IR 05000317/2023011

Title 10 of the Code of Federal Regulations 50.69 Risk-Informed Categorization and Treatment of Structures, Systems, and Components Inspection Report 05000317/2023011 and 05000318/2023011

ML23130A003
Person / Time
Site:	Calvert Cliffs
Issue date:	05/10/2023
From:	Glenn Dentel NRC/RGN-I/DORS
To:	Rhoades D Constellation Energy Generation, Constellation Nuclear
References
IR 2023011
Download: ML23130A003 (1)

Text

May 10, 2023 David Senior Vice President Constellation Energy Generation, LLC President & Chief Nuclear Officer (CNO)

Constellation Nuclear 4300 Winfield Road Warrenville, IL 60555 SUBJECT: CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1 AND 2 - TITLE 10 OF THE CODE OF FEDERAL REGULATIONS 50.69 RISK-INFORMED CATEGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS, AND COMPONENTS INSPECTION REPORT 05000317/2023011 AND 05000318/2023011

Dear David Rhoades:

On April 27, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Calvert Cliffs Nuclear Power Plant, Units 1 and 2 and discussed the results of this inspection with Patrick Navin, 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 (CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Digitally signed by Glenn Glenn T. T. Dentel Date: 2023.05.10 Dentel 07:50:27 -04'00'

Glenn T. Dentel, Chief Engineering Branch 2 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: 05000317/2023011 and 05000318/2023011 Enterprise Identifier: I-2023-011-0017 Licensee: Constellation Energy Generation, LLC Facility: Calvert Cliffs Nuclear Power Plant Location: Lusby, MD Inspection Dates: April 10, 2023 to April 27, 2023 Inspectors: J. Bozga, Senior Reactor Inspector C. Hobbs, Reactor Inspector M. Patel, Senior Reactor Inspector D. Werkheiser, Senior Reactor Analyst Approved By: Glenn T. Dentel, Chief Engineering Branch 2 Division of Operating Reactor Safety Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a special 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

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 37060 - 10 CFR 50.69 Risk-Informed Categorization and Treatment of Structures, Systems, and Components Inspection The inspectors reviewed the licensees program and implementation of 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors, in accordance with the following procedure sections. Section 02.04 was not completed during this inspection because the feedback and process adjustment required by 10 CFR 50.69(e) was not implemented by the licensee. As of the date of this inspection, two refueling outages have not occurred since system categorization was completed on at least three systems.

Review of the Licensees Programs and Procedures (IP Section 02.01) (1 Partial)

(1) (Partial)

The inspectors reviewed the licensees program and procedures associated with 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components (SSCs) for Nuclear Power Reactors, license amendment described in the plant safety evaluation and Updated Final Safety Analysis Report and documented in the staffs Safety Evaluation Report (ADAMS Accession Nos.

ML19330D909).

Review of the Licensees 10 CFR 50.69 Program Implementation (IP Section 02.02) (1 Partial)

(1) (Partial)

The inspectors reviewed the licensees 10 CFR 50.69 categorization process and alternate treatment requirements completed on the following systems.

• Saltwater

• Component Cooling Water

• Emergency Diesel Generator

• Emergency Core Cooling

• Chemical and Volume Control Problem Identification and Resolution (IP Section 02.03) (1 Partial)

(1) (Partial)

For the systems listed above, the inspectors reviewed the licensees corrective action program to verify that conditions that would prevent RISC-3 SSCs from performing their safety-related function have been corrected. Additionally, the inspector verified that, as appropriate, the licensee performed common cause reviews for RISC-3 SSC deficiencies to ensure that the licensees SSC categorization process remains valid.

