IR 05000317/2014003

IR 05000317-14-003, 05000318-14-003; 04/01/2014 - 06/30/2014; Calvert Cliffs Nuclear Power Plant Units 1 and 2 (Ccnpp); Equipment Alignment and Operability Determination and Functionality Assessments

ML14219A624
Person / Time
Site:	Calvert Cliffs
Issue date:	08/08/2014
From:	Ho Nieh Division Reactor Projects I
To:	George Gellrich Exelon Generation Co
Schroeder D
References
EA-14-100 IR-2014-003
Download: ML14219A624 (55)

Text

ust 8, 2014

SUBJECT:

CALVERT CLIFFS NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000317/2014003 AND 05000318/2014003 WITH PRELIMINARY WHITE FINDING

Dear Mr. Gellrich:

On June 30, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Calvert Cliffs Nuclear Power Plant (CCNPP). The enclosed inspection report documents the results, which were discussed on July 23, 2014, with Mr. Mark Flaherty, Plant General Manager, and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

The enclosed inspection report discusses a Unit 2 finding that has preliminarily been determined to be White, a finding with low to moderate safety significance, which may require additional inspections, regulatory actions, and oversight. As described in Section 1R15 of the enclosed report, the finding is associated with an apparent violation of Title 10 of the Code of Federal Regulations (10 CFR) Part 50.54(q)(2), which requires a licensee to develop and maintain an emergency plan which meets the requirements of 10 CFR 50.47(b), and 10 CFR 50, Appendix E. Contrary to these requirements, from October 11, 2013, through March 4, 2014, CCNPP failed to maintain in effect an emergency plan that met the standards in 10 CFR 50.47(b)(4) for Unit 2. Specifically, during the replacement of the Unit 2 main steam line radiation monitors, CCNPPs staff inaccurately calculated the associated emergency action levels (EALs) effluent threshold values for Alert, Site Area Emergency, and General Emergency, and incorporated these thresholds into Table R-1, Effluent Monitor Classification Threshold, of the EALs. This error could have resulted in an over-classification of an event, an unnecessary protective action recommendation, and caused Offsite Response Organizations to implement unnecessary protective actions for the public. Exelon Generation Company, LLC (Exelon) identified the issue, entered it into their corrective action program, implemented appropriate compensatory actions, and initiated corrective actions to revise the EAL table. The inspectors determined the finding no longer presents an immediate safety concern since appropriate compensatory actions have been implemented. The finding was assessed based on the best available information, using the NRCs Emergency Preparedness Significance Determination Process (SDP). The basis for the NRCs preliminary significance determination is described in the enclosed report. Because the finding is also an apparent violation of NRC requirements, it is being considered for escalated enforcement action in accordance with the Enforcement Policy, which appears on the NRCs Web site at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html.

The NRC will inform you, in writing, when the final significance has been determined. We intend to complete and issue our final safety significance determination within 90 days from the date of this letter. The NRCs SDP is designed to encourage an open dialogue between your staff and the NRC; however, the dialogue should not affect the timeliness of our final determination.

We believe that we have sufficient information to make a final significance determination.

However, before we make a final decision, we are providing you an opportunity to provide your perspective on this matter, including the significance, causes, and corrective actions, as well as any other information that you believe the NRC should take into consideration. Accordingly, you may notify us of your decision within 10 days to: (1) request a regulatory conference to meet with the NRC and provide your views in person; (2) submit your position on the finding in writing; or, (3) accept the finding as characterized in the enclosed inspection report.

If you choose to request a regulatory conference, the meeting should be held in the NRC Region I office within 30 days of the date of this letter, and will be open for public observation.

The NRC will issue a public meeting notice and a press release to announce the date and time of the conference. We encourage you to submit supporting documentation at least 1 week prior to the conference in an effort to make the conference more efficient and effective. If you choose to provide a written response, it should be sent to the NRC within 30 days of the date of this letter. You should clearly mark the response as Response to Preliminary White Finding in Inspection Report No. 05000317 & 05000318/2014003; EA-14-100, and send it to the U.S.

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, Region I, and a copy to the NRC Senior Resident Inspector at CCNPP.

You may also elect to accept the finding as characterized in this letter and the inspection report, in which case the NRC will proceed with its regulatory decision. However, if you choose not to request a regulatory conference or to submit a written response, you will not be allowed to appeal the NRCs final significance determination.

Please contact Daniel Schroeder at (610) 337-5262 within 10 days from the issue date of this letter to notify the NRC of your intentions. If we have not heard from you within 10 days, we will continue with our significance determination and enforcement decision. Because the NRC has not made a final determination in this matter, no notice of violation is being issued for this inspection finding at this time. In addition, please be advised that the number and characterization of the apparent violation may change based on further NRC review.

This report also documents a violation of NRC requirements which was of very low safety significance (Green). Additionally, two licensee-identified violations, which were determined to be of very low safety significance, are listed in this report. However, because of the very low safety significance, and because they are entered into your corrective action program, the NRC is treating these findings as non-cited violations, consistent with Section 2.3.2.a of the NRC Enforcement Policy. If you contest the non-cited violations in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at CCNPP. In addition, if you disagree with the cross-cutting aspect assigned to any finding, 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 Regional Administrator, Region I, and the NRC Resident Inspector at CCNPP.

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 component of NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Ho K. Nieh Director Division of Reactor Projects Docket Nos. 50-317 and 50-318 License Nos. DPR-53 and DPR-69

Enclosure:

Inspection Report 05000317/2014003 and 05000318/2014003 w/Attachment: Supplemental Information

REGION I==

Docket Nos. 50-317 and 50-318 License Nos. DPR-53 and DPR-69 Report Nos. 05000317/2014003 and 05000318/2014003 Licensee: Exelon Generation Company, LLC (Exelon)

Facility: Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Location: Lusby, MD Dates: April 1, 2014 through June 30, 2014 Inspectors: S. Kennedy, Senior Resident Inspector R. Clagg, Senior Resident Inspector E. Torres, Resident Inspector H. Anagnostopoulus, Health Physicist S. Barr, Senior Emergency Preparedness Inspector T. OHara, Reactor Inspector D. Orr, Senior Reactor Inspector A. Rosebrook, Senior Project Engineer Approved by: Daniel L. Schroeder, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure

SUMMARY

IR 05000317/2014003, 05000318/2014003; 04/01/2014 - 06/30/2014; Calvert Cliffs Nuclear

Power Plant Units 1 and 2 (CCNPP); Equipment Alignment and Operability Determination and Functionality Assessments.

This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. The inspectors identified a licensee-identified preliminary low to moderate safety significance (White) finding associated with an apparent violation. Additionally, the inspectors identified a very low safety significance (Green) finding, which was a non-cited violation (NCV). The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP), dated June 2, 2011.

Cross-cutting aspects are determined using IMC 0310, Aspects Within the Cross-Cutting Areas, dated December 19, 2013. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated July 9, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.

Cornerstone: Emergency Preparedness

Preliminary White: The inspectors documented a licensee-identified apparent violation of Title 10 of the Code of Federal Regulations (10 CFR) 50.54(q)(2), which preliminarily has been determined to be of low to moderate safety significance (White). Specifically, 10 CFR 50.54(q)(2) requires a licensee to develop and maintain an emergency plan which meets the requirements of 10 CFR 50.47(b), and 10 CFR 50, Appendix E. Contrary to this requirement, from October 11, 2013, through March 4, 2014, CCNPP failed to maintain in effect an emergency plan that met the standards in 10 CFR 50.47(b)(4) and 10 CFR 50,

Appendix E,Section IV.B.1 for Unit 2. CCNPP did not maintain an adequate standard emergency level scheme because inaccurate effluent radiation monitor thresholds were incorporated into Table R-1, Effluent Monitor Classification Threshold. During the replacement of the Unit 2 main steam line radiation monitors (MSLRMs), CCNPPs staff inaccurately calculated the associated emergency action levels (EALs) effluent threshold values for Alert, Site Area Emergency, and General Emergency, and incorporated these thresholds into Table R-1. This error could have resulted in an over-classification of an event and at the general emergency level potentially resulted in an unnecessary protective action recommendation and could cause offsite response organizations to implement unnecessary protective actions. Exelon identified the issue, entered it into their corrective action program (CAP), implemented appropriate compensatory actions, and initiated corrective actions to revise the EAL table. The inspectors determined the finding no longer presents an immediate safety concern since appropriate compensatory actions have been implemented.

The failure to maintain the EAL threshold values in Table R-1 of the site approved emergency plan was a performance deficiency that was within the Exelon staff ability to foresee and correct and should have been prevented. Using IMC 0612, Appendix B, Issue Screening, the performance deficiency was determined to be more than minor because it impacted the procedure quality attribute of the Emergency Preparedness cornerstone and adversely impacts the associated 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, an EAL change was improperly implemented, which could result in an over-classification of an event and at the general emergency level potentially result in unnecessary protective action recommendations and movement of the public. The inspectors utilized IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, to determine the significance of the performance deficiency. The performance deficiency is associated with the emergency classification planning standard and is considered a risk significant planning standard (RSPS) function. This performance deficiency impacts the following required planning standard and RSPS function: 10 CFR 50.47(b)(4), Emergency Classification System. The inspectors were directed by the SDP to compare the performance deficiency with the examples in Section 5.4, 10 CFR 50.47(b)(4), Emergency Classification System, to evaluate the significance of this performance deficiency. Using Table 5.4-1, Significance Examples §50.47(b)(4)," the inspectors determined that the performance deficiency matched an example of a degraded RSPS function, which would be assessed as

White.

Specifically, the example states, in part, that the performance deficiency would be assessed White if the EAL classification process would result in an over-classification that would lead to off-site response organizations implementing, by procedure, unnecessary protective actions for the public. This condition should also be considered met if the licensee would make a protective action recommendation to the off-site response organizations because of the over-classification.

The inspectors determined that the cross-cutting aspect that contributed most to the root cause is H.12, Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes.

Individuals implement appropriate error reduction techniques. Specifically, Exelon staff did not independently validate the new EAL threshold values prior to revising and implementing the EAL scheme change. (Section 1R15)

Green: The inspectors identified a Green NCV of 10 CFR 50.54 (q)(2) and 10 CFR 50.47(b)(4) because Exelon did not maintain the emergency plan to adequately meet the standards in 10 CFR 50.47(b)(4). Specifically, Exelon failed to include Unit 1 and Unit 2 component cooling (CC) rooms under EAL initiating condition HA3.1. As a result, an Alert declaration would have not been made during a hazardous gas event in a vital area. Exelon entered this issue into their CAP as condition report (CR)-2014-004683. Immediate corrective actions included revising EAL initiating condition HA3.1 to include the CC rooms and verify that there are no other areas that need to be included in EAL HA3.1.

