Operator Performance in the Main Control Room
a. Inspection Scope
The inspectors observed and reviewed the downpower and main turbine valve testing conducted on Unit 2, September 10, 2017. The inspectors observed infrequently performed test or evolution briefings, pre-shift briefings, and reactivity control briefings to verify that the briefings met the criteria specified in Exelon procedures, OP-AA-103-102, Watch Standing Practices, Revision 16, and HU-AA-1211, Pre-Job Briefings, Revision 11. Additionally, the inspectors observed evolution performance to verify that procedure use, crew communications, and coordination of activities between work groups similarly met established expectations and standards.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system, and component (SSC) performance and reliability. The inspectors reviewed system health reports, CAP documents, maintenance WOs, and maintenance rule basis documents to ensure that Exelon was identifying and properly evaluating performance problems within the scope of the maintenance rule. For each sample selected, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.65 and verified that the (a)(2) performance criteria established by Exelon staff was reasonable. As applicable, for SSCs classified as (a)(1),the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2). The inspectors ensured that Exelon staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries. Additionally, inspectors verified quality control verifications are properly specified in accordance with the Quality Assurance Program, and are implemented as specified.
- AR04035456, 21 switchgear heating, ventilation, and air conditioning breaker tripped, short circuit indicated
- Review of quality verifications for WOs C92961725, C92350192, C93325372, C92289253, and C92341252
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that Exelon performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors determined that Exelon performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When Exelon performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk.
The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the stations probabilistic risk analyst to verify that plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.
- Unit 1, Maintenance risk assessment for 13 charging pump alignment inspection/replacement and discharge relief valve 1-RV-324 overhaul, July 5-6, 2017
- Unit 2, Updated maintenance risk assessment for 2-SW-5171 CV failed open on stroke time, July 6, 2017
- Unit 2, Updated maintenance risk assessment for 22A and 22B service water (SRW)
HX plenum cleaning with 22 SRW out of service for bay temperature > 80 F, July 19, 2017
- Unit 2, Updated maintenance risk assessment for 23 containment air cooler failed to start in slow speed, July 28, 2017
- Unit 1, Updated maintenance risk assessment for 13 containment air cooler circuit failed, August 8, 2017
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed operability determinations for the degraded or non-conforming conditions listed below based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS and UFSAR to Exelon staffs evaluations to determine whether the components or systems were operable. The inspectors confirmed, where appropriate, compliance with bounding limitations associated with the evaluations. Where compensatory measures were required to maintain operability, such as in the case of operator work arounds, the inspectors evaluated whether the measures in place would function as intended and were properly controlled by Exelon staff.
- 2-SW-5171 CV failed open on stroke time (AR04028976)
- Vibration increasing on 23 high pressure safety injection pump bearing (AR04037460)
- 1CV5159A did not operate on auto flush (AR04045989)
- OF1 found melted cubicle stab connections (AR04047266)
- 1RIT5421 - 11 main steam effluent radiation monitor is malfunctioning (AR04050546)
- Fan housing base plate corroded, caulking is degraded (AR04052717)
- Spalling concrete above and west of 23 saltwater pump motor (AR04053075)
b. Findings
No findings were identified.
1R18 Plant Modifications
Permanent Modifications
a. Inspection Scope
The inspectors evaluated the modifications listed below and verified that the design basis, licensing bases, and performance capability of the affected systems were not degraded by the modifications. In addition, the inspectors reviewed modification documents associated with the upgrade and design change. The inspectors also reviewed revisions to the control room alarm response procedure and interviewed engineering and operations personnel to ensure the procedure could be reasonably performed.
- ES200800185-001, Saltwater Chemical Addition, Revision 003
- ECP-16-000742, Replace 1A EDG Governing and Control System, Revision 003
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure were consistent with the information in the applicable licensing basis and/or design basis documents, and that the test results were properly reviewed and accepted and problems were appropriately documented. The inspectors also walked down the affected job site, observed the pre-job brief and post-job critique where possible, and confirmed work site cleanliness was maintained. Additionally, the inspectors witnessed the test or reviewed test data to verify quality control hold points were performed and checked, and ensured that results demonstrated adequate restoration of the affected safety functions.