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

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

• On April 27, 2023, the inspectors presented the special inspection results to Patrick Navin, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

37060 Corrective Action 04354107

Documents 04382129

04382133

04382136

04415947

04421707

04440416

04501647

04503419

04505413

04517507

04529372

04529524

04546790

04548940

Corrective Action 04669728

Documents 04670772

Resulting from 04671594

Inspection

Engineering ECP-22-000095 Technical Evaluation for Alternative Treatment for EQ Revision 0

Changes components categorized RISC-3 per 10CFR50.69

Engineering AT-21-0050 ECCS Relief Valves Alternative Treatment Plan

Evaluations AT-21-0066 ECCS AOV IST Position Indication Testing Alternative

Treatment Plan

AT-21-0067 ECCS Manual Valves IST Alternative Treatment Plan

AT-21-0068 ECCS AOVs Inservice Test Alternative Treatment Plan

AT-21-0070 Shutdown Cooling Heat Exchanger CC Inlet Thermal Relief

Valves AT Plan

AT-21-0071 Emergency Diesel Generator Relief Valves AT Plan

AT-21-0073 Component Cooling Relief Valves AT Plan

AT-22-0082 CVCS Relief Valve Alternative Treatment

AT-22-0085 CVCS AOVs Alternative Treatment

Inspection Type Designation Description or Title Revision or

Procedure Date

AT-22-0088 50.69 White Paper for Alternative Treatment Plan

AT-22-0089 Alternative Treatment for RISC-3 components of system 15

(Component Cooling)

AT-22-0091 Alternative Treatment for system 52 (ECCS) RISC-3

components

AT-22-0094 CVCS Pumps & Check Valves IST Alternative Treatment

CA-5069-007 Estimates of Surveillance Limits for 10 CFR 50.69 Revision 0

Categorized Systems of ECCS, EDG, and EDG Oil

CA-5069-012-003 10 CFR 50.69 SCD - Saltwater System Revision 0

CA-5069-015-003 10 CFR 50.69 SCD - Component Cooling System Revision 0

CA-5069-024-003 10 CFR 50.69 SCD - Emergency Diesel Generator System Revision 2

CA-5069-041-002 CVCS Passive Consequence Development in Support of Revision 0

50.69 Passive Support Categorization

CA-5069-041-003 10 CFR 50.69 SCD - Chemical and Volume Control System Revision 0

CA-5069-052- ECCS Passive Consequence Development in Support of Revision 0

061-002 50.69 Passive Categorization

CA-5069-052- 10 CFR 50.69 SCD - Emergency Core Cooling System Revision 1

061-003

Miscellaneous CA-PRA-005.012 Saltwater Cooling System Notebook Revision 1

CA-PRA-005.015 Component Cooling System Notebook Revision 3

CA-PRA-005.023- DO and EDG System Notebook Revision 3

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CA-PRA-005.041 Chemical and Volume Control System Notebook Revision 3

CA-PRA-005.052 Safety Injection System Notebook Revision 3

CA-PRA-005.061 Containment Spray System Notebook Revision 2

CA-PRA-012 Internal Flood Notebook Revision 8

ER-CA-330-1004 Calvert Cliffs Nuclear Power Plant Fifth Interval Risk Revision 0

Informed Inservice Inspection Report

LOI-024A Operations Training - Fairbanks Morse Diesel Engine and Revision 8

Generator Controls

LOI-024C Operations Training - SACM Emergency Diesel Generators Revision 9

LOI-041-1 Operations Training - CVCS: Letdown Revision 8

LOI-041-2 Operations Training - CVCS: Charging Revision 7

Inspection Type Designation Description or Title Revision or

Procedure Date

Procedures ER-AA-569 10 CFR 50.69 Program Revision 6

ER-AA-569-1001 10 CFR 50.69 Active Component Risk Significance Insights Revision 6

ER-AA-569-1002 10 CFR 50.69 Passive Component Categorization Revision 4

ER-AA-569-1003 10 CFR 50.69 Risk Informed Categorization for Structures, Revision 8

Systems, and Components

ER-AA-569-1004 10 CFR 50.69 Alternative Treatment Implementation Process Revision 8

ER-AA-569-1005 Integrated Decision-Making Panel for Risk Informed SSC Revision 8

Categorization Duties and Responsibilities

ER-AA-569-1006 Requirements for Immediate and Periodic Performance Revision 5

Monitoring Reviews

ER-AA-569-1007 Job Familiarization of 50.69 Project Team and Site Revision 6

Personnel

STP O-8A-2 Test of 2A DG and 4 kV Bus 21 UV 02/13/2023

STP O-8B-2 Test of 2B DG and 4 kV Bus 24 UV 02/14/2023

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