The failure to update the EAL scheme the site approved emergency plan following a plant modification was a performance deficiency that was within the Exelon staff ability to foresee and correct and should have been prevented. Using IMC 0612, Appendix B, Issue Screening, the performance deficiency was determined to be more than minor because it impacted the procedure quality attribute of the Emergency Preparedness cornerstone and adversely impacts the associated 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, a plant modification was completed which required operators to be able to enter the CC room in order to bring the plant to cold shutdown and the EAL scheme was not updated to reflect this change. The inspectors utilized IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, to determine the significance of the performance deficiency. The performance deficiency is associated with the emergency classification planning standard and is considered a RSPS function. This performance deficiency impacts the following required planning standard and RSPS function: The inspectors were directed by the SDP to compare the performance deficiency with the examples in Section 5.4, 10 CFR 50.47(b)(4),

Emergency Classification System, to evaluate the significance of this performance deficiency. The inspectors determined that the EAL was ineffective because it, in and of itself, no longer resulted in a timely and accurate declaration of an Alert for the initiating condition. Utilizing Figure 5.4.1, an ineffective EAL where an Alert would not be declared when required would screen as a Green finding.

This finding has a cross-cutting aspect in the area of Human Performance, Change Management, because Exelon personnel didnt use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority. Specifically,

Engineering personnel did not ensure that the impact to the Emergency Plan was adequately evaluated as a result of the permanent plant change engineering change package (ECP)-11-000983 [H.3]. (Section 1R15)

Other Findings

Two violations of very low safety significance that were identified by the licensee have been reviewed by the inspectors. Corrective actions taken, or planned, by Exelon staff has been entered into Exelons CAP. These violations and corrective action tracking numbers are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period at 100 percent power. On May 1, 2014, the unit tripped due to a malfunction in the reactor protection system (RPS) trip circuit breakers testing matrix. On May 2, operators commenced a unit start up. On May 3, operators synchronized the unit to the grid. On May 4, the unit was returned to 100 percent power. The unit remained at or near 100 percent power for the remainder of the inspection period.

Unit 2 began the inspection period at 100 percent power. On June 20, 2014, operators down powered the unit to 82 percent power to conduct main condenser water box cleaning. On June 21, operators returned the unit to 100 percent power. On June 28, operators down powered the unit to 86 percent power to conduct main condenser water box cleaning. On June 29, the unit was returned to 100 percent power. The unit remained at or near 100 percent power for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

.1 Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

The inspectors performed a review of Exelons readiness for the onset of seasonal high temperatures. The review focused on emergency diesel generators (EDGs). The inspectors reviewed the Updated Final Safety Analysis report (UFSAR), technical specifications (TS), control room logs, and the CAP to determine what temperatures or other seasonal weather could challenge this system, and to ensure Exelon personnel had adequately prepared for these challenges. The inspectors reviewed station procedures, including Exelons seasonal weather preparation procedure and applicable operating procedures. The inspectors performed walkdowns of the selected system to ensure station personnel identified issues that could challenge the operability of the systems during hot weather conditions. Documents reviewed for each section of this inspection report are listed in the Attachment.

b. Findings

No findings were identified.

.2 Summer Readiness of Offsite and Alternate Alternating Current (AC) Power Systems

a. Inspection Scope

The inspectors performed a review of plant features and procedures for the operation and continued availability of the offsite and alternate AC power system to evaluate readiness of the systems prior to seasonal high grid loading. The inspectors reviewed Exelons procedures affecting these areas and the communications protocols between the transmission system operator and Exelon. This review focused on changes to the established program and material condition of the offsite and alternate AC power equipment. The inspectors assessed whether Exelon established and implemented appropriate procedures and protocols to monitor and maintain availability and reliability of both the offsite AC power system and the onsite alternate AC power system. The inspectors evaluated the material condition of the associated equipment by reviewing CRs and open work orders, and walking down portions of the offsite and AC power systems including the 500 kilovolt (kV) switchyard.

b. Findings

No findings were identified.

.3 External Flooding

a. Inspection Scope

During the week of June 2, 2014, the inspectors performed an inspection of the external flood protection measures for CCNPP. The inspectors reviewed TS, procedures, design documents, and the UFSAR, Chapter 2.5, which depicted the design flood levels and protection areas containing safety-related equipment to identify areas that may be affected by external flooding. The inspectors conducted a general site walkdown of external areas of the plant, including the auxiliary building and intake structure to ensure that Exelon flood protection measures were in accordance with design specifications.

The inspectors also reviewed operating procedures for mitigating external flooding during severe weather to determine if Exelon planned or established adequate measures to protect against external flooding events.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems:

13 Battery charger with 21 battery charger out of service on April 30, 2014 0C EDG during 1A EDG outage window on May 20, 2014 21B Service water (SRW) heat exchanger (HX) with 21A SRW HX out of service on May 27, 2014 23 Saltwater (SW) pump with 22 SW pump out of service on June 17, 2014 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable procedures, system diagrams, the UFSAR, TS, CRs, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable.

The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Exelon staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.

b. Findings

No findings were identified.

.2 Complete System Walkdown

a. Inspection Scope

On June 4, 2014, the inspectors performed a complete system walkdown of accessible portions of the containment isolation system, to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, emergency operating procedures (EOP), surveillance tests, drawings, equipment line-up check-off lists, and the UFSAR to verify the system was aligned to perform its required safety functions.

The inspectors reviewed CA06453, Steam Generator Tube Rupture using Alternate Source Terms, and maintenance strategies for certain containment isolation valves (CIVs). The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies.

Additionally, the inspectors reviewed a sample of related CRs and work orders to ensure Exelon appropriately evaluated and resolved any deficiencies.

b. Findings

Introduction:

An unresolved item (URI) was identified by the inspectors relating to an issue regarding the failure of Exelon to scope main steam line drains (MSLDs) and CIVs motor operated valves (MOVs) (6611, 6612, 6613, 6615, 6620, and 6621) into their in-service testing (IST) program.

Description:

The inspectors identified an issue of concern involving Exelons scoping of MSLD MOVs into the IST program. The MSLD MOVs are normally open valves with the ability to be remotely-operated from the main control room. The MSLD MOVs are classified as CIVs per UFSAR, Figure 5-10, Containment Structure Isolation Valve Arrangement, Sheet 24 and 25. This figure classifies the main steam penetrations as Type III, and requires the valves to be closed to perform their CIV function. UFSAR, Section 5.2, Isolation System, Subsection 5.2.2, System Design, defines a Type III penetration as a line not directly connected to the reactor coolant system (RCS) or the containment structure atmosphere that has at least one valve, either a check valve or a remotely-operated valve, outside of the containment structure. These valves are classified as American Society of Mechanical Engineers (ASME) Code, Class 2, per drawing 60740, Sheet 0001, Steam Line Drainage System, Revision 39, and M-601, Piping Class Summary Sheets, Revision 49. The ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) 2004, Subsection ISTA, General Requirements, Section ISTA-1100, Scope, states in part, Section IST establishes the requirements for pre-service and IST and examination of certain components to assess their operational readiness in light-water reactor nuclear power plants. These requirements apply to: a) pumps and valves that are required to perform a specific function in shutting down the reactor to the safe shutdown condition, in maintaining the safe shutdown condition, or in mitigating the consequences of an accident. 10 CFR 50.55a(f)(1), Codes and Standards, requires the establishment of OM Code IST test requirements to components which are classified ASME Code Class 1, 2 and 3.

The inspectors require additional information from Exelon to determine if there is a performance deficiency which is more than minor. Specifically, the revision to calculation CA06453, Steam Generator Tube Rupture Accident Using Source Terms; calculation referenced in April 6, 1988, memo from D. S. Elkins to B. B. Mrowca, Impact of the Main Steam Drain Line on the 10CFR100 Limits of the Steam Generator Event; and for CCNPP to research which standard for the design of CIVs the plant was licensed to (equivalent to ANSI N271-1976, Containment Isolation Provisions for Fluid Systems.) The issue is identified as (URI 05000317/318/2014003-01, Main Steam Line Drain Containment Isolation Valves not Scoped in In-Service Testing Program.)

1R05 Fire Protection

.1 Resident Inspector Quarterly Walkdowns

a. Inspection Scope

The inspectors conducted a tour of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that Exelon controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.

1B EDG room, fire area 30, room 420, on April 4, 2014 2A EDG room, fire area 31, room 422, on April 4, 2014 Unit 1, 45 west electrical penetration room, fire area 32, room 423, on April 16, 2014 Unit 1, 69 west electrical penetration room, fire area 37, room 529, on April 16, 2014 Unit 2, 45 west electrical penetration room, fire area 27, room 414, on April 16, 2014 Unit 2, 69 west electrical penetration room, fire area 38, room 532, on April 16, 2014

b. Findings

No findings were identified.

.2 Fire Protection - Drill Observation

a. Inspection Scope

The inspectors observed an unannounced fire drill conducted on April 24, 2014, that involved a fire in the 1B cable chase room. The inspectors evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that Exelon personnel identified deficiencies, openly discussed them in a self-critical manner at the debrief, and took appropriate corrective actions as required. The inspectors evaluated specific attributes as follows:

Proper wearing of turnout gear and self-contained breathing apparatus Proper use and layout of fire hoses Employment of appropriate fire-fighting techniques Sufficient fire-fighting equipment brought to the scene Effectiveness of command and control Search for victims and propagation of the fire into other plant areas Smoke removal operations Utilization of pre-planned strategies Adherence to the pre-planned drill scenario Drill objectives met The inspectors also evaluated the fire brigades actions to determine whether these actions were in accordance with Exelons fire-fighting strategies.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

.1 Annual Review of Cables Located in Underground Bunkers/Manholes

a. Inspection Scope

The inspectors conducted an inspection of underground bunkers/manholes subject to flooding that contain cables whose failure could affect risk-significant equipment on May 19, 2014. The inspectors performed walkdowns of risk-significant areas, including manholes HH-25 and HH-26 (containing EDG cables), to verify that the cables were not submerged in water, that cables and/or splices appeared intact, and to observe the condition of cable support structures. When applicable, the inspectors verified proper sump pump operation and verified level alarm circuits were set in accordance with station procedures and calculations to ensure that the cables will not be submerged.

The inspectors also ensured that drainage was provided and functioning properly in areas where dewatering devices were not installed.

b. Findings

No findings were identified.