- WO C92350192, dated February 17, 2017, overhaul valve and actuator 2-CV-5171, July 27, 2017
- WO C93635104, 2-CVC-512 CV leaks by, August 15, 2017
- WO C93623804, functional test charging pump 21 control relay, August 28, 2017
- WO C93637133, 1CV5159A did not operate on auto flush, August 29, 2017
- WO C93596473, remove 22 auxiliary feedwater (AFW) pump strainers and check valves, September 19, 2017
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed performance of a surveillance test and reviewed test data of selected risk-significant SSCs to assess whether test results satisfied TS, the UFSAR, and Exelon procedure requirements. The inspectors verified that test acceptance criteria were clear, the test demonstrated operational readiness, and was consistent with design documentation. Additionally, the inspectors ensured that the test instrumentation had current calibrations and the range and accuracy for the application, the test was performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that the equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance test:
- OI-21A, 2A Diesel Generator, Revision 02404, July 5, 2017
- STP-O-5A11-1, 11 Auxiliary Feedwater Pump Quarterly Surveillance Test, Revision 3, July 10, 2017
- STP-M-212B-1, Channel B Reactor Protective System Functional Test, Revision 013, July 27, 2017
- STP-O-009-1, AFAS Logic Test, Revision 1500, August 4, 2017
- STP-O-731-2, HPSI Pump and Check Valve Quarterly Operability Test, Revision 12, August 8, 2017 (in-service testing)
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation
Emergency Preparedness Drill Observation
a. Inspection Scope
On July 18, 2017, the inspectors reviewed and observed Exelons performance of an emergency preparedness drill that involved a simulated failure of ECCS motor operated valves, a reactor trip, a loss of AFW, and high radiation levels in the containment resulting in a General Emergency declaration. The inspectors observed emergency response operations in the simulator, technical support center, and emergency operations facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the station drill critique to compare inspector observations with those identified by Exelon staff in order to evaluate Exelons critique and to determine whether the Exelon staff was properly identifying weaknesses and entering them into the CAP. Drill issues were captured by Exelon in the CAP as ARs 04032950, 04032977,
===04033036, 04033388, 04033390, 04033475, 04033477, and 04033478.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
Mitigating Systems Performance Index ===
a. Inspection Scope
The inspectors reviewed Exelons submittal of the CCNPP Unit 1 and Unit 2 Mitigating Systems Performance Index for the systems listed below for the period July 1, 2016, through June 30, 2017:
- Emergency alternating current power system (MS06)
- High pressure injection system (MS07)
- Heat removal system (MS08)
- Residual heat removal system (MS09)
- Cooling water system (MS10)
To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7. The inspectors also reviewed the Exelons operator narrative logs, ARs, event reports, system health reports, and NRC integrated inspection reports to validate the accuracy of the submittals.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review of Problem Identification and Resolution Activities
a. Inspection Scope
As required by Inspection Procedure 71152, Problem Identification and Resolution, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to determine if Exelon entered issues into the CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the CAP and periodically attended AR screening meetings. The inspectors also confirmed, on a sampling basis, that, as applicable, for identified defects and non-conformances, Exelon staff performed an evaluation in accordance with 10 CFR 21.
b. Findings
No findings were identified.
.2 Semi-Annual Trend Review
The inspectors performed a semi-annual review of site issues, as required by Inspection Procedure 71152, Problem Identification and Resolution, to identify trends that might indicate the existence of more significant safety issues. In this review, the inspectors included repetitive or closely-related issues that may have been documented by Exelon personnel outside of the CAP, such as trend reports, performance indicators, major equipment problem lists, system health reports, maintenance rule assessments, and maintenance or CAP backlogs. The inspectors also reviewed Exelons CAP database for the first and second quarters of 2017 to assess condition reports written in various subject areas (equipment problems, human performance issues, etc.), as well as individual issues identified during the NRCs daily inspection report review (Section 4OA2.1). The inspectors reviewed Exelons quarterly trend report for the first and second quarters of 2017, conducted under PI-AA-125-1005, Coding and Analysis Manual, Revision 0, to verify that Exelon personnel were appropriately evaluating and trending adverse conditions in accordance with applicable procedures.
b. Findings and Observations
No findings were identified.
The inspectors evaluated a sample of condition reports generated by departments that provide input to the quarterly trend reports. The inspectors determined that the issues were appropriately evaluated by Exelon staff for potential trends and resolved within the scope of the CAP. The inspectors reviewed self-assessments performed by Exelon outside of the CAP including quarterly performance assessment reports, Nuclear Oversight Audits, and others, and verified that trends identified were input into the CAP and appropriately evaluated.
.3 Annual Sample: Review of Evaluations Performed for Preventative Maintenance
Changes Associated with Safety-Related Equipment
a. Inspection Scope
The inspectors performed an in-depth review of evaluations, preventive maintenance (PM) strategies, technical justifications, and corrective actions associated with Exelons PM optimization process, which included an effort to reclassify system components based on recent changes to industry guidance (AP-913, Equipment Reliability Process Description). These changes were reflected in Exelons procedures for equipment reliability, component classification, and PM. These changes also included a revision to the industry definition of what constitutes a critical component, which is now defined as any component whose failure can cause a reactor trip, a power reduction greater than 20 percent, a functional failure of a system monitored under a mitigating systems performance index, or a complete loss of safety function or maintenance rule high safety-significant functional failure. Exelons engineering reclassification of critical components was initiated in October 2016 and captured in the CAP in ARs 02721166, 02715053, and 03964936. The final critical component validation review was performed by the PM Oversight Committee in May 2017 (AR04002733).
The inspectors reviewed Exelons identification, assessment, and documentation of the critical component and PM changes in the CAP, associated evaluations, extent of condition reviews, and the prioritization and timeliness of Exelons actions to determine whether Exelons corrective actions were appropriate. The inspectors compared the actions taken to the requirements of Exelons procedures and 10 CFR Part 50, Appendix B. In addition, the inspectors reviewed engineering technical justifications and interviewed maintenance, engineering, and operations personnel to assess the effectiveness of the implemented corrective actions.
b. Findings and Observations
No findings were identified.
The inspectors noted in the industry guidance that the desired end state for each site was to reduce the number of critical components by as much as 50 percent through revising the critical component definition to include only those components whose direct failure could result in unacceptable consequences. The results of Exelons critical component reclassification effort resulted in a decrease of approximately 30 percent of the total number of critical components onsite. The inspectors found this to be comparable to, but on the low end of, the industry average reduction in critical components.
The inspectors reviewed and assessed critical component designation changes and PM changes in several risk significant systems. In total 96 PM changes were reviewed. A significant majority (~70 percent) of these PM changes were concentrated in 3 high risk significant systems, EDG, AFW, and Safety Injection.
The inspectors verified that the programmatic changes to the stations equipment reliability program were appropriately proceduralized, and found that overall, Exelons critical component reclassification and PM optimization process was appropriately managed, conservatively applied, and technically justified.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On October 11, 2017, the inspectors presented the inspection results to Mr. Mark Flaherty, Site Vice President, and other members of the Exelon staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- M. Flaherty, Site Vice President
- T. Tierney, Plant General Manager
- M. Fick, Principal Engineer, Regulatory Assurance
- K. Greene, Principal Engineer, Regulatory Assurance
- C. Jackson, Engineering Manager
- B. Larrabee, Senior Maintenance Specialist
- B. Lynch, System Engineer
- D. Schrumpf, CMO Manager
- N. Smith, System Engineer
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
None