IR 05000317/2019002

Integrated Inspection Report 05000317/2019002 and 05000318/2019002

ML19217A035
Person / Time
Site:	Calvert Cliffs
Issue date:	08/05/2019
From:	Erin Carfang NRC Region 1
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
References
IR 2019002
Download: ML19217A035 (12)

Text

ust 5, 2019

SUBJECT:

CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1 AND 2 -

INTEGRATED INSPECTION REPORT 05000317/2019002 AND 05000318/2019002

Dear Mr. Hanson:

On June 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Calvert Cliffs Nuclear Power Plant, Units 1 and 2. On July 31, 2019, the NRC inspectors discussed the results of this inspection with Mr. Mark Flaherty and other members of your staff.

The results of this inspection are documented in the enclosed report.

The NRC inspectors did not identify any findings or violations 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 at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Erin E. Carfang, Chief Reactor Projects Branch 1 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: 05000317/2019002 and 05000318/2019002 Enterprise Identifier: I-2019-002-0039 Licensee: Exelon Generation Company, LLC Facility: Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Location: Lusby, MD Inspection Dates: April 01, 2019 to June 30, 2019 Inspectors: R. Clagg, Senior Resident Inspector J. Furia, Senior Health Physicist C. Roettgen, Resident Inspector A. Rosebrook, Senior Project Engineer J. Schoppy, Senior Reactor Inspector Approved By: Erin E. Carfang, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure

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 05000318,05000317/ LER 2018-003-00 for Calvert 71153 Closed 2018-003-00 Cliffs, Unit 1, Control Room Loss of Ventilation due to Smoke Detector Failure Causing Common Supply Damper to Shut.

LER 05000318,05000317/ LER 2018-003-01 for Calvert 71153 Closed 2018-003-01 Cliffs Nuclear Power Plant,

Units No. 1 and 2, Control Room Loss of Ventilation due to Smoke Detector Failure Causing Common Supply Damper to Shut.

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 June 15, 2019, the unit was down powered to 65 percent to support steam generator feedwater pump maintenance. The unit was returned to rated thermal power on June 16, 2019, and 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 plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. 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.

71111.01 - Adverse Weather Protection Impending Severe Weather Sample (IP Section 03.03)

(1) The inspectors evaluated readiness for impending adverse weather conditions for severe thunderstorms and high winds forecasted for June 13, 2019.

Seasonal Extreme Weather Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal high temperatures for the 1A, 1B, 2A, and 2B emergency diesel generators, and the intake structure.

Summer Readiness Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated summer readiness of offsite and alternate alternating current power systems.

71111.04 - Equipment Alignment Partial Walkdown Sample (IP Section 03.01)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) 12 component cooling train during 11 component cooling train out of service for maintenance, April 3, 2019

(2) 'B' emergency core cooling system train during 11 high pressure safety injection pump and 'A' emergency core cooling system train out of service for maintenance, April 4, 2019

(3) 1A emergency diesel generator during 12 component cooling train out of service for maintenance, April 16, 2019

(4) Unit 1, 'A' high pressure safety injection train during 'B' high pressure safety injection train out of service for maintenance, May 14, 2019

71111.04S - Equipment Alignment Complete Walkdown Sample (IP Section 03.02)

(1) The inspectors evaluated system configurations during a complete walkdown of the Unit 2 480 volt and below distribution system including reactor motor control centers on June 27, 2019.

71111.05Q - Fire Protection Quarterly Inspection (IP Section 03.01)

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Units 1 and 2, cable spreading rooms, 1C and 2C chase, battery rooms and hallway outside cable spreading rooms, fire areas 16, 16A, 16B, 17, 17A and 17B, April 9, 2019

(2) 1B, 2A, and 2B, emergency diesel generator rooms, fire areas 28, 30, and 31, May 15, 2019

(3) Outside yard area and buildings, includes the fire pump house, fire area YARD, May 16, 2019

(4) Unit 2, service water pump room, fire area 40, May 21, 2019

(5) Unit 2, east and west penetration rooms, fire areas 26 and 27, May 30, 2019

(6) Cable chase 1A, 1B, 2A, 2B, and control room complex, fire areas 20, 21, 22, 23, and 24, June 12, 2019

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) The inspectors observed and evaluated licensed operator performance in the Unit 2 main control room during high frequency on 24 inverter causing 2Y04, 120 volt alternating current instrument bus inoperability on May 23, 2019.

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

(1) The inspectors observed and evaluated a training event involving a loss of offsite power, loss of one safety-related emergency diesel generator, and loss of the station blackout diesel generator resulting in the declaration of an Alert on May 14, 2019.

71111.12 - Maintenance Effectiveness Quality Control (IP Section 02.02)

The inspectors evaluated maintenance and quality control activity associated with Action Request (AR) 04249160 issues identified during closeout of work orders for missing VT-2 exams on June 7, 2019.

