IR 05000317/2006003: Difference between revisions
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{{Adams|number = ML062060024}} | {{Adams | ||
| number = ML062060024 | |||
| issue date = 07/21/2006 | |||
| title = IR 05000317-06-003 and IR 05000318-06-003 on 04/01/06-06/30/06 for Calvert Cliffs, Units 1 and 2; Surveillance Testing, Public Radiation Safety | |||
| author name = McDermott B J | |||
| author affiliation = NRC/RGN-I/DRP/PB1 | |||
| addressee name = Spina J A | |||
| addressee affiliation = Constellation Generation Group | |||
| docket = 05000317, 05000318 | |||
| license number = DPR-053, DPR-069 | |||
| contact person = | |||
| case reference number = FOIA/PA-2010-0209 | |||
| document report number = IR-06-003 | |||
| document type = Inspection Report, Letter | |||
| page count = 39 | |||
}} | |||
{{IR-Nav| site = 05000317 | year = 2006 | report number = 003 }} | {{IR-Nav| site = 05000317 | year = 2006 | report number = 003 }} | ||
| Line 7: | Line 22: | ||
[[Issue date::July 21, 2006]] | [[Issue date::July 21, 2006]] | ||
Mr. James A. Spina, Vice | Mr. James A. Spina, Vice President Calvert Cliffs Nuclear Power Plant, Inc. | ||
Constellation Generation Group, LLC | Constellation Generation Group, LLC | ||
SUBJECT: CALVERT CLIFFS NUCLEAR POWER PLANT - NRC | 1650 Calvert Cliffs Parkway | ||
Lusby, Maryland 20657-4702 | |||
SUBJECT: CALVERT CLIFFS NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000317/2006003 AND 05000318/2006003 | |||
==Dear Mr. Spina:== | ==Dear Mr. Spina:== | ||
On June 30, 2006, the US Nuclear Regulatory Commission (NRC) completed an inspection | On June 30, 2006, the US Nuclear Regulatory Commission (NRC) completed an inspection at your Calvert Cliffs Nuclear Power Plant Units 1 and 2. The enclosed inspection report | ||
documents the inspection results, which were discussed on July 12, 2006, with you and other | |||
Sincerely,/RA Samuel L. Hansell For/ Brian McDermott, Chief Projects Branch 1 Division of Reactor ProjectsDocket Nos.50-317, 50- | members of your staff. | ||
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. | |||
The inspectors reviewed selected procedures and records, observed activities, and interviewed | |||
personnel. | |||
This report documents two NRC-identified findings of very low safety significance (Green) that were determined to involve violations of NRC requirements. However, because of the very low | |||
safety significance and because these issues were entered into your corrective action program, the NRC is treating these violations as non-cited violations (NCVs) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest any NCV 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 the Calvert Cliffs Nuclear Power Plant. | |||
In accordance with 10 CFR 2.390 of the NRC's "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 Pub licly Available Records (PARS) component of 2 NRC's document 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 Samuel L. Hansell For/ | |||
Brian McDermott, Chief Projects Branch 1 | |||
Division of Reactor ProjectsDocket Nos.50-317, 50-318 License Nos. DPR-53, DPR-69 | |||
===Enclosure:=== | ===Enclosure:=== | ||
Inspection Report 05000317/2006003 and 05000318/2006003 | Inspection Report 05000317/2006003 and 05000318/2006003 | ||
===w/Attachment:=== | ===w/Attachment:=== | ||
Supplemental Information | Supplemental Information 3 cc w/encl: | ||
M. J. Wallace, President, Constellation Generation | |||
B. McDermott, DRP A. Burritt, DRP J. Giessner, DRP, Senior Resident Inspector (Acting) | |||
M. Davis, Resident Inspector C. Newgent - Resident OA ROP Reports Region I Docket Room (with concurrences)SUNSI Review Complete: SLH (Reviewer's Initials)DOCUMENT NAME: C:\MyFiles\Copies\CC IR 2006-003. | J. M. Heffley, Senior Vice President and Chief Nuclear Officer | ||
President, Calvert County Board of Commissioners | |||
C. W. Fleming, Senior Counsel, Constellation Generation Group, LLC | |||
Director, Nuclear Regulatory Matters | |||
R. McLean, Manager, Nuclear Programs | |||
K. Burger, Esquire, Maryland People's Counsel | |||
State of Maryland (2) | |||
4 Distribution w/encl: | |||
S. Collins, RA | |||
M. Dapas, DRA | |||
B. Sosa, RI OEDO | |||
R. Laufer, NRR | |||
P. Milano, PM, NRR | |||
R. Guzman, PM, NRR (Backup) | |||
B. McDermott, DRP | |||
A. Burritt, DRP | |||
J. Giessner, DRP, Senior Resident Inspector (Acting) | |||
M. Davis, Resident Inspector | |||
C. Newgent - Resident OA | |||
ROP Reports | |||
Region I Docket Room (with concurrences)SUNSI Review Complete: SLH (Reviewer's Initials | |||
)DOCUMENT NAME: C:\MyFiles\Copies\CC IR 2006-003.wpd After declaring this document "An Official Agency Record" it will be released to the Public.To receive a copy of this document, indicate in the box: | |||
" C" = Copy without attachment/enclosure " E" = Copy with attachment/enclosure " N" = No copyOFFICERI/DRPRI/DRPRI/DRPNAMEABurrittMDavis/SLH FORBMcDermott/SLH FORDATE07/21 /0607/21/0607/ 21 /06 OFFICIAL RECORD COPY Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION I Docket Nos.50-317, 50-318License Nos.DPR-53, DPR-69 Report Nos.05000317/2006003 and 05000318/2006003 Licensee:Constellation Generation Group, LLC Facility:Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Location:Lusby, MD Dates:April 1, 2006 through June 30, 2006 Inspectors:Mark A. Giles, Senior Resident Inspector Marlone Davis, Resident Inspector | |||
John R. McFadden, Health Physicist | |||
Nancy T. McNamara, EP Inspector | |||
Anne DeFrancisco, Reactor Inspector | |||
Jennifer Bobiak, Reactor InspectorApproved by:Brian McDermott, Chief Projects Branch 1 | |||
Division of Reactor Projects ii Enclosure | |||
=SUMMARY OF FINDINGS= | =SUMMARY OF FINDINGS= | ||
... | IR 05000317/2006-003, 05000318/2006-003; 04/01/06 - 06/30/06; Calvert Cliffs Nuclear Power | ||
Plant, Units 1 and 2; Surveillance Testing, Public Radiation Safety. | |||
The report covered a three-month period of inspection by resident inspectors and announced inspections performed by reactor and emergency preparedness inspectors and a health physicist. The inspection identified two Green findings which were determined to be non-cited violations (NCVs). The significance of most findings is indicated by their color (Green, White, | |||
Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination | |||
Process" (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor | |||
Oversight Process," Revision 3, dated July 2000.A. | |||
===NRC-Identified and Self-Revealing Findings=== | |||
===Cornerstone: Mitigating System=== | |||
: '''Green.''' | |||
The inspectors identified a non-cited violation of 10 CFR 50.55a, Codes and Standards, because Constellation did not establish new reference values or reconfirm the previous reference values following maintenance that affected hydraulic or mechanical parameters on the auxiliary feedwater (AFW) and emergency core cooling system (ECCS)pumps as required by the American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) | |||
Code for inservice testing. Constellation entered this issue into their corrective action program as IRE-014-764. The planned corrective action include a review of maintenance and IST data to determine whether new reference values are needed or reconfirm existing reference values for the AFW and ECCS pumps. | |||
This finding is more than minor because the same issue affected a number of safety-related pumps tested, the issue was repetitive and if left uncorrected the finding could become a more significant safety concern. The finding has a very low safety significance because the condition did not result in an actual failure of the AFW and ECCS pumps or result in systems being declared inoperable for greater than their allowed Technical Specification outage time. A contributing cause of the finding is related to the cross-cutting aspect in the area of problem identification and resolution (PI&R) because Constellation did not periodically trend and assess information to identify programmatic and common cause problems. (Section 1R22) | |||
== | ===Cornerstone: Public Radiation Safety=== | ||
...... | : '''Green.''' | ||
The inspectors identified a non-cited violation of 10 CFR 20.1501 for failure to make surveys of the radioactivity in a "sink hole" to assure compliance with 10 CFR 20.1301(a)(1) regarding the total effective dose equivalent limit for individual members of the public from licensed operations, specifically regarding assessing dose for batch releases of liquid radioactive waste and assessing iv annual dose. Constellation entered this issue into their corrective action program as IRE-010-005. Constellation created a detailed action plan for this issue to find the leaking component, fix the leaking component, determine the extent of contamination, map the plume, and evaluate the need for remediation. | |||
This violation is more than minor because it is associated with the cornerstone attribute of maintaining a program and process to estimate offsite dose due to abnormal releases and to record and report on such releases and because it affected the Radiation Safety/Public Radiation Safety Cornerstone's objective to ensure the adequate protection of public health and safety from exposure to radioactive materials released into the public domain. The violation is of very low significance because, while it did impair Constellation's ability to assess the timing of dose consequence and the accuracy of the batch and annual effluent release dose records and reports due to the large difference in transit times for the permitted and non-permitted discharge pathways to the bay, Constellation did account for all released radioactivity and did assess the cumulative doses from their effluent releases. Additionally, the unanalyzed non-permitted pathway (i.e., | |||
via groundwater to the bay) did not impact private property, and the assessed doses did not exceed the dose values in Appendix I to 10 CFR 50. (Section 4OA2.4) | |||
===B.Licensee-Identified Violations=== | |||
== | |||
None | |||
== | =REPORT DETAILS= | ||
== | ===Summary of Plant Status=== | ||
Unit 1 began the inspection period in a refueling outage. On April 14, 2006, the unit returned to full power operation (100 percent) and remained unchanged throughout the inspection period. | |||
Unit 2 began the inspection period at 100 percent reactor power and remained unchanged until May 20 when power was reduced to 85 percent for main turbine control valve testing. Following | |||
the completion of the test the unit was restored to 100 percent power and remained there the | the completion of the test the unit was restored to 100 percent power and remained there the | ||
rest of the inspection period.1.REACTOR | |||
rest of the inspection period.1.REACTOR SAFETY Cornerstone: Initiating Events, Mitigating Systems, Barrier Integrity1R04Equipment Alignment (71111.04Q - 5 samples) | |||
Partial Walkdown | |||
====a. Inspection Scope==== | |||
The inspectors verified that selected equipment trains of safety-related and risk significant systems were properly aligned. The inspectors reviewed plant documents to | |||
determine the correct system and power alignments, as well as the required positions of | determine the correct system and power alignments, as well as the required positions of | ||
critical valves and breakers. The inspectors verified that Constellation had properly | critical valves and breakers. The inspectors verified that Constellation had properly | ||
identified and resolved equipment alignment | |||
identified and resolved equipment alignment pr oblems that could cause initiating events or potentially impact the availability of associated mitigating systems. The applicable | |||
documents used for this inspection are located in the Attachment. The inspectors | documents used for this inspection are located in the Attachment. The inspectors | ||
performed a partial walkdown for the following activities.*13.8kV during internal inspection and testing of the 2H2103 voltage regulator*1B emergency diesel generator (EDG) walkdown during maintenance on the | |||
performed a partial walkdown for the following activities.*13.8kV during internal inspection and testing of the 2H2103 voltage regulator*1B emergency diesel generator (EDG) walkdown during maintenance on the 1A EDG*4.16kV service transformers during the transfer of the 4kV unit busses from their normal to alternate supply*Unit 1 service water (SRW) system equipment alignment walkdown during maintenance on the13 SRW pump breaker*21 vital 125 Vdc bus being attached and removed from the 125 Vdc reserve battery | |||
SRW) system equipment alignment walkdown | |||
====b. Findings==== | |||
No findings of significance were identified. | |||
2 Enclosure1R05Fire Protection (71111.05Q - 10 samples) | |||
Fire Protection - Tours | |||
====a. Inspection Scope==== | |||
The inspectors conducted a tour of accessible portions of the ten areas listed below to assess Constellation's control of transient combustible material and ignition sources, fire | |||
detection and suppression capabilities, fire barriers, and related compensatory | detection and suppression capabilities, fire barriers, and related compensatory | ||
measures when required. The inspectors assessed the material condition of fire | measures when required. The inspectors assessed the material condition of fire | ||
protection suppression and detection equipment to determine whether any conditions or | protection suppression and detection equipment to determine whether any conditions or | ||
deficiencies existed which could impair the availability of that equipment. The inspectors | deficiencies existed which could impair the availability of that equipment. The inspectors | ||
also reviewed administrative procedure SA-1-100, Fire Fighting, and the Fire Fighting | also reviewed administrative procedure SA-1-100, Fire Fighting, and the Fire Fighting | ||
Strategies Manual were referenced for this inspection activity. The ten areas are as | Strategies Manual were referenced for this inspection activity. The ten areas are as | ||
follows:*Unit 1 main steam isolation valve room*Unit 2 main steam isolation valve room | follows:*Unit 1 main steam isolation valve room*Unit 2 main steam isolation valve room | ||
*Unit 1 cable spreading room | *Unit 1 cable spreading room | ||
| Line 146: | Line 213: | ||
*Unit 2 turbine building basement | *Unit 2 turbine building basement | ||
*Unit 1 intake structure (inside) | *Unit 1 intake structure (inside) | ||
*Unit 2 intake structure (inside) | *Unit 2 intake structure (inside) | ||
Individual Plant Examination (IPE) report and the Updated Final Safety Analysis Report | |||
(UFSAR). The inspectors performed a walkdown of the Unit 1 and Unit 2 service water | ====b. Findings==== | ||
pumps rooms (rooms 226 and 205) which | No findings of significance were identified. | ||
{{a|1R06}} | |||
==1R06 Flood Protection== | |||
(71111.06 - 2 internal flooding samples) | |||
====a. Inspection Scope==== | |||
The inspectors reviewed flood protection measures associated with internal flood events. | |||
These events were described in the Calvert Cliffs' Engineering Standard on flooding, the | |||
Individual Plant Examination (IPE) report and the Updated Final Safety Analysis Report (UFSAR). The inspectors performed a walkdown of the Unit 1 and Unit 2 service water | |||
pumps rooms (rooms 226 and 205) which c ontain risk significant systems and components. The inspectors observed the condition of watertight doors, drain systems | |||
and sumps, penetrations in floors and walls, and safety related instrumentation located | and sumps, penetrations in floors and walls, and safety related instrumentation located | ||
in these areas. In addition, the inspector reviewed operating procedures and related | in these areas. In addition, the inspector reviewed operating procedures and related | ||
internal flooding industry operating experience (OE). | internal flooding industry operating experience (OE). | ||
====b. Findings==== | |||
No findings of significance were identified. | |||
{{a|1R11}} | |||
==1R11 Licensed Operator Requalification Program== | |||
(71111.11Q - 1 sample) | |||
====a. Inspection Scope==== | |||
