IR 05000317/2023010

Biennial Problem Identification and Resolution Inspection Report 05000317/2023010 and 05000318/2023010

ML23324A004
Person / Time
Site:	Calvert Cliffs
Issue date:	11/20/2023
From:	Brice Bickett NRC/RGN-I/DORS
To:	Rhoades D Constellation Energy Generation, Constellation Nuclear
References
IR 2023010
Download: ML23324A004 (1)

Text

November 20, 2023

SUBJECT:

CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1 AND 2 - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000317/2023010 AND 05000318/2023010

Dear David Rhoades:

On November 2, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed a p roblem identification and resolution inspection at your Calvert Cliffs Nuclear Power Plant, Units 1 and 2, and discussed the results of this inspection with Patrick D. Navin, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations problem identification and resolution 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 problem identification and resolution 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.

One finding of very low safety significance (Green) is documented in this report. This finding did not involve a violation of NRC requirements. If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555- 0001; with copies to the Regional Administrator, Region I; and the NRC Resident Inspector at Calvert Cliffs Nuclear Power Plant, Units 1 and 2.

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 (10 CFR) 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: 05000317/2023010 and 05000318/2023010

Enterprise Identifier: I-2023-010- 0016

Licensee: Constellation Energy Generation, LLC

Facility: Calvert Cliffs Nuclear Power Plant, Units 1 and 2

Location: Lusby, MD

Inspection Dates: October 16, 2023 to November 02, 2023

Inspectors: N. Warnek, Senior Project Engineer J. Brand, Senior Reactor Inspector T. Eck, Security Specialist C. Khan, Senior Project Engineer

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

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

Failure to Implement Timely Corrective Actions to Address a Degraded Condition Associated with the Meteorological Tower Cornerstone Significance Cross-Cutting Report Aspect Section Emergency Green [H.4] - 71152B Preparedness FIN 05000317,05000318/2023010- 01 Teamwork Open/Closed The inspectors identified a finding of very low safety significance (Green) when Constellation did not promptly correct a degraded condition associated with the site meteorological tower.

Specifically, since at least 2016, Constellation failed to address overgrown vegetation adjacent to the meteorological tower that could impact the accuracy and reliability of instrumentation used for public dose assessment and emergency response.

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 03.04)

(1) The inspectors performed a biennial assessment of the effectiveness of the licensees problem identification and resolution program, use of operating experience, self-assessments and audits, and safety-conscious work environment.

• Problem Identification and Resolution Effectiveness: The inspectors assessed the effectiveness of the licensees problem identification and resolution program in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five -year review of the Unit 2 auxiliary feedwater system.

• Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience.

• Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through audits and self-assessments.

• Safety-Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.

INSPECTION RESULTS

Assessment 71152B Corrective Action Program Effectiveness

The inspectors determined that Constellations problem identification and resolution program at Calvert Cliffs was generally effective in identifying, evaluating, and correcting problems.

Problem Identification: The inspectors reviewed a sample of issues that were processed through Constellations problem identification and resolution program since the last biennial team inspection. The inspectors determined that, in general, the station identified issues and entered them into the corrective action program accurately, timely, and at an appropriately low threshold.

Problem Prioritization and Evaluation: Based on the samples reviewed, the inspectors determined that, in general, Constellation appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem. Constellation appropriately screened issue reports (IRs) for operability and reportability, categorized IRs by significance, and assigned actions to the appropriate department for evaluation and resolution.

Corrective Actions: The inspectors determined that the overall problem identification and resolution program performance related to resolving problems was effective. In most cases, Constellation developed and implemented corrective actions to resolve problems in a timely manner. However, the inspectors identified one instance in which corrective actions were not implemented in a timely manner for a condition adverse to quality. This issue is documented below as a Green finding. Additionally, the inspectors identified one instance in which a corrective action extension was not performed in accordance with Constellation procedures.

This issue is documented below as a minor performance deficiency.

Assessment 71152B Use of Operating Experience

The inspectors determined that, in general, Constellation appropriately evaluated industry operating experience for its relevance to Calvert Cliffs and appropriately incorporated both external and internal operating experience into plant procedures and processes.

Assessment 71152B Self-Assessment and Audits

The inspectors reviewed a sample of self -assessments and audits performed by both Nuclear Oversight and individual departments and determined that Constellation had an effective self-assessment and audits process. In general, self-assessments and audits appropriately assessed performance and identified performance trends, issues of regulatory significance, and areas for improvement.

