IR 05000317/2021004

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Integrated Inspection Report 05000317/2021004 and 05000318/2021004
ML22031A173
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 01/31/2022
From: Brice Bickett
NRC/RGN-I/DORS
To: Rhoades D
Exelon Generation Co LLC, Exelon Nuclear
Bickett B
References
IR 2021004
Download: ML22031A173 (14)


Text

January 31, 2022

SUBJECT:

CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1 AND 2 -

INTEGRATED INSPECTION REPORT 05000317/2021004 AND 05000318/2021004

Dear Mr. Rhoades:

On December 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Calvert Cliffs Nuclear Power Plant, Units 1 and 2. On January 26, 2022, the NRC inspectors discussed the results of this inspection with Mr. Thomas Haaf, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

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, Brice A. Bickett, Chief Projects Branch 3 Division of Operating Reactor Safety

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:

05000317/2021004 and 05000318/2021004

Enterprise Identifier: I-2021-004-0125

Licensee:

Exelon Generation Company, LLC

Facility:

Calvert Cliffs Nuclear Power Plant, Units 1 and 2

Location:

Lusby, MD

Inspection Dates:

October 1, 2021 to December 31, 2021

Inspectors:

H. Anagnostopoulos, Senior Health Physicist

R. Clagg, Senior Resident Inspector

C. Lally, Senior Operations Engineer

K. Mangan, Senior Reactor Inspector

S. Obadina, Resident Inspector

Approved By:

Brice A. Bickett, Chief

Projects Branch 3

Division of Operating Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees

performance by conducting an integrated 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

Type

Issue Number

Title

Report Section

Status

LER 05000318/2021003-00

LER 2021-003-00 for Calvert

Cliffs Nuclear Power Plant,

Unit No. 2, Auxiliary

Feedwater Pump Inoperable

Due to Improper Reset of

Trip Throttle Valve.

71153

Closed

PLANT STATUS

Unit 1 operated at or near rated thermal power for the entire inspection period.

Unit 2 began the inspection period at rated thermal power. On November 21, 2021, a manual reactor trip was inserted due to lowering steam generator water levels. A unit startup was

commenced on November 22, 2021, and the unit was restored to rated thermal power on

November 23, 2021. The unit remained at or near rated thermal power for the remainder of the

inspection period.

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 performed activities described in IMC 2515,

Appendix D, Plant Status, conducted routine reviews using IP 71152, Problem Identification

and Resolution, observed risk significant activities, and completed on-site portions of IPs. 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.

REACTOR SAFETY

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1)

The inspectors evaluated readiness for seasonal extreme weather conditions prior to

the onset of seasonal cold temperatures for the emergency diesel generators and

intake structure on December 16, 2021.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following

systems/trains:

(1)

Unit 2, 22 auxiliary feedwater pump during 2A emergency diesel generator out of

service for maintenance, October 7, 2021

(2)

Unit 1, 13 auxiliary feedwater pump during 23 auxiliary feedwater pump out of service

for maintenance, November 16, 2021

(3)

Unit 2, 2A emergency diesel generator during 2B emergency diesel generator out of

service for maintenance, December 13, 2021

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a

walkdown and performing a review to verify program compliance, equipment functionality,

material condition, and operational readiness of the following fire areas:

(1)

Unit 2, service water pump room, fire area 40, October 15, 2021

(2)

Unit 2, 27' and 45' switchgear rooms and purge air room, fire areas 19, 19A, and 34,

November 15, 2021

(3)

Unit 2, auxiliary feedwater pump room, fire area 43, November 19, 2021

(4)

Units 1 and 2, intake structure, intake structure outside, and intake structure pump

room, fire area IS, December 1, 2021

(5)

Units 1 and 2, outside yard area and buildings, includes the fire pump house, fire area

YARD, December 1, 2021

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the:

(1)

Unit 2, 23 service water pump drain overflow and impact to flood hazards analysis,

December 30, 2021

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

Requalification Examination Results (IP Section 03.03) (1 Sample)

(1)

The inspectors reviewed and evaluated the licensed operator examination failure

rates for the requalification annual operating exam administered on November 16-18,

2021.