Routine Maintenance Effectiveness Inspection (IP Section 02.01) (1 Sample)

The inspectors evaluated the effectiveness of routine maintenance activity associated with AR04234227, perform Maintenance Rule (a)(1) determination for post-accident monitoring system on May 21, 2019.

71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01)

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Unit 1, maintenance risk assessment for 11 component cooling heat exchanger out of service for maintenance and elevated risk condition, April 3, 2019

(2) Units 1 and 2, maintenance risk assessment for 11 high pressure safety injection pump and 21 component cooling heat exchanger out of service for maintenance, April 4, 2019

(3) Unit 2, maintenance risk assessment for 22 component cooling heat exchanger out of service for maintenance and elevated risk condition, April 10, 2019

(4) Unit 1, maintenance risk assessment for 12 component cooling heat exchanger out of service for maintenance and elevated risk condition, April 16, 2019

(5) Unit 2, risk informed completion time for failure of 24 inverter, June 4, 2019

(6) Units 1 and 2, review of fire risk management actions for 0C diesel generator out of service for maintenance, June 7, 2019

71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 02.02)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) AR04237752, 2B emergency diesel generator causing abnormal oscillations on service water header pressure, April 9, 2019

(2) AR04168047, 12 battery charger 'unable to share' light illuminated, May 29, 2019

(3) AR04253609, 2Y11, backup inverter bus, voltage low, June 4, 2019

(4) AR04238251, temperature in the technical support center was approximately 81 degrees, June 5, 2019

(5) AR04237765, 1B, 2A, and 2B emergency diesel generator rooms fixed louvers not installed per design, June 8, 2019

(6) Review operator work around program, June 18, 2019

(7) AR04258437, received reactor vessel level monitoring system channel 'B' alarm, June 24, 2019

71111.19 - Post-Maintenance Testing Post Maintenance Test Sample (IP Section 03.01)

The inspectors evaluated the following post maintenance tests:

(1) WO C93704621, 2B emergency diesel generator causing abnormal oscillations on service water header, April 19, 2019

(2) WO C93597046, fabricate and install coupling shaft guard shield on 13 high pressure safety injection pump, May 14, 2019

(3) WO C93711946, 0C diesel generator lube oil leak near A5 cylinder, June 12, 2019

(4) WO C91970729, replace the control room smoke removal damper actuators with a new model, June 12, 2019

(5) WO C93712096, 2B emergency diesel generator crank case vacuum high out of specification, June 13, 2019

(6) WO C93612196, inspect and lubricate 2MOV403OP, Unit 2 pressurizer pressure relief block valve operator, June 29, 2019

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Inservice Testing (IP Section 03.01)

(1) STP-O-065T-1, "ECCS Valves Powered From MCC-114R Operability Test,"

Revision 7, June 18, 2019

Surveillance Tests (other) (IP Section 03.01) (4 Samples)

(1) STP-O-08B-1, "Test of 1B DG and 14 4 kV Bus UV," Revision 33, April 11, 2019

(2) STP-F-696-0, "Fire Pump Flow Test," Revision 101, April 19, 2019

(3) PEO-O-024-08-O-M, "Monthly Performance Evaluation of the 0C Diesel Generator,"

Revision 301, May 2, 2019

(4) STP-O-08B-2, "Test of 2B DG and 4 kV Bus 24 UV," Revision 34, May 14, 2019

71114.06 - Drill Evaluation Drill/Training Evolution Observation (IP Section 03.02)

The inspectors evaluated the conduct of a simulator training evolution involving loss of offsite power, reactor trip, and extended loss of all power resulting in a General Emergency declaration on June 19, 2019.

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)

(1 Sample)

(1) The inspectors observed and evaluated the conduct of an emergency drill involving loss of spent fuel pool water level resulting in a General Emergency declaration on May 21,

71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation Radioactive Material Storage (IP Section 02.01)

The inspectors observed radioactive waste container storage areas and verified the postings and controls and that the licensee had established a process for monitoring the impact of long-term storage of the waste.

Radioactive Waste System Walkdown (IP Section 02.02) (1 Sample)

The inspectors walked down accessible portions of liquid and solid radioactive waste processing systems, abandoned in place radioactive waste processing equipment, and current methods and procedures for dewatering waste.

Shipment Preparation (IP Section 02.04) (1 Sample)

The inspectors reviewed the records of shipment packaging, surveying, labeling, marking, placarding, vehicle checks, emergency instructions, disposal manifest, shipping papers provided to the driver, and licensee verification of shipment readiness.

Shipping Records (IP Section 02.05) (1 Sample)

The inspectors reviewed five non-excepted package shipment records: 18-052;18-057; 18-083;18-108; and 18-110.

Waste Characterization and Classification (IP Section 02.03) (1 Sample)

The inspectors identified radioactive waste streams and reviewed radiochemical sample analysis results to support radioactive waste characterization. The inspectors reviewed the use of scaling factors and calculations to account for difficult-to-measure radionuclides.