.2 Internal Flooding Review

a. Inspection Scope

The inspectors reviewed the UFSAR, the site flooding analysis, and plant procedures to assess susceptibilities involving internal flooding. The inspectors also reviewed the CAP to determine if Exelon staff identified and corrected flooding problems and whether operator actions for coping with flooding were adequate. The inspectors focused on the adequacy of equipment seals located below the flood line, floor and water penetration seals, watertight door seals, common drain lines and sumps, sump pumps, level alarms, control circuits, and temporary or removable flood barriers. The following areas were evaluated:

2A EDG room Intake Structure room

b. Findings

No findings were identified.

1R07 Heat Sink Performance

Triennial Heat Sink Performance (71111.07T - 2 samples)

a. Inspection Scope

Triennial Heat Sink and HX Sample Selection Based on Units 1 and 2 risk ranking of safety-related HXs, past triennial heat sink inspections, recent operational experience, and resident inspector input, the inspectors selected Unit 1 SW ultimate heat sink and Unit 2 22 shutdown cooling (SDC) HX for inspection samples.

For the samples selected, the inspectors reviewed program and system health reports, self-assessments, and maintenance methods (inspection, cleaning, maintenance, and performance monitoring) used to ensure heat removal capabilities for the safety-related HXs and ultimate heat sinks and compared them to Exelons commitments made in the revised response to Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment, dated June 30, 1994.

Unit 1 SW System (Ultimate Heat Sink Sample)

The inspectors completed an inspection of the Unit 1 SW system in accordance with the applicable steps of Inspection Procedure 71111.07, Sections 02.02(d)(4), 02.02(d)(5),02.02(d)(6) and 02.02(d)(7). The Unit 1 SW system transfers heat from the CC HXs, the SRW HXs, and the emergency core cooling system room coolers to the ultimate heat sink, the Chesapeake Bay.

The inspectors reviewed recent buried piping inspections to assess the condition and structural integrity of the SW piping. The inspectors reviewed a sample of SW pipe nondestructive examination records, intake structure silt inspections, structures monitoring inspection results, and associated engineering evaluations to ensure that Exelon staff was appropriately addressing observed degradation in SW piping and the intake structure. The inspectors observed that the SW unavailability has been historically very low, and that the system had been available to perform its ultimate heat sink safety function.

The inspectors reviewed the operation of the SW system. The review included system design changes, system procedures, intake structure operating procedures, abnormal SW operating procedures, loss of the SW intake structure operating procedure, adverse weather condition procedures, and SW leak isolation procedures. The inspectors verified that the Exelon staff was maintaining design drawings, design basis calculations, and operating procedures consistent with their design and licensing basis and that plant operators could reasonably implement the procedures. The inspectors performed a walkdown of the accessible portions of the SW system and the intake structure to verify that instrumentation relied upon by operators for decision making tasks was available and functional. The inspectors verified that the SW piping had been analyzed to demonstrate resistance to water hammer susceptibility. Also, the inspectors verified Exelons IST procedures tested for the correct operation of the SW pump discharge check valves, precluding the potential for weak-pump/strong-pump interaction during system operation. Also, susceptibility of the SW system to weak pump/strong pump interaction is further reduced because station operating procedures preclude operation with adjacent pumps operating at the same time. Exelon staff also replaced the original pump discharge swing-check valves with new, non-slam check valves. The inspectors reviewed the previous three IST tests for the three SW pumps and the discharge check valves. The results of these tests were satisfactory.

The inspectors reviewed the visual inspection records and eddy current inspection records from recent cleanings of the CC HXs, which were performed to verify the structural integrity and fouling condition of the HXs. Additionally, the CC HXs and the CC system are protected from corrosive degradation by hydrazine chemical treatment.

The SRW HXs are also cooled by the SW system. These HXs are plate and frame type HXs which are subject to clogging and fouling resulting from close clearances between the HX plates. The inspectors reviewed the results of periodic flow tests of the SRW HXs to assess the level of flow blockage and/or fouling. The inspectors determined that if significant fouling is evident, Exelon staff disassembles the HX and cleans the plates to restore flow and heat removal capability. During these cleanings, Exelon staff performs visual inspections for degradation which could affect structural integrity. Performance of eddy current testing is not possible on these HXs because they do not have separate integral tubes.

The inspectors reviewed SW system isolation valve tests between the SW system and seal water supply to the circulating pumps and to the chemical injection system. The tests indicated the isolation valve functions worked as designed. The non-safety related functions, providing seal water flow to circulating pumps and to the chemical injection system, were controlled by operations procedures. The SW system flow verification test showed that the required flow was being supplied to provide the necessary design cooling.

The inspectors reviewed Exelon staff's disposition of a sample of active thru wall SW piping leaks, including structural evaluations and completed and/or planned corrective actions. The SW piping is rubber lined, carbon steel piping and has experienced few leaks. Exelon engineering evaluations have not determined a dominant corrosion mechanism for the leaks which have occurred. Leaks do occur in piping segments where the inside of the piping has not been completely coated and the carbon steel piping material has been exposed to SW. The SW piping is monitored by the flow accelerated corrosion program and erosion/corrosion effects have not been evident.

Microbiologically induced corrosion has not been evident in the SW piping systems at CCNPP. Ultrasonic testing examinations were appropriately performed in accordance with ASME,Section XI, Boiler and Pressure Vessel Code, and ASME Code Case N-513-

2. The inspectors concluded that the engineering evaluations and the ultrasonic testing

examinations demonstrated that structural integrity was maintained.

The inspectors verified that Exelon staff established appropriate chemistry procedures to control, detect, and prevent system degradation due to macrofouling of the SW pumps, valves, and piping. Biocide treatments of the SW system were controlled, monitored, trended, and evaluated to ensure adequate biotic control. The inspectors reviewed the SW system performance testing, SW flow balance test results, and flow balance calculations to verify that the minimum calculated SW flow rates were maintained to essential equipment and met the acceptance criteria in the UFSAR.

The inspectors performed a walkdown of the intake building (including the trash racks, SW pumps, SW traveling water screens, and structural supports), and the accessible areas of the intake building containing SW piping to look for indications of piping leakage and/or degradation. The inspectors verified that intake structure pump bay silt accumulation was monitored, trended, and maintained at an acceptable level. The inspectors interviewed the cognizant system engineers, reviewed silt deposition inspection records, and the results of past bay silt measurements.

Unit 2 22 SDC HX (HX Sample)

The inspectors reviewed the 22 SDC HX in accordance with the applicable steps of Inspection Procedure 71111.07, Sections 02.02 (b)(2) and 02.02(c).

22 SDC HX is a stainless steel HX cooled by the CC system. The chemistry of the 22 SDC HX (primary side) was maintained at primary water chemistry quality to prevent corrosive degradation. The CC system was also treated with similar chemistry to prevent corrosive degradation. 22 SDC HX has 859 tubes and no tubes have been plugged. 22 SDC HX is not cleaned or inspected by visual testing or by eddy current.

The CC system is a closed cooling system that accepts heat from both of the SDC HXs.

The inspectors reviewed the design basis heat removal calculation for the 22 SDC HX.

The CC system cools the 22 SDC HX and transfers the heat load to the Unit 2 SW system and the Chesapeake Bay, which is the ultimate heat sink. The inspectors reviewed the design basis heat capacity calculation for this system. During operation, Exelon staff relied upon maintenance of primary water chemistry in the SDC HXs to ensure that system heat removal capability was maintained.

The inspectors verified that the 22 SDC HX condition and operation were consistent with design assumptions in the plants heat transfer calculations. The design and operation of each of the two SDC HXs has been analyzed for potential water hammer effects and plant operating procedures for CC assure that the HX does not experience damage due to water hammer conditions. Similarly, design analysis determined the flow rates which could cause excessive flow-induced vibration and plant operating procedures restricted SDC HX flow rates to acceptable levels to avoid excessive tube vibration and wear.

The inspectors concluded that the 22 SDC HX was effectively protected from degradation as evidenced by no tubes being plugged in any of the two SDC HXs. The SDC HXs operated at a pressure of 80 psi and the CC system operates at 45 psi to prevent leakage from the CC system into the SDC HXs during operation.

The SDC HXs are only used for plant cooldown. The inspectors reviewed recent flow tests and verified that 22 SDC HX has successfully completed the cooldown of the plant during recent plant outages. The inspectors reviewed the most recently completed inspection/cleaning work orders to verify that the as-found and as-left condition of the CC system HXs was bounded by assumptions in the engineering analyses and provided reasonable assurance of continued operability. The inspectors compared recent CC system HX surveillance test data to the established acceptance criteria to verify that the results were acceptable and that operation was consistent with design. The inspectors reviewed the SDC HX flow balance calculation to verify that the minimum calculated CC system flow rate, in conjunction with the heat transfer capability of the CC system HXs, would support the minimum heat transfer rates assumed during accident and transient conditions described in the UFSAR.

Problem Identification and Resolution The inspectors selected and reviewed a sample of CAP reports related to the heat sink equipment and HX samples chosen for this inspection. The review verified that Exelon staff is appropriately identifying, characterizing, and correcting problems related to these systems and components, and that the planned or completed corrective actions for the reported issues were appropriate.

Findings No findings were identified.

1R11 Licensed Operator Requalification Program

.1 Quarterly Review of Licensed Operator Requalification Testing and Training

a. Inspection Scope

The inspectors observed licensed operator simulator training on May 13, 2014, which included a main turbine control valve open failure with main turbine high vibrations, a steam line break in containment, and a failure of containment spray actuation signal.

Operators implemented abnormal operating procedure (AOP)-7E, Main Turbine Malfunction; AOP-7K, Overcooling Event in Mode One and Two; EOP-0, Post Trip Immediate Actions; and EOP-4, Excess Steam Demand Event. The inspectors evaluated operator performance during the simulated events and verified completion of risk significant operator actions, including the use of AOPs and EOPs. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager and the TS action statements entered by the shift technical advisor. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.

b. Findings

No findings were identified.

.2 Quarterly Review of Licensed Operator Performance in the Main Control Room

a. Inspection Scope

The inspectors observed operators in the plant and control room on May 3, 2014, performing Unit 1 startup activities, including rod withdrawal, reactivity management, and steam generator feed pump manipulations. Additionally, the inspectors observed procedure use and adherence, crew communications, and coordination of activities between work groups to verify that established expectations and standards were met.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system, and component (SSC) performance and reliability. The inspectors reviewed system health reports, CAP documents, maintenance work orders, and maintenance rule basis documents to ensure that Exelon was identifying and properly evaluating performance problems within the scope of the maintenance rule. For each sample selected, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with 10 CFR 50.65 and verified that the (a)(2) performance criteria established by Exelon staff was reasonable. As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2). Additionally, the inspectors ensured that Exelon staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.