71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)

(1)

Biennial Requalification Written Examinations

The inspectors evaluated the quality of the licensed operator biennial requalification

written examination administered on November 19, 2021.

Annual Requalification Operating Tests

The inspectors evaluated the adequacy of the facility licensees annual requalification

operating test.

Administration of an Annual Requalification Operating Test

The inspectors evaluated the effectiveness of the facility licensee in administering

requalification operating tests required by Title 10 of the Code of Federal Regulations

55.59(a)(2) and that the facility licensee is effectively evaluating their licensed

operators for mastery of training objectives.

Requalification Examination Security

The inspectors evaluated the ability of the facility licensee to safeguard examination

material, such that the examination is not compromised.

Remedial Training and Re-examinations

The inspectors evaluated the effectiveness of remedial training conducted by the

licensee, and reviewed the adequacy of re-examinations for licensed operators who

did not pass a required requalification examination.

Operator License Conditions

The inspectors evaluated the licensees program for ensuring that licensed operators

meet the conditions of their licenses.

Control Room Simulator

The inspectors evaluated the adequacy of the facility licensees control room

simulator in modeling the actual plant, and for meeting the requirements contained in

Title 10 of the Code of Federal Regulations 55.46.

Problem Identification and Resolution

The inspectors evaluated the licensees ability to identify and resolve problems

associated with licensed operator performance.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)

(1)

The inspectors observed and evaluated licensed operator performance in the main

control room during the restart of Unit 2 following a manual reactor trip on

November 22, 2021.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1)

The inspectors observed and evaluated licensed operator simulator training for

Units 1 and 2 involving two dropped control element assemblies, reactor trip, and loss

of offsite power resulting in a declaration of a Site Area Emergency on November 30,

2021.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following

structures, systems, and components (SSCs) remain capable of performing their intended

function:

(1)

Units 1 and 2, maintenance rule periodic a(3) assessment review, November 29,

2021

(2)

Unit 1, AR04452491, 12 battery charger tripped during surveillance testing,

December 7, 2021

Aging Management (IP Section 03.03) (1 Sample)

The inspectors evaluated the effectiveness of the aging management program for the

following SSCs that did not meet their inspection or test acceptance criteria:

(1)

Unit 1, AR04400321, 11A service water heat exchanger plate degradation,

December 30, 2021

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the

following planned and emergent work activities to ensure configuration changes and

appropriate work controls were addressed:

(1)

Unit 2, elevated risk condition due to 2A emergency diesel generator out of service

for maintenance, October 7, 2021

(2)

Unit 1, elevated risk condition due to 12 containment spray pump out of service for

maintenance, October 15, 2021

(3)

Unit 2, elevated risk condition due to 23 auxiliary feedwater pump out of service for

maintenance, November 24, 2021

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the

following operability determinations and functionality assessments:

(1)

Units 1 and 2, AR04434456, 0C station blackout diesel output generator cables

wetted during severe weather event, November 15, 2021

(2)

Unit 2, AR04451565, water hammer in 2A and 2B emergency diesel generator

service water control valve loops, December 1, 2021

(3)

Unit 1, AR04460943, 1A emergency diesel generator 1A2 engine high temperature

heater not working, December 1, 2021

(4)

Unit 2, AR04453202, 2A emergency diesel generator tripped outside normal setpoint

range during overspeed trip testing, December 2, 2021

(5)

Unit 2, AR04448267, 2A emergency diesel generator low starting air pressure alarm

received, December 6, 2021

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)

The inspectors evaluated the following temporary or permanent modifications:

(1)

Unit 2, ECP-21-000069, permanent modifications to revise main vent radiation

monitor high flow setpoint to prevent spurious trips of the 21 radiation monitoring

system pump, December 28, 2021

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the following post-maintenance test activities to verify system

operability and functionality:

(1)

Unit 2, WO C93803998, 22A service water heat exchanger maintenance, October 27,

2021

(2)

Unit 2, WO C93761654, 2A emergency diesel generator maintenance and testing,

November 2, 2021

(3)

Unit 2, WO C93771477, 23 auxiliary feedwater pump maintenance, November 19,

2021

(4)

Unit 2, WO C93775334, 2B emergency diesel generator maintenance and testing,

December 30, 2021

(5)

Units 1 and 2, WO C93679484, 12 spent fuel pool cooling pump maintenance and

testing, December 30, 2021

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01) (2 Samples)

(1)

Unit 2, STP-O-731-2, "22 High Pressure Safety Injection Pump and Check Valve

Quarterly Operability Test, Revision 13, November 8, 2021

(2)

Unit 2, STP-M-212A, "Channel 'A' Reactor Protective System Functional Test,"

Revision 02000, December 8, 2021

RADIATION SAFETY

71124.06 - Radioactive Gaseous and Liquid Effluent Treatment

Walkdowns and Observations (IP Section 03.01) (4 Samples)

The inspectors evaluated the following radioactive effluent systems during walkdowns:

(1)

Unit 1, wide range noble gas effluent radiation monitor

(2)

Unit 2, wide range noble gas effluent radiation monitor

(3)

Unit 1, plant vent stack and associated effluent sampling ports

(4)

Unit 2, plant vent stack and associated effluent sampling ports

Sampling and Analysis (IP Section 03.02) (4 Samples)

Inspectors evaluated effluent samples, sampling processes and compensatory samples, as

available. Specifically:

(1)

The inspectors observed a routine sample of the Units 1 and 2 waste gas surge tank.

(2)

The inspectors observed a routine sample of the 11 waste gas decay tank.

(3)

The inspectors inspected the sample piping and associated heat tracing on the Unit 2

wide range noble gas effluent radiation monitor.

(4)

The inspectors reviewed the results of sampling under Title 10 of the Code of Federal

Regulations Part 61 to verify that effluent waste streams were appropriately

characterized.

Dose Calculations (IP Section 03.03) (2 Samples)

The inspectors evaluated the following dose calculations:

(1)

Discharge permit for the Unit 1 plant vent for the month of September 2021

(2)

Discharge permit for the Units 1 and 2 reactor coolant waste monitoring tank

71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &

Transportation

Radioactive Waste System Walkdown (IP Section 03.02) (2 Samples)

Inspectors walked down accessible portions of the radioactive waste systems and evaluated

system configuration and functionality, including:

(1)

The reactor coolant waste evaporator pre-filter

(2)

The 12 reactor coolant waste monitoring tank

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) (2 Samples)

(1)

Unit 1, October 1, 2020 - September 30, 2021

(2)

Unit 2, October 1, 2020 - September 30, 2021

IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (2 Samples)

(1)

Unit 1, October 1, 2020 - September 30, 2021

(2)

Unit 2, October 1, 2020 - September 30, 2021

IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (2 Samples)

(1)

Unit 1, October 1, 2020 - September 30, 2021

(2)

Unit 2, October 1, 2020 - September 30, 2021

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1)

September 2020 through September 2021

PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual

Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample

(IP Section 02.16) (1 Sample)

(1)

September 2020 through September 2021

71152 - Problem Identification and Resolution (PI&R)

Semiannual Trend Review (IP Section 02.02) (1 Sample)

(1)

The inspectors reviewed the licensees corrective action program for potential

adverse trends that might be indicative of a more significant safety issue.

Annual Follow-up of Selected Issues (IP Section 02.03) (3 Samples)

The inspectors reviewed the licensees implementation of its corrective action program

related to the following issues:

(1)

Units 1 and 2, review the evaluation and corrective actions for NCV 05000317;

318/2018004-01, failure to store and maintain FLEX equipment such that reliable

starting is reasonably assured during extreme cold, and OpESS 2020/01 FLEX

equipment design control, maintenance, and testing, December 20, 2021

(2)

Unit 2, review the evaluation and corrective actions for repeat identifications of

adverse conditions for 23 saltwater pump thrust bearing high temperature

(AR04379171, AR04346113), November 3, 2021

(3)

Unit 2, review the evaluation and corrective actions for clogging of the floor drain on

the south side of the 23 service water pump (AR01798703, AR03986363),

December 30, 2021

71153 - Follow Up of Events and Notices of Enforcement Discretion

Event Report (IP Section 03.02) (1 Sample)

The inspectors evaluated the following licensee event reports (LERs):

(1)

LER 05000318/2021-003-00, Auxiliary Feedwater Pump Inoperable Due to Improper

Reset of Trip Throttle Valve (Agencywide Documents Access and Management

System (ADAMS) Accession No. ML21271A066). The inspection details and

conclusions associated with this LER were previously documented in Inspection

Report 05000317;318/2021002 under the Inspection Results Section.

Personnel Performance (IP Section 03.03) (1 Sample)

(1)

The inspectors evaluated a loss of 21 steam generator feed pump, Unit 2 manual reactor trip, and the licensees performance on November 21, 2021.

INSPECTION RESULTS

Observation: Review the Evaluations and Corrective Actions of the Licensee in

Response to Identification of Adverse Conditions for the 23 Saltwater Pump

Following Pump Replacement

71152

The inspectors reviewed the licensees evaluations and corrective actions in response to

identification of adverse conditions for the 23 saltwater pump following pump replacement.

Corrective actions were performed following the identification of a rising thrust bearing

temperature trend for the 23 "swing" saltwater pump. Licensee staff identified, following the

overhaul of the pump in May 2020, a higher-than-expected temperature reading for the

bearing. The issue was entered into the corrective action program (AR04346113).

The inspectors noted that licensee staff evaluated the bearing temperature and established

operability limits for the maximum allowable bearing temperature. Troubleshooting activities

determined that the most likely cause was a bend in the 16-foot vertical shaft that coupled the

motor to the pump. In October 2020, licensee staff declared the pump inoperable when the

bearing temperature reached established limits. In December 2020, the licensee replaced

the shaft and restored the 23 saltwater pump to service. Post-maintenance testing of the

pump found that vibration and temperature measurements associated with the bearing had

returned to levels comparable to the other five saltwater pumps installed at the Calvert Cliffs

Units 1 and 2. Additionally, licensee staff updated the pump overhaul procedure to measure

the shaft deflection to determine if it met industry standards.

The inspectors reviewed the work order that determined the installed shaft was bent and

installed the new shaft. The inspectors reviewed the post-maintenance testing of the 23

saltwater pump after installation of the new shaft and reviewed current bearing temperatures

of all six saltwater pumps and noted the licensee identified the deficiencies that caused the

high bearing temperature.

The inspectors did not identify any findings or violations of more than minor significance.

Observation: Semi-Annual Trend Review

71152

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. An adverse trend was identified by

the licensee due to several configuration control issues, which were entered into their

corrective action program in order to be appropriately addressed. The first example occurred

on August 17, 2021, and is documented in AR04441204. Specifically, electricians were

tasked with lifting leads on the 14 diesel fire pump, which is the owner-controlled area fire

pump. The electricians proceeded to lift leads on the 12 diesel fire pump, which is the

protected area fire pump. The station entered a technical requirements manual action

statement and declared the 12 fire pump non-functional. A prompt investigation was

performed and determined that technicians failed to stop when the component ID listed in the

clearance order did not match the component ID in the field. The second example occurred

on August 17, 2021, and is documented as observation 2021-268089. Specifically, during the

installation of a flowmeter to support charging pump performance testing, the licensee

installed the flowmeter on the incorrect pump. The licensee determined that first time

performance and inadequate labeling led to the error. The third example occurred on

September 23, 2021, and is documented in ARs 04448267 and 04448295. Specifically, after

completion of the leak rate testing of the starting air receiver inlet check valves, the starting

air compressor was left in the Off position instead of automatic. The licensee was alerted to

the condition when an unexpected alarm was received in the control room indicating an issue

with the 2A emergency diesel generator. Operators were dispatched to the diesel and

identified that the starting air compressor was in the Open/Off position. A prompt investigation

was performed, and the licensee determined that the compressor was supposed to be

returned to the On position by operations but was instead signed for by the technician and not

completed. These deficiencies demonstrate an adverse trend with regards to configuration

control and the licensee generated ARs 04449058, 04448888, and 04449081 to address the

deficiencies. No additional trends were identified. The corrective actions included improved

labeling, cross functional observation of maintenance activities focused on human

performance and verification activities, performing a review of all maintenance work

instructions for proper verification practices, and establishing configuration control as a

maintenance focus area.

The inspectors did not identify any findings or violations of more than minor significance.

Observation: Review the Evaluations and Corrective Actions for Clogging of the

Floor Drain on the South Side of the 23 Service Water Pump

71152

The inspectors reviewed the licensee's evaluation and corrective actions for the clogging of

the 23 service water pump floor drain and the degradation of the other floor drains in the

service water pump rooms. The identified degradation of the Unit 2 service water pump room

floor drains is documented in AR02539814, AR03986363, and AR03986907. The service

water pump room has several floor drains that are equipped with float valves. On several

occasions a pool of water was identified near one of the drains. This typically occurs when

the licensee cleans the service water heat exchangers since the water is directed to the floor

drains in the room. The licensee performed borescope inspections, which determined that the

drain was clogged with concrete. In order to improve flow, the licensee performed

hydrolazing, which resulted in a slight increase in flow.

The inspectors reviewed the licensees flood hazards analysis and determined there were no

impacts due to the fact that the floors drains are not credited. In addition, the drains are

equipped with float valves that prevent water from the turbine building sump from entering the

service water pump room. In discussion with licensee personnel and review of work orders,

the inspectors determined that the floats are cleaned and inspected every two years. In

addition, the valve seating surface is ensured to be debris free in order to ensure proper

sealing in the event of backflow from the turbine building sump. The inspectors also reviewed

the licensees control room alarm response procedures associated with a leak in the service

water pump room and identified no impacts. The licensees interim corrective actions include

redirecting water from the 23 service water pump floor drain to the other drains in the room.

The licensee has also stationed a pump in the room in order to pump water from the 23

service water pump floor drain to another drain. This prevents the water from creating a

puddle around the floor drain. In addition, the licensees long term corrective actions include

repair of the drain.

The inspectors did not identify any findings or violations of more than minor significance.

Observation: Review the Evaluations and Corrective Actions for NCV

05000317;318/2018-0004-01, Failure to Store and Maintain FLEX Equipment

Such that Reliable Starting is Reasonably Assured During Extreme Cold

71152

The inspectors reviewed the licensee's evaluation and corrective actions associated with

the failure to store and maintain FLEX equipment such that reliable starting is reasonably

assured during extreme cold. The inspectors reviewed licensee corrective action documents

and noted that the licensees corrective actions for this issue included adding a fuel additive

to FLEX diesel equipment and diesel fuel oil storage tanks to ensure the continued reliability

of the equipment. The inspectors reviewed the licensees evaluation and completed licensee

work orders to verify that a suitable fuel additive was chosen and subsequently added to the

appropriate equipment and storage tanks.

The inspectors did not identify any findings or violations of more than minor significance.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

  • On January 26, 2022, the inspectors presented the integrated inspection results to

Mr. Thomas Haaf, Site Vice President, and other members of the licensee staff.

On October 29, 2021, the inspectors presented the radioactive gaseous and liquid

effluent treatment inspection results to Mr. Thomas Haaf, Site Vice President, and other

members of the licensee staff.