Assessment 71152B Safety-Conscious Work Environment

The inspectors interviewed 31 individuals across various organizations to evaluate the willingness of licensee staff to raise nuclear safety issues and to assess the perceived effectiveness of the corrective action program at resolving identified problems. Interviewees included staff and managers from Operations, Engineering, Maintenance, Security, Radiation Protection, Chemistry, Emergency Preparedness, Organizational Effectiveness, and the Employee Concerns Program (ECP). All interviewees indicated that they would raise safety concerns; they were trained and proficient on initiating IRs; and they felt their management was receptive to receiving safety concerns. Most indicated they were aware of the licensees ECP and would be willing to use it if needed. None of the interviewees stated that they had experienced or heard of an instance of retaliation for raising safety issues. The inspectors reviewed the last two years of Nuclear Safety Culture Monitoring Panel meeting minutes, the ECP case log and select files, the 2023 Safety Culture Assessment, and the results of the 2022 Employee Engagement Survey. The inspectors determined that the conditions at Calvert Cliffs appeared to be conducive to a safety-conscious work environment. No indications of reluctance to report safety issues were identified.

Failure to Implement Timely Corrective Actions to Address a Degraded Condition Associated with the Meteorological Tower Cornerstone Significance Cross-Cutting Report Aspect Section Emergency Green [H.4] - 71152B Preparedness FIN 05000317,05000318/2023010- 01 Teamwork Open/Closed The inspectors identified a finding of very low safety significance (Green) when Constellation did not promptly correct a degraded condition associated with the site meteorological tower.

Specifically, since at least 2016, Constellation failed to address overgrown vegetation adjacent to the meteorological tower that could impact the accuracy and reliability of instrumentation used for public dose assessment and emergency response.

Description:

In April 2023, Constellation Nuclear Oversight (NOS) generated IR 04673164 identifying that trees and other vegetation around the Calvert Cliffs meteorological tower exceeded the height requirements identified in procedure CY-AA-170- 1000, Radiological Environmental Monitoring Program and Meteorological Program Implementation, and that the condition had existed since at least 2016. NOS provided several recommended actions, including removing the vegetation and evaluating the meteorological tower instrumentation for accuracy. Constellation generated a corrective action under IR 04673164 to remove the vegetation, but the action was closed without addressing the vegetation. Additionally, no evaluation of instrument accuracy was performed.

The inspectors reviewed the licensee's annual meteorological tower inspection reports dating back to 2016. Each inspection report documented the presence of multiple obstructions that could affect the meteorological tower instrumentation. Specifically, the reports identified trees that exceeded height limitations in CY -AA-170- 1000 and NRC Regulatory Guide 1.23, Meteorological Monitoring Programs for Nuclear Power Plants, in multiple compass directions. The inspectors noted that the meteorological tower instrumentation is relied on by the station to make protective action recommendations during a radiological emergency and to calculate offsite dose during normal operation and accident conditions. The inspectors reviewed Regulatory Guide 1.23 and noted the height limitations are intended to ensure that vegetation does not impact wind patterns in the vicinity of the tower, which could affect the reliability and accuracy of the instrumentation. The inspectors identified that Constellation had not captured this degraded condition in the corrective action program until the NOS-generated IR in April 2023.

The inspectors reviewed IRs 04699174, 04699663, 04702168, and 04702575, generated between August 29, 2023, and September 14, 2023, and noted they documented multiple instances of the need to remove tree growth and conduct an evaluation of the impact of the growth on meteorological instrumentation.

The inspectors identified that as of November 2, 2023, Constellation had not removed the trees, secured a contract for tree removal, or evaluated the impact on the meteorological n instrumentation.

The inspectors reviewed Constellation procedure PI-AA-125, Corrective Action Program Procedure, and noted it documents that corrective actions should typically be completed within 90 calendar days of issue identification; however, if action cannot be completed until plant conditions permit, schedule reference should be defined. The inspectors determined that the overgrown vegetation was identified in the corrective action program in April 2023, yet as of November 2, 2023, corrective actions had not been completed and a schedule had not been established. The inspectors also reviewed PI-AA-120, Issue Identification and Screening Process, which defined an interim corrective action, in part, as an action taken to temporarily prevent the effects of a condition during the period when the condition is being evaluated and until final corrective actions are completed. Inspectors noted that the licensee did not consider the use of interim actions, which could have included removing some of the closest or tallest trees while an outside contract was being pursued, evaluating instrument accuracy to ensure the trees were not having a negative impact, or instructing emergency response staff to use alternate wind data until the trees could be removed.

Corrective Actions: Constellation entered the issue into their corrective action program as IRs 04714856 and 04715705 and established a compensatory measure for emergency response staff to verify wind data using alternate sources in the event a protective action recommendation is needed.

Corrective Action References: IRs 04715705, 04714856, 04699663, and 04673164

Performance Assessment:

Performance Deficiency: The inspectors determined that Constellations failure to correct a degraded condition associated with overgrown vegetation near the meteorological tower was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Facilities and Equipment attribute of the Emergency Preparedness cornerstone and adversely affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, the station failed to ensure that meteorological equipment relied on by the station for making protective action recommendations remained accurate and reliable when obstructions exceeded the height requirements in Constellation procedure CY-AA-170- 1000 and Regulatory Guide 1.23.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix B, Emergency Preparedness SDP, Attachment 2, and determined the finding to be of very low safety significance, Green, because it was a failure to comply that did not constitute a lost or degraded risk significant planning standard function or a loss of a planning standard function.

Cross-Cutting Aspect: H.4 - Teamwork: Individuals and work groups communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety is maintained. Specifically, since 2016, Constellation failed to communicate contractor inspection report results and coordinate corrective actions between various work groups including Chemistry, Emergency Preparedness, Organizational Effectiveness, Nuclear Oversight, and outside contractors, to ensure the overgrown trees were promptly identified and corrected, and their impacts evaluated.

Enforcement:

Inspectors did not identify a violation of regulatory requirements associated with this finding.

Minor Performance Deficiency 71152B Corrective Action Extension Did Not Meet Site Procedural Requirements

Minor Performance Deficiency: Corrective Action Program Evaluation (CAPE) 04225806 was performed by Constellation in May 2019 in response to a containment isolation valve that exceeded its allowable leakage during local leak rate testing. The valve, 2-RCW -4260- CV, 21 Reactor Coolant Waste Drain Tank Pump Discharge Control Valve, had exceeded its Appendix J administrative limit of 297 standard cubic centimeters on four consecutive as-found local leak rate tests.

As part of the CAPE, a corrective action was generated to repair the valve in the 2021 refueling outage. This corrective action was closed to a work order with a corrective action indicator applied. The repair plan was to first perform actuator work and, if that failed to reduce the leakage, perform valve internals work as well. During the 2021 refueling outage, work was performed on the actuator, which failed to reduce the leakage. However, the valve internals work was descoped and rescheduled for 2023. The same sequence of events took place in 2023 and, the valve internals work was descoped and deferred to 2025.

The inspectors reviewed PI -AA-125, Corrective Action Program Procedure, and noted that corrective action extensions are required to be approved by the site Management Review Committee (MRC) or MRC Chair. The inspectors identified that MRC did not review or approve the descoping of the 2021 and 2023 corrective maintenance work orders for 2-RCW-4260- CV, even though they were coded as corrective actions and therefore their deferral constituted corrective action extensions. The inspectors determined that Constellations failure to obtain MRC approval prior to deferring the MRC-approved corrective action work order was a performance deficiency.

Corrective Actions: Constellation entered this issue into their corrective action program as IR 04714082. The station plans to replace the containment isolation valve in 2025 and address gaps in their outage procedures that allowed for the work orders to be descoped without obtaining MRC approval.

Screening: The inspectors evaluated the performance deficiency in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, and determined the issue was of minor significance, because the leakage had not exceeded the operability limit of 10, 000 standard cubic centimeters and, therefore, had remained capable of performing its containment isolation function.

EXIT MEETINGS AND DEBRIEFS

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

• On November 2, 2023, the inspectors presented the biennial problem identification and resolution inspection results to Patrick D. Navin, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71152B Corrective Action 4104458

Documents 4225806

25806

4336454

4395296

4408648

4415382

4435016

4439039

4440050

4441204

4445643

4447731

4448094

4450824

4451427

4455498

4460171

4474149

4475232

4475850

4476404

4482647

4489791

4493959

4494648

4501045

4504393

4518072

22477

24139

26754

Inspection Type Designation Description or Title Revision or

Procedure Date

28287

4530189

4532098

4534838

4536036

4537868

4538598

4541369

4542979

4543218

4544315

4546529

4546736

4549583

4549953

4550397

4550611

4550788

4550824

4556335

4559881

4561931

4563693

4563702

4565463

4666477

4668131

4668927

4669565

4671506

4673164

4673404

4673756

4674971

Inspection Type Designation Description or Title Revision or

Procedure Date

4675097

4676524

4676530

4678549

4680856

4680930

4684376

4684376

4689075

4689541

4690558

4691500

4692250

4692585

4693677

4694465

4695499

4695501

4699174

4701199

4705036

4139484

4397885

4410394

4434093

4434219

4434796

4435964

4436008

4502105

4518586

26595

4452704

4558778

Inspection Type Designation Description or Title Revision or

Procedure Date

4559548

4670784

4673404

4673732

4673739

4673771

4684376

4685166

4688144

4699395

4539638-43

4471830-18

Corrective Action 4710360

Documents 4710362

Resulting from 4710368

Inspection 4710378

4710381

4710568

4710687

4710901

4710926

4710937

4710941

4710942

4710962

4711010

4711257

4711355

4712214

4713077

4713692

4713732

4713977

4714418

Inspection Type Designation Description or Title Revision or

Procedure Date

4714422

4714428

4714489

4714538

4714821

4714830

4714834

4714843

4714856

4714982

4715158

4715705

Engineering ECP-23-000101 SW Pump 22 Had Rejectable Indications - Pump Pedestal

Evaluations Corrosion

ESR-19-000579 Design Flaw on Pump SRW22

Miscellaneous 2022 Engagement Survey Results for CCNPP

CCNP Station Trend Report, January - June 2022

CCNP Station Trend Report, January - June 2023

23-0206-00001 Calvert Cliffs Maintenance Rule Periodic A(3) Assessment 01/31/2023

AP-2023-1440 Performance Improvement Action Plan for CAP 10/18/2023

Quality/Timeliness Issues

C93912863 Adverse Condition Monitoring Plan - Unit 1 RCS Leak

CA10120 Gas Accumulation Calculation on High Points of SI and CS 1

Suction Piping

CA10121 Gas Accumulation Calculation on High Points of SI and CS 0

Suction Piping

CAL-0-2016-0500 Risk Assessment for Saltwater Above Ground Leaks 06/08/2023

Part 21-55453 Non-conforming Relay Led to Battery Charger Failures

Operability CR-2011-006838, Operability Determination for U2 Water Leaking into JB

Evaluations 2J025A/B

Procedures CC-AA-606-100- Cyber Security Software Repository Upload Process 2

1001

CY-AA-170-1000 Radiological Environmental Monitoring Program and 12

Meteorological Program Implementation

Inspection Type Designation Description or Title Revision or

Procedure Date

CY-CA-170-301 Offsite Dose Calculation Manual 3

CY-CA-180-825 Meteorological Data Acquisition Methods 0

EP-AA-1011 Radiological Emergency Plan Annex for Calvert Cliffs 5

EP-AA-111-F-12 Calvert Cliffs PAR Flowchart A

ER-AA-200 Preventative Maintenance Program 7

ES-001 Flooding 5

MA-AA-716-011 Work Execution & Close Out 28

NO-AA-10 Quality Assurance Topical Report 98

OP-AA-108-105 Equipment Deficiency Identification and Documentation 12

PI-AA-115-1004-PI-OP-AA-108-115-1004 Form 1

F-04

PI-AA-120 Issue Identification and Screening Process 13

PI-AA-125 Corrective Action Program Procedure 8

PI-AA-125-1003 Corrective Action Program Evaluation Manual 7

PI-AA-125-1004 Effectiveness Review Manual 2

PI-AA-125-1006 Investigation Techniques Manual 7

RM-AA-101 Records Management Program 11

RM-AA-101-1008 Processing and Storage of Records 9

RP-AA-700 Controls for Radiation Protection Instrumentation 9

RP-AA-901 Explosive Gas Monitoring Program 6

SY-AA-1034-F-02 Standing Order: Observation of Security UPS Alarm Panels 03/17/2022

WC-AA-120 Preventive Maintenance (PM) Database Revision 6

Requirements

Self-Assessments AR 04689109 Biennial SOER 02-04 Safety Culture Self-Assessment 08/18/2023

AR 04690967 2023 Preparation for NRC PI&R inspection 09/27/2023

NOSA-CAL-22-01 Maintenance Rule Functional Audit Report

NOSA-CAL-22-02 Emergency Preparedness Audit Report

NOSA-CAL-22-06 Cyber Security Program Audit Report

NOSA-CAL-23-04 Engineering Programs Audit Report

Work Orders C93309164

C93608374

C93656464

C93704911

Inspection Type Designation Description or Title Revision or

Procedure Date

C93748531

C93749902

C93763438

C93900879

C93902448

C93910008

C93912863

14