14 containment air cooler through wall leakage on SRW piping supply (CR-2014-001639)21 Atmospheric dump valve leaking past seat with controller output at zero (CR-2014-000700)22 Circulating water pump trip (CR-2014-003908)

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that Exelon performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that Exelon personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When Exelon performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk.

The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the stations probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

Unit 1 Auxiliary feedwater actuation system ZE sensor channel maintenance on April 10, 2014 2A EDG planned maintenance on April 14, 2014 Unit 1 pressurizer power operated relief block valves planned maintenance on April 25, 2014 Emergent maintenance on 11 4kV bus 0C EDG feeder breaker (152-1106) on May 7, 2014 Unit 1 yellow risk due to 1A EDG outage window on May 19, 2014 Emergent maintenance on 2B EDG volt fuse regulator on June 13, 2014 Emergent maintenance on 1A EDG on June 23, 2014

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:

11A and 11B check valve pressure high alarm, annunciator H11, coming in frequently on April 4, 2014 (CR-2014-002860)

MSLRM EAL threshold valves inaccurate on April 7, 2014 (CR-2014-003573)

Low pressure safety injection isolation valves (MOV 635 and MOV 645) left open on April 17, 2014 (CR-2014-000282)

Need to add CC rooms to EAL initial condition HA3.1 on May 19, 2014 (CR-2014-004683)

Through wall SW leakage on 21A SRW HX piping on June 5, 2014 (CR-2014-005170)13 Auxiliary feedwater pump inboard bearing package leakage inadequate on June 9, 2014 (CR-2014-005314)

Steam generator tube rupture (SGTR) dose calculation assessment on June 10, 2014 (CR-2014-003231)

The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS and UFSAR to Exelons evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by Exelon. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.

.1 Inaccurate EAL Threshold Values Incorporated into Site EAL Scheme Change

Introduction:

The inspectors documented a licensee-identified apparent violation of 10 CFR 50.54(q)(2), which preliminarily has been determined to be of low to moderate safety significance (White). Specifically, 10 CFR 50.54(q)(2) requires a licensee to develop and maintain an emergency plan which meets the requirements of 10 CFR 50.47(b), and 10 CFR 50, Appendix E. Contrary to this requirement, from October 11, 2013, through March 4, 2014, CCNPP failed to maintain in effect an emergency plan that met the standards in 10 CFR 50.47(b)(4) and 10 CFR 50, Appendix E, Section IV.B.1 for Unit 2. CCNPP did not maintain a standard emergency level scheme because inaccurate effluent radiation monitor thresholds were incorporated into Table R-1, Effluent Monitor Classification Threshold.

Description:

The MSLRMs are designed to provide an indication of primary to secondary leakage into the steam generators. The MSLRMs are calibrated to detect Nitrogen-16 activity being carried over into the main steam system during a steam generator tube leak. The instrument is calibrated to alarm at activity levels equivalent to primary to secondary leak rates of 150 gallon per day and 1 gallon per minute.

Additionally, since during a SGTR event, steam releases will occur via the steam generator code safety valves and/or the atmospheric dump valves, an unmonitored, unfiltered release path, the MSLRM provides an indication of the Noble Gas and Iodine release rates during such an event. Thus, EAL Hot Matrix Table R-1 has MSLRM threshold values which correspond to Noble Gas release rates needed to produce dose at the site boundary at the Protective Action Guideline Limits. Thus, Table R-1 has EAL threshold limits for the MSLRM for General Emergency (GE) (RG1.1), Site Area Emergency (RS1.1), and Alert (RA1.1). Per the EAL Basis Document, during a SGTR, the MSLRM provides indication of: 1) quantification of the radioactive release rate; 2)loss of RCS boundary; and 3) fuel damage. The EAL matrix states that if both dose assessment projections based upon actual atmospheric conditions and MSLRM indications are both available, the dose assessment results should be used; however, an EAL declaration should not be delayed in order to complete a dose assessment.

In October 2013, Exelon replaced the Unit 2 MSLRM instrumentation. The original instrumentation were scintillation detectors and measured radiation in units of mrem/hr.

The replacement instrumentation are Geiger-Mueller detectors and measure radiation in units of uCi/cc. Because the new instrumentation measured different units, Exelon staff calculated new EAL threshold values for the Alert, Site Area Emergency, and GE declarations. The calculations and the new EAL threshold values were reviewed by the engineering and radiation protection departments. On October 11, 2013, the new EAL threshold values were subsequently approved for use by the Plant Oversight Review Committee.

In March 2014, while developing new threshold values for the new Unit 1 MSLRM, Exelon staff raised questions regarding the methodology used to calculate the Unit 2 MSLRM values. On March 4, 2014, the Unit 2 MSLRM was declared non-functional for EAL declaration and compensatory actions were put in place while the staff assessed the calculation issue. On April 7, 2014, Exelon determined that the values in the EAL table for Unit 2 were inaccurate.

Exelon concluded that the inaccurate MSLRM thresholds were in place from October 11, 2013, through March 4, 2014, and that the thresholds values were off by a factor of 100 due to a conversion factor error. Exelon staff concluded that the calculation error would result in an EAL over-classification issue and subsequently, implemented compensatory measures, which included discontinuing the use of the MSLRM for EAL classification and using dose assessment in place of the MSLRM indication.

The inspectors reviewed the issue with the assistance of regional Emergency Preparedness staff and determined that the issue was potentially significant since a valid instrument reading would result in an EAL over-classification and would result in making an unnecessary emergency declaration and, at the general emergency level, unwarranted protective action recommendations for the public to state and local officials.

Exelon determined that during the period in which the MSLRM GE threshold was incorrectly low (October 11, 2013 through March 4, 2014) with RCS activities that existed during that time period, the GE threshold would not have been exceeded during a SGTR concurrent with a stuck open main steam safety valve. During that period, if Unit 2 had operated with primary coolant activity up to the TSs shutdown limit, the GE threshold would not have been exceeded during a SGTR with a concurrent stuck open main steam safety valve. If during that period, clad damage occurred concurrent with a SGTR and stuck open main steam safety valve, the MSLRM GE threshold could have been exceeded, and a GE declared. In this case, Exelon developed a timeline which indicates that the site would retract the GE prior to the time in which the state would issue protective action recommendations to the public. Exelon also noted that, cases where clad damage or core melt occurs would likely drive the station to a GE based on other plant parameters independent of the MSLRM.

The NRC staff reviewed the information provided by Exelon. The staff was not able to determine that based upon Exelons guidance that the site would retract a GE declaration and associated protection action recommendations prior to the time in which the State would issue protective action recommendations to the public.

10 CFR 50.47(b)(4), requires a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and state and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures. As such, emergency preparedness is not limited to design basis events, but includes a spectrum of events from anticipated transients to severe accidents. EALs and protective action recommendations are designed to be the last level of protection for public health and safety. For a major SGTR scenario, which occurs rapidly and with minimal warning, additional plant parameters needed to confirm the presence of fuel damage and make the GE declaration may not be available in a manner comparable to making timely emergency declarations and protective action recommendations. That is why this EAL basis identifies the MSLRM for this casualty.

Analysis:

Using IMC 0612, Appendix B, Issue Screening, the performance deficiency was determined to be more than minor because it impacted the procedure quality attribute of the Emergency Preparedness cornerstone and adversely impacts the associated 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, an EAL change was improperly implemented which would result in an over-classification of an event and potentially result in unnecessary protective action recommendations and movement of the public.

The inspectors utilized IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, to determine the significance of the performance deficiency.

The performance deficiency is associated with the emergency classification planning standard and is considered a RSPS function. The inspectors were directed by the SDP to compare the performance deficiency with the examples in Section 5.4, 10 CFR 50.47(b)(4), Emergency Classification System, to evaluate the significance of this performance deficiency.

Using Table 5.4-1, Significance Examples 50.47(b)(4)," the inspectors determined that the performance deficiency matched an example of a degraded RSPS function, which would be assessed as White. Specifically, the example states, in part, that the performance deficiency would be assessed White if the EAL classification process would result in an over-classification that would lead to off-site response organizations implementing, by procedure, unnecessary protective actions for the public. This condition should also be considered met if the licensee would make a protective action recommendation to the off-site response organizations because of the over-classification.

Additionally, using Figure 5.4-1, Significance Determination for Ineffective EALs and Over-classification, an EAL over-classification issue would result in unnecessary protective action recommendations for the public. The significance logic would only be considered for public protective actions that would be triggered by an off-site response organization receiving notification of a particular emergency classification (e.g., an invalid GE declaration) and does not apply to over-classifications during an actual event.

The emergency preparedness SDP states that unnecessary public protective actions caused by an over-classification is a concern since the public could be placed at increased health risks without realizing the dose avoidance benefit of a necessary protective action. The NRC encourages conservative decision making in uncertain events. However, the licensees emergency classification process should, to the extent possible, support timely and accurate declarations should an emergency occur. A deficient emergency classification process that would result in an over-classification and cause the licensee to make a protective action recommendation, or cause off-site response organizations to implement protective actions by procedure, should be identified as a degradation of a RSPS function. Based on the information provided in IMC 0609, Appendix B, Figure 5.4-1 of the emergency preparedness SDP, and the similarity between the performance deficiency and the White example, this issue was determined by the NRC staff to be White finding.

The inspectors determined that the cross-cutting aspect that contributed most to the root cause is H.12, Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes.

Individuals implement appropriate error reduction techniques. Specifically, Exelon staff did not independently validate the new EAL threshold values prior to revising and implementing the EAL scheme change.

Enforcement:

10 CFR 50.54(q)(2), requires that a holder of a nuclear power reactor operating license under this part, shall follow and maintain the effectiveness of an emergency plan that meets the requirements in Appendix E of this part and the standards in 10 CFR 50.47(b) and 10 CFR 50, Appendix E.

10 CFR 50.47(b)(4), requires a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and state and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.

10 CFR 50, Appendix E, Section IV.B.1, requires, in part, that the means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including EALs that are to be used as criteria for determining the need for notification and participation of local and state agencies, the commission, and other federal agencies, and the EALs that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety. The EALs shall be based on in-plant conditions and instrumentation in addition to onsite and offsite monitoring.