The inspectors observed a licensed operator simulator training scenario conducted on May 18, 2006, in order to assess operator performance and the adequacy of licensed | |||
operators training program. The training scenario involved a condensate header rupture | operators training program. The training scenario involved a condensate header rupture | ||
that resulted in a loss of main feed event causing the operators to perform a manual | that resulted in a loss of main feed event causing the operators to perform a manual | ||
reactor trip. Following the trip, equipment failures occurred ultimately resulting in a loss | reactor trip. Following the trip, equipment failures occurred ultimately resulting in a loss | ||
of all feedwater. During this inspection, the inspectors focused on high-risk operator | of all feedwater. During this inspection, the inspectors focused on high-risk operator | ||
actions performed during implementation of the abnormal and emergency operating | actions performed during implementation of the abnormal and emergency operating | ||
procedures, emergency plan (EP) implementation, and classification of the event. | procedures, emergency plan (EP) implementation, and classification of the event. | ||
The inspectors evaluated the clarity and formality of communications, the | The inspectors evaluated the clarity and formality of communications, the | ||
implementation of appropriate actions in response to alarms, the performance of timely | implementation of appropriate actions in response to alarms, the performance of timely | ||
control board operations and manipulations, and the oversight and direction provided by | control board operations and manipulations, and the oversight and direction provided by | ||
the shift supervisor. The inspectors also reviewed simulator fidelity to evaluate the | the shift supervisor. The inspectors also reviewed simulator fidelity to evaluate the | ||
degree of similarity to the actual control room, especially regarding recent control board | degree of similarity to the actual control room, especially regarding recent control board | ||
modifications. b. | |||
modifications. | |||
====b. Findings==== | |||
No findings of significance were identified. | |||
{{a|1R12}} | |||
==1R12 Maintenance Effectiveness== | |||
Quarterly Review (71111.12Q - 2 samples) | |||
====a. Inspection Scope==== | |||
The inspectors reviewed Constellation effectiveness in performing routine maintenance activities. This review included an assessment of Constellation's practices pertaining to | |||
the identification, scoping, and handling of degraded equipment conditions, as well as | the identification, scoping, and handling of degraded equipment conditions, as well as | ||
common cause failure evaluations, and the resolution of historical equipment problems. | common cause failure evaluations, and the resolution of historical equipment problems. | ||
For those systems, structures, and components (SSC) scoped in the maintenance rule | For those systems, structures, and components (SSC) scoped in the maintenance rule | ||
per 10 CFR 50.65, the inspectors verified that reliability and unavailability were properly | per 10 CFR 50.65, the inspectors verified that reliability and unavailability were properly | ||
monitored and that 10 CFR 50.65 (a)(1) and (a)(2) classifications were justified in light of | monitored and that 10 CFR 50.65 (a)(1) and (a)(2) classifications were justified in light of | ||
the reviewed degraded equipment condition. The inspectors conducted this inspection | the reviewed degraded equipment condition. The inspectors conducted this inspection | ||
for the following equipment issues:*Unit 1 auxiliary feedwater isolation control valves | |||
for the following equipment issues:*Unit 1 auxiliary feedwater isolation control valves CV-4511 and CV-4512*11 condensate storage tank (CST) rupture valve | |||
CV-4512*11 condensate storage tank (CST) rupture valve | |||
====b. Findings==== | |||
No findings of significance were identified. | |||
{{a|1R13}} | |||
==1R13 Maintenance Risk Assessments and Emergent Work Control== | |||
(71111.13 - 8 samples) | |||
====a. Inspection Scope==== | |||
The inspectors reviewed Constellation's assessments concerning the risk impact of removing from service those components associated with the work items listed below. | |||
This review primarily focused on activities determined to be risk significant within the | This review primarily focused on activities determined to be risk significant within the | ||
maintenance rule. The inspectors compared the risk assessments and risk | maintenance rule. The inspectors compared the risk assessments and risk | ||
management actions performed by station procedure NO-1-117, "Integrated Risk | management actions performed by station procedure NO-1-117, "Integrated Risk | ||
Management," to the requirements of | |||
Management," to the requirements of 10 CFR 50.65(a)(4), the recommendations of | |||
NUMARC 93-01, Revision 2, "Industry Guideline for Monitoring the Effectiveness of | |||
Maintenance at Nuclear Power Plants," and approved station procedures. | Maintenance at Nuclear Power Plants," and approved station procedures. | ||
The inspectors compared the assessed risk configuration to actual plant conditions to | The inspectors compared the assessed risk configuration to actual plant conditions to | ||
evaluate whether the assessment was accurate and comprehensive. In addition, the | evaluate whether the assessment was accurate and comprehensive. In addition, the | ||
inspectors assessed the adequacy of Constellation's identification and resolution of | inspectors assessed the adequacy of Constellation's identification and resolution of | ||
problems associated with maintenance risk assessments and emergent work activities. | problems associated with maintenance risk assessments and emergent work activities. | ||
The inspectors reviewed the following selected work activities:*11A service water basket strainer cleaning*12 containment air cooler repair (reverse flow in fast speed) | The inspectors reviewed the following selected work activities:*11A service water basket strainer cleaning*12 containment air cooler repair (reverse flow in fast speed) | ||
*21 vital 125 Vdc bus being attached and removed from the 125 Vdc | *21 vital 125 Vdc bus being attached and removed from the 125 Vdc reserve battery*13.8kV during internal inspection and testing of the 2H2103 voltage regulator | ||
*1A emergency diesel generator for planned maintenance | *1A emergency diesel generator for planned maintenance | ||
*22 switchgear Heating Ventilation and Air Conditioning (HVAC) inspection | *22 switchgear Heating Ventilation and Air Conditioning (HVAC) inspection and lubrication*23 auxiliary feedwater pump maintenance to replace the breaker hand switch | ||
*11 and 14 4kV busses during maintenance on the 14 4kV bus normal | *11 and 14 4kV busses during maintenance on the 14 4kV bus normal feeder breaker | ||
physics testing. On April 8, 2006, at | ====b. Findings==== | ||
No findings of significance were identified. | |||
5 Enclosure1R14Operator Performance During Non-Routine Plant Evolutions and Events (71111.14 - 2 samples) | |||
====a. Inspection Scope==== | |||
Untrippable Control Element Assembly The inspectors assessed operator performance associated with a Unit 1 event that involved a misaligned control element assembly (CEA) while performing low power | |||
physics testing. On April 8, 2006, at appr oximately 6:35 p.m., control room operators (CRO) began to insert regulating group 2 after testing groups 5, 4 and 3 with no position | |||
anomalies. When regulating group 2 was inserted, the operators received a deviation | anomalies. When regulating group 2 was inserted, the operators received a deviation | ||
alarm in the control room. The alarm was due to regulating group 2, CEA #21, stopping | alarm in the control room. The alarm was due to regulating group 2, CEA #21, stopping | ||
and being misaligned with the other CEA's in that group, which was greater than the | and being misaligned with the other CEA's in that group, which was greater than the | ||
allowable technical specification deviation. At approximately 6:45 p.m., the Unit | |||
allowable technical specification deviation. At approximately 6:45 p.m., the Unit 1 CRO | |||
CEA Malfunction, to establish | entered the Abnormal Operating Procedure AOP-1B, CEA Malfunction, to establish | ||
group realignment and maintain reactivity control. A troubleshooting plan was | |||
group realignment and maintain reactivity control. | |||
A troubleshooting plan was | |||
developed and further reactivity controls were performed through dilution and boration of | developed and further reactivity controls were performed through dilution and boration of | ||
the reactor coolant while the investigation of the misaligned CEA continued. However, | |||
the CEA did not respond to initial insertion signal and the electrical traces taken on the | the reactor coolant while the investigation of the misaligned CEA continued. However, the CEA did not respond to initial insertion signal and the electrical traces taken on the | ||
drive mechanism during insertion attempts indicated abnormal responses to the lower | drive mechanism during insertion attempts indicated abnormal responses to the lower | ||
and upper gripper coil. This prompted the operators to declare CEA #21 untrippable. | and upper gripper coil. This prompted the operators to declare CEA #21 untrippable. | ||
At 10:45 p.m., the operators exited low | |||
At 10:45 p.m., the operators exited low pow er physics testing and then manually tripped the reactor. Although CEA #21 did not insert, the rest of the rods did insert to provide | |||
adequate shutdown margin. On April 09, 2006, at approximately 1:20 a.m., Unit 1 was | adequate shutdown margin. On April 09, 2006, at approximately 1:20 a.m., Unit 1 was | ||
in Mode 3 and the operators had exited AOP-1B.The inspectors assessed the plant response and conditions specific to the event | |||
in Mode 3 and the operators had exited AOP-1B. | |||
The inspectors assessed the plant response and conditions specific to the event and evaluated the performance of licensed operators. The inspectors also reviewed control | |||
room procedures and operator logs to determine if operators performed the appropriate | room procedures and operator logs to determine if operators performed the appropriate | ||
actions in accordance with their training and established station procedures.Unit 1 Main Turbine Control Valve | |||
actions in accordance with their training and established station procedures. | |||
Unit 1 Main Turbine Control Valve Oscillations The inspectors assessed operator performance associated with a Unit 1 main turbine startup after the installation of a new turbine control system. On April 11, 2006, at 2:30 | |||
a.m., Unit 1 main turbine control valves experienced high frequency valve oscillations | a.m., Unit 1 main turbine control valves experienced high frequency valve oscillations | ||
when the turbine reached 1800 revolutions per minute. The rapid cycling of the control | when the turbine reached 1800 revolutions per minute. The rapid cycling of the control | ||
valves created excessive vibrations in the Electro Hydraulic Control (EHC) piping | valves created excessive vibrations in the Electro Hydraulic Control (EHC) piping | ||
system. This excessive vibration was reported to the control room and the operators | system. This excessive vibration was reported to the control room and the operators | ||
immediately tripped and secured the main turbine. When the main turbine was tripped, | |||
the vibration of the EHC piping stopped.The inspectors assessed the plant response and conditions specific to the event, | immediately tripped and secured the main turbine. | ||
When the main turbine was tripped, the vibration of the EHC piping stopped. | |||
The inspectors assessed the plant response and conditions specific to the event, and evaluated the performance of licensed operators. The inspectors also reviewed control | |||
room procedures and operator logs to determine if operators performed the appropriate | room procedures and operator logs to determine if operators performed the appropriate | ||
actions in accordance with their training and established station procedures. | actions in accordance with their training and established station procedures. | ||
====b. Findings==== | |||
No findings of significance were identified. | |||
{{a|1R15}} | |||
==1R15 Operability Evaluations== | |||
(71111.15 - 6 samples) | |||
====a. Inspection Scope==== | |||
The inspectors reviewed six operability determinations to verify that the operability of systems important to safety were proper ly established and that affected components or systems remained capable of performing their intended safety function. The inspectors | |||
reviewed the selected operability determinations to verify they were performed in | reviewed the selected operability determinations to verify they were performed in | ||
accordance with NO-1-106, "Functional Evaluation - Operability Determination," and | accordance with NO-1-106, "Functional Evaluation - Operability Determination," and | ||
QL-2-100, "Issue Reporting and Assessment." The following operability evaluations were | QL-2-100, "Issue Reporting and Assessment." The following operability evaluations were | ||
reviewed:*12 containment air cooler repair (reverse flow in fast speed)*11, 12, and 13 high pressure safety injection pumps | reviewed:*12 containment air cooler repair (reverse flow in fast speed)*11, 12, and 13 high pressure safety injection pumps | ||
*12 containment spray pump overhaul following pump bearing failure | *12 containment spray pump overhaul following pump bearing failure | ||
*#21 control element assembly testing | *#21 control element assembly testing | ||
*#8 control element assembly testing | *#8 control element assembly testing | ||
*12 component cooling water heat exchanger due to saltwater pin hole leak | *12 component cooling water heat exchanger due to saltwater pin hole leak on temperature probe | ||
====b. Findings==== | |||
No findings of significance were identified1R19Post-Maintenance Testing (71111.19 - 9 samples) | |||
====a. Inspection Scope==== | |||
The inspectors observed and/or reviewed post-maintenance tests associated with the following nine work activities to verify that equipment was properly returned to service | |||
and that appropriate testing was specified and conducted to ensure that the equipment | and that appropriate testing was specified and conducted to ensure that the equipment | ||
was operable and could perform its intended safety function following the completion of | was operable and could perform its intended safety function following the completion of | ||
maintenance. Post-maintenance testing activities were conducted as specified in station | maintenance. Post-maintenance testing activities were conducted as specified in station | ||
procedure MN-1-101, "Control Of Maintenance Activities." Post-maintenance test results | procedure MN-1-101, "Control Of Maintenance Activities." Post-maintenance test results | ||
associated with the maintenance activities listed below were reviewed.*12 containment air cooler repair (reverse flow in fast speed)*12 auxiliary feedwater pump | associated with the maintenance activities listed below were reviewed.*12 containment air cooler repair (reverse flow in fast speed)*12 auxiliary feedwater pump | ||
*#21 control element assembly testing | *#21 control element assembly testing | ||
*Unit 2 main steam safety valve lift settings test | *Unit 2 main steam safety valve lift settings test | ||
*13.8kV during internal inspection and testing of the 2H2103 voltage regulator | *13.8kV during internal inspection and testing of the 2H2103 voltage regulator 7 Enclosure*1A emergency diesel generator for after planned maintenance*Unit 2 containment isolation valves | ||
*22 switchgear hvac inspection and lubrication | *22 switchgear hvac inspection and lubrication | ||
*23 auxiliary feedwater pump | *23 auxiliary feedwater pump | ||