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) ===

(1) Unit 1, April 1, 2018 - March 31, 2019

(2) Unit 2, April 1, 2018 - March 31, 2019

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues (IP Section 02.03)

The inspectors reviewed the licensees implementation of its corrective action program related to the switchgear room heating ventilation and air conditioning support system reliability concern.

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.

71153 - Followup of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

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

(1) LER 05000317, 318/2018-003-00, 01, Control Room Loss of Ventilation Due to Smoke Detector Failure Causing Common Supply Damper to Shut. The circumstances surrounding this LER is documented in the inspection results section this report.

INSPECTION RESULTS

Observation: Semi-Annual Trend 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. In this review, the inspectors included repetitive or closely-related issues that may have been documented by Exelon personnel outside of the corrective action program, such as trend reports, performance indicators, major equipment problem lists, system health reports, maintenance rule assessments, and maintenance or corrective action program backlogs. The inspectors also reviewed Exelon's corrective action program database for the first and second quarters of 2019 to assess action requests written in various subject areas (equipment problems, human performance issues, etc), as well as individual issues identified during the NRC's daily action request review. The inspectors reviewed Exelon's quarterly trend report for the first and second quarters of 2019 to verify that Exelon personnel were appropriately evaluation and trending adverse conditions in accordance with applicable procedures.

The inspectors evaluated a sample of action requests generated by departments that provide input to the quarterly trend reports. The inspectors assessed whether the issues were appropriately evaluated by Exelon staff for potential trends and resolved within the scope of the corrective action program. The inspectors reviewed self-assessments performed by Exelon outside of the corrective action program, including quarterly performance assessment reports and Nuclear Oversight Audits, and verified that trends identified were input into the corrective action program and appropriately evaluated.

No findings were identified.

Observation: Switchgear Room Heating Ventilation And Air Conditioning Support 71152 System Reliability Concern The inspectors reviewed Exelon's evaluation and corrective actions associated with multiple failures of switchgear room heating ventilation and air conditioning circuits documented under AR04177833. The inspectors concluded that Exelon had taken timely and appropriate actions in accordance with Exelons operating and alarm response procedures, PI-AA-125, Corrective Action Program (CAP) Procedure, 10 CFR Part 50 Appendix B, and Maintenance Rule requirements. The inspectors determined that Exelons associated engineering evaluations and trending were sufficiently thorough and based on the best available information, sound judgment, and relevant operating experience. Exelons assigned corrective actions were aligned with engineering evaluations, adequately tracked, appropriately documented, and completed as scheduled. Based on the documents reviewed, switchgear room and heating ventilation and air conditioning system walkdowns, and discussions with engineering personnel, the inspectors noted that Exelon personnel identified problems and entered them into the corrective action program at a low threshold.

Minor Performance Deficiency 71153 Minor Performance Deficiency: The inspectors reviewed LER 05000317,318/2018-003-00, 01, control room ventilation system records, and Exelon procedure ER-AA-2004, System Vulnerability Identification and Mitigation, Revision 008, and determined that Exelon engineers recognized a single point vulnerability to lose both trains of ventilation in the main control room due to a failed inlet damper during a system review in 2010 and 2015. Contrary to Exelon procedure ER-AA-2004, Exelon engineers did not develop and document a mitigation strategy for the single point vulnerability resulting in the loss of both trains of control room ventilation when the common inlet ducting smoke detector spuriously actuated shutting the inlet damper. Exelon entered Technical Specification 3.0.3, as required, and reopened the inlet damper within seven minutes. Exelon entered the issue into the corrective action program as AR04153797 and implemented a preventative maintenance repetitive task to clean and inspect the smoke detector.

Screening: The inspectors determined the performance deficiency was minor. The inspectors determined that Exelon not mitigating the single point vulnerability was a minor performance deficiency because it was not a precursor to a more significant event, if left uncorrected it would not lead to a more significant safety concern, it did not relate to a performance indicator that would have caused the indicator to exceed a threshold, and it did not adversely affect any reactor oversight process cornerstone objectives.

The disposition of this performance deficiency closes LER 05000317,318/2018-003-00,

EXIT MEETINGS AND DEBRIEFS

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

• On July 31, 2019, the inspectors presented the integrated inspection results to Mr. Mark Flaherty and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71152 Corrective Action AR03984740, AR03994483, AR03994488, AR04022779,

Documents AR04132640, AR04135280, AR04141229, AR04146716,

AR04147442, AR04151532, AR04153797, AR04159055,

AR04165286, AR04177833, AR04225216, AR04225228,

AR04232731, AR04232870, and AR04232877

71153 Miscellaneous Engage Strategy Component Vulnerability Assessment for 08/17/2016

0DAMP5342, Control Room AC Supply Damper

Procedures ER-AA-2004 System Vulnerability Identification and Mitigation 8

PI-AA-125-1003 Corrective Action Program Evaluation Manual 004

10