Contrary to the above, from October 11, 2013, through March 4, 2014, CCNPP failed to maintain in effect an emergency plan that met the standards in 10 CFR 50.47(b)(4) and the requirements in 10 CFR 50, Appendix E, Section IV.B.1 for Unit 2. Specifically, CCNPP did not maintain an adequate standard emergency level scheme because inaccurate effluent radiation monitor thresholds were incorporated into Table R-1, Effluent Monitor Classification Threshold. During the replacement of the Unit 2 MSLRM, CCNPPs staff inaccurately calculated the effluent threshold for GE EAL RG1.1 and incorporated the threshold into Table R-1. This error would have resulted in an over-classification of an event and potentially resulted in an unnecessary protective action recommendation and could cause off-site response organizations to implement unnecessary protective actions. Immediate corrective actions included Exelon entering the issue into their CAP as CR-2014-003573, implemented appropriate compensatory actions, and initiated corrective actions to revise the EAL table. These issues are being characterized as an apparent violation in accordance with the NRCs Enforcement Policy, and its final significance will be dispositioned in separate future correspondence.

(Apparent Violation 05000318/2014003-02, Inaccurate EAL Threshold Values Incorporated Into Site EAL Scheme Change)

.2 Inadequate EAL Initiating Condition

Introduction:

The inspectors identified a Green NCV of 10 CFR 50.54 (q)(2) and 10 CFR 50.47(b)(4) because Exelon did not maintain the Emergency Plan to adequately meet the standards in 10 CFR 50.47(b)(4). Specifically, Exelon failed to include Unit 1 and Unit 2 CC rooms under EAL initiating condition HA3.1, an Alert for a Hazardous Gas Event.

Description:

On April 24, 2014, during a review of EAL initiating condition HA3.1, the inspectors identified that Exelon failed to include the CC rooms into the initiating condition area list. EAL Category H, Hazards and Other Conditions Affecting Plant Safety, Subcategory 3, Hazardous Gas, ensures an Alert condition is declared when access to vital areas is prohibited due to toxic, corrosive, asphyxiate, or flammable gases which jeopardize operation of operable equipment required to maintain safe operations or safely shutdown the reactor.

EAL-TB, Emergency Action Level Technical Basis Document, for initiating condition HA3.1 states, in part, Locations designated in the EAL are those areas that are required for Cold Shutdown that cannot be completed from the Control Room. In other words, any area outside of the control room that requires access to perform actions to ensure operability of a safety-related SSC, needs to be included in EAL initiating condition HA3.1. The inspectors questioned whether Unit 1 and Unit 2 CC rooms should have been included in the HA3.1 area list. The CC rooms have CV-306, which functions as the low pressure safety injection flow control valve during modes 1, 2 and 3 with pressurizer pressure 1750 psia, in addition, it performs the SDC temperature control function in modes 4 and 5. This valve is an air operated valve that has Surveillance Requirement 3.5.2.1 to ensure the valve is in the open position with power to the valve operator removed every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during modes 1, 2, and 3 with pressurizer pressure 1750 psia. In December 2011, after questions from NRC inspectors, the licensee decided to isolate air to CV-306 air operator in order to comply with Surveillance Requirement 3.5.2.1. ECP-11-000983 implemented the permanent change to maintain the air supply valve isolated. In order for operations personnel to control SDC temperatures from the control room, operators require access to the CC rooms to open the air supply valve to the CV-306 operator. As a result, the inspectors determined that access to the CC room is required for cold shutdown and should be included in the EAL initiating condition HA3.1. The inspectors concluded that in a hazardous gas event in the CC rooms, Exelon personnel would have missed an EAL Alert declaration.

The inspectors determined that Exelon had opportunities to identify this issue. ECP-11-000989 did not evaluate the permanent change impact on the Emergency Plan. Also, Exelon received a safety evaluation report for the Nuclear Energy Institute 99-01, Revision 5 EAL technical basis on February 29, 2012, from the NRC. After a period of training and practice on the new EALs, Revision 5 EAL scheme was implemented in October 17, 2012. This issue was not identified during that period.

Exelon entered this issue into their CAP as CR-2014-004683. Immediate actions include revising EAL initiating condition HA3.1 to include the CC rooms and verify that there are no other areas that need to be included in EAL HA3.1.

Analysis:

The failure to update the EAL scheme the site approved emergency plan following a plant modification was a performance deficiency that was within the Exelon staff ability to foresee and correct and should have been prevented. Using IMC 0612, Appendix B, Issue Screening, the performance deficiency was determined to be more than minor because it impacted the procedure quality attribute of the Emergency Preparedness cornerstone and adversely impacts the associated 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, a plant modification was completed which required operators to be able to enter the CC room in order to bring the plant to cold shutdown and the EAL scheme was not updated to reflect this change. The inspectors utilized IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, to determine the significance of the performance deficiency. The performance deficiency is associated with the emergency classification planning standard and is considered a RSPS function.

This performance deficiency impacts the following required planning standard and RSPS function: The inspectors were directed by the SDP to compare the performance deficiency with the examples in Section 5.4, 10 CFR 50.47(b)(4), Emergency Classification System, to evaluate the significance of this performance deficiency. The inspectors determined that the EAL was ineffective because it, in and of itself, no longer resulted in a timely and accurate declaration of an Alert for the initiating condition.

Utilizing Figure 5.4.1, for an ineffective EAL where an Alert would not be declared when required, this would screen as a Green finding.

This finding has a cross-cutting aspect in the area of Human Performance, Change Management, because Exelon personnel didnt use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority.

Specifically, engineering personnel did not ensure that the impact to the Emergency Plan was adequately evaluated as a result of the permanent plant change ECP-11-000983 [H.3].

Enforcement:

10 CFR 50.54 (q)(2) requires, in part, that a licensee "shall follow and maintain in effect emergency plans which meet the standards in 10 CFR 50.47(b) and the requirements in Appendix E of this part. 10 CFR 50.47(b)(4) requires, in part, that emergency response plans include a standard emergency classification and action level scheme, the bases of which include a standard facility system and effluent parameters.

The emergency classification and action level scheme required to be used by the nuclear facility licensee, and state and local response plans, rely on information provided by facility licensees for determination of minimum initial offsite response measures.

Contrary to these requirements, from October 17, 2012, until July 7, 2014, Exelon did not have an adequate emergency classification and action level scheme in place for the hazardous gas initiating condition HA3.1. Immediate corrective actions included entering this issue into their CAP and revising initiating condition HA3.1 vital area list.

Because this finding is of very low safety significance (Green) and was entered into Exelons CAP as CR-2014-004683, this issue is being treated as an NCV consistent with Section 2.3.2.a of the Enforcement Policy. (NCV 05000317/318/2014003-03:

Inadequate EAL Initiating Condition HA3.1)

1R18 Plant Modifications

.1 Permanent Modifications

a. Inspection Scope

The inspectors evaluated the below modifications and verified that the design bases, licensing bases, and performance capability of the affected systems were not degraded by the modifications. The inspectors also reviewed revisions to the UFSAR and system design basis documents to ensure the modifications were incorporated into these documents.

Modification to the 1A EDG building implemented by engineering change packages ESR 13-000663/ECP-13-000510, 1A EDG building modification to ensure 1A DG is operable in external wind speed up to 100 mph, and ECP-14-000007, Perform evaluation of 0C radiator fan under extreme wind conditions. In addition, the inspectors reviewed modification documents associated with the upgrade and design change, including a review of civil and structural calculations, pre and post modification radiator performance evaluation and testing, and the 10 CFR 50.59 evaluation conducted to evaluate the potential for an additional failure mechanism introduced by the modification Modification to the Unit 1 Mark VI turbine control system power supply implemented by engineering change package ECP-14-000128. In addition, the inspectors reviewed modification documents associated with the upgrade and design change, including a review of the newly installed undervoltage circuit breaker specifications, seismic qualification calculations, drawing changes, and the 10 CFR 50.59 evaluation

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure were consistent with information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.

Replace 2YX2X1023A1, 22 steam generator level to RPS loop power supply on May 6, 2014 1A EDG overhaul on June 18, 2014 12 SRW pump motor replacement on June 19, 2014 23 Containment air cooler SRW inlet valve timing adjustment on June 20, 2014

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied TS, the UFSAR, and Exelon procedural requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:

Surveillance test procedure (STP)-O-073C-2, CC pump quarterly test on May 6, 2014 STP-M-031-0, Relief valve testing and setting on May 7, 2014 (IST)

STP-O-072, High pressure safety injection pump and check valve operability test on May 25, 2014

b. Findings

No findings were identified.

1EP6 Drill Evaluation

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine CCNPP emergency drill on May 21, 2014, to identify any weaknesses and deficiencies in the classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator and technical support center to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the station drill critique to compare inspector observations with those identified by Exelon staff in order to evaluate Exelons critique and to verify whether Exelon staff was properly identifying weaknesses and entering them into the CAP.

b. Findings

No findings were identified.

.2 Training Observation

a. Inspection Scope

The inspectors observed a simulator training evolution for licensed operators on May 6, 2014, which required emergency plan implementation by an operations crew. Exelon planned for this evolution to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the post-evolution critique for the scenario. The focus of the inspectors activities was to note any weaknesses and deficiencies in the crews performance and ensure that Exelon evaluators noted the same issues and entered them into the CAP.

b. Findings

No findings were identified.

2RS5 Radiation Monitoring Instrumentation

a. Inspection Scope

During June 23 - 27, 2014, the inspectors verified that CCNPP is assuring the accuracy and operability of radiation monitoring instruments that are used to protect the public from nuclear power plant operations. The inspectors used the requirements in 10 CFR 20, 10 CFR 50, Appendix A, Criterion 60, Control of Release of Radioactivity to the Environment, and Criterion 64, Monitoring Radioactive Releases, 10 CFR 50, Appendix I, Numerical Guides for Design Objectives and Limiting Conditions for Operation to meet the Criterion As Low as is Reasonably Achievable for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents, 40 CFR 190, Environmental Radiation Protection Standards for Nuclear Power Operations, NUREG-0737, Clarification of Three Mile Island Corrective Action Requirements, TS/Offsite Dose Calculation Manual (ODCM), applicable industry standards, and procedures as criteria for determining compliance.

Inspection Planning

The inspectors reviewed the CCNPP UFSAR to identify radiation instruments that are associated with monitoring process streams and effluents. The inspectors reviewed effluent monitor alarm set-point bases and their calculation methods provided in the ODCM.

Walkdowns and Observations The inspectors walked down one liquid and one gaseous effluent radiation monitoring system. This review included flow measurement devices and all accessible point-of-discharge liquid and gaseous effluent monitors. The inspectors assessed whether the effluent/process monitor configurations align with what is described in the UFSAR and ODCM.