b. | |||
====b. Findings==== | |||
TS compliance and that test | No findings of significance were identified. | ||
{{a|1R22}} | |||
==1R22 Surveillance Testing== | |||
(71111.22 - 9 samples) | |||
====a. Inspection Scope==== | |||
The inspectors observed and/or reviewed the nine surveillance tests listed below associated with selected risk-significant SSCs to verify TS compliance and that test | |||
acceptance criteria was properly specified. The inspectors also verified that proper test | acceptance criteria was properly specified. The inspectors also verified that proper test | ||
conditions were established as specified in the procedures, no equipment | conditions were established as specified in the procedures, no equipment | ||
preconditioning activities occurred, and that acceptance criteria had been satisfied.*STP O-8A-1, Test Of 1A | |||
preconditioning activities occurred, and that acceptance criteria had been satisfied.*STP O-8A-1, Test Of 1A DG and 11 4KV bus LOCI sequencer*STP O-073G-1, HPSI Pump Large Flow Test | |||
*STP O-073L-1, LPSI Pump Large Flow Test | |||
*STP O-073L-1, | |||
*STP O-073M-1, Containment Spray Flow Test | *STP O-073M-1, Containment Spray Flow Test | ||
*STP O-029-1, Monthly CEA Partial Movement | *STP O-029-1, Monthly CEA Partial Movement | ||
*STP -662-1, Integrated Leak Rate Test Unit 1 Containment | *STP -662-1, Integrated Leak Rate Test Unit 1 Containment | ||
*STP O-5A-1, Auxiliary Feedwater | *STP O-5A-1, Auxiliary Feedwater Sy stem Quarterly Surveillance Test*STP O-035-2, Safety Injection Tank Outlet Isolation Valve Test | ||
*STP M-3A-0, On line main steam safety valve testing | *STP M-3A-0, On line main steam safety valve testing | ||
====b. Findings==== | |||
=====Introduction.===== | |||
The inspectors identified a non-cited violation of 10 CFR 50.55a, Codes and Standards, because Constellation did not establish new reference values or | |||
reconfirm the previous reference values following maintenance that affected hydraulic or | reconfirm the previous reference values following maintenance that affected hydraulic or | ||
mechanical parameters on the | |||
mechanical parameters on the AFW and emergency core cooling pumps. | |||
=====Description.===== | |||
ECCS pumps in accordance with the 1995 | In May of 2002, the NRC granted Constellation a relief request (PR-12) to perform the inservice testing of the AFW and ECCS pumps in accordance with the 1995 | ||
Edition of the American Society of Mechanical Engineers (ASME) Code through the | Edition of the American Society of Mechanical Engineers (ASME) Code through the | ||
1996 Addenda of the | |||
1996 Addenda of the ASME Operation and Maintenance (OM) Code. The ASME OM | |||
Code, Subsection ISTB, requires, in part, that when a reference value or set of reference | |||
values that may have been affected by repair, replacement, or routine servicing of a | values that may have been affected by repair, replacement, or routine servicing of a | ||
pump, a new reference value or set of values shall be determined or previous values | pump, a new reference value or set of values shall be determined or previous values | ||
reconfirmed by an inservice test run before declaring the pump operable. | reconfirmed by an inservice test run before declaring the pump operable. | ||
8 Enclosure The inspectors identified maintenance activities that would have affected the hydraulic or mechanical characteristics of the AFW and ECCS pumps. However, no new reference | |||
ECCS pumps. However, no new reference | |||
values were established or the previous values reconfirmed before declaring the pumps | values were established or the previous values reconfirmed before declaring the pumps | ||
operable. For example, the 12 containment spray (CS) pump was overhauled in May of | operable. For example, the 12 containment spray (CS) pump was overhauled in May of | ||
2002 and March of 2006 with maintenance activities that affected the hydraulic (larger | 2002 and March of 2006 with maintenance activities that affected the hydraulic (larger | ||
impeller) and mechanical (thrust bearing) parameters respectively. Subsequent testing | impeller) and mechanical (thrust bearing) parameters respectively. Subsequent testing | ||
performed for the 12 CS pump did not establish new reference values or validate | performed for the 12 CS pump did not establish new reference values or validate | ||
existing values; therefore, Constellation could not demonstrate that the pump | existing values; therefore, Constellation could not demonstrate that the pump | ||
performance curve or the mechanical parameters did not change following maintenance | performance curve or the mechanical parameters did not change following maintenance | ||
activities. Furthermore, a number of the | |||
activities. Furthermore, a number of the ECCS pumps have exceeded inservice testing (IST) acceptance criteria for their surveillance test procedure. This could be contributed | |||
IST) acceptance criteria for their surveillance test procedure. This could be contributed | |||
to the fact that new reference values were not established or the existing values | to the fact that new reference values were not established or the existing values | ||
reconfirmed after maintenance that affected the hydraulic or mechanical parameters for | reconfirmed after maintenance that affected the hydraulic or mechanical parameters for | ||
their | |||
their IST reference values. | |||
IRE-014-764. Additionally, to assess the extent of condition, Constellation conducted a more detailed | |||
review of the maintenance performed prior to May 2002 on all the | Constellation entered this issue into their corrective action program as IRE-014-764. | ||
Additionally, to assess the extent of condition, Constellation conducted a more detailed | |||
review of the maintenance performed prior to May 2002 on all the AFW and ECCS | |||
pumps. This review will determine whether or not the maintenance activities performed | pumps. This review will determine whether or not the maintenance activities performed | ||
required a new reference value to be developed or if the existing values were valid. Analysis. The inspectors concluded that a performance deficiency existed | |||
required a new reference value to be developed or if the existing values were valid. | |||
=====Analysis.===== | |||
The inspectors concluded that a performance deficiency existed because Constellation did not establish new reference values or reconfirm the previous reference | |||
values following maintenance that affected hydraulic or mechanical parameters on the | values following maintenance that affected hydraulic or mechanical parameters on the | ||
ECCS pumps. The finding is more than minor because the same issue | AFW and ECCS pumps. The finding is more than minor because the same issue | ||
affected a number of pumps tested, the issue was repetitive and if left uncorrected | |||
affected a number of pumps tested, the issue was repetitive and if left uncorrected the finding could become a more significant safety concern due to the potential to not detect pump degradation which could impact pump operability. This finding has a very low safety significance because the conditions did not result in an actual failure of the AFW | |||
and ECCS pumps or result in systems being declared inoperable for greater than their | |||
allowed Technical Specification outage time. The planned corrective actions included a | allowed Technical Specification outage time. The planned corrective actions included a | ||
review of maintenance and IST data to determine whether new reference values are | review of maintenance and IST data to determine whether new reference values are | ||
needed or if there is a need to reconfirm existing reference values for the | |||
needed or if there is a need to reconfirm existing reference values for the AFW and | |||
ECCS pumps. The inspectors identified that a contributing cause of this finding was | |||
related to the cross-cutting aspect of PI&R because Constellation did not periodically | related to the cross-cutting aspect of PI&R because Constellation did not periodically | ||
trend and assess information to identify programmatic and common cause problems.Enforcement. Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a,Codes and Standards, requires, in part, that testing of safety related pumps meet the | |||
requirements of the | trend and assess information to identify programmatic and common cause problems. | ||
=====Enforcement.===== | |||
Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a, Codes and Standards, requires, in part, that testing of safety related pumps meet the | |||
ISTB, states that | |||
requirements of the ASME OM Code. The ASME Code, Subsection ISTB, states that | |||
when a reference value or set of reference values that may have been affected by | when a reference value or set of reference values that may have been affected by | ||
repair, replacement, or routine servicing of a pump, a new reference value or set of | repair, replacement, or routine servicing of a pump, a new reference value or set of | ||
values shall be determined or previous values reconfirmed by an inservice test run | values shall be determined or previous values reconfirmed by an inservice test run | ||
before declaring the pump operable. Contrary to the above, Constellation did not | before declaring the pump operable. Contrary to the above, Constellation did not | ||
establish new vibration or hydraulic reference values or reconfirm the previous values | establish new vibration or hydraulic reference values or reconfirm the previous values | ||
were acceptable following maintenance that affected the reference values of the | |||
were acceptable following maintenance that affected the reference values of the AFW | |||
and ECCS pumps. This violation is documented in Constellation's corrective action 9 Enclosure program as IRE-014-764 and is being treated as a non-cited violation consistent with Section VI.A.1 of the NRC Enforcement Policy: | |||
NCV 05000317 and 318/2006003-01, Failure to establish appropriate reference values or reconfirm previous values for AFW and ECCS pumps. | |||
===Cornerstone:=== | |||
Emergency Preparedness (EP)1EP4Emergency Action Level and Emergency Plan (E-Plan) Changes (71114.04 - 1 sample) | |||
====a. Inspection Scope==== | |||
During the period of September 2005 - February 2006, the NRC received changes made to Constellation Nuclear's E-Plan in accordance with 10 CFR 50.54(q). Constellation | |||
CFR 50.54(q). Constellation | |||
Nuclear determined the changes did not decrease the effectiveness of the E-Plan and | Nuclear determined the changes did not decrease the effectiveness of the E-Plan and | ||
also that the E-Plan continued to meet the requirements of 10 CFR 50.47(b) and | also that the E-Plan continued to meet the requirements of 10 CFR 50.47(b) and | ||
Appendix E to 10 CFR Part 50. A selected sample of E-Plan changes were reviewed in- | Appendix E to 10 CFR Part 50. A selected sample of E-Plan changes were reviewed in- | ||
office by the inspector. This review does not constitute approval of the changes and, as | office by the inspector. This review does not constitute approval of the changes and, as | ||
such, the changes and the associated | |||
such, the changes and the associated 10 CFR 50.54(q) reviews are subject to future | |||
NRC Inspection | NRC inspection. The inspection was conducted in accordance with NRC Inspection | ||
Procedure 71114, Attachment 4. b. | |||
preparedness. This training exercise focused on equipment failures and operator | Procedure 71114, Attachment 4. | ||
challenges that would typically exist | |||
associated event classification was observed and evaluated by the inspectors. b. | ====b. Findings==== | ||
No findings of significance were identified. 1EP6Drill Evaluation (71114.06 - 1 sample ) | |||
Simulator Exercises | |||
OS)2OS1Access Control to Radiologically Significant Areas (71121.01 - 7 samples) | |||
records, and other program documents to | ====a. Inspection Scope==== | ||
completion of seven (7) samples relative to this inspection area | The inspectors observed control room simulator training exercises conducted on May 18, 2006, to assess licensed operators' performance in the area of emergency | ||
partially fulfills the annual inspection requirements.Plant Walk Downs and | preparedness. This training exercise focused on equipment failures and operator | ||
RWPs) for airborne radioactivity | challenges that would typically exist dur ing an anticipated transient without scram (ATWS) and total loss of feedwater event. The required procedural transitions and | ||
associated event classification was observed and evaluated by the inspectors. | |||
====b. Findings==== | |||
No findings of significance were identified. | |||
10 Enclosure2.RADIATION SAFETYCornerstone: Occupational Radiation Safety (OS)2OS1Access Control to Radiologically Significant Areas (71121.01 - 7 samples) | |||
====a. Inspection Scope==== | |||
The inspector reviewed radiological work activities and practices and procedural implementation during observations and tours of the facilities and inspected procedures, records, and other program documents to ev aluate the effectiveness of Constellation's access controls to radiologically significant areas. This inspection activity represents the | |||
completion of seven | |||
: (7) samples relative to this inspection area (i.e., inspection procedure sections 02.02.d thru f, 02.03.a, and 02.05.a thru c) and | |||
partially fulfills the annual inspection requirements. | |||
Plant Walk Downs and RWP Reviews (02.02.d, e, and f) | |||
During this inspection and the previous 2006 inspection during the Unit 1 refueling outage the inspector reviewed radiation work permits (RWPs) for airborne radioactivity | |||
areas with the potential for individual worker internal exposures of greater than | areas with the potential for individual worker internal exposures of greater than | ||
millirems Committed Effective Dose Equivalent (CEDE). For these selected | |||
airborne radioactive material areas the inspector examined the performance of controls, | 50 millirems Committed Effective Dose Equivalent (CEDE). For these selected | ||
such as use of containments, ventilation | |||
radioactive material since the last inspection. The inspector reviewed and assessed the | airborne radioactive material areas the inspector examined the performance of controls, such as use of containments, ventilation sy stems, and procedural processes. Also, the inspector discussed with radiation protection personnel their experience with uptakes of | ||
adequacy of Constellation's internal dose assessment for the highest actual internal | |||
exposure which was less than 50 millirems | radioactive material since the last inspection. The inspector reviewed and assessed the | ||
adequacy of Constellation's internal dose assessment for the highest actual internal | |||
materials (non-fuel) stored within spent fuel and other storage pools.PI&R (02.03.a)The inspector discussed with Constellation their schedule for self-assessments | |||
exposure which was less than 50 millirems CEDE. The inspection also examined Constellation's physical and programmatic controls for highly activated or contaminated | |||
materials (non-fuel) stored within spent fuel and other storage pools. | |||
PI&R (02.03.a) | |||
The inspector discussed with Constellation their schedule for self-assessments and audits. The inspector reviewed one recent self-assessment on shutdown source term | |||
management. The inspector also examined the plan for a corporate radiological release | management. The inspector also examined the plan for a corporate radiological release | ||
audit which was scheduled for Calvert Cliffs in the near future. The inspector's review of | audit which was scheduled for Calvert Cliffs in the near future. The inspector's review of | ||
condition reports in the corrective action program indicated that problems in the | condition reports in the corrective action program indicated that problems in the | ||
