IR 05000317/2019010
| ML19340A043 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 12/05/2019 |
| From: | Matt Young NRC/RGN-I/DRP/PB5 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| Young M | |
| References | |
| IR 2019010 | |
| Download: ML19340A043 (12) | |
Text
ber 5, 2019
SUBJECT:
CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1 AND 2 - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000317/2019010 AND 05000318/2019010
Dear Mr. Hanson:
On November 8, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Calvert Cliffs Nuclear Power Plant, Units 1 and 2 and discussed the results of this inspection with Jacob Smith, Director of Organizational Performance & Regulatory Assurance, and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment.
Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
No findings or violations of more than minor significance were identified during this inspection. 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 at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Matthew R. Young, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket Nos. 05000317 and 05000318 License Nos. DPR-53 and DPR-69
Enclosure:
As stated
Inspection Report
Docket Numbers: 05000317 and 05000318 License Numbers: DPR-53 and DPR-69 Report Numbers: 05000317/2019010 and 05000318/2019010 Enterprise Identifier: I-2019-010-0008 Licensee: Exelon Generation Company, LLC Facility: Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Location: Lusby, MD Inspection Dates: October 21, 2019 to November 8, 2019 Inspectors: L. Cline, Senior Project Engineer L. Dumont, Reactor Inspector P. Finney, Senior Project Engineer C. Roettgen, Resident Inspector Approved By: Matthew R. Young, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at Calvert Cliffs Nuclear Power Plant, Units 1 and 2, in accordance with the Reactor Oversight Process.
The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations No findings or violations of more than minor significance were identified.
Additional Tracking Items None.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)
- (1) The inspectors performed a biennial assessment of the licensees problem identification and resolution performance in the following areas:
Corrective Action Program Effectiveness including problem identification, prioritization and evaluation, and corrective actions, which included a review of corrective actions completed to address Unit 1 safety injection tank leakage and site-wide roof leakage in safety-related areas over the past five years.
Use of Operating Experience.
Completed Self-Assessments and Audits.
Health of the Safety Conscious Work Environment.
INSPECTION RESULTS
Assessment 71152B Corrective Action Program Effectiveness -
Problem Identification: The inspectors determined that, in general, the licensee identified issues and entered them into the corrective action program at a low threshold.
Problem Prioritization and Evaluation: Based on the samples reviewed, the inspectors determined that, in general, the licensee appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem. The licensee appropriately screened issue reports (IRs) for operability and reportability, categorized IRs by significance, and assigned actions to the appropriate department for evaluation and resolution.
However, the inspectors identified one minor performance deficiency and one observation regarding the licensee's evaluation of issues. The details of the minor performance deficiency and the observation are documented in the applicable sections below.
Corrective Actions: The inspectors determined that the overall corrective action program performance related to resolving problems was effective. In most cases, the licensee implemented corrective actions to resolve problems in a timely manner.
Assessment 71152B Use of Operating Experience -
The team determined that the licensee appropriately evaluated industry operating experience for its relevance to the facility. The licensee appropriately incorporated both internal and external operating experience into plant procedures and processes, as well as lessons learned for training and pre-job briefs.
Self-Assessments and Audits -
The team reviewed a sample of self-assessments and audits to assess whether the licensee was identifying and addressing performance trends. The team concluded that the licensee had an effective self-assessment and audit process.
Assessment 71152B Safety Conscious Work Environment -
The team interviewed a total of 32 individuals. The purpose of these interviews was to evaluate the willingness of the licensee staff to raise nuclear safety issues; to evaluate the perceived effectiveness of the corrective action program at resolving identified problems; and to evaluate the licensee's safety-conscious work environment. The personnel interviewed were randomly selected by the inspectors from the Operations, Engineering, Maintenance, Security, and Radiation Protection work groups. To supplement these discussions, the team interviewed the Employee Concerns Program (ECP) representative to assess his perception of the site employees' willingness to raise nuclear safety concerns. The team also reviewed the ECP case log and select case files.
All individuals interviewed indicated that they would raise safety concerns. All individuals felt that their management was receptive to receiving safety concerns and generally addressed them promptly, commensurate with the significance of the concern. Most interviewees indicated they were adequately trained and proficient on initiating condition reports. All interviewees were aware of the licensee's ECP, stated they would use the program if necessary, and expressed confidence that their confidentiality would be maintained if they brought issues to the ECP. When asked whether there have been any instances where individuals experienced retaliation or other negative reaction for raising safety concerns, all individuals interviewed stated that they had neither experienced nor heard of an instance of retaliation at the site. The team determined that the processes in place to mitigate potential safety conscious work environment issues were adequately implemented.