Process and Effluent Monitors The inspectors selected three effluent monitor instruments and evaluated whether channel calibration and functional tests were performed consistent with CCNPP TS/ODCM. The inspectors assessed whether:

(a) CCNPP calibrated its monitors with National Institute of Standards and Technology traceable sources;

(b) primary calibrations adequately represent the plant radionuclide mix;

(c) secondary calibration sources used were verified by comparison with primary calibration sources; and

(d) CCNPP channel calibrations encompassed the instruments alarm set-point range.

The inspectors assessed whether the effluent monitor alarm set-points are established as provided in the CCNPP ODCM and station procedures. For changes to effluent monitor set-points, the inspectors evaluated the basis for any changes.

Calibration and Check Sources The inspectors reviewed Exelons waste stream characterization per 10 CFR 61, Licensing Requirements for Land Disposal of Radioactive Waste, to assess whether calibration sources used were representative of the types and energies of radiation encountered in the plant.

Problem Identification and Resolution The inspectors evaluated whether problems associated with radiation monitoring instrumentation were being identified by Exelon at an appropriate threshold and were properly addressed for resolution in their CAP. The inspectors assessed the appropriateness of the corrective actions for a selected sample of problems documented by Exelon that involved radiation monitoring instrumentation.

b. Findings

No findings were identified.

2RS6 Radioactive Gaseous and Liquid Effluent Treatment

a. Inspection Scope

During June 23 - 27, 2014, the inspectors verified that gaseous and liquid effluent processing systems are maintained so radiological discharges are properly reduced, monitored, and released. The inspectors also verified the accuracy of the calculations for effluent releases and public doses.

The inspectors used the requirements in 10 CFR 20, Standards for Protection Against Radiation; 10 CFR 50.34(a), Preliminary Safety Analysis Report; TS; 10 CFR 50, Appendix A ,Criterion 60, Control of Release of Radioactivity to the Environment, and Criterion 64, Monitoring Radioactive Releases; 10 CFR 50, Appendix I, Numerical Guides for Design Objectives and Limiting Conditions for Operations to Meet the Criterion As Low as is Reasonably Achievable for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents; 10 CFR 50.75(g), Reporting and Recordkeeping for Decommissioning Planning; 40 CFR 141, Maximum Contaminant Levels for Radionuclides; 40 CFR 190, Environmental Radiation Protection Standards for Nuclear Power Operations; Regulatory Guide 1.109, Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents; Regulatory Guide 1.21, Measuring, Evaluating, Reporting Radioactive Material in Liquid and Gaseous Effluents and Solid Waste; Regulatory Guide 4.1, Radiological Environmental Monitoring for Nuclear Power Plants; Regulatory Guide 4.15, Quality Assurance for Radiological Monitoring Programs; NUREG 1301, Offsite Dose Calculation Manual (ODCM) Guidance:

Standard Radiological Effluent Controls; applicable Industry standards; and Exelon procedures required by TS/ODCM as criteria for determining compliance.

Event Report and Effluent Report Reviews The inspectors reviewed the 2012 and 2013 CCNPP Annual Radioactive Effluent Release Reports to determine if the reports were submitted as required by the ODCM/TS. The inspectors reviewed anomalous results, unexpected trends, abnormal releases, and effluent monitor operability issues that were identified. The inspectors determined if these effluent results were evaluated, were entered in the CAP, and were adequately resolved.

ODCM and UFSAR Review The inspectors reviewed the CCNPP UFSAR descriptions of the radioactive effluent monitoring systems, treatment systems, and effluent flow paths to identify system design features and required functions.

The inspectors reviewed changes to the CCNPP ODCM made by Exelon since the last inspection. When differences were identified, the inspectors reviewed the technical basis or evaluations of the change and determined whether they were technically justified and maintained effluent releases as low as is reasonably achievable.

The inspectors reviewed documentation to determine if any non-radioactive systems that have become contaminated were disclosed either through an event report or the ODCM.

The inspectors reviewed selected 10 CFR 50.59 evaluations and made a determination if any newly contaminated systems had an unmonitored effluent discharge path to the environment.

Groundwater Protection Initiative Program The inspectors reviewed reported groundwater monitoring results and changes to Exelons program for identifying and controlling contaminated spills/leaks to groundwater.

Procedures, Special Reports, and Other Documents The inspectors reviewed Licensee Event Reports (LERs), event reports, and special reports related to the effluent program issued since the previous inspection to identify any additional focus areas for the inspection based on the scope/breadth of problems described in these reports.

The inspectors reviewed effluent program implementing procedures, including those associated with effluent sampling, effluent monitor set-point determinations, and dose calculations.

The inspectors reviewed copies of Exelons and third party (independent) evaluation reports of the effluent monitoring program since the last inspection to gather insights into the effectiveness of the program.

Walkdowns and Observations The inspectors walked down selected components of the gaseous and liquid discharge systems to verify that equipment configuration and flow paths align with the descriptions in the UFSAR and to assess equipment material condition. This review included any potential unmonitored release points, building alterations which could impact airborne or liquid effluent controls, and ventilation system leakage that communicate directly with the environment.

The inspectors reviewed effluent system material condition surveillance records for equipment and areas associated with the systems selected for review that were not readily accessible due to radiological conditions. The inspectors walked down filtered ventilation systems to verify there are no degraded conditions associated with high-efficiency particulate air /charcoal banks, improper alignment, or system installation issues that would impact the performance or the effluent monitoring capability of the effluent system. The inspectors observed portions of the routine processing and discharge of radioactive gaseous effluent system to verify that appropriate treatment equipment was used and the processing activities align with discharge permits.

The inspectors determined that Exelon had not made any changes to their effluent release paths since the last inspection.

The inspectors observed portions of the routine processing and discharge of liquid waste. The inspectors verified that appropriate effluent treatment equipment is being used and that radioactive liquid waste is being processed and discharged in accordance with TS/ODCM and procedures.

Sampling and Analyses The inspectors selected three effluent sampling activities, and assessed whether adequate controls have been implemented to ensure representative samples were obtained.

The inspectors selected two effluent discharges made with inoperable effluent radiation monitors to verify that controls are in place to ensure compensatory sampling is performed consistent with the TS/ODCM and that those controls are adequate to prevent the release of unmonitored liquid and gaseous effluents.

The inspectors determined whether the facility is routinely relying on the use of compensatory sampling in lieu of adequate system maintenance, based on the frequency of compensatory sampling since the last inspection.

The inspectors reviewed the results of the inter-laboratory and intra-laboratory comparison program to verify the quality of the radioactive effluent sample analyses.

The inspectors also assessed whether the intra- and inter-laboratory comparison program includes hard-to-detect isotopes.

Effluent Flow Measuring Instruments The inspectors reviewed the methodology that Exelon uses to determine the effluent stack and vent flow rates to verify that the flow rates are consistent with TS/ODCM and UFSAR values. The inspectors reviewed the differences between assumed and actual stack and vent flow rates to ensure that they do not affect the calculated results of public dose.

Air Cleaning Systems The inspectors assessed whether surveillance test results for TS required ventilation effluent discharge systems meet the applicable acceptance criteria.

Dose Calculations The inspectors reviewed all significant changes in reported dose values compared to the previous radioactive effluent release report to evaluate the factors which may have resulted in any changes.

The inspectors reviewed three radioactive liquid and three gaseous waste discharge permits to verify that the projected doses to members of the public were accurate and based on representative samples of the discharge path.

Inspectors evaluated the methods used to ensure that all radionuclides in the effluent stream source term are included, within detectability limitations. The review included the current waste stream analyses to ensure hard-to-detect radionuclides are included in the effluent releases.

The inspectors reviewed changes in Exelons methodology for offsite dose calculations since the last inspection to verify the changes are consistent with the ODCM and Regulatory Guide 1.109. The inspectors reviewed meteorological dispersion and deposition factors used in the ODCM and effluent dose calculations to ensure appropriate dispersion/deposition factors are being used for public dose calculations.

The inspectors reviewed the latest land use census to verify changes that affect public dose pathways have been factored into the dose calculations and environmental sampling/ analysis program.

The inspectors evaluated whether the calculated doses are within the 10 CFR 50, Appendix I and TS dose criteria.

The inspectors reviewed one record of an abnormal gaseous discharge to ensure the abnormal discharge was monitored by the discharge point effluent monitor. Discharges made with inoperable effluent radiation monitors, or unmonitored leakages, were reviewed to ensure that an evaluation was made of the discharge to account for the effluent release and were included in the calculated doses to the public.

Groundwater Protection Initiative Implementation The inspectors reviewed monitoring results of the voluntary Nuclear Energy Institute Groundwater Protection Initiative to determine if Exelon has implemented the industry standards as intended. For anomalous results or missed samples, the inspectors assessed whether Exelon identified and addressed deficiencies through its CAP.

The inspectors reviewed identified leakage or spill events and entries made into Exelons decommissioning files. The inspectors reviewed evaluations of leaks or spills, and reviewed the effectiveness of any remediation actions. The inspectors reviewed onsite contamination events involving contamination of ground water and assessed whether the source of the leak or spill was identified and isolated/terminated.

For unmonitored spills, leaks, or unexpected liquid or gaseous discharges, the inspectors assessed whether an evaluation was performed to determine the type and amount of radioactive material that was discharged by: assessing whether sufficient radiological surveys were performed to evaluate the extent of the contamination and assessing whether a survey/evaluation has been performed; and determining whether Exelon completed offsite notifications, as provided in its Groundwater Protection Initiative implementing procedures.

The inspectors assessed whether on-site ground water sample results and a description of any significant on-site leaks/spills into ground water for each calendar year are documented in the Annual Radioactive Effluent Release Report.

Problem Identification and Resolution Inspectors assessed whether problems associated with the effluent monitoring and control program are being identified by Exelon at an appropriate threshold and are properly addressed for resolution in their CAP. In addition, the inspectors evaluated the appropriateness of the corrective actions for a selected sample of problems documented.

b. Findings

No findings were identified.

4OA1 Performance Indicator Verification

.1 Safety System Functional Failures (2 samples)

a. Inspection Scope

The inspectors sampled Exelons submittals for the Safety Systems Functional Failures performance indicator (MS05) for both Unit 1 and Unit 2 for the period of July 1, 2013, through June 30, 2014. To determine the accuracy of the performance indicator data reported during those periods, inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 10 CFR 50.73. The inspectors reviewed Exelons operator narrative logs, operability assessments, maintenance rule records, maintenance work orders, CRs, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review of Problem Identification and Resolution Activities

a. Inspection Scope

As required by Inspection Procedure 71152, Problem Identification and Resolution, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that Exelon personnel entered issues into the CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the CAP.

b. Findings

No findings were identified.

.2 Semi-Annual Trend Review

a. Inspection Scope

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 CAP, such as trend reports, performance indicators, major equipment problem lists, system health reports, maintenance rule assessments, and maintenance or CAP backlogs. The inspectors also reviewed Exelons CAP database for the fourth quarter of 2013 and first quarter of 2014 to assess CRs written in various subject areas (equipment problems, human performance issues, etc.), as well as individual issues identified during the NRCs daily CR review (Section 4OA2.1). The inspectors reviewed Exelon staffs quarterly trend reports for the first quarter of 2014, conducted under CNG-CA-1.01-1007, Performance Improvement Program Trending and Analysis, to verify that Exelon personnel were appropriately evaluating and trending adverse conditions in accordance with applicable procedures.

b. Findings and Observations

No findings were identified.

The inspectors evaluated a sample of departments that are required to provide input into the quarterly trend reports, which included maintenance, operations, and engineering.

This review included a sample of issues and events that occurred over the course of the past two quarters to objectively determine whether issues were appropriately considered or ruled as emerging or adverse trends, and in some cases, verified the appropriate disposition of resolved trends. The inspectors verified that these issues were addressed within the scope of the CAP, or through department review, and documentation in the quarterly trend report for overall assessment. For example, Exelons staff continued to address a previously identified declining trend in the area of configuration control involving component mispositioning. Exelons personnel noted in CR-2014-005179 that there had been a total of seven component mispositionings over the past six months.

Causes identified are associated with individual accountability and supervisory oversight.

The inspectors verified that Exelon staff had corrective actions in place to address the identified causes. Corrective actions include assessment of operations supervisors for gaps associated with leadership skills and implementation of development plans to close gaps; field observations each shift; and an increase number of unannounced observations. The inspectors plan to conduct an in-depth problem identification and resolution inspection to review this issue.

Additionally, the inspectors noted an increase in the number of through wall leakage issues in the SW system. None of the SW through wall leakage affected the ability of the system to perform the SW system design safety function. The inspectors noted that within the last 18 months, there were four SW system through wall leakage issues.

Exelon staff was aware of this issue and initiated CR-2014-005667 to document and evaluate this trend.

.3 Annual Sample: Unit 1 RPS Unavailability

a. Inspection Scope

The inspectors performed an in-depth review of Exelons apparent cause evaluation and corrective actions associated with CR-2013-007091. CR-2013-007091 was initiated on September 6, 2013. CR-2013-007091 documented that the Unit 1 RPS exceeded its allowed unavailability hours established by the CCNPP maintenance rule program.

Unavailability was measured at the redundant sensor and channel level and did not necessarily imply TS inoperability. CCNPP specifically established as performance criteria for the Unit 1 RPS that unavailability within a 2 year rolling window be maintained less than 300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br />. Consistent with maintenance rule program requirements, Exelon completed an evaluation and established goals to improve the Unit 1 RPS unavailability.

At the time of the apparent cause evaluation, Unit 1 RPS had logged a total of 405 hours0.00469 days <br />0.113 hours <br />6.696429e-4 weeks <br />1.541025e-4 months <br /> of unavailability. The apparent cause evaluation included a common cause analysis and a cause road map analysis to determine the apparent causes. The apparent cause evaluation was presented to CCNPPs management review committee on October 25, 2013, and was approved with comments. As a result of the apparent cause evaluation, Unit 1 RPS was placed in maintenance rule (a)(1) status.

The inspectors assessed Exelons problem identification threshold, causal analyses, technical analyses, extent of condition reviews, and the prioritization and timeliness of corrective actions to determine whether Exelon was appropriately identifying, characterizing, and correcting problems associated with this issue. The inspectors focused on opportunities for Exelon to have identified any earlier common cause issues that significantly contributed to Unit 1 RPS unavailability. The inspectors also assessed Exelons corrective actions to reduce Unit 1 RPS unavailability to within maintenance rule program performance criteria. The inspectors compared the actions taken to the requirements of Exelons CAP and 10 CFR 50, Appendix B, Criterion XVI, Corrective Action. In addition, the inspectors reviewed documentation associated with this issue, including condition and failure analysis reports, and interviewed engineering and instrument and calibration maintenance personnel to assess the effectiveness of the implemented and planned corrective actions.

b. Findings and Observations

No findings were identified.

Exelon promptly initiated an apparent cause evaluation and the management review committee approved its problem statement on September 20, 2013. The apparent cause evaluation evaluators appropriately considered all events that incurred unavailability during the two year monitoring period. Potential contributors were separated into eight bins. Of those eight bins, one was identified as the apparent cause and two were identified as contributing causes. The apparent cause of Unit 1 RPS exceeding its maintenance rule allowed unavailability was part failures due to aging and wear. The contributing causes were time spent performing risk assessment of emergent maintenance and the complexity of many of the equipment issues that required multiple iterations of troubleshooting which extended the out of service time.

Exelon established timely corrective actions to address the apparent cause and contributing causes. Exelon completed a bridging strategy to address the aging and wearing parts issues. The bridging strategy was developed using Administrative Procedure, CNG-AM-1.01-1034, Bridging and Mitigation Strategies, Revision 0. A bridging strategy was a plan of actions (corrective, preventive, and compensatory)meant to lessen the impact, frequency, and consequences resulting from a currently degraded issue until the issue is finally remedied. The bridging strategy included preventative maintenance tasks to maintain the reliability of key RPS subcomponents.

The contributing causes were appropriately addressed with corrective actions intended to improve troubleshooting effectiveness and streamline the process for completing risk assessments of emergent maintenance conditions.

The inspectors determined that Exelons overall response to the Unit 1 RPS unavailability issue was commensurate with the safety significance, was timely, and the actions taken and planned were reasonable to restore its availability within maintenance rule program performance criteria. The inspectors additionally reviewed several lower level CRs associated with Unit 1 and Unit 2 RPS equipment and determined each issue was appropriately identified, reported, and corrected.

.4 Annual Sample: 1A EDG Ventilation External Winds Vulnerability

a. Inspection Scope

The inspectors performed an in-depth review of CR 2012-009021 and CR 2013-004310, which address a design vulnerability for the 1A Société Alsacienne de Constructions Mécaniques (SACM) EDG installed in 1995. The inspectors reviewed the evaluations of this issue, and the adequacy of the compensatory and corrective actions developed and implemented to address this identified condition adverse to quality. These corrective actions included the implementation of a permanent plant modification (ECP-13-000510), modifying the 1A EDG building structure.

The inspectors assessed Exelons problem identification threshold, cause analyses, extent of condition reviews, compensatory actions, and the prioritization and timeliness of Exelons corrective actions to determine whether Exelon was appropriately identifying, characterizing, and correcting problems associated with this issue and whether the planned or completed corrective actions were appropriate. The inspectors compared the actions taken to the requirements of Exelons CAP and 10 CFR 50, Appendix B. In addition, the inspectors performed field walkdowns and interviewed engineering personnel to assess the effectiveness of the implemented corrective actions.

b. Findings and Observations

The inspectors documented a licensee-identified NCV associated with inadequate design control. The enforcement aspects of this finding are discussed in section 4OA7 of this report.

In 1995, CCNPP installed two French made SACM EDG sets, one to provide safety-related emergency power supply for Unit 1 (1A EDG) and one to provide a non-safety related power supply in the event of a station blackout (0C EDG). These two EDGs were air cooled, in that the cooling medium for lube oil and jacket water cooling systems was an air cooled radiator, vice the SRW system used for cooling the three original station EDGs. In 1995, the NRC issued a license amendment and safety evaluation report authorizing the use of these EDGs at CCNPP.

In 1996, questions were raised about cooling system performance due to high winds and tornados. These questions focused on system performance under sustained winds of 22 mph or greater and tornado induced gusts. The vendor (Bechtel) evaluated the concerns, documented their review in (SPR 95-609M), and concluded that the fans would be able to start and run under all postulated conditions; however, when sustained winds where from the South East, air flow through the radiators would be reduced below design flow when wind speed was greater than 28 mph, and at 42 mph wind speed air flow would be reduced to 72 percent rated and the fan would enter an unstable harmonic and may trip. Thus operation with sustained winds (greater than 1 min average) of greater than 42 mph adequate air flow could not be ensured and the engine could overheat and trip due to high oil and jacket water temperatures if not derated. Bechtel concluded that the 1A EDG still met the Licensing Basis requirements and meet the NRC Standard Review Plan guidance, and continued operation was permitted. CCNPP sent the results to a second independent vendor (MPR Associates), who confirmed Bechtels analysis and provided two recommendations for modifications to address the low air flow concerns during high winds. However, these recommendations were not adopted or entered into the site CAP and the design vulnerability was not incorporated into the system design basis or system operating instructions. In 2011, during a diesel system vulnerability self-assessment, CCNPP identified that there was no record of how the 1996 MPR Associates recommendations were dispositioned. CR 2011-011377 was opened to investigate this concern. This CR captured the recommendations as system enhancements.

In 2012, during the conduct of an internal engineering audit following Hurricane Irene, the 1996 Bechtel document was reviewed and the concern was entered into the stations CAP as CR-2012-009021 and an operability evaluation was performed. CCNPP engineering staff believed the 1996 Bechtel Letter was overly conservative and that a high wind condition was outside the 1A EDG design basis, thus they concluded the EDG was operable based upon engineering judgment. However, corrective actions were created to reanalyze the concern using current analytical tools to validate the operability call. No compensatory actions were put in place at the time. The 2012 CR also contained corrective actions to develop a plant modification if the results of the evaluation did confirm the 1996 letters conclusions. This evaluation was completed in May 2013 and re-affirmed the conclusion of the 1996 Bechtel Letter that with external wind speeds of 42 mph from the southeast, the diesel radiator would not have enough air flow to support operability. CCNPP wrote CR-2013-004310 to develop and implement appropriate compensatory actions, to ensure the EDG was declared inoperable when wind speed and direction would adversely impact EDGs ability to carry out its safety function. The NRC residents conducted an inspection to verify the adequacy of the compensatory actions. This inspection was documented in NRC Inspection Report 05000317/2013003 and 05000318/2013003. The licensee also developed long term corrective actions; an engineering modification to install an external baffle plate to reduce the backpressure felt at the radiator due to external winds. This modification was completed in spring 2014.

The SACM EDGs were designed to meet Institute for Electrical and Electronics Engineers (IEEE) Standard 308, IEEE Standard for Class 1E Power Systems for Nuclear Power Generating Stations. IEEE Standard 308, Section 4.4, Design Basis, states, in part, The design basis shall include, as a minimum, the following:

(f) the malfunctions, accidents, environmental events, and operating modes (see Table 1) that could physically damage Class 1E power systems or lead to degradation of system performance and for which provisions shall be incorporated. Table 1 includes natural phenomena such as wind, hurricane, and tornado. This wind condition is also well within the design basis sustained wind speeds discussed in the plants UFSAR. Thus the inspectors determined this condition was within the plant design basis and should have been incorporated into the system design and operating instructions when it was identified in 1996. The inspectors also questioned whether compensatory actions should have been incorporated in 2012 since there was a reasonable doubt of operability given the conclusions of the1996 Bechtel and MPR Associates letters were contrary to the engineering judgment used in a operability determination.

The enforcement aspects of this issue are discussed in Section 4OA7 of this report.

4OA3 Follow-Up of Events and Notices of Enforcement Discretion

.1 Plant Events

a. Inspection Scope

For the plant events listed below, the inspectors reviewed and/or observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant events to appropriate regional personnel, and compared the event details with criteria contained in IMC 0309, Reactive Inspection Decision Basis for Reactors, for consideration of potential reactive inspection activities. As applicable, the inspectors verified that Exelon made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR 50.72 and 50.73. The inspectors reviewed Exelons follow-up actions related to the events to assure that Exelon implemented appropriate corrective actions commensurate with their safety significance.

Unit 1 Reactor Trip on May 1, 2014, due to RPS testing matrix malfunction

b. Findings

No findings were identified

.2 (Closed) LER 05000317/318/2013-001-00: Inoperable Control Room Ventilation Train

Due to Broken Springs on Damper On September 29, 2013, a plant operator noticed that the 12 post loss of coolant incident filter fan (PLFF) was slowly rotating in the forward direction with both the 11 and 12 PLFFs de-energized. Troubleshooting identified that the discharge damper for the 12 PLFF was partially open, allowing excessive bypass flow for the 11 PLFF. The 11 PLFF was declared inoperable on September 29, 2013, at 4:30 p.m. The 12 PLFF discharge damper was repaired and the 11 PLFF was returned to service on October 3, 2013, at 11:25 p.m. A review of STP-O-012, Control Room Post Loss of Coolant Incident Ventilation System, revealed that the surveillance was previously completed on September 22, 2013, at 10:24 p.m. On October 3, 2013, at 11:25 p.m., 11 PLFF was declared operable. Exelon determined that the condition existed since September 22, 2013; therefore, resulting in Unit 1 and Unit 2 operating in a condition prohibited by TS for approximately 4 days. The enforcement aspects of this issue are discussed in Section 4OA7. The inspectors did not identify any new issues during the review of the LER. This LER is closed.

.3 (Closed) LER 05000318/2013-005-00: Manufacturing Defect Results in Shutdown Due

to Dropped Control Element Assembly On September 5, 2013, Unit 2s control element assembly (CEA) No. 27 dropped to the fully inserted position while the CEA was being operated as part of a surveillance test.

Operators entered applicable TS for the dropped CEA. When operators were unable to restore the CEA to its proper alignment within the required TS limiting conditions of operation completion time, operators commenced a reactor shutdown. Exelon personnel identified that the control element drive mechanism No. 27 lift coil was grounded internally to the coil housing due to a chafed wire. Exelon staff conducted a root cause analysis and determined that the root cause for the dropped CEA was a manufacturing defect that resulted in circumferential displacement of the coil within the coil housing and the misalignment of the lift coil lead wire within the coil housing nipple.

Corrective actions included replacement of the control element drive mechanism coil stack with one that includes a change in design featuring a protective heat shrink wrap at the point where the lead wire penetrates the coil housing nipple. All other Unit 2 control element drive mechanism were meggered with satisfactory results. Planned corrective actions include replacement of the Unit 2 coil stacks. Exelon concluded that the condition is not present on the CEA coil stacks on Unit 1 since they were replaced with coil stacks that include the improved design for the lead wires during the reactor vessel head replacement project in 2006. The inspectors did not identify any findings or violations of NRC requirements during the review of the LER. This LER is closed.

.4 (Closed) LER 05000317/2014-002-00: Condition Prohibited by Technical Specifications

Due to Auxiliary Feedwater Train Inoperable Due to Human Performance Error On February 7, 2014, at 10:37 p.m., during the performance of STP-O-009, Auxiliary Feedwater Actuating System Logic Test, Operations personnel discovered MS-225

[steam line condensate collection tank (mud leg) drain valve] and MS-228 (mud leg steam trap bypass valve) were open. Further investigation revealed that these valves were left open during the routine draining evolution of the mud legs performed during day shift. The draining evolution occurred at 10:25 a.m. As a result, 11 and 12 turbine driven auxiliary feedwater pumps were inoperable for approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The enforcement aspects of this issue are discussed in NRC Inspection Report 05000317/2014002 and 05000318/2014002, Section 1R15. The inspectors did not identify any new issues during the review of the LER. This LER is closed.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On July 23, 2014, the inspectors presented the inspection results to Mr. Mark Flaherty, Plant General Manager, and other members of the Exelon staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

On July 31, 2014, the inspectors re-exited with Mr. Doug Lauver, Director of Licensing, to discuss that inspection report item 05000317,05000318/2014003-01 would be documented as an URI.

4OA7 Licensee-Identified Violations

The following violations of very low safety significance (Green) were identified by Exelon and are violations of NRC requirements which meet the criteria of the NRC Enforcement Policy for being dispositioned as a NCV.

TS 3.7.8, Control Room Emergency Ventilation System (CREVS), requires two CREVS trains operable during modes 1, 2, 3, 4, and during movement of irradiated fuel assemblies. With one CREVS train inoperable due to excessive bypass flow, TS 3.7.8, Condition E, is required to be entered. The required action is to restore CREVS train to operable status within seven days. This action was not completed within the required completion time because the issue was discovered after the required completion time had expired. Contrary to the above, one train of CREVS was inoperable from September 22, 2013, through October 3, 2014, due to the 12 PLFF discharge damper failure in its partially open position. As a result, Exelon operated in a condition prohibited by TS for approximately 4 days. Exelon entered this issue into their CAP as CR-2013-007736. In accordance with IMC 0609.04, Initial Characterization of Findings, and IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings at Power, Exhibit 3, Barrier Integrity Screening Questions, the inspectors determined that this finding is of very low safety significance (Green) because the finding only represented a degradation of the radiological barrier function provided for the control room.

10 CFR 50, Appendix B, Criterion III, Design Control, requires, in part, Measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in §50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions. IEEE Standard 308, IEEE Standard for Class 1E Power Systems for Nuclear Power Generating Stations, Section 4.4, Design Basis, states, in part, The design basis shall include, as a minimum, the following:

(f) the malfunctions, accidents, environmental events, and operating modes (see Table 1) that could physically damage Class 1E power systems or lead to degradation of system performance and for which provisions shall be incorporated. Table 1 includes natural phenomena such as Wind, Hurricane, and Tornado. Contrary to the above, from 1996 until May 2013, a design vulnerability was identified which resulted in a degradation of 1A EDG under certain environmental conditions (Sustained high winds); however, Exelon failed to incorporate this vulnerability into the stations design basis documents and system operating instructions and make provisions to address this required design basis element. Exelon entered this issue into the CAP as CR 2012-000511 and CR 2013-004310, implemented appropriate compensatory actions, and implemented a permanent plant modification (ECP-13-000510) in the spring of 2014 to address this design vulnerability. The inspectors determined that the finding was of very low safety significance (Green) in accordance with IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, Question 1. Specifically, the finding is a deficiency affecting the design or qualification of a mitigating SSC, in which the SSC maintains its operability or functionality.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Exelon Personnel

G. Gellrich, Site Vice President

M. Flaherty, Plant General Manager

A. Ball, Supervisor, Radiation Protection Operations

T. Baummer, Engineering Team Lead

C. Birke, Safety Injection System Engineer

C. Blue, ALARA Supervisor

B. Brown, Senior Engineering Analyst, Engineering Systems

Laurel Cahill, Chemistry Analyst

F. Copsey, Mechanic-Nuclear, Maintenance Mechanical

H. Daman, Manager, Maintenance

J. Delgado, Service Water System Engineer

H. Enoch, Buried Piping Program Engineer

H. Enoch, Underground Piping & Tanks, Program Owner

B. Erdman, Supervisor, Radiation Protection

J. Gaines, General Supervisor, Shift Operations

J. Gines, Service Water System Engineer, 89-13 Program Manager

Gerald Helmrich, Chemistry Shift Technician

T. Hunkle, Engineer, Regulatory Compliance

P. Jones, Radiological Engineer

Patricia Jones, Senior Plant Health Physicist

Ed Kreahling, System Engineer

W. Lang, Component Cooling, Service Water Engineer

D. Lauver, Director, Licensing

M. Leno, Supervisor, Instrument & Calibration

Wes Mahaffey, Supervisor - Chemistry Operations

M. McMahon, Principal Analyst

David Merryman, Senior Environmental Specialist

Denise Mokshefski, Chemistry Technician

D. Moore, Boric Acid Program Manager

R. Nelson, Supervisor, BOP Systems

B. Pickett, Supervisor, Radiation Protection Support

Richard Szoch, General Supervisor - Chemistry

Ernest Thomas, Chemistry Technician

Ron Thomas, Supervisor - Chemistry Support

B. Wright, Intake Structures Engineer

Raymond Wright, Principal Chemistry Technician

J. Wynn, Principal Engineer, Engineering

J. York, General Supervisor, Radiation Protection

LIST OF ITEMS

Opened

05000317/318/2014003-01 URI Main Steam Line Drain Containment Isolation Valves not Scoped in IST (Section 1R04)

05000318/2014003-02 AV Inaccurate EAL Threshold Values Incorporated into Site EAL Scheme Change (Section 1R15.1)

Opened and Closed

05000317/318/2014003-03 NCV Inadequate EAL Initiating Condition HA3.1 (Section 1R15.2)

Closed

05000317/318/2013-001-00 LER Inoperable Control Room Ventilation Train Due to Broken Springs on Damper (Section 4OA3)

05000318/2013-005-00 LER Manufacturing Defect Results in Shutdown Due to Dropped CEA (Section 4OA3)

05000317/2014-002-00 LER Condition Prohibited by TS Due to Auxiliary Feedwater Train Inoperable Due to Human Performance Error (Section 4OA3)