occupational radiation safety area were being identified. High Risk Significant, High Dose Area and Very High Radiation Area (VHRA) Controls(02.05.a, b, and c)The inspector met with the Radiation Protection Manager (RPM) and discussed high-dose-rate (HDR) high radiation areas and | |||
occupational radiation safety area were being identified. | |||
these areas. The inspector did not identify any significant procedural changes since the | High Risk Significant, High Dose Area and Very High Radiation Area (VHRA) Controls (02.05.a, b, and c) | ||
The inspector met with the Radiation Protection Manager (RPM) and discussed high-dose-rate (HDR) high radiation areas and VHRA's and the procedures and controls for | |||
these areas. The inspector did not identify any significant procedural changes since the 11 Enclosure last inspection which would substantially reduce the effectiveness and level of worker protection. The inspector discussed with several first-line Health Physics (HP) | |||
supervisors the controls in place for special areas that have the potential to become | supervisors the controls in place for special areas that have the potential to become | ||
VHRA's during certain plant operations. Also, during tours inside the radiologically | |||
controlled area during this and the previous inspection, the inspector verified adequate | controlled area during this and the previous inspection, the inspector verified adequate | ||
posting and locking of selected entrances to | |||
posting and locking of selected entrances to HDR high radiation areas and VHRA's. | |||
Related Activities The inspector performed a selective examinati on of documents (as listed in the List of Documents Reviewed section) to evaluate the adequacy of radiological controls. | |||
The review in this area was against criteria contained in 10 CFR 19.12, 10 CFR 20 (Subparts D, F, G, H, I, and J), Technical Specifications, and procedures. | |||
completion of six (6) samples relative to this inspection area (i.e., inspection procedure | ====b. Findings==== | ||
No findings of significance were identified.2OS2As Low As Reasonably Achievable (ALARA) Planning and Controls (71121.02 - 6 samples) | |||
====a. Inspection Scope==== | |||
The inspector reviewed the effectiveness of Constellation's program to maintain occupational radiation exposure ALARA. This inspection activity represents the | |||
completion of six | |||
: (6) samples relative to this inspection area (i.e., inspection procedure | |||
sections 02.01.a, c, and d, 02.02.c, and 02.03.a and b) and partially fulfills the biennial | sections 02.01.a, c, and d, 02.02.c, and 02.03.a and b) and partially fulfills the biennial | ||
inspection requirements.Inspection Planning (02.01.a, c, and d)The inspector reviewed pertinent information regarding plant collective exposure history,current exposure trends, and ongoing or planned activities in order to assess current | |||
performance and exposure challenges. The inspector determined the plant's current | inspection requirements. | ||
3-year rolling average collective exposure. The inspector examined the source term measurements which Constellation had collected for trending purposes. Additionally, | |||
the inspector reviewed the site specific procedures associated with maintaining | Inspection Planning (02.01.a, c, and d) | ||
occupational exposures | The inspector reviewed pertinent information regarding plant collective exposure history, current exposure trends, and ongoing or planned activities in order to assess current | ||
performance and exposure challenges. The inspector determined the plant's current | |||
estimate and track work activity specific exposures.Radiological Work Planning (02.02.c)The inspector compared selected person-rem results achieved during the recent Unit | |||
3-year rolling average collective exposure. | |||
The inspector examined the source term measurements which Constellation had collected for trending purposes. Additionally, the inspector reviewed the site specific procedures associated with maintaining | |||
occupational exposures ALARA. These procedures covered the processes used to | |||
estimate and track work activity specific exposures. | |||
Radiological Work Planning (02.02.c) | |||
The inspector compared selected person-rem results achieved during the recent Unit 1 refueling outage with the estimated doses established in Constellation's ALARA | |||
planning for these work activities. The inspector selected the refueling outage tasks with | planning for these work activities. The inspector selected the refueling outage tasks with | ||
the highest person-rem results and/or with the largest inconsistencies between intended | |||
the highest person-rem results and/or with the largest inconsistencies between intended 12 Enclosure and actual work activity doses. For the selected jobs the inspector reviewed documentation and discussed the results with ALARA personnel to determine the | |||
reasons for the inconsistencies. | |||
reasons for the inconsistencies.Verification of Dose Estimates and Exposure Tracking Systems (02.03.a and b)The inspector reviewed the assumptions and basis for the current annual | |||
Verification of Dose Estimates and Exposure Tracking Systems (02.03.a and b) | |||
The inspector reviewed the assumptions and basis for the current annual collective exposure estimate. Also, the inspector discussed Constellation's methodology for | |||
estimating work-activity-specific exposures and the intended dose outcomes with | estimating work-activity-specific exposures and the intended dose outcomes with | ||
ALARA personnel. The inspector evaluated both the dose rate and man-hour estimates | |||
for reasonable accuracy. The inspector also reviewed Constellation's method for | for reasonable accuracy. The inspector also reviewed Constellation's method for | ||
adjusting exposure estimates, or re-planning work, when unexpected changes in scope | adjusting exposure estimates, or re-planning work, when unexpected changes in scope | ||
or emergent work are encountered in order to determine if adjustments to estimated | or emergent work are encountered in order to determine if adjustments to estimated | ||
exposure (intended dose) were based on sound radiation protection and | |||
exposure (intended dose) were based on sound radiation protection and ALARA | |||
principles.Related | principles. | ||
radiation exposure.The review was against criteria contained in | |||
Related Activities The inspector performed a selective examinati on of documents (as listed in the List of Documents Reviewed section) for regulatory compliance and for adequacy of control of | |||
CFR 20.1701 (Use of process or other engineering | |||
controls) and procedures. b. | radiation exposure. | ||
equipment. This inspection activity represents the completion of three (3) samples | |||
relative to this inspection area | The review was against criteria contained in 10 CFR 20.1101 (Radiation protection programs), 10 CFR 20.1701 (Use of process or other engineering | ||
(i.e., inspection procedure sections 02.04.a and 02.06.a and b) and partially fulfills the | |||
controls) and procedures. | |||
====b. Findings==== | |||
No findings of significance were identified.2OS3Radiation Monitoring Instrumentation and Protective Equipment (71121.03 - 3 samples) | |||
====a. Inspection Scope==== | |||
The inspector reviewed the program for health physics instrumentation and protective equipment to determine the accuracy and operability of the instrumentation and | |||
equipment. This inspection activity represents the completion of three | |||
: (3) samples | |||
relative to this inspection area (i.e., inspection procedure sections 02.04.a and 02.06.a and b) and partially fulfills the | |||
biennial inspection requirements. | biennial inspection requirements. | ||
13 Enclosure PI&R (02.04.a) | |||
The review of internal exposures was accomplished during the inspection activity documented in Section 2OS1 (02.02.e). | |||
Self-Contained Breathing Apparatus (SCBA) Maintenance and User Training (02.06.a and b) | |||
and transporting | The inspector reviewed the status and surveillance records of SCBA staged and ready for use in the plant. Also, the inspector examined Constellation's capability for refilling | ||
and transporting SCBA air bottles to and from the control room and operations support | |||
center during emergency conditions. The inspector conducted an examination of records | center during emergency conditions. The inspector conducted an examination of records | ||
and had discussions with cognizant personnel to determine that control room operators | and had discussions with cognizant personnel to determine that control room operators | ||
and other emergency response and radiation protection personnel | |||
(assigned in-plant search and rescue duties or as required by Emergency Operating | and other emergency response and radiation protection personnel (assigned in-plant search and rescue duties or as required by Emergency Operating | ||
Procedures (EOP) or the | |||
Procedures (EOP) or the EP) were trained and qualified in the use of SCBA (including air bottle change-out). The inspector also determined that personnel assigned | |||
SCBA | |||
(including air bottle change-out). The inspector also determined that personnel assigned | to refill bottles were trained and qualified for that task. The inspector determined that | ||
to refill bottles were trained and qualified for that task. The inspector determined that | |||
only personnel who possessed manufacturer-certified training/qualifications were | only personnel who possessed manufacturer-certified training/qualifications were | ||
allowed to perform maintenance and repairs on | |||
allowed to perform maintenance and repairs on SCBA components vital to the unit's | |||
function. The inspector reviewed selected records for the testing and maintenance of | function. The inspector reviewed selected records for the testing and maintenance of | ||
these | |||
these SCBA components and checked for the required, periodic hydrostatic testing and | |||
marking for a number of air bottles.Related | marking for a number of air bottles. | ||
Related Activities The inspector performed a selective examinati on of documents (as listed in the List of Documents Reviewed section) for regulatory compliance and adequacy. | |||
The review was against criteria contained in 10 CFR 20.1501, 10 CFR 20 Subpart H, Technical Specifications (TS), and procedures. | |||
====b. Findings==== | |||
No findings of significance were identified.4.OTHER ACTIVITIES (OA)40A1Performance Indicator Verification (71151 - 8 samples) | |||
====a. Inspection Scope==== | |||
The inspectors reviewed Constellation's program to gather, evaluate and report information on the following four performance indicators (PIs). The inspectors used the | |||
guidance provided in NEI 99-02, Revision 3, "Regulatory Assessment Performance | guidance provided in NEI 99-02, Revision 3, "Regulatory Assessment Performance | ||
Indicator Guideline" to assess the accuracy of Constellation's collection and reporting of | Indicator Guideline" to assess the accuracy of Constellation's collection and reporting of | ||
PI data for the period April 2005 through March 2006. The inspectors reviewed licensee | |||
PI data for the period April 2005 through March 2006. | |||
The inspectors reviewed licensee 14 Enclosure event reports (LERs), monthly operating reports, Calvert Cliffs Nuclear Power Plant (CCNPP) power history charts, NRC inspection reports, and operator narrative logs. Unit 1 and 2 Unplanned Scrams per 7000 Critical HoursUnit 1 and 2 Unplanned Scrams with Loss of Normal Heat RemovalUnit 1 and 2 Unplanned Power Changes per 7000 Critical HoursUnit 1 and 2 Safety System Functional Failures | |||
====b. Findings==== | |||
No findings of significance were identified.4OA2Identification and Resolution of Problems.1Corrective Action Review by Resident Inspectors | |||
====a. Inspection Scope==== | |||
Continuous Review The inspectors performed a daily screening of items entered into Constellation's corrective action program as required by Inspection Procedure 71152, "Identification and | |||
Resolution of Problems." The review facilitated the identification of potentially repetitive | Resolution of Problems." The review facilitated the identification of potentially repetitive | ||
equipment failures or specific human performance issues for follow-up inspection. It was | equipment failures or specific human performance issues for follow-up inspection. It was | ||
accomplished by reviewing each issue report and attending screening meetings, and | accomplished by reviewing each issue report and attending screening meetings, and | ||
accessing Constellation's computerized database. . | |||
accessing Constellation's computerized database. | |||
PI&R review of | |||
===.2 Semi-Annual PI&R Review=== | |||
The inspectors performed an in-depth, semi-annual, PI&R review of Constellation documents written from January 2006 through June 2006 to verify that Constellation is | |||
identifying issues at the appropriate threshold, entering them into the corrective action | identifying issues at the appropriate threshold, entering them into the corrective action | ||
program, and ensuring that there are no significant adverse trends outside of the | program, and ensuring that there are no significant adverse trends outside of the | ||
corrective action program which would indicate the existence of a more significant safety | corrective action program which would indicate the existence of a more significant safety | ||
issue. The inspectors reviewed Constellation PIs, self-assessment reports, quality | |||
issue. The inspectors reviewed Constellation PIs, self-assessment reports, quality assurance audit/surveillance reports, corrective action reports, and system health reports and | |||
compared the results of the review with results reported in the NRC baseline inspection | compared the results of the review with results reported in the NRC baseline inspection | ||
program. Additionally, the inspectors | |||
program. Additionally, the inspectors eval uated the reports against the requirements of the Constellation Nuclear's CAP as delineated in QL-2, "Self-Assessment/Corrective | |||
QL-2, "Self-Assessment/Corrective | |||
Action Program." | Action Program." | ||
====b. Findings==== | |||
IR) Nos. IRE-012-638, -012-716, and -013-639). The issues were | No findings of significance were identified..3Identification and Resolution of Problems - Occupational Radiation Safety (71121.01, | ||
associated with radiography boundaries, intermittent tele-dosimetry contact, and the | |||
year-end collective radiation exposure goal, respectively. The documented reports for the issues were reviewed to determine whether the full extent of the issues was | ===.02 , and .03)=== | ||
identified, an appropriate evaluation was performed, and appropriate corrective actions | |||
were specified and prioritized. b. | ====a. Inspection Scope==== | ||
The inspector selected three issues identified in the CAP for review (i.e., Issue Report (IR) Nos. IRE-012-638, -012-716, and -013-639). The issues were | |||
associated with radiography boundaries, intermittent tele-dosimetry contact, and the | |||
year-end collective radiation exposure goal, respectively. The documented reports for the issues were reviewed to determine whether the full extent of the issues was | |||
identified, an appropriate evaluation was performed, and appropriate corrective actions | |||
were specified and prioritized. | |||
====b. Findings==== | |||
No findings of significance were identified. | |||
===.4 Annual sample review - Elevated Levels of Tritium Found in #11 Piezometer Tube=== | |||
====a. Inspection Scope==== | |||
The inspectors selected the issue of elevated levels of tritium found in a groundwater sample collected on Calvert Cliffs site property for a detailed review. Routine annual | |||
groundwater samples from four piezometer tubes (40 to 50 feet deep) were collected on | groundwater samples from four piezometer tubes (40 to 50 feet deep) were collected on | ||
December 3, 2005. Three of the four samples did not indicate any radioactivity. | December 3, 2005. Three of the four samples did not indicate any radioactivity. | ||
Samples from #11 piezometer tube, however, indicated 1800 picocuries per liter (pCi/l) | Samples from #11 piezometer tube, however, indicated 1800 picocuries per liter (pCi/l) | ||
of tritium in the groundwater. No gamma-emitting radioactivity was detected in any | of tritium in the groundwater. No gamma-emitting radioactivity was detected in any | ||
samples. The previous annual samples for these four tubes did not identify any plant- | samples. The previous annual samples for these four tubes did not identify any plant- | ||
related radioactivity. Issue Report (IR) IRE-010-005 was written to identify this issue, | |||
and the | related radioactivity. Issue Report (IR) IRE-010-005 was written to identify this issue, and the NRC was notified. The IR was categorized as requiring an apparent causal | ||
IR was categorized as requiring an apparent causal | |||
evaluation. The last sample for #11 piezometer tube, which measured positive for | evaluation. The last sample for #11 piezometer tube, which measured positive for | ||
tritium, was taken on December 21, 2005. Monthly samples since then have not | tritium, was taken on December 21, 2005. Monthly samples since then have not | ||
indicated any plant-related radioactivity. During this inspection, the inspectors discussed this issue with cognizant personnel | |||
indicated any plant-related radioactivity. | |||
During this inspection, the inspectors discussed this issue with cognizant personnel and reviewed the following:-the Action Plan for Tritium in Groundwater (Updated as of April 17, 2006), -the positive sample results for #11 piezometer tube, | |||
-the negative sample results from the thirteen onsite deep wells (approximately | -the negative sample results from the thirteen onsite deep wells (approximately | ||
-460 feet) available for supplying site drinking water and makeup water, from | -460 feet) available for supplying site drinking water and makeup water, from the onsite storm drains, from the onsite subsurface drains (SSDs), and from the | ||
piezometer tubes (other than #11), | piezometer tubes (other than #11), | ||
16 Enclosure-the input to the 10 CFR 50.75(g) file, -OE21958 - low levels of tritium found in groundwater at Calvert Cliffs, | |||
OE21958 - low levels of tritium found in groundwater at Calvert Cliffs, | |||
-the Tritium and Generic Implications Presentation prepared for the site's Nuclear | -the Tritium and Generic Implications Presentation prepared for the site's Nuclear | ||
-Safety Review Board, and | -Safety Review Board, and | ||
-the Corporate Radiological Release Audit Project Plan. b. | -the Corporate Radiological Release Audit Project Plan. | ||
accordance with | |||
====b. Findings==== | |||
CFR 20.1301(a)(1) | |||
=====Introduction.===== | |||
A Green Non-Cited Violation (NCV) was identified for failure to make surveys of the radioactivity in a large "sink hole" in order to make an evaluation in | |||
accordance with 10 CFR 20.1501(a) to assure compliance with 10 CFR 20.1301(a)(1) | |||
regarding the total effective dose equivalent limit for individual members of the public | regarding the total effective dose equivalent limit for individual members of the public | ||
from the licensed operations.Description. Routine annual liquid samples from four piezometer tubes (40 to 50 | |||
from the licensed operations. | |||
=====Description.===== | |||
Routine annual liquid samples from four piezometer tubes (40 to 50 feet deep) were collected on December 3, 2005. These piezometer tubes were installed | |||
during the site hydrology study prior to plant construction. Their purpose was for | during the site hydrology study prior to plant construction. Their purpose was for | ||
measurement of ground water depth at the site. A piezometer consists of a small- | measurement of ground water depth at the site. A piezometer consists of a small- | ||
diameter steel pipe equipped with a well point or perforated PVC pipe. Three of the four | diameter steel pipe equipped with a well point or perforated PVC pipe. Three of the four | ||
liquid samples indicated no activity. Multiple samples from #11 piezometer tube, | |||
however, indicated 1800 picocuries per liter (pCi/l) of tritium in the groundwater. For | liquid samples indicated no activity. Multiple samples from #11 piezometer tube, however, indicated 1800 picocuries per liter (pCi/l) of tritium in the groundwater. For | ||
comparison, these sample results are below the Environmental Protection Agency's | comparison, these sample results are below the Environmental Protection Agency's | ||
drinking water standard for tritium which is 20,000 pCi/l. No gamma-emitting | drinking water standard for tritium which is 20,000 pCi/l. No gamma-emitting | ||
radioactivity was detected in any samples. The previous annual samples for these four | radioactivity was detected in any samples. The previous annual samples for these four | ||
tubes did not identify any plant-related radioactivity. | |||
tubes did not identify any plant-related radioactivity. IR IRE-010-005 was written to | |||
IRE-010-005 was written to | |||
identify this issue and the | identify this issue and the NRC was notified. The IR was categorized as requiring an | ||
IR was categorized as requiring an | |||
apparent causal evaluation. The last sample for #11 piezometer tube, which measured | apparent causal evaluation. The last sample for #11 piezometer tube, which measured | ||
positive for tritium, was taken on December 21, 2005. Monthly samples since then have | positive for tritium, was taken on December 21, 2005. Monthly samples since then have | ||
not indicated any plant-related radioactivity. Upon identification of this issue Constellation recognized the need to investigate | |||
not indicated any plant-related radioactivity. | |||
Upon identification of this issue Constellation recognized the need to investigate the source of the tritium and effect corrective actions. Their documented action plan for this | |||
issue (updated as of April 17, 2006) included multiple stages, including finding the | issue (updated as of April 17, 2006) included multiple stages, including finding the | ||
leaking component, fixing the leaking component, determining the extent of | leaking component, fixing the leaking component, determining the extent of | ||
contamination, mapping the plume, and evaluating the need for remediation. The plan | contamination, mapping the plume, and evaluating the need for remediation. The plan | ||
included 36 action items, each with an assigned responsible individual and with an | included 36 action items, each with an assigned responsible individual and with an | ||
estimated completion date. Action items which have been initiated included increasing | estimated completion date. Action items which have been initiated included increasing | ||
the number of sampling points and sampling frequencies for groundwater monitoring, | |||
contracting for the services of an experienced hydrologist/geologist for consultation, | the number of sampling points and sampling frequencies for groundwater monitoring, contracting for the services of an experienced hydrologist/geologist for consultation, attempting to "age" the tritium samples, and obtaining site drawings showing the location | ||
attempting to "age" the tritium samples, and obtaining site drawings showing the location | |||
and arrangement of building foundations, tanks, pools, and underground piping to | and arrangement of building foundations, tanks, pools, and underground piping to | ||
evaluate systems as potential sources of the tritium. As of January 3, 2006, the investigation indicated that a previously-ruptured,underground pipe, plugged in 2001, was partially or wholly responsible for the tritium | |||
evaluate systems as potential sources of the tritium. | |||
As of January 3, 2006, the investigation indicated that a previously-ruptured, underground pipe, plugged in 2001, was partially or wholly responsible for the tritium | |||
contamination. By design, the circulating water discharge conduits (CWDCs) accept | contamination. By design, the circulating water discharge conduits (CWDCs) accept | ||
normal, permitted, liquid radioactive waste discharges and dilute the liquid waste prior to | |||
normal, permitted, liquid radioactive waste discharges and dilute the liquid waste prior to 17 Enclosure discharges to the Chesapeake Bay. At a point downstream of the liquid radioactive waste connection to the CWDC #22, this conduit, by design, was connected to a | |||
subsurface drain (SSD) system by a section of underground piping. This piping | subsurface drain (SSD) system by a section of underground piping. This piping | ||
connection allowed circulating water (containing tritium) to enter the SSD system | |||
(essentially a large, industrial French drain) and the circulating water (saltwater) | connection allowed circulating water (containing tritium) to enter the SSD system (essentially a large, industrial French drain) and the circulating water (saltwater) | ||
corroded the metal piping connection to the French drain. The corroded section of | corroded the metal piping connection to the French drain. The corroded section of | ||
underground piping to the French drain allowed a pathway for circulating water to leak to | underground piping to the French drain allowed a pathway for circulating water to leak to | ||
the soil approximately 50 feet from # 11 piezometer tube. The circulating water leakage | the soil approximately 50 feet from # 11 piezometer tube. The circulating water leakage | ||
washed out soil in that area which eventually resulted in a large "sink hole" that opened | washed out soil in that area which eventually resulted in a large "sink hole" that opened | ||
and revealed itself on February 26, 2001. This "sink hole" was oval-shaped, measured | and revealed itself on February 26, 2001. This "sink hole" was oval-shaped, measured | ||
approximately 6 feet by 4 feet in cross-section and approximately 11 feet deep, and | approximately 6 feet by 4 feet in cross-section and approximately 11 feet deep, and | ||
required 800 cubic feet of dirt to fill. To stop the circulating water from entering the | required 800 cubic feet of dirt to fill. To stop the circulating water from entering the | ||
corroded section of underground piping to the French drain, the connection to the | corroded section of underground piping to the French drain, the connection to the | ||
CWDC #22 was plugged in April of 2001. | |||
As of April 20, 2006, the station is still continuing actions to verify that there are no additional sources contributing to this contamination to determine the extent of | |||
contamination and to map the plume. Also, the station is currently evaluating the need | contamination and to map the plume. Also, the station is currently evaluating the need | ||
to drill additional monitoring wells. The investigation is ongoing. Based on the above and only assessing the time period from December 3, 2005, to | |||
to drill additional monitoring wells. The investigation is ongoing. | |||
Based on the above and only assessing the time period from December 3, 2005, to the present time the station's problem identification, classification, and prioritization of this | |||
issue and the identification of needed corrective actions appear timely and adequate for | issue and the identification of needed corrective actions appear timely and adequate for | ||
this point in their investigation. Constellation's action plan acknowledged that there were | this point in their investigation. Constellation's action plan acknowledged that there were | ||
further evaluations and actions which still needed to be completed. However, during the time period from the appearance of the "sink hole" to the | |||
further evaluations and actions which still needed to be completed. | |||
However, during the time period from the appearance of the "sink hole" to the plugging of the underground pipe connection to CWDC #22 and the backfill of the "sink hole," no | |||
radiation surveys of the contents of the "sink hole" were performed to ascertain the | radiation surveys of the contents of the "sink hole" were performed to ascertain the | ||
nature and extent of radioactive contamination or the possibility of a ground water | nature and extent of radioactive contamination or the possibility of a ground water | ||
plume. This was the case even though the "sink hole" was created by the action of | plume. This was the case even though the "sink hole" was created by the action of | ||
circulating water containing radioactive material from routine, permitted, plant discharges | circulating water containing radioactive material from routine, permitted, plant discharges | ||
of liquid radioactive waste. Thus, such a survey would have been reasonable and | of liquid radioactive waste. Thus, such a survey would have been reasonable and | ||
appropriate under the circumstances. Thus, for an unknown period of time, some | appropriate under the circumstances. Thus, for an unknown period of time, some | ||
portions of routine permitted liquid radioactive waste discharges to | |||
portions of routine permitted liquid radioactive waste discharges to CWDC #22 were | |||
inadvertently released on site into the ground instead of being released as planned and | inadvertently released on site into the ground instead of being released as planned and | ||
permitted into the Chesapeake Bay. Based on information in Section 2.5, Hydrology, of | permitted into the Chesapeake Bay. Based on information in Section 2.5, Hydrology, of | ||
the site's Undated Final Safety Analysis Report (UFSAR), these portions would flow to | the site's Undated Final Safety Analysis Report (UFSAR), these portions would flow to | ||
the bay via shallow groundwater flow (i.e., a non-permitted pathway) within the site's | the bay via shallow groundwater flow (i.e., a non-permitted pathway) within the site's | ||
boundaries; the transit time for groundwater flow to the bay is much longer than that for | boundaries; the transit time for groundwater flow to the bay is much longer than that for | ||
permitted discharges via the | |||
permitted discharges via the CWDC which transit time is a matter of seconds or minutes. | |||
CFR 20.1501 and is more | |||
=====Analysis.===== | |||
The performance deficiency was that no radiation surveys of the contents of the "sink hole" were performed. This was a violation of 10 CFR 20.1501 and is more | |||
than minor because it is associated with the cornerstone attribute of maintaining a | than minor because it is associated with the cornerstone attribute of maintaining a | ||
program and process to estimate offsite dose due to abnormal releases and to properly | program and process to estimate offsite dose due to abnormal releases and to properly | ||
report such releases, and because it affected the Radiation Safety/Public Radiation | |||
report such releases, and because it affected the Radiation Safety/Public Radiation 18 Enclosure Safety Cornerstone's objective to ensure the adequate protection of public health and safety from exposure to radioactive materials released into the public domain. This | |||
finding did not meet the criteria for traditional enforcement. Using Manual Chapter 0609, | |||
Appendix D, the Public Radiation Safety Significance Determination Process (SDP), it | finding did not meet the criteria for traditional enforcement. Using Manual Chapter 0609, Appendix D, the Public Radiation Safety Significance Determination Process (SDP), it | ||
was determined that this violation did not involve the radioactive material control or | was determined that this violation did not involve the radioactive material control or | ||
environmental monitoring program branches but did involve the SDP's | |||
environmental monitoring program branches but did involve the SDP's radioactive effluent release program branch. Further, it was determined that this violation was of | |||
very low significance based on the fact that while it did impair Constellation's ability to | very low significance based on the fact that while it did impair Constellation's ability to | ||
assess the timing of dose consequence and the accuracy of the batch and annual | assess the timing of dose consequence and the accuracy of the batch and annual | ||
effluent release dose records and reports due to the large difference in transit times for | effluent release dose records and reports due to the large difference in transit times for | ||
the permitted and non-permitted discharge pathways to the bay, Constellation did | the permitted and non-permitted discharge pathways to the bay, Constellation did | ||
account for all released radioactivity and did assess the cumulative doses from their | account for all released radioactivity and did assess the cumulative doses from their | ||
effluent releases. Additionally, the violation is of very low significance because the | effluent releases. Additionally, the violation is of very low significance because the | ||
involved radioactivity had been addressed in Constellation permits prior to release, the | involved radioactivity had been addressed in Constellation permits prior to release, the | ||
unanalyzed non-permitted pathway (i.e., via groundwater to the bay) did not impact | unanalyzed non-permitted pathway (i.e., via groundwater to the bay) did not impact | ||
private property, and the dose consequences | |||
the dose values in Appendix I to | private property, and the dose consequences woul d not differ significantly from those calculated in Constellation's release permits, and the assessed doses did not exceed | ||
CFR 20.1501 requires that each licensee make or cause to be | the dose values in Appendix I to 10 CFR 50. Therefore, the finding is Green. | ||
and that are reasonable under the circumstances to evaluate the extent of radiation | |||
=====Enforcement.===== | |||
10 CFR 20.1501 requires that each licensee make or cause to be made surveys that may be necessary for Constellation to comply with the regulations in Part | |||
20 and that are reasonable under the circumstances to evaluate the extent of radiation | |||
levels, concentrations or quantities of radioactive materials, and the potential radiological | levels, concentrations or quantities of radioactive materials, and the potential radiological | ||
hazards that could be present. Contrary to the above, as of February 26, 2001, | |||
Constellation did not make surveys to assure compliance with 10 CFR 20.1301(a)(1) | hazards that could be present. Contrary to the above, as of February 26, 2001, Constellation did not make surveys to assure compliance with 10 CFR 20.1301(a)(1) | ||
regarding the dose limit for individual members of the public from licensed operations. | regarding the dose limit for individual members of the public from licensed operations. | ||
Specifically, for an unknown period of time, some portions, of routine permitted liquid | Specifically, for an unknown period of time, some portions, of routine permitted liquid | ||
radioactive waste discharges to | |||
radioactive waste discharges to CWDC #22, were inadvertently released into the ground | |||
instead of being released as planned and permitted into the Chesapeake Bay. Based on | instead of being released as planned and permitted into the Chesapeake Bay. Based on | ||
information in Section 2.5, Hydrology, of the site's | |||
information in Section 2.5, Hydrology, of the site's UFSAR, these portions would flow to | |||
the bay via shallow groundwater flow (i.e., a non-permitted pathway) within the site's | the bay via shallow groundwater flow (i.e., a non-permitted pathway) within the site's | ||
boundaries. The transit time for groundwater flow to the bay is much longer than that for | boundaries. The transit time for groundwater flow to the bay is much longer than that for | ||
permitted discharges via the | |||
permitted discharges via the CWDC's which transit time is a matter of seconds or | |||
minutes and Constellation did not accurately assess, record, and report the annual dose | minutes and Constellation did not accurately assess, record, and report the annual dose | ||
to individual members of the public during that time period. Because this failure to meet | to individual members of the public during that time period. Because this failure to meet | ||
a survey requirement is of very low safety significance and has been entered into the | a survey requirement is of very low safety significance and has been entered into the | ||
corrective action program (CAP) Condition Report (CR) IRE-014-244, this violation is | corrective action program (CAP) Condition Report (CR) IRE-014-244, this violation is | ||
being treated as a Non-Cited Violation (NCV), consistent with Section | |||
being treated as a Non-Cited Violation (NCV), consistent with Section VI.A of the NRC Enforcement Policy: | |||
NCV 05000317, 05000318/2006003-02, Failure to perform anadequate survey for radioactivity | |||
. | |||
19 Enclosure4OA3Event Followup (Closed) LER 05000317/2006-002 Control Element Assembly Determined to be Untrippable On April 8, 2006, while performing low power physic testing, CEA 21 stopped inserting at approximately 134 inches. Upon further attempts to troubleshoot the situation, CEA 21 | |||
CEA 21 stopped inserting | |||
was determined to be untrippable. Operators then commenced a shutdown and placed | was determined to be untrippable. Operators then commenced a shutdown and placed | ||
the unit in Mode 3 in accordance with station procedures and TS Limiting Condition for | the unit in Mode 3 in accordance with station procedures and TS Limiting Condition for | ||
Operation (LCO) 3.1.4.F. Following the shutdown, testing was performed on CEA 21 | Operation (LCO) 3.1.4.F. Following the shutdown, testing was performed on CEA 21 | ||
and all other | |||
and all other CEAs. The LER was reviewed by the inspectors and no findings of | |||
LER was reviewed by the inspectors and no findings of | |||
significance were identified, and no violation of NRC requirements occurred. | significance were identified, and no violation of NRC requirements occurred. | ||
Constellation documented the event in their corrective actions program as | |||
Constellation documented the event in their corrective actions program as IRE-013-755. | |||
LER is closed.4OA5Other | |||
This LER is closed.4OA5Other Activities Implementation of Temporary Instruction (TI) 2515/165 - Operational Readiness of Offsite Power and Impact on Plant Risk | |||
====a. Inspection Scope==== | |||
The objective of TI 2515/165, "Operational Readiness of Offsite Power and Impact on Plant Risk," was to gather information to support the assessment of nuclear power plant | |||
operational readiness of offsite power systems and impact on plant risk. The inspectors | operational readiness of offsite power systems and impact on plant risk. The inspectors | ||
evaluated Constellation procedures against the specific offsite power, risk assessment | evaluated Constellation procedures against the specific offsite power, risk assessment | ||
and system grid reliability requirements of TI 2515/165. They also discussed the | and system grid reliability requirements of TI 2515/165. They also discussed the | ||
attributes with Constellation personnel. The information gathered while completing this TI was forwarded to the Office of | |||
attributes with Constellation personnel. | |||
FME) and parts inventory for the new | The information gathered while completing this TI was forwarded to the Office of Nuclear Reactor Regulation for further review and evaluation. bFindings No findings of significance were identified..24R01Reactor Vessel Head Replacement Inspection (71007 - 1 sample) | ||
====a. Inspection Scope==== | |||
The scope covers onsite and in-office review of post-installation, testing and storage activities that occurred during the refueling outage. | |||
20 Enclosure Post-Installation Testing Post-installation verification and testing inspections were reviewed in the following areas:-Constellation's post-installation inspections and verifications program and its implementation.-The conduct of reactor coolant system leakage testing and review the test results.-The procedures for equipment performance testing required to confirm the design and to establish baseline measurements and the conduct of testing.-Compliance with regulatory requirements including the incorporation of inservice inspection requirements of 10 CFR 50.55a (g).-Adherence to and reconciliation of code requirements. | |||
Specifically, the inspector reviewed Constellation's inspection results for component alignment, cleanliness, foreign material exclusion (FME) and parts inventory for the new | |||
reactor head and enhanced service structure, as documented in the "Post Construction | reactor head and enhanced service structure, as documented in the "Post Construction | ||
Record of Walkdown," and discussed the walkdown with knowledgeable members of | Record of Walkdown," and discussed the walkdown with knowledgeable members of | ||
plant staff. In addition, the results of several types of tests conducted at the conclusion | plant staff. In addition, the results of several types of tests conducted at the conclusion | ||
of the outage were reviewed by the inspector, including: the polar crane post | of the outage were reviewed by the inspector, including: the polar crane post | ||
maintenance testing (mechanical and non-destructive examination (NDE), control rod | maintenance testing (mechanical and non-destructive examination (NDE), control rod | ||
drop time tests, and visual testing (VT-2) performed on the reactor coolant system (RCS) | drop time tests, and visual testing (VT-2) performed on the reactor coolant system (RCS) | ||
to confirm no leakage was observed. | |||
to confirm no leakage was observed. | |||
Storage The inspector directly observed the storage package on the old head and the security barriers present at the storage location. The radiological surveys taken for contact and | |||
general area dose rates were reviewed. The inspector verified that access to the | general area dose rates were reviewed. The inspector verified that access to the | ||
storage area was properly controlled and did not create the potential for an unmonitored | storage area was properly controlled and did not create the potential for an unmonitored | ||
effluent release pathway and that external radiation levels at the perimeter would be | effluent release pathway and that external radiation levels at the perimeter would be | ||
below applicable limits, and dose rates at the perimeter were below applicable limits.TSP | |||
condition report on the installation process in their corrective action program | below applicable limits, and dose rates at the perimeter were below applicable limits. | ||
(IRE-012-607). During the third phase of onsite inspection the inspector reviewed an | |||
independent assessment of whether the modifications to the TSP could affect design | TSP Modifications The last report referenced Constellation's efforts to align the new thimble support plate (TSP) onto the upper guide structure in the vessel. Constellation documented a | ||
basis structural analysis and loading conditions. The inspector also reviewed FME | |||
controls implemented during the outage while the TSP was being modified, as well as | condition report on the installation process in their corrective action program (IRE-012-607). During the third phase of onsite inspection the inspector reviewed an | ||
the operational decision making checklist. At the time of the inspection exit, | |||
Constellation was compiling design and condition report information to incorporate into a | independent assessment of whether the modifications to the TSP could affect design | ||
root cause report and determine the applicability of these issues to the upcoming TSP | |||
basis structural analysis and loading conditions. The inspector also reviewed FME | |||
controls implemented during the outage while the TSP was being modified, as well as | |||
the operational decision making checklist. At the time of the inspection exit, Constellation was compiling design and condition report information to incorporate into a | |||
root cause report and determine the applicability of these issues to the upcoming TSP | |||
replacement planned for Unit 2. | replacement planned for Unit 2. | ||
====b. Findings==== | |||
No findings of significance were identified.4OA6Meetings, Including Exit | |||
===Exit Meeting Summary=== | |||
On July 12, 2006, the resident inspectors presented the inspection results to yourself and other members of your staff who acknowledged the findings. The inspectors asked | |||
Constellation whether any of the material examined during the inspection should be | Constellation whether any of the material examined during the inspection should be | ||
considered proprietary. No proprietary information was identified.ATTACHMENT: | |||
: [[ | considered proprietary. No proprietary information was identified. | ||
: [[ | |||
: [[ | ATTACHMENT: | ||
: [[ | |||
: [[ | =SUPPLEMENTAL INFORMATION= | ||
: [[ | |||
: [[ | ==KEY POINTS OF CONTACT== | ||
: [[ | |||
: [[ | Constellation Personnel | ||
: [[contact::J. Adams]], Constellation, TSP Engineering/Installation | |||
: [[contact::R. Conatser]], Chemist | |||
: [[contact::B. Dansberger]], Health Physics Work Leader (Materials Processing Facility) | |||
: [[contact::S. Etnoyer]], Plant Health Physicist | |||
: [[contact::H. Evans]], Health Physics Work Leader (Dosimetry) | |||
: [[contact::J. Johnson]], Engineering Analyst | |||
: [[ | : [[contact::V. Johnson]], Health Physics Technician | ||
: [[ | : [[contact::G. Joy]], Training, Fire Brigade SCBA | ||
: [[contact::G. Khouri]], Component Replacement Engr | |||
: [[contact::T. Kirkham]], Health Physics Supervisor (Operations) | |||
: [[ | : [[contact::T. Konerth]], Fab PM/Project Engineer | ||
: [[ | : [[contact::W. Lankford]], Operations, Fire Brigade | ||
: [[contact::J. Lenhart]], Health Physics Work Leader (Operations) | |||
: [[contact::P. Lombardi]], Maintenance | |||
: [[contact::K. Prescott]], Admin assist | |||
: [[contact::J. Remenuik]], ESS Task Manager/P.E., PMP | |||
: [[ | : [[contact::I. Rice]], Health Physics Technician | ||
: [[ | : [[contact::E. Roach]], General Supervisor of Health Physics | ||
: [[contact::G. B. Rudell]], Engineering Programs.Quinn, Installation TM | |||
: [[contact::J. Branyan]], Functional Surveillance Test Coordinator | |||
: [[ | : [[contact::M. Flaherty]], Engineering Services Manager | ||
: [[ | : [[contact::L. Larragoite]], Constellation Licensing Director | ||
: [[contact::D. Bauder]], Operations Manager | |||
: [[contact::A. Simpson]], Sr. Licensing Engineer | |||
: [[contact::M. Stanley]], Operations, Fire Brigade | |||
: [[contact::D. Taylor]], Administrative Assistantt | |||
: [[contact::B. Tench]], Acting Director, RVH Projet | |||
: [[contact::L. Williams]], System Manager | |||
: [[contact::M. Yox]], Engineering Analyst | |||
Attachment | |||
==LIST OF ITEMS== | |||
===OPENED, CLOSED AND DISCUSSED=== | |||
: [[ | ===Opened and Closed=== | ||
: | 05000317-318/2006003-01NCVFailure to establish appropriate reference | ||
values or reconfirm previous values | |||
: | |||
: | reference values for the AFW and ECCS | ||
pumps (Section 1R22)05000317-318/2006003-02NCVFailure to perform an adequate survey for | |||
: | radioactivity (Section 4OA2) | ||
: | |||
: | ===Closed=== | ||
: | : [[Closes LER::05000317/LER-2006-002]]LERControl Element Assembly Determined to | ||
: | be Untrippable (section 4OA3) | ||
: | |||
: | ==LIST OF DOCUMENTS REVIEWED== | ||
==Section 1R04: == | |||
: | : Equipment Alignment | ||
: 13.8kV during internal inspection and testing of the 2H2103 voltage regulator Maintenance Order (MO) 2200401489 | |||
: Operating Instruction (OI) 27B, 13.8 kV System | |||
: Drawing 61001SH001 | |||
: Clearance Order | |||
: | : 2200500173 | ||
: | : Clearance Order | ||
: | : 2200500602 | ||
: 1B emergency diesel generator (EDG) walkdown during maintenance on the 1A EDG | |||
: Operating Instruction (OI) 21B-1, 1B Diesel Generator | |||
: | : 4.16kV service transformers Maintenance Order (MO) 1200503371 | ||
: Operating Instruction (OI) 27C, 4.16 kV System | |||
: SRW pump breaker equipment alignment Operating Instruction (OI) 15-1, Service Water System Maintenance Order (MO) 1200501844 | |||
: | : Drawing 61080SH0003 | ||
: | vital 125 Vdc bus being attached and removed from the 125 Vdc reserve battery Operating Instruction (OI) 26A, 125 Volt Vital DC System Attachment Maintenance Order (MO) 2200502563 | ||
: | |||
==Section 1R05: Fire Protection== | |||
: IRE-013-795 | |||
: Calvert Cliffs UFSAR Section 9.9, CCNPP Fire Protection Program, Rev. 37 | |||
: FP-00002, Fire Hazards Analysis Summary Document, Rev. 0 | |||
==Section 1R06: Flood Protection Measures== | |||
: ES-001, Flooding, Rev. 2 | |||
: Calvert Cliffs Nuclear Power Plant Probabilistic Risk Assessment Individual Plant Examination | |||
: Summary Report, dated December 1993 | |||
: AOP-7A, Unit 1 Loss of Saltwater Cooling, Rev. 14 | |||
: | : AOP-7A, Unit 2 Loss of Saltwater Cooling, Rev. 12 | ||
: | : OI-29, Unit 2 Saltwater System, Rev. 52 | ||
: | : OI-45, Unit 2 Service Water System, Rev. 44 | ||
: Information Notice No. 83-44, Supplement 1: | |||
: Potential Damage to Redundant Safety Equipment as a Result of Backflow Through the Equipment and Floor Drain System, dated 8/30/90 | |||
: Information Notice No. 83-44: Potential Damage to Redundant Safety Equipment as a Result of | |||
: Backflow Through the Equipment and Floor Drain System, dated 7/1/83 | |||
: | : Section 1R11 | ||
: | |||
Drawing | : Licensed Operator Requalification Program Licensed Operator Requalification Training Program Manual | ||
: OP-24, Simulator Operating Examination for the Licensed Operator Training Program at the | |||
: | : Calvert Cliffs Nuclear Power Plant Section 1R12: Maintenance Effectiveness Unit 1 auxiliary feedwater isolation control valves | ||
: | : CV-4511 and CV-4512 | ||
: IRE-015-024 | |||
MO) | : Maintenance Order (MO) 1200602819 | ||
Drawing 61001SH001 | : STP O-5A-1, Auxiliary Feedwater Sy stem Quarterly Surveillance Test condensate storage tank rupture valve | ||
Clearance Order | : IRE-009-227 | ||
Clearance Order | : Maintenance Order (MO) | ||
Maintenance Order (MO) 1200500480 | : 1200504137 | ||
Maintenance Order (MO) 1200504037 | : Attachment | ||
Maintenance Order (MO) 1200504044 | |||
Maintenance Order (MO) | ==Section 1R13: == | ||
: Maintenance Risk Assessments and Emergent Work Control | |||
Drawing | : 11A service water basket strainer cleaning: | ||
: Maintenance Order (MO) 1200504373 | |||
MO) | : Maintenance Order (MO) 1200504765 | ||
Drawing | : Maintenance Order (MO) 1200503808 | ||
: | : Maintenance Order (MO) 1200603151 | ||
IRE-014- | : IRE-015-188 | ||
Drawing | containment air cooler repair (reverse flow in fast speed): | ||
: IRE-014-186, U1 containment temperature is relatively high for this time of year | |||
: | : 10CFR50.59/10CFR72.48 screening form, dated 8/15/2001 | ||
: Drawing 61076SH0011D, Schematic Diagr am Containment Cooling Fan 12 | |||
: | : Containment temperature profile graphs (4/28/06 - 5/4/06) | ||
: MN-1-110, Troubleshooting control form, dated 5/10/06 | |||
: | vital 125 Vdc bus being attached and removed from the 125 Vdc reserve battery Maintenance Order (MO) 2200502563 | ||
CEA) Malfunctions, Rev. | : STP M 552-2, 21 Station Battery Service Test | ||
Maintenance Order (MO) 1200601808 | : 13.8kV internal inspection and testing of the 2H2103 voltage regulator Maintenance Order (MO) 2200401489 | ||
: | : Operating Instruction (OI) 27B, 13.8 kV System | ||
IRE-014-186, U1 containment temperature is relatively high for this time of | : Drawing 61001SH001 | ||
Drawing 61076SH0011D, Schematic | : Clearance Order | ||
MN-1-110, Troubleshooting control form, dated 5/10/06 | : 2200500173 | ||
: Clearance Order | |||
IRE-011-991 | : 2200500602 | ||
(ES) 2004000048- | : 1A emergency diesel generator for planned maintenance | ||
Containment Spray Flow | : IRE-014-223 | ||
Monthly | : Maintenance Order (MO) 1200602153 | ||
: Maintenance Order (MO) 1200500480 | |||
: | : Maintenance Order (MO) 1200504037 | ||
: Maintenance Order (MO) 1200504044 | |||
: Maintenance Order (MO) 1200504093 | |||
: | switchgear hvac inspection and lubrication Performance Evaluation (PE) 2-023-02-0-M | ||
RSP-1-106, Rev. 10, Special work permit administration | : Maintenance Order (MO) | ||
Procedure RSP-1-117, Rev. 11, Issuance and wearing of respiratory protection | : 2200504655 | ||
: Attachment Maintenance Order (MO) 2200504679 | |||
Focused self-assessment on shutdown source term management at Calvert | : Maintenance Order (MO) 2200501668 | ||
: | auxiliary feedwater pump maintenance to replace the breaker hand switch Maintenance Order (MO) 220043186 | ||
: Clearance Order | |||
: | : 2200600130 | ||
: | : Drawing 61087SH0010A | ||
and 14 4kV busses during maintenance on the 14 4kV bus normal feeder breaker Maintenance Order (MO) 1200503371 | |||
: | : Operating Instruction (OI) 27C, 4.16 kV System | ||
: | : Drawing 61052SH0004 | ||
==Section 1R15: Operability Evaluations== | |||
containment air cooler repair (reverse flow in fast speed): | |||
: IRE-014-186 | |||
: 10CFR50.59/10CFR72.48 screening form, dated 8/15/2001 | |||
: Drawing 61076SH0011D, Schematic Diagr am Containment Cooling Fan 12 | |||
: Containment temperature profile graphs (4/28/06 - 5/4/06) | |||
: MN-1-110, Troubleshooting control form, dated 5/10/06 | |||
#21 control element assembly testing Operability Determination (OD) 06-002 | |||
: License Event Report (LER) 2006-002 | |||
: PSTP-02, Initial Approach to Criticality and Low Power Physics Testing, Rev. | |||
: AOP-1B, Control Element Assembly (CEA) Malfunctions, Rev. | |||
: Maintenance Order (MO) 1200601808 | |||
: IRE-013-755 | |||
==Section 1R19: Post-Maintenance Testing== | |||
containment air cooler repair (reverse flow in fast speed): | |||
: IRE-014-186, U1 containment temperature is relatively high for this time of year | |||
: 10CFR50.59/10CFR72.48 screening form, dated 8/15/2001 | |||
: Drawing 61076SH0011D, Schematic Diagr am Containment Cooling Fan 12 | |||
: Containment temperature profile graphs (4/28/06 - 5/4/06) | |||
: MN-1-110, Troubleshooting control form, dated 5/10/06 | |||
: Attachment | |||
==Section 1R22: Surveillance Testing== | |||
: HPSI Pump Large Flow Test | |||
: IRE-011-980 | |||
: IRE-011-986 | |||
: IRE-011-991 | |||
(ES) 2004000048-000 | |||
: LPSI Pump Large Flow Test | |||
: IRE-014-764 | |||
: Containment Spray Flow Test | |||
: IRE-014-764 | |||
: Monthly CEA #21 Partial Movement | |||
: IRE-013-755 | |||
: Tech Spec 3.1.4 | |||
: Integrated Leak Rate Test Unit 1 Containment Maintenance Order (MO) 1200404741 | |||
: Integrated Leak Rate Outage Plan 2006 | |||
: Auxiliary Feedwater System Quarterly Surveillance Test | |||
: IRE-015-024 | |||
: Maintenance Order (MO) 1200602819 | |||
: Safety Injection Tank Outlet Isolation Valve Test | |||
: IRE-014-969 | |||
: Maintenance Order (MO) - 2200602819Section EP4: Emergency Action Level and Emergency Plan (E-Plan) Changes Calvert Cliffs Emergency Plan and Implementing Procedures | |||
==Section 2OS1: Access Control to Radiologically Significant Areas== | |||
===Procedure=== | |||
: RSP-1-101, Rev. 22, Routine radiological surveys | |||
===Procedure=== | |||
: RSP-1-106, Rev. 10, Special work permit administration | |||
===Procedure=== | |||
: RSP-1-117, Rev. 11, Issuance and wearing of respiratory protection Attachment devices used to protect against airborne radioactivity | |||
===Procedure=== | |||
: RSP-1-132, Rev. 9, Job coverage in radiologically controlled areas | |||
: Focused self-assessment on shutdown source term management at Calvert Cliffs | |||
==Section 2OS2: ALARA Planning and Controls== | |||
===Procedure=== | |||
: RP-1-100, Rev. 8, Radiation Protection | |||
===Procedure=== | |||
: RSP-1-200, Rev. 22, ALARA planning and SWP preparation | |||
: ALARA packages for SWPs | |||
: 20061351, Rev. 2, Demolish thimble support pate/guide tubes | |||
: 20061358, Rev. 0, Surface destruction activities to remove interference | |||
from new TSP | from new TSP | ||
20061373, Rev. 0, Remove TSP cut up station | : 20061373, Rev. 0, Remove TSP cut up station | ||
20061420, Rev. 2, Half nozzle replacements on the reactor coolant | : 20061420, Rev. 2, Half nozzle replacements on the reactor coolant | ||
system hot legs | system hot legs | ||
20061423, Rev. 2, Mechanical stress improvement | : 20061423, Rev. 2, Mechanical stress improvement process | ||
RSP-2-301, Rev. 14, Respiratory protection device | ==Section 2OS3: Radiation Monitoring Instrumentation and Protective Equipment== | ||
Procedure OI-20A, Rev. 12, Fire protection performance evaluations and fire | |||
system | ===Procedure=== | ||
: RSP-2-301, Rev. 14, Respiratory protection device maintenance | |||
OE21958 - Low Levels of Tritium Found in Groundwater at Calvert Cliffs, | ===Procedure=== | ||
Tritium and Generic Implications Presentation prepared for the site's Nuclear | : RSP-2-304, Rev. 0, Operation of the Bauer breathing air compressor | ||
Safety Review Board, and | ===Procedure=== | ||
Corporate Radiological Release Audit Project Plan. | : OI-20A, Rev. 12, Fire protection performance evaluations and fire | ||
Procedure CP-224, Rev. 13, Monitoring radioactivity in systems normally | |||
uncontaminated | system inspections Section 4OA2: Identification and Resolution of Problems (paragraph 02.02 - SelectedIssue Follow-up Inspection) | ||
Procedure CP-501, Rev. 10, Liquid and steam sampling techniques | : Action Plan for Tritium in Groundwater (Updated as of April 17, 2006), OE21958 - Low Levels of Tritium Found in Groundwater at Calvert Cliffs, Tritium and Generic Implications Presentation prepared for the site's Nuclear | ||
Procedure | : Safety Review Board, and | ||
: | : Corporate Radiological Release Audit Project Plan. | ||
===Procedure=== | |||
OAP 94-5, "Guidelines for Nuclear Plant | : CP-224, Rev. 13, Monitoring radioactivity in systems normally | ||
OCP--3, "Planning and Scheduling", Rev 0 | |||
uncontaminated | |||
===Procedure=== | |||
: | : CP-501, Rev. 10, Liquid and steam sampling techniques | ||
: | ===Procedure=== | ||
: QL-2-100, Rev. 20, Corrective Action Program Section 4OA5: Other Activities Implementation of Temporary Instruction (TI) 2515/165 - Operational Readiness of Offsite Power and Impact on Plant Risk | |||
: | : AOP-7M, "Major Grid Disturbances", Rev 1 | ||
: | : OAP 91-09, "Communications for Load Reduction or Outage" | ||
HE-55 | : OAP 94-5, "Guidelines for Nuclear Plant Operat ions Support for Electric System Operation and Planning Department", Rev 10 | ||
Visual Examination for Leakage(VT-2), Report No. | : OCP--3, "Planning and Scheduling", Rev 0 | ||
: Attachment Operations Coordination and Interconnection Agreement between Baltimore Gas and Electric Company and Constellation Power Source Generation, INC., May 1 2003 | |||
: NO-1-117, "Integraded Risk Management", Rev 15 | |||
: | : 4R01Reactor Vessel Head Replacement Inspection Post-Installation Testing: | ||
: MO# | |||
: 1200404115, Containment Polar Crane 180/25 TON/Periodic Inspection | |||
: | : CCNPP Technical Procedure HE-05 | ||
: CCNPP Technical Procedure HE-55 | |||
: Visual Examination for Leakage(VT-2), Report No. CC06-BV-079 | |||
: | : CCNPP Technical Procedure, ETP99-015R, U0, CEDM Performance Testing, Rev. 3, for test dated 4/7/06 | ||
: ESP No. ES200200485/ES200300312, various supplements, Form 4, Record of Walkdown Storage: Storage of U-1 Old Reactor Vessel Head (ORVH), Map Rev. 0 | |||
: | : TSP Modifications: | ||
RFO Modification | : Presentation, RV | ||
Closeout Letter for Independent Review of Thimble Support Plate Modifications | : TSP 2006 RFO Modification Summary | ||
Constellation letter, 3/31/2006, Exemption of Class B Requirements for the | : MPR Associates Inc., April 4, 2006 letter to Constellation Energy Group, Calvert Cliffs Unit 1 | ||
: | : Closeout Letter for Independent Review of Thimble Support Plate Modifications | ||
: Constellation letter, 3/31/2006, Exemption of Class B Requirements for the RCS | |||
IRT Issues/Hot Particles and FME | : Operational Decision-Making Checklist, RFO IRT Issues/Hot Particles and FME | ||
Procedure Field Change Request, Field Change No. FCR-013, Traveler for Installation of the | ===Procedure=== | ||
Replacement | : Field Change Request, Field Change No. | ||
: FCR-013, Traveler for Installation of the | |||
IRE-012- | : Replacement TSP and Thimble at Calvert Cliffs Condition Reports: | ||
IRE-012-737 | : IRE-012-607 | ||
IRE-013-293 | : IRE-012-644 | ||
: | : IRE-012-737 | ||
: | : IRE-013-293 | ||
UFSAR, Table 4-2, Reactor Vessel | : IRE-012-917 | ||
: IRE-011-923 | |||
: Other: Calvert Cliffs UFSAR, Table 4-2, Reactor Vessel Parameters | |||
: AREVA Letter of Qualification Waiver, 3/10/2006 | |||
: [[ | : Attachment | ||
==LIST OF ACRONYMS== | |||
: [[ | ADAMSAgencywide Documents | ||
Access and Management SystemASMEAmerican Society of Mechanical Engineers | |||
: [[AFWA]] [[uxiliary Feedwater]] | |||
: [[ALARAA]] [[Low As Reasonably Achievable]] | |||
AOPAbnormal Operating Procedure | |||
ATWSAnticipated Transient Without Scram | |||
CAPCorrective Action Program | |||
CCNPPCalvert Cliffs Nuclear Power Plant | |||
CEAControl Element Assembly | |||
CEDECommitted Effective Dose Equivalent | |||
CEDMControl Element Drive Mechanism | |||
CFRCode of Federal Regulations | |||
CRCondition Report | |||
CROControl Room | |||
CSContainment Spray | |||
CWDCCirculating Water Discharge Conduit | |||
ECCSEmergency Core Cooling System | |||
EDGEmergency Diesel Generator | |||
EHCElectro Hydraulic Control | |||
EOPEmergency Operating Procedure | |||
EPEmergency Preparedness | EPEmergency Preparedness | ||
EPEmergency Plan | EPEmergency Plan | ||
E-PlanEmergency Plan | E-PlanEmergency Plan | ||
FMEForeign Material Exclusion | |||
HDRHigh Dose Rate | |||
HPHealth Physics | |||
HVACHeating, Ventilation, and Air Conditioning | |||
IMCInspection Manual Chapter | |||
IPEIndividual Plant Examination | |||
IRIssue Report | |||
ISTInService Testing | |||
LERLicensee Event Report | |||
LCOLimiting Condition Operation | |||
: [[NCVN]] [[on-Cited Violation]] | |||
: [[ | |||
: [[NDE]] [[Non Destructive Examination]] | : [[NDE]] [[Non Destructive Examination]] | ||
NRCNuclear Regulatory Commission | |||
OAOther Activities | OAOther Activities | ||
: [[OMO]] [[peration and Maintenance]] | : [[OMO]] [[peration and Maintenance]] | ||
: [[ | : [[ORVH]] [[Old Reactor Vessel Head]] | ||
OSOccupational Safety | |||
PARSPublicly Available Records | |||
PIPerformance Indicators | |||
PI&RProblem Identification & Resolution | |||
RProblem Identification & Resolution | |||
pCi/lPico-curies per Liter | pCi/lPico-curies per Liter | ||
AttachmentRCS Reactor Coolant SystemRPMRadiation Protection Manager | |||
RWPRadiation Work Permit | |||
SCBASelf-Contained Breathing Apparatus | |||
SDPSignificance Determination Process | |||
SRWService Water | |||
SSCSystems, Structures, and Components | |||
SSDSub-Surface Drain | |||
: [[TIT]] [[emporary Instruction]] | |||
: [[TSP]] [[Thimble Support Plate]] | |||
TSTechnical Specifications | |||
UFSARUpdated Final Safety Analysis Report | |||
: [[VHRAV]] [[ery High Radiation Area]] | |||
: [[ | |||
: [[ | |||
: [[ | |||
}} | }} | ||
Revision as of 21:28, 26 October 2018
| ML062060024 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs |
| Issue date: | 07/21/2006 |
| From: | McDermott B J Reactor Projects Branch 1 |
| To: | Spina J A Constellation Generation Group |
| References | |
| FOIA/PA-2010-0209 IR-06-003 | |
| Download: ML062060024 (39) | |
Text
July 21, 2006
Mr. James A. Spina, Vice President Calvert Cliffs Nuclear Power Plant, Inc.
Constellation Generation Group, LLC
1650 Calvert Cliffs Parkway
Lusby, Maryland 20657-4702
SUBJECT: CALVERT CLIFFS NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000317/2006003 AND 05000318/2006003
Dear Mr. Spina:
On June 30, 2006, the US Nuclear Regulatory Commission (NRC) completed an inspection at your Calvert Cliffs Nuclear Power Plant Units 1 and 2. The enclosed inspection report
documents the inspection results, which were discussed on July 12, 2006, with you and other
members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel.
This report documents two NRC-identified findings of very low safety significance (Green) that were determined to involve violations of NRC requirements. However, because of the very low
safety significance and because these issues were entered into your corrective action program, the NRC is treating these violations as non-cited violations (NCVs) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest any NCV 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 the Calvert Cliffs Nuclear Power Plant.
In accordance with 10 CFR 2.390 of the NRC's "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 Pub licly Available Records (PARS) component of 2 NRC's document 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 Samuel L. Hansell For/
Brian McDermott, Chief Projects Branch 1
Division of Reactor ProjectsDocket Nos.50-317, 50-318 License Nos. DPR-53, DPR-69
Enclosure:
Inspection Report 05000317/2006003 and 05000318/2006003
w/Attachment:
Supplemental Information 3 cc w/encl:
M. J. Wallace, President, Constellation Generation
J. M. Heffley, Senior Vice President and Chief Nuclear Officer
President, Calvert County Board of Commissioners
C. W. Fleming, Senior Counsel, Constellation Generation Group, LLC
Director, Nuclear Regulatory Matters
R. McLean, Manager, Nuclear Programs
K. Burger, Esquire, Maryland People's Counsel
State of Maryland (2)
4 Distribution w/encl:
S. Collins, RA
M. Dapas, DRA
B. Sosa, RI OEDO
R. Laufer, NRR
B. McDermott, DRP
A. Burritt, DRP
J. Giessner, DRP, Senior Resident Inspector (Acting)
M. Davis, Resident Inspector
C. Newgent - Resident OA
ROP Reports
Region I Docket Room (with concurrences)SUNSI Review Complete: SLH (Reviewer's Initials
)DOCUMENT NAME: C:\MyFiles\Copies\CC IR 2006-003.wpd After declaring this document "An Official Agency Record" it will be released to the Public.To receive a copy of this document, indicate in the box:
" C" = Copy without attachment/enclosure " E" = Copy with attachment/enclosure " N" = No copyOFFICERI/DRPRI/DRPRI/DRPNAMEABurrittMDavis/SLH FORBMcDermott/SLH FORDATE07/21 /0607/21/0607/ 21 /06 OFFICIAL RECORD COPY Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION I Docket Nos.50-317, 50-318License Nos.DPR-53, DPR-69 Report Nos.05000317/2006003 and 05000318/2006003 Licensee:Constellation Generation Group, LLC Facility:Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Location:Lusby, MD Dates:April 1, 2006 through June 30, 2006 Inspectors:Mark A. Giles, Senior Resident Inspector Marlone Davis, Resident Inspector
John R. McFadden, Health Physicist
Nancy T. McNamara, EP Inspector
Anne DeFrancisco, Reactor Inspector
Jennifer Bobiak, Reactor InspectorApproved by:Brian McDermott, Chief Projects Branch 1
Division of Reactor Projects ii Enclosure
SUMMARY OF FINDINGS
IR 05000317/2006-003, 05000318/2006-003; 04/01/06 - 06/30/06; Calvert Cliffs Nuclear Power
Plant, Units 1 and 2; Surveillance Testing, Public Radiation Safety.
The report covered a three-month period of inspection by resident inspectors and announced inspections performed by reactor and emergency preparedness inspectors and a health physicist. The inspection identified two Green findings which were determined to be non-cited violations (NCVs). The significance of most findings is indicated by their color (Green, White,
Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination
Process" (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor
Oversight Process," Revision 3, dated July 2000.A.
NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating System
- Green.
The inspectors identified a non-cited violation of 10 CFR 50.55a, Codes and Standards, because Constellation did not establish new reference values or reconfirm the previous reference values following maintenance that affected hydraulic or mechanical parameters on the auxiliary feedwater (AFW) and emergency core cooling system (ECCS)pumps as required by the American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM)
Code for inservice testing. Constellation entered this issue into their corrective action program as IRE-014-764. The planned corrective action include a review of maintenance and IST data to determine whether new reference values are needed or reconfirm existing reference values for the AFW and ECCS pumps.
This finding is more than minor because the same issue affected a number of safety-related pumps tested, the issue was repetitive and if left uncorrected the finding could become a more significant safety concern. The finding has a very low safety significance because the condition did not result in an actual failure of the AFW and ECCS pumps or result in systems being declared inoperable for greater than their allowed Technical Specification outage time. A contributing cause of the finding is related to the cross-cutting aspect in the area of problem identification and resolution (PI&R) because Constellation did not periodically trend and assess information to identify programmatic and common cause problems. (Section 1R22)
Cornerstone: Public Radiation Safety
- Green.
The inspectors identified a non-cited violation of 10 CFR 20.1501 for failure to make surveys of the radioactivity in a "sink hole" to assure compliance with 10 CFR 20.1301(a)(1) regarding the total effective dose equivalent limit for individual members of the public from licensed operations, specifically regarding assessing dose for batch releases of liquid radioactive waste and assessing iv annual dose. Constellation entered this issue into their corrective action program as IRE-010-005. Constellation created a detailed action plan for this issue to find the leaking component, fix the leaking component, determine the extent of contamination, map the plume, and evaluate the need for remediation.
This violation is more than minor because it is associated with the cornerstone attribute of maintaining a program and process to estimate offsite dose due to abnormal releases and to record and report on such releases and because it affected the Radiation Safety/Public Radiation Safety Cornerstone's objective to ensure the adequate protection of public health and safety from exposure to radioactive materials released into the public domain. The violation is of very low significance because, while it did impair Constellation's ability to assess the timing of dose consequence and the accuracy of the batch and annual effluent release dose records and reports due to the large difference in transit times for the permitted and non-permitted discharge pathways to the bay, Constellation did account for all released radioactivity and did assess the cumulative doses from their effluent releases. Additionally, the unanalyzed non-permitted pathway (i.e.,
via groundwater to the bay) did not impact private property, and the assessed doses did not exceed the dose values in Appendix I to 10 CFR 50. (Section 4OA2.4)
B.Licensee-Identified Violations
None
REPORT DETAILS
Summary of Plant Status
Unit 1 began the inspection period in a refueling outage. On April 14, 2006, the unit returned to full power operation (100 percent) and remained unchanged throughout the inspection period.
Unit 2 began the inspection period at 100 percent reactor power and remained unchanged until May 20 when power was reduced to 85 percent for main turbine control valve testing. Following
the completion of the test the unit was restored to 100 percent power and remained there the
rest of the inspection period.1.REACTOR SAFETY Cornerstone: Initiating Events, Mitigating Systems, Barrier Integrity1R04Equipment Alignment (71111.04Q - 5 samples)
Partial Walkdown
a. Inspection Scope
The inspectors verified that selected equipment trains of safety-related and risk significant systems were properly aligned. The inspectors reviewed plant documents to
determine the correct system and power alignments, as well as the required positions of
critical valves and breakers. The inspectors verified that Constellation had properly
identified and resolved equipment alignment pr oblems that could cause initiating events or potentially impact the availability of associated mitigating systems. The applicable
documents used for this inspection are located in the Attachment. The inspectors
performed a partial walkdown for the following activities.*13.8kV during internal inspection and testing of the 2H2103 voltage regulator*1B emergency diesel generator (EDG) walkdown during maintenance on the 1A EDG*4.16kV service transformers during the transfer of the 4kV unit busses from their normal to alternate supply*Unit 1 service water (SRW) system equipment alignment walkdown during maintenance on the13 SRW pump breaker*21 vital 125 Vdc bus being attached and removed from the 125 Vdc reserve battery
b. Findings
No findings of significance were identified.
2 Enclosure1R05Fire Protection (71111.05Q - 10 samples)
Fire Protection - Tours
a. Inspection Scope
The inspectors conducted a tour of accessible portions of the ten areas listed below to assess Constellation's control of transient combustible material and ignition sources, fire
detection and suppression capabilities, fire barriers, and related compensatory
measures when required. The inspectors assessed the material condition of fire
protection suppression and detection equipment to determine whether any conditions or
deficiencies existed which could impair the availability of that equipment. The inspectors
also reviewed administrative procedure SA-1-100, Fire Fighting, and the Fire Fighting
Strategies Manual were referenced for this inspection activity. The ten areas are as
follows:*Unit 1 main steam isolation valve room*Unit 2 main steam isolation valve room
- Unit 1 cable spreading room
- Unit 2 cable spreading room
- Unit 1 4 kV service transformers
- Unit 2 4 kV service transformers
- Unit 1 turbine building basement
- Unit 2 turbine building basement
- Unit 1 intake structure (inside)
- Unit 2 intake structure (inside)
b. Findings
No findings of significance were identified.
1R06 Flood Protection
(71111.06 - 2 internal flooding samples)
a. Inspection Scope
The inspectors reviewed flood protection measures associated with internal flood events.
These events were described in the Calvert Cliffs' Engineering Standard on flooding, the
Individual Plant Examination (IPE) report and the Updated Final Safety Analysis Report (UFSAR). The inspectors performed a walkdown of the Unit 1 and Unit 2 service water
pumps rooms (rooms 226 and 205) which c ontain risk significant systems and components. The inspectors observed the condition of watertight doors, drain systems
and sumps, penetrations in floors and walls, and safety related instrumentation located
in these areas. In addition, the inspector reviewed operating procedures and related
internal flooding industry operating experience (OE).
b. Findings
No findings of significance were identified.
1R11 Licensed Operator Requalification Program
(71111.11Q - 1 sample)
a. Inspection Scope
The inspectors observed a licensed operator simulator training scenario conducted on May 18, 2006, in order to assess operator performance and the adequacy of licensed
operators training program. The training scenario involved a condensate header rupture
that resulted in a loss of main feed event causing the operators to perform a manual reactor trip. Following the trip, equipment failures occurred ultimately resulting in a loss
of all feedwater. During this inspection, the inspectors focused on high-risk operator
actions performed during implementation of the abnormal and emergency operating
procedures, emergency plan (EP) implementation, and classification of the event.
The inspectors evaluated the clarity and formality of communications, the
implementation of appropriate actions in response to alarms, the performance of timely
control board operations and manipulations, and the oversight and direction provided by
the shift supervisor. The inspectors also reviewed simulator fidelity to evaluate the
degree of similarity to the actual control room, especially regarding recent control board
modifications.
b. Findings
No findings of significance were identified.
1R12 Maintenance Effectiveness
Quarterly Review (71111.12Q - 2 samples)
a. Inspection Scope
The inspectors reviewed Constellation effectiveness in performing routine maintenance activities. This review included an assessment of Constellation's practices pertaining to
the identification, scoping, and handling of degraded equipment conditions, as well as
common cause failure evaluations, and the resolution of historical equipment problems.
For those systems, structures, and components (SSC) scoped in the maintenance rule
per 10 CFR 50.65, the inspectors verified that reliability and unavailability were properly
monitored and that 10 CFR 50.65 (a)(1) and (a)(2) classifications were justified in light of
the reviewed degraded equipment condition. The inspectors conducted this inspection
for the following equipment issues:*Unit 1 auxiliary feedwater isolation control valves CV-4511 and CV-4512*11 condensate storage tank (CST) rupture valve
b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
(71111.13 - 8 samples)
a. Inspection Scope
The inspectors reviewed Constellation's assessments concerning the risk impact of removing from service those components associated with the work items listed below.
This review primarily focused on activities determined to be risk significant within the
maintenance rule. The inspectors compared the risk assessments and risk
management actions performed by station procedure NO-1-117, "Integrated Risk
Management," to the requirements of 10 CFR 50.65(a)(4), the recommendations of
NUMARC 93-01, Revision 2, "Industry Guideline for Monitoring the Effectiveness of
Maintenance at Nuclear Power Plants," and approved station procedures.
The inspectors compared the assessed risk configuration to actual plant conditions to
evaluate whether the assessment was accurate and comprehensive. In addition, the
inspectors assessed the adequacy of Constellation's identification and resolution of
problems associated with maintenance risk assessments and emergent work activities.
The inspectors reviewed the following selected work activities:*11A service water basket strainer cleaning*12 containment air cooler repair (reverse flow in fast speed)
- 21 vital 125 Vdc bus being attached and removed from the 125 Vdc reserve battery*13.8kV during internal inspection and testing of the 2H2103 voltage regulator
- 1A emergency diesel generator for planned maintenance
- 22 switchgear Heating Ventilation and Air Conditioning (HVAC) inspection and lubrication*23 auxiliary feedwater pump maintenance to replace the breaker hand switch
b. Findings
No findings of significance were identified.
5 Enclosure1R14Operator Performance During Non-Routine Plant Evolutions and Events (71111.14 - 2 samples)
a. Inspection Scope
Untrippable Control Element Assembly The inspectors assessed operator performance associated with a Unit 1 event that involved a misaligned control element assembly (CEA) while performing low power
physics testing. On April 8, 2006, at appr oximately 6:35 p.m., control room operators (CRO) began to insert regulating group 2 after testing groups 5, 4 and 3 with no position
anomalies. When regulating group 2 was inserted, the operators received a deviation
alarm in the control room. The alarm was due to regulating group 2, CEA #21, stopping
and being misaligned with the other CEA's in that group, which was greater than the
allowable technical specification deviation. At approximately 6:45 p.m., the Unit 1 CRO
entered the Abnormal Operating Procedure AOP-1B, CEA Malfunction, to establish
group realignment and maintain reactivity control.
A troubleshooting plan was
developed and further reactivity controls were performed through dilution and boration of
the reactor coolant while the investigation of the misaligned CEA continued. However, the CEA did not respond to initial insertion signal and the electrical traces taken on the
drive mechanism during insertion attempts indicated abnormal responses to the lower
and upper gripper coil. This prompted the operators to declare CEA #21 untrippable.
At 10:45 p.m., the operators exited low pow er physics testing and then manually tripped the reactor. Although CEA #21 did not insert, the rest of the rods did insert to provide
adequate shutdown margin. On April 09, 2006, at approximately 1:20 a.m., Unit 1 was
in Mode 3 and the operators had exited AOP-1B.
The inspectors assessed the plant response and conditions specific to the event and evaluated the performance of licensed operators. The inspectors also reviewed control
room procedures and operator logs to determine if operators performed the appropriate
actions in accordance with their training and established station procedures.
Unit 1 Main Turbine Control Valve Oscillations The inspectors assessed operator performance associated with a Unit 1 main turbine startup after the installation of a new turbine control system. On April 11, 2006, at 2:30
a.m., Unit 1 main turbine control valves experienced high frequency valve oscillations
when the turbