IR 05000317/2013008
| ML13310A554 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 11/05/2013 |
| From: | Daniel Schroeder Reactor Projects Branch 1 |
| To: | George Gellrich Constellation Energy Nuclear Group |
| Schroeder D | |
| References | |
| IR-13-008 | |
| Download: ML13310A554 (16) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ber 5, 2013
SUBJECT:
CALVERT CLIFFS NUCLEAR POWER PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000317/2013008 AND 05000318/2013008
Dear Mr. Gellrich:
On September 27, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Calvert Cliffs Nuclear Power Plant, Units 1 and 2. The enclosed report documents the inspection results, which were discussed on September 27, 2013, with you and other members of your staff.
This inspection examined activities conducted under your license as they relate to identification and resolution of problems and compliance with the Commissions rules and regulations and conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.
Based on the samples selected for review, the inspectors concluded that Constellation was generally effective in identifying, evaluating, and resolving problems. Constellation personnel identified problems and entered them into the corrective action program (CAP) at a low threshold. Constellation prioritized and evaluated issues commensurate with the safety significance of the problems and corrective actions were generally implemented in a timely manner.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA RPowell for/
Daniel L. Schroeder, 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 05000317/2013008 and 05000318/2013008 w/Attachment: Supplemental Information
REGION I==
Docket Nos: 50-317 and 50-318 License Nos: DPR-53 and DPR-69 Report No: 05000317/2013008 and 05000318/2013008 Licensee: Constellation Energy Nuclear Group, LLC (Constellation)
Facility: Calvert Cliffs Nuclear Power Plant, Units 1 and 2 (CCNPP)
Location: Lusby, MD Dates: September 9 - 13, 2013 September 23 - 27, 2013 Team Leader: S. Barber, Senior Project Engineer, Division of Reactor Projects (DRP)
Inspectors: H. Gray, Senior Reactor Inspector, Division of Reactor Safety E. Torres, Resident Inspector, DRP S. McCarver, Reactor Inspector, DRP Approved by: Daniel L. Schroeder, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000317/2013008 and 05000318/2013008; 09/09/2013 - 09/27/2013; Calvert Cliffs Nuclear
Power Plant, Units 1 and 2 (CCNPP); Biennial Baseline Inspection of Problem Identification and Resolution.
This NRC team inspection was performed by one resident inspector and three regional inspectors. No findings were identified during this inspection. The NRC s program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.
Problem Identification and Resolution The inspectors concluded that Constellation was generally effective in identifying, evaluating, and resolving problems. Constellation personnel identified problems, entered them into the CAP at a low threshold, and prioritized issues commensurate with their safety significance. In most cases, Constellation appropriately screened issues for operability and reportability, and performed causal analyses that appropriately considered extent of condition, generic issues, and previous occurrences. The inspectors also determined that Constellation typically implemented corrective actions to address the problems identified in the CAP in a timely manner.
The inspectors concluded that, in general, Constellation adequately identified, reviewed, and applied relevant industry operating experience to Calvert Cliffs operations. In addition, based on those items selected for review, the inspectors determined that Constellation self-assessments and audits were thorough.
Based on the interviews the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual CAP and employee concerns program issues, the inspectors did not identify any indications that site personnel were unwilling to raise safety issues nor did they identify any conditions that could have had a negative impact on the sites safety conscious work environment.
REPORT DETAILS
OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution
This inspection constitutes one biennial sample of problem identification and resolution as defined by Inspection Procedure 71152. All documents reviewed during this inspection are listed in the Attachment to this report.
.1 Assessment of Corrective Action Program Effectiveness
a. Inspection Scope
The inspectors reviewed the procedures that described Constellation Energy Nuclear Group, LLCs (CENG) corrective action program (CAP) at Calvert Cliffs. To assess the effectiveness of the CAP, the inspectors reviewed performance in three primary areas:
problem identification, prioritization and evaluation of issues, and corrective action implementation. The inspectors compared performance in these areas to the requirements and standards contained in 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, and CNG-CA-1.01-1000, Corrective Action Program. For each of these areas, the inspectors considered risk insights from the stations risk analysis and reviewed condition reports selected across the seven cornerstones of safety in the NRCs Reactor Oversight Process. Additionally, the inspectors attended multiple Plan-of-the-Day, Condition Report Screening, and Management Review Committee meetings.
The inspectors selected items from the following functional areas for review:
engineering, operations, maintenance, emergency preparedness, radiation protection, chemistry, physical security, and oversight programs.
- (1) Effectiveness of Problem Identification In addition to the items described above, the inspectors reviewed system health reports, a sample of completed corrective and preventative maintenance work orders, completed surveillance test procedures, operator logs, and periodic trend reports. The inspectors also completed field walkdowns of various systems on site, such as the emergency diesel generators, station battery 11, 12, 21 and 22 rooms, component cooling head tanks, component cooling pump rooms, service water head tanks, refueling water tanks to ensure that observable deficiencies were documented. Additionally, the inspectors reviewed a sample of condition reports (CRs) written to document issues identified through internal self-assessments, audits, emergency preparedness drills, and the operating experience program. The inspectors completed this review to verify that Constellation entered conditions adverse to quality into their CAP as appropriate.
- (2) Effectiveness of Prioritization and Evaluation of Issues The inspectors reviewed the evaluation and prioritization of a sample of CRs issued since the last NRC biennial Problem Identification and Resolution inspection completed in September 2011. The inspectors also reviewed CRs that were assigned lower levels of significance that did not include formal cause evaluations to ensure that they were properly classified. The inspectors review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate corrective actions to address the identified causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of the issues.
- (3) Effectiveness of Corrective Actions The inspectors reviewed Constellations completed corrective actions through documentation review and, in some cases, field walkdowns to determine whether the actions addressed the identified causes of the problems. The inspectors also reviewed CRs for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed Constellations timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of CRs associated with selected non-cited violations (NCVs) and findings to verify that Constellations personnel properly evaluated and resolved these issues. The inspectors also reviewed a sample of CRs associated with selected NCVs, findings, and licensee event reports to verify that Constellation personnel properly evaluated and resolved these issues. In addition, the corrective action review was expanded to five years to evaluate Constellations actions related to system performance issues identified for the 125 VDC system.
b. Assessment
- (1) Effectiveness of Problem Identification Based on the samples selected, the inspectors determined that, in general, Constellation identified problems and entered them into the CAP at a low threshold. Constellation personnel at Calvert Cliffs initiated approximately 23,000 CRs between September 2011 and September 2013. Based on the samples reviewed, the inspectors determined that Constellation trended equipment and programmatic issues, and appropriately identified problems in CRs. The inspectors verified that conditions adverse to quality identified through this review were entered into the CAP as appropriate. Additionally, inspectors concluded that personnel were identifying trends at low levels. In general, inspectors did not identify any issues or concerns that had not been appropriately entered into the CAP for evaluation and resolution. In response to several questions and minor equipment observations identified by the inspectors during plant walkdowns, Constellation personnel promptly initiated CRs and/or took immediate action to address the issues.
- (2) Effectiveness of Prioritization and Evaluation of Issues The inspectors determined, based on the samples selected, that Constellation, in general, appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem. CRs were screened for operability and reportability, categorized by significance, and assigned to a department for evaluation and resolution. The inspectors observed the various CR screening and management review groups and noted that they considered equipment operability and reportability, human performance issues, radiological safety concerns, repetitiveness, adverse trends, and potential impact on safety conscious work environment (SCWE) during the conduct of these reviews.
Items reviewed by the inspectors during the inspection were categorized for evaluation and resolution commensurate with the significance of the issues. Guidance provided by Constellation procedure, CNG-CA-1.01-1000, Corrective Action Program, for categorization appeared sufficient to ensure consistent implementation based on the sample of CRs reviewed by the inspectors. In general, issues were appropriately screened and prioritized commensurate with their safety significance.
The inspectors reviewed a sample of root cause analyses with included common cause analyses, apparent cause analyses, and a number of individual CR evaluations. For the evaluations reviewed, the inspectors noted that Constellations evaluations were generally thorough and appropriately considered extent of condition, generic issues, and previous occurrences.
- (3) Effectiveness of Corrective Actions The inspectors concluded that corrective actions for identified deficiencies were typically timely and adequately implemented. The inspectors also concluded that Constellation performed in-depth effectiveness reviews for significant issues to verify that implemented corrective actions were effective. The inspectors review of the CR disposition documentation and verification of corrective action implementation showed that Constellation routinely developed adequate corrective action as evidenced by the lack of repetitive events. The inspectors also reviewed corrective actions for the 125 VDC system for the last five years to evaluate Constellations actions for various system performance issues and noted comprehensive actions for significant issues, and reasonable corrective actions for minor issues.
c. Findings
No findings were identified.
.2 Assessment of the Use of Operating Experience (OE)
a. Inspection Scope
The inspectors reviewed a sample of CRs associated with review of industry OE to determine whether Constellation appropriately evaluated the OE information for applicability to Calvert Cliffs and had taken appropriate actions, when warranted. The inspectors also reviewed evaluations of OE documents associated with a sample of NRC generic communications to ensure that Constellation adequately considered the underlying problems associated with the issues for resolution via their CAP. In addition, the inspectors observed various plant activities to determine if the station considered industry OE during the performance of routine and infrequently performed activities.
b. Assessment The inspectors determined that Constellation appropriately considered industry OE information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The inspectors determined that OE was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable. The inspectors also observed that industry OE was routinely discussed and considered during the conduct of condition report screening meetings and pre-job briefs.
c. Findings
No findings were identified.
.3 Assessment of Self-Assessments and Audits
a. Inspection Scope
The inspectors reviewed a sample of audits, including the most recent audit of the CAP, departmental self-assessments, and assessments performed by independent organizations. These reviews were performed to determine if problems identified through these assessments were entered into the CAP when appropriate and whether corrective actions were initiated to address identified deficiencies. The effectiveness of the audits and assessments was evaluated by comparing audit and assessment results against self-revealing and NRC-identified observations made during the inspection.
b. Assessment The inspectors concluded that self-assessments, audits, and other internal Constellation assessments were generally critical, probing, thorough, and effective in identifying issues. The inspectors observed that these audits and self-assessments were completed in a methodical manner by personnel knowledgeable in the subject matter.
The audits and self-assessments were completed to a sufficient depth to identify issues that were entered into the CAP for evaluation. In general, corrective actions associated with the identified issues were implemented commensurate with their safety significance.
c. Findings
No findings were identified.
4. Assessment of Safety Conscious Work Environment
a. Inspection Scope
During interviews with station personnel, the inspectors assessed the safety conscious work environment at Calvert Cliffs. Specifically, the inspectors interviewed personnel to determine whether they were hesitant to raise safety concerns to their management and/or the NRC. The inspectors also interviewed the station Employee Concerns Program coordinator to determine what actions are implemented to ensure employees were aware of the program and its availability with regards to raising safety concerns.
The inspectors reviewed the Employee Concerns Program files to ensure that Constellation entered issues into the CAP, when appropriate.
b. Assessment During interviews, Calvert Cliffs staff expressed a willingness to use the CAP to identify plant issues and deficiencies and stated that they were willing to raise safety issues.
The inspectors noted that no one interviewed stated that they personally experienced or were aware of a situation in which an individual had been retaliated against for raising a safety issue. All persons interviewed demonstrated an adequate knowledge of the CAP and the Employee Concerns Program. Based on these limited interviews, the inspectors concluded that there was no evidence of an unacceptable safety conscious work environment and no significant challenges to the free flow of information.
c. Findings
No findings were identified.
4OA6 Meetings, Including Exit
On September 27, 2013, the inspectors presented the inspection results to Mr. George Gellrich, Site Vice President, and other members of the Calvert Cliffs staff. The inspectors confirmed that proprietary information was reviewed by inspectors during the course of the inspection, that any proprietary information that was reviewed was returned to Constellation, and that the content of this report includes no proprietary information.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- G. Gellrich, Site Vice President
- M. Flaherty, Plant General Manager
- S. Henry, Manager, Operations
- D. Lauver, Director, Licensing
- D. Dellario, Manager, Engineering
- H. Daman, Manager, Maintenance
- M. Jones, Director, Performance Improvement Unit
- C. Neyman, Senior Engineering Analyst, Licensing
- J. Schoolcraft, Performance Improvement Unit
- J. Phifer, Senior Analyst, Quality and Performance Assessment
- S. Loeper, Principal Engineer, System Engineering
- E. Kreahling, Principal Engineer, System Engineering
- R. Jones, Supervisor, Engineering Programs
- C. Grooms, General Supervisor, Operations Support
- L. Smith, General Supervisor, Engineering Asset Management
- G. Dare, Senior Engineering Analyst, System Engineering
- M. Major, Senior Engineering Analyst, System Engineering
- R. Bleacher, Operations Technical Writer
- J. Gaines, General Supervisor Shift Operations
- P. Beavers, General Supervisor Operations Training
- R. Stark, Design Engineer
- J. Wynn, System Engineer
- C. Conover, Chemistry Supervisor
- J. Stone, Supervisor Engineering
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
None