IR 05000317/2021002

Integrated Inspection Report 05000317/2021002 and 05000318/2021002

ML21222A039
Person / Time
Site:	Calvert Cliffs
Issue date:	08/10/2021
From:	Matt Young NRC/RGN-I/DORS
To:	Rhoades D Exelon Generation Co LLC, Exelon Nuclear
Young M
References
IR 2021002
Download: ML21222A039 (15)

Text

August 10, 2021

SUBJECT:

CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1 AND 2 -

INTEGRATED INSPECTION REPORT 05000317/2021002 AND 05000318/2021002

Dear Mr. Rhoades:

On June 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Calvert Cliffs Nuclear Power Plant, Units 1 and 2. On July 29, 2021, 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.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

A licensee-identified violation which was determined to be of very low safety significance and Severity Level IV is documented in this report. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy. The NRC will not conduct a follow-up inspection for this violation because it does not involve any of the initiating criteria in Inspection Procedure 92702, Follow-up on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, and Orders."

If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Calvert Cliffs Nuclear Power Plant, Units 1 and 2.

If you disagree with a cross-cutting aspect assignment 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 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Matt R. Young, Chief Projects Branch 5 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:

05000317/2021002 and 05000318/2021002

Licensee:

Exelon Generation Company, LLC

Facility:

Calvert Cliffs Nuclear Power Plant, Units 1 and 2

Location:

Lusby, MD

Inspection Dates:

April 1, 2021 to June 30, 2021

Inspectors:

H. Anagnostopoulos, Senior Health Physicist

D. Beacon, Resident Inspector

K. Chambliss, Project Engineer

R. Clagg, Senior Resident Inspector

S. Obadina, Resident Inspector

Approved By:

Matt R. Young, Chief

Projects Branch 5

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. A

licensee-identified non-cited violation is documented in report section: 71153.

List of Findings and Violations

Failure to Properly Reset the 22 Auxiliary Feedwater Pump Results in Pump Inoperability

Cornerstone

Significance

Cross-Cutting

Aspect

Report

Section

Mitigating

Systems

Green

NCV 05000318/2021002-01

Open/Closed

[H.7] -

Documentation

71111.15

The inspectors identified a Green finding and associated non-cited violation of Technical Specification 5.4.1, Procedures, when the licensee failed to properly reset the 22 auxiliary

feedwater pump trip throttle valve as required by site procedures. Specifically, on March 20,

2021, the licensee failed to ensure that the trip throttle valve trip hook and latch-up lever was

fully engaged as required by STP-O-5A22-2, 22 Auxiliary Feedwater Pump Quarterly

Surveillance Test, Revision 8, which resulted in the inoperability of the 22 auxiliary feedwater

pump and failure to take the required actions of Technical Specification Limiting Conditions for

Operation 3.7.3.A and 3.7.3.E within the required completion times.

Additional Tracking Items

Type

Issue Number

Title

Report Section

Status

LER 05000318/2021-001-00

LER 2021-001-00 for Calvert

Cliffs Nuclear Power Plant

Unit No. 2, Pressure Heater

Sleeve Weld Pressure

Boundary Leakage Caused

by Primary Water Stress

Corrosion Cracking

71153

Closed

PLANT STATUS

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

Unit 2 operated at or near rated thermal power for the entire 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 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.

Starting on March 20, 2020, in response to the National Emergency declared by the President

of the United States on the public health risks of the coronavirus (COVID-19), resident and

regional inspectors were directed to begin telework and to remotely access licensee information

using available technology. During this time, the resident inspectors performed periodic site

visits each week, increasing the amount of time on site as local COVID-19 conditions permitted.

As part of their onsite activities, resident inspectors conducted plant status activities as

described in IMC 2515, Appendix D; observed risk significant activities; and completed on site

portions of IPs. In addition, resident and regional baseline inspections were evaluated to

determine if all or a portion of the objectives and requirements stated in the IP could be

performed remotely. If the inspections could be performed remotely, they were conducted per

the applicable IP. In some cases, portions of an IP were completed remotely and on site. The

inspections documented below met the objectives and requirements for completion of the IP.

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 hot temperatures for the Units 1 and 2 emergency diesel

generators and the intake structure on June 15, 2021.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following

systems/trains:

(1)

Unit 2, 21 component cooling heat exchanger during 22 component heat exchanger

is out of service for maintenance, April 16, 2021

(2)

Unit 2, 23 auxiliary feedwater pump during Unit 1 steam-driven auxiliary feedwater

emergency ventilation is out of service for maintenance, May 25, 2021

(3)

Unit 2, 23 saltwater pump during 21 saltwater pump is out of service for maintenance,

June 4, 2021

(4)

Units 1 and 2, emergency diesel generators during 0C diesel generator out of service

for maintenance, June 14, 2021

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1)

The inspectors evaluated system configurations during a complete walkdown of the

Unit 1 emergency diesel generators on June 2, 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)

Units 1 and 2, component cooling water pump rooms, fire areas 12 and 15, May 6,

2021

(2)

Units 1 and 2, 5' fan rooms, fire areas 13 and 14, May 6, 2021

(3)

Units 1 and 2, emergency diesel generator rooms, fire areas 28, 30 and 31, May 24,

2021

(4)

Unit 2, switchgear and purge air rooms, fire areas 18, 18A and 25, June 29, 2021

(5)

Unit 1, emergency core cooling system pump rooms, fire areas 3 and 4, June 30,

2021

71111.07A - Heat Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1)

21 component cooling heat exchanger maintenance and testing, June 7, 2021

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 Unit 1 main turbine valve testing on May 22, 2021.

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

(1)

The inspectors observed a simulator training event involving a super storm, loss of

offsite power, and the failure of all diesels to start resulting in the declaration of a Site

Area Emergency and the entry into extended loss of alternating current procedure on

May 21, 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)

Unit 1, compressed air system, June 30, 2021

(2)

Unit 2, containment spray system, June 30, 2021

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (7 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 preventive maintenance on the 22 component

cooling heat exchanger, April 15, 2021

(2)

Unit 1, elevated risk condition due to preventative maintenance on 11A service water

heat exchanger, May 6, 2021

(3)

Unit 2, elevated risk condition due to 23 saltwater pump motor replacement, May 21,

2021

(4)

Unit 2, elevated risk condition due to preventative maintenance on 21 saltwater

pump, June 2, 2021

(5)

Units 1 and 2, review of fire risk management actions for 0C diesel generator out of

service for maintenance, June 16, 2021

(6)

Unit 2, review of risk management actions for charging of the 21 main steam isolation

valve nitrogen accumulator, June 16, 2021

(7)

Unit 2, elevated risk condition due to 22 steam generator auxiliary feedwater flow

control valve maintenance, June 21, 2021

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (7 Samples)

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

following operability determinations and functionality assessments:

(1)

Unit 1, AR04426678, debris ingestion into 11A/B service water heat exchanger,

May 31, 2021

(2)

Unit 2, AR04427200, defect in base of 21 steam generator feed pump, June 3, 2021

(3)

Unit 1, AR04428393, debris adhered to 12 auxiliary feedwater pump governor valve

stem system, June 9, 2021

(4)

Unit 1, AR04424010, reactor protection system channel A calibration potentiometer

setpoint issue, June 16, 2021

(5)

Unit 2, AR04411634, 22 auxiliary feedwater pump trip throttle valve engagement

issue, June 22, 2021

(6)

Unit 1, AR04425768, 11 control room heating, ventilation, and air conditioning system

inoperable due to broken condenser fan motor mounting bolt, June 22, 2021

(7)

Unit 1, AR04431830, ultimate heat sink, degrading cooling, 11A service water heat

exchanger flow less than 5000 gallons per minute, June 27, 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)

Units 1 and 2, WO C93776700, installation of nano bubbler in the intake structure,

June 30, 2021

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (9 Samples)

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

operability and functionality:

(1)

Unit 1, WO C93713781, auxiliary feedwater to 12 steam generator flow control valve

actuator replacement and testing, May 12, 2021

(2)

Unit 1, WO C93793597045, 12 high pressure safety injection pump coupling guard

replacement, May 19, 2021

(3)

Unit 2, WO C93700861, remove and replace 21 saltwater pump and inspection

coupling, June 3, 2021

(4)

Unit 2, WO C93780925, 2RV431, 21 shutdown cooling heat exchanger relief valve

maintenance testing, June 4, 2021

(5)

Unit 2, WO C93696722, 23 saltwater pump motor replacement, June 14, 2021

(6)

Units 1 and 2, WO C93707413, replace 0C diesel generator overspeed/speed field

flash switches, June 14, 2021

(7)

Unit 2, WO C93622313, 2SV5212, 22B service water heat exchanger saltwater outlet

valve replacement and testing, June 15, 2021

(8)

Unit 2, WO C93704562, 21 component cooling heat exchanger relief valve

replacement and testing, June 22, 2021

(9)

Unit 1, WO C93748496, 11 saltwater pump breaker maintenance, June 30, 2021

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01) (3 Samples)

(1)

Unit 1, STP-O-065QB-1, "B Train Safety Injection System Valve Quarterly Operability

Test," Revision 5, May 3, 2021

(2)

Unit 2, STP-M-502-2, "Calibration Check of #21 4kV Bus LOCI and Shutdown

Sequencer," Revision 002, May 5, 2021

(3)

Unit 2, STP-O-73A2-2, "B Train Saltwater Pump and Check Valve Quarterly

Operability Test," Revision 5, May 12, 2021

Inservice Testing (IP Section 03.01) (2 Samples)

(1)

Unit 2, STP-O-5A21-2, "21 Auxiliary Feedwater Pump Quarterly Surveillance Test,"

Revision 8, May 12, 2021

(2)

Unit 2, STP-O-65R-2, "ECCS Valves Powered From MCC-240R Operability Test,"

Revision 6, June 16, 2021

71114.06 - Drill Evaluation

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 Preparedness

drill involving a loss of offsite power, failure of the 1A emergency diesel generator,

steam-driven auxiliary feedwater pump trips, lowering steam generator levels, and a

steam leak from containment emergency airlock resulting in a General Emergency

declaration on May 12, 2021.

Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

The inspectors evaluated:

(1)

The conduct of a simulator training evolution involving a solar magnetic disturbance,

loss of offsite power, and a reactor trip resulting in a Notice of Unusual Event

declaration on June 24, 2021.

RADIATION SAFETY

71124.02 - Occupational ALARA Planning and Controls

Radiological Work Planning (IP Section 03.01) (3 Samples)

The inspectors evaluated the licensees radiological work planning.

(1)

Outage Reactor Head Disassembly/Reassembly (CC-2-21-00613)

(2)

Outage Aux/Containment Scaffold (CC-1-20-00505)

(3)

DM Weld Repair (CC-2-19-00413)

Verification of Dose Estimates and Exposure Tracking Systems (IP Section 03.02) (3 Samples)

The inspectors evaluated dose estimates and exposure tracking.

(1)

ALARA Plan 21R-0010

(2)

ALARA Plan 20R0028

(3)

ALARA Plan 19RFO-0062

Implementation of ALARA and Radiological Work Controls (IP Section 03.03) (2 Samples)

The inspectors reviewed as low as reasonably achievable practices and radiological work

controls.

(1)

Routine calibration of the containment hi-range radiation monitors (accident monitors)

(2)

Removal of the fuel transfer tube blind flange

Radiation Worker Performance (IP Section 03.04) (1 Sample)

The inspectors evaluated radiation worker and radiation protection technician performance

during:

(1)

Calibration of the containment hi-range radiation monitors

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) (2 Samples)

(1)

Unit 1, April 1, 2020 - March 31, 2021

(2)

Unit 2, April 1, 2020 - March 31, 2021

71152 - Problem Identification and Resolution

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 - 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 05000318/2021-001-00 for Calvert Cliffs Nuclear Power Plant Unit No. 2,

Pressure Heater Sleeve Weld Pressure Boundary Leakage Caused by Primary Water

Stress Corrosion Cracking. The circumstances surrounding this LER and identified

violation are discussed in the Inspection Results section of this report. No additional

violations were identified.

INSPECTION RESULTS

Failure to Properly Reset the 22 Auxiliary Feedwater Pump Results in Pump Inoperability

Cornerstone

Significance

Cross-Cutting

Aspect

Report

Section

Mitigating

Systems

Green

NCV 05000318/2021002-01

Open/Closed

[H.7] -

Documentation

71111.15

The inspectors identified a Green finding and associated non-cited violation of Technical Specification 5.4.1, Procedures, when the licensee failed to properly reset the 22 auxiliary

feedwater pump trip throttle valve as required by site procedures. Specifically, on March 20,

2021, the licensee failed to ensure, that the trip throttle valve trip hook and latch-up lever was

fully engaged as required by STP-O-5A22-2, 22 Auxiliary Feedwater Pump Quarterly

Surveillance Test, Revision 8, which resulted in the inoperability of the 22 auxiliary feedwater

pump and failure to take the required actions of Technical Specification Limiting Conditions

for Operation 3.7.3.A and 3.7.3.E within the required completion times.

Description: On March 24, 2021, the inspectors identified a misalignment of the 22 auxiliary

feedwater pump trip throttle valve trip hook and the latch-up lever. The trip throttle valve is

part of the overspeed trip mechanism for the auxiliary feedwater pump and functions to shut

off steam to the turbine on an overspeed condition. During normal operation, the trip throttle

valve is fully open, and is held open against spring pressure by a tripping latch. The licensee

initiated AR04411634 and performed an inspection of the trip hook on March 25, 2021. The

licensee conducted an operability evaluation, documented in AR04411634, and determined

that the 22 auxiliary feedwater pump would operate and not trip in the as found condition due

to sufficient engagement existing to provide reasonable assurance that the pump will perform

its intended safety function for the duration of a design basis event. In addition, the licensee

reset the 22 auxiliary feedwater pump and confirmed proper engagement of the trip throttle

valve trip hook and latch-up lever.

The inspectors reviewed AR04411634 and noted that the operability evaluation was based on

engineering judgment and did not include a specification for engagement between the trip

throttle valve trip hook and latch-up lever. The inspectors reviewed licensee procedure

TURB-004, AFW Turbine Overspeed Trip Adjustment, Revision 0500, and noted that step

6.1.18 states ensure latching faces are as follows: (6) Contact is at least 75% of surface

area. The inspectors noted that the specification was derived from Electrical Power

Research Institute Maintenance Manual, Terry Turbine Maintenance Guide, AFW

Application, TR 1007461. The inspectors reviewed the maintenance manual and noted that it

requires proper surface contact and engagement between the trip throttle valve trip hook and

latch-up lever, where surface contact is measured across the faces of the trip hook and latch-

up lever and engagement is measured by how far the latch-up lever fits into the trip hook from

left to right.

The inspectors reviewed the maintenance that was performed on the 22 auxiliary feedwater

pump and noted that TURB-004 was satisfactorily completed on March 12, 2021. This

procedure is required to be performed prior to overspeed trip testing as part of post-

maintenance testing following maintenance activities on the pump. TURB-004 ensures that

the 22 auxiliary feedwater pumps overspeed trip mechanism is restored to proper alignment

following maintenance, specifically the procedure checks for proper engagement of the trip

throttle valve trip hook and latch-up lever as well as proper contact surface area between the

latching faces. The inspectors also noted that the 22 auxiliary feedwater pump was tested,

after the maintenance activities were completed, on March 20, 2021. The post-maintenance

testing of the auxiliary feedwater pump was performed in accordance with STP-O-5A22-2,

22 Auxiliary Feedwater Pump Quarterly Surveillance Test, Revision 8. The inspectors

reviewed the completed surveillance procedure and noted that it is used to reset the trip

throttle valve trip hook and latch-up lever following post-maintenance testing and verifies that

they are fully engaged. Step 6.1.3 of STP-O-5A22-2, states, that the trip throttle valve

handwheel should be rotated clockwise until the valve trip/latch lever and trip hook are fully

engaged. However, the inspectors determined that the trip hook and latch-up lever were not

fully engaged in accordance with procedure. In addition, the inspectors determined that the

station could not meet the requirement for 75% contact surface area since there was not

enough overlap between the two surfaces (i.e. full engagement between the trip hook and

latch-up lever). The inspectors concluded that due to the trip throttle valve and latch-up lever

not being fully engaged and not having at least 75% surface area contact there was

reasonable doubt of the 22 auxiliary feedwater pumps operability from March 20, 2021 until

March 26, 2021.

Corrective Actions: The licensees immediate corrective actions included resetting the 22

auxiliary feedwater pump trip mechanism and confirming proper engagement of the trip

throttle valve trip hook and latch-up lever. The licensee also revised STP-O-5A22-2, 22

Auxiliary Feedwater Pump Quarterly Surveillance Test, Revision 8, with a picture showing

proper engagement of the trip hook and latch-up lever. In addition, the licensee took a video

of resetting the 21 auxiliary feedwater pump trip throttle valve during the performance of

quarterly surveillance to capture all the aspects that are checked. The video was supplied to

training for inclusion in future auxiliary feedwater lesson plans.

Corrective Action References: AR04411634

Performance Assessment:

Performance Deficiency: The inspectors determined the licensees failure to properly reset

the 22 auxiliary feedwater pump trip throttle valve was a performance deficiency. Specifically,

on March 20, 2021, the licensee failed to ensure, that the trip throttle valve trip hook and

latch-up lever were fully engaged as required by STP-O-5A22-2, 22 Auxiliary Feedwater

Pump Quarterly Surveillance Test, Revision 8, which resulted in the inoperability of the 22

auxiliary feedwater pump and failure to take the required actions of Technical Specification

Limiting Conditions for Operation 3.7.3.A and 3.7.3.E within the required completion times.

Screening: The inspectors determined the performance deficiency was more than minor

because it was associated with the Human Performance attribute of the Mitigating Systems

cornerstone and adversely affected the cornerstone objective to ensure the availability,

reliability, and capability of systems that respond to initiating events to prevent undesirable

consequences. The inspectors reviewed IMC 0612, Appendix B, Issue Screening, issued on

January 1, 2020, and determined that the issue is more than minor because it was associated

with the Human Performance attribute of the Mitigating Systems cornerstone and adversely

affected the cornerstone objective to ensure the availability, reliability, and capability of

systems that respond to initiating events to prevent undesirable consequences. Specifically,

on March 20, 2021, the licensee failed to properly reset the trip throttle valve for the 22

auxiliary feedwater pump, which resulted in the inoperability of the pump.

Significance: The inspectors assessed the significance of the finding using Appendix A, The

Significance Determination Process (SDP) for Findings At-Power. The inspectors assessed

the significance of the finding using Exhibit 2 of IMC 0609, Appendix A, The Significance

Determination Process (SDP) for Findings At-Power, issued on November 30, 2020, and

determined that the finding represented a deficiency affecting the design or qualification of

the mitigating structure, system, and component, where the operability of the structure,

system, and component was not maintained. However, the degraded condition did not

represent a loss of probabilistic risk assessment function of one train of a multi-train technical

specification system for greater than its technical specification allowed outage time.

Therefore, the inspectors determined the finding to be of very low safety significance (Green).

Cross-Cutting Aspect: H.7 - Documentation: The organization creates and maintains

complete, accurate and up-to-date documentation. The inspectors determined that the

licensees surveillance procedure did not provide a complete description for resetting the trip

throttle valve. Specifically, the licensee surveillance procedure did not provide an adequate

description of the steps required to ensure the trip throttle valve was fully engaged.

Enforcement:

Violation: The Renewed Facility Operating License for Calvert Cliffs Nuclear Power Plant,

Unit 2, Technical Specification 5.4.1 requires, in part, that written procedures shall be

established, implemented, and maintained as covered in Regulatory Guide 1.33, Revision 2,

Appendix A, February 1978, of which Section 8 requires procedures for surveillance tests of

the auxiliary feedwater systems. Technical Specification 3.7.3.A for an inoperable steam-

driven auxiliary feedwater pump requires the remaining operable steam-driven pump be

aligned for automatic initiating status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, and the steam-driven pump brought

back to operable status within 7 days or the calculated risk informed completion time or

brought to MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and MODE 4 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Contrary to the above, on March 20, 2021, the licensee failed to satisfactorily implement a

surveillance test procedure, STP-O-5A22-2. As a result, from March 20, 2021 to March 26,

2021, the 22 auxiliary feedwater pump was inoperable. During this time, with one steam-

driven pump inoperable, the licensee did not align the remaining steam-driven pump for

automatic initiating status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and did not bring the unit to MODE 3 or MODE 4

within the required completion times.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with

Section 2.3.2 of the Enforcement Policy.

Licensee-Identified Non-Cited Violation

71153

This violation of very low safety significance was identified by the licensee and has been

entered into the licensee corrective action program and is being treated as a non-cited

violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: Technical Specification 3.4.13, "RCS Operational Leakage," prohibits pressure

boundary leakage. Contrary to this, during planned visual examinations conducted each

refueling outage, the licensee identified an inactive boric acid leak at a Unit 2 pressurizer

heater sleeve penetration and subsequently determined that the leak most likely existed

during plant operation. The inspectors determined that the cause of the violation was not

within the licensees ability to foresee and correct and therefore was not reasonably

preventable. As a result, no performance deficiency was identified, and the resulting violation

was dispositioned using the traditional enforcement process.

Significance/Severity: Green. Severity Level IV. The NRC Enforcement Policy, Section

2.2.1 states, in part, that, whenever possible, the NRC uses risk information in assessing the

safety significance of violations. Accordingly, after considering that the condition was of very

low safety significance, the inspectors concluded that the violation would be best

characterized as Severity Level IV under the traditional enforcement process. For information,

the inspectors screened the significance of the condition using IMC 0609, Appendix A, The

Significance Determination Process for Findings At-Power, issued on January 1, 2021, and

determined that the condition was of very low safety significance (Green) because the leak

did not result in exceeding the reactor coolant system leak rate for a small loss of coolant

accident and did not affect systems used to mitigate a loss of coolant accident.

The disposition of this violation closes LER 05000318/2021-001-00.

Corrective Action References: AR04406378

EXIT MEETINGS AND DEBRIEFS

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

• On July 29, 2021, the inspectors presented the integrated inspection results to

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

THIRD PARTY REVIEWS

Inspectors reviewed Institute on Nuclear Power Operations reports that were issued during the

inspection period.