Minor Performance Deficiency 71152B Minor Performance Deficiency: The inspectors determined that two root cause analyses (RCAs) completed during the period were not conducted in accordance with the licensee's corrective action program guidance for use of evaluation techniques. Specifically, procedure PI-AA-125-1001, Root Cause Analysis Manual, states, in part, that, although an event and causal factor chart is typically required, the use can be waived provided adequate justification is documented. Contrary to this guidance, the inspectors identified that two of the three completed RCAs (the August 2017 Dry storage cask Uptake Event (AR 4040215) and the February 2018 11A Reactor Coolant Pump Bay Uncontrolled Locked High Radiation Area Event (AR 4107884)), did not provide evidence that an event and causal factor chart was used nor documented the basis for not using an event and casual factor chart.
For these RCAs, the inspectors interviewed licensee staff who conducted the investigations as well as those responsible for implementing the directed corrective actions. They also reviewed the completed RCAs and associated supporting documentation. Based on these interviews and document reviews, the inspectors concluded that the causal factors identified by each RCA were reasonable and that corrective actions and corrective actions to prevent recurrence, as applicable, were adequate based on the evaluation results.
Screening: The inspectors determined the performance deficiency was minor. Using NRC Inspection Manual Chapter 0612, Appendices B and E, the inspectors determined the performance deficiency was minor because it did not impact the adequacy of the corrective actions completed to prevent recurrence of the associated conditions adverse to quality. The licensee documented this minor performance deficiency in IR 04294549.
Observation: Weaknesses in Causal Evaluation Performance and Review 71152B The inspectors reviewed three RCAs and eleven corrective action program evaluations (CAPEs) completed for issues identified during the inspection period. Although the inspectors determined the corrective actions for these issues were adequate and timely and the evaluations complied with applicable standards and regulations; they also identified an adverse trend in the execution and documentation of the evaluations, and in the quality of the management review of the evaluations.
Several of the causal evaluation reports did not include objective evidence and documentation that demonstrated how the licensee identified causal factors and determined the root, contributing, and/or apparent causes. Examples included: the RCA reports did not use or include the completed event and causal factor charts; the RCA reports did not discuss all potential casual factors for the event/issue and its consequences; some CAPE reports used TapRooT investigation techniques but did not discuss or include the event and causal factor chart normally used with this technique; one CAPE report used a support/refute matrix but did not include the matrix result; and one CAPE report used two analysis techniques that produced conflicting results but did not discuss the conflict.
The inspectors also reviewed licensee guidance for management review of completed RCAs and CAPEs. In accordance with site procedures, RCAs require a lead investigator review and RCAs and CAPEs both require responsible manager and management review committee review. The licensees procedures did not provide specific direction on what was required to conduct or document these reviews, but the inspectors identified that corrective action program procedure, PI-AA-125-1001, did suggest that the lead investigator and responsible manager use Attachment 3, Investigation Report Quality Checklist, for a completed RCA review. The inspectors determined that many of the critical and important attributes identified in this checklist could have identified the inspector-identified causal evaluation weaknesses listed above.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On November 8, 2019, the inspectors presented the biennial problem identification and resolution inspection results to Jacob Smith, Director of Organizational Performance &
Regulatory Assurance, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71152B Corrective Action 2632602, 2636152, 2642479, 2644405, 2693413, 2707583,
Documents 2721584, 4000385, 4039165, 4042199, 4042695, 4044315,
4045023, 4047414, 4047695, 4048211, 4048236, 4049825,
4053168, 4053645, 4054403, 4054643, 4058419, 4059671,
4063778, 4064875, 4066096, 4068478, 4068672, 4069005,
4070712, 4070732, 4072614, 4074039, 4084199, 4087101,
4088149, 4101431, 4102575, 4105873, 4107962, 4108011,
4108041, 4108119, 4108876, 4109513, 4109966, 4111829,
4113555, 4113595, 4113596, 4113599, 4114316, 4115012,
4115386, 4118580, 4123918, 4126041, 4127164, 4127246,
27435, 4127862, 4128096, 4128408, 4128978, 4137793,
4139331, 4150464, 4156632, 4158882, 4167233, 4170945,
4172814, 4177148, 4180603, 4183896, 4192991, 4193436,
200530, 4200920, 4203193, 4208769, 4216814, 4220152,
20609, 4220790, 4220795, 4221352, 4222236, 4222897,
25770, 4227978, 4228454, 4229529, 4230917, 4230952,
231083, 4236280, 4238136, 4247781, 4252613, 4254790,
254792, 4255207, 4256218, 4265063, 4270719, 4274612
CAPE 4075301 EDG 2B Failed to maintain Combustion
CAPE 4111790 Oil Sheen was Observed on the Bay
CAPE 4120959 Unit 1 Main Turbine Linear Variable Differential Transformer
(LVDT) mounting bracket broke off
CAPE 4130918 21A RCP Seal Leakage from Pressure Transmitter Line Flex
Hose
CAPE 4153797 Ventilation was OOS
CAPE 4177689 Corporate Maintenance Elevation AD-AA-1110
CAPE 4182707 EDG Low Header Press
CAPE 4203915 OF1 U1 Steam Generators Entered AL1 For Sulfates
CAPE 4225806 2CV4260, Tested Above Admin Limit During 2019 RFO As-
Found and As-Left Local Leak Rate Testing (LLRT)
CAPE 4227781 Misapplication of Technical Specification Following Failed
Surveillance Resulted in Operation Prohibited by Technical
Inspection Type Designation Description or Title Revision or
Procedure Date
Specifications
CAPE 4253533 Loss of 2Y04 Inverter 24
RCA 4040215 Dry Storage Cask Uptake Event
RCA 4064538 Clearance and Tagging Event per OP-AA-106-101-1001
RCA 4107884 11A Reactor Coolant Pump Bay Uncontrolled Locked High
Radiation Area (LHRA)
Corrective Action 4290430, 4290627, 4290909, 4291003, 4291081, 4291978,
Documents 4294549, 4294674, 4295344, 4295433, 4290824, 4295106,
Resulting from 4295425, 4295472
Inspection
Engineering ECP_18-000194 Evaluate Mounting 1YXA2 Configuration Using a Different Rev. 0
Changes Plug 1C04BB
Miscellaneous Maintenance Department PI MRM Summary 1Q19
UFSAR Chapters 9.5, 9.10
(a)(1) Determination Issue Report Number: 4261127 9/19/2019
Procedures CC-AA-309-101 Engineering Technical Evaluations Rev.15
EE-AA-200-1001 Equipment Classification Rev. 4
ER-AA-1200 Critical Component Failure Clock Rev. 14
ER-AA-700 Aging Management Implementation Rev. 7
FASTENER-01 Torqueing and Fastener Applications 400
MA-AA-716-017 Station Rework Reduction Program Rev.8
PI-AA-120 Issue Identification Screening Process Rev. 8
PI-AA-125 Corrective Action Program Rev. 6
PI-AA-125-1003 Corrective Action Program Evaluation Manual Rev. 5
WC-AA-106 Work Screening and Processing Rev. 18
Self-Assessments NOSA-CAL-17-07 Nuclear Fuels Audit Report 05/23/2017
NOSA-CAL-17-08 Operations Functional Area Audit Report 10/11/2017
NOSA-CAL-18-03 Emergency Preparedness Audit Report 05/02/2018
NOSA-CAL-18-04 Chemistry, Radwaste, Effluent and Environmental Monitoring 07/11/2018
Audit Report
NOSA-CAL-18-05 Engineering Programs and Station Blackout Audit Report 04/26/2018
NOSA-CAL-18-06 Fire Protection Audit Report 10/24/2018
NOSA-CAL-18-07 Training and Staffing Audit Report 07/10/2018
Inspection Type Designation Description or Title Revision or
Procedure Date
NOSA-CAL-18-09 Inservice Inspection, Inservice Testing, and Appendix J Audit 09/19/2018
Report
NOSA-CAL-19-02 Security Programs Audit Report 02/13/2019
NOSA-CAL-19-06 Radiation Protection Audit Report 08/21/2019
NOSC-CAL-18-01 Maintenance Functional Area Audit Report, (4090531) Jan-Feb 18
Work Orders C92759014 STP M-031-0 -1RV409, High Pressure Safety Injection Relief 02/22/2016
Valve Set Pressure Test
C93444081 STP O-073G-1, High Pressure Safety Injection Pump Large 03/17/2018
Flow Test
C93444358 STP-O-067C-1, Miscellaneous Check Valve Test (Safety 03/17/2018
injection)
C93610383 STP-O-067C-2, Miscellaneous Check Valve Test (Safety 03/15/2019
injection)
C93610579 STP O-073G-2, High Pressure Safety Injection Pump Large 02/23/2019
Flow Test
C93621898 Perform Alignment of 23 AFW Pump 11/7/2017
C93622591 Sample Oil on 23 AFW Pump & Motor due to Misalignment 8/7/2017
C93661271 BACC 23 HPSI pump has boric acid leakage 03/26/2018
C93661290 NRC: 11 HPSI Pp inboard bearing has evidence of an oil 06/12/2018
leak
C93661293 OF1 - 21 HPSI motor oil levels are elevated 04/18/2018
C93667437 BACC - Detectable Leak On 13 HPSI Pp Discharge Flange 06/12/2018
C93668288 STP O-73A1-2, A Train Saltwater Pump and Check Valve Rev.2,
Quarterly Operability Test 7/5/19
C93669912 STP O-73A2-2, B Train Saltwater Pump and Check Valve Rev. 3,
Quarterly Operability Test 7/18/19
C93673157 Material defect discovered at EPL during failure analysis 07/06/2018
C93677129 STP O-62-2 Monthly Valve Position Verification Unit 2 9/15/2019
C93678804 STP O-73A1-2, A Train Saltwater Pump and Check Valve Rev. 2,
Quarterly Operability Test 10/3/19
C93680595 STP O-73A2-2, B Train Saltwater Pump and Check Valve Rev. 3,
Quarterly Operability Test 10/17/19
C93699030 Space heaters are not passing current 03/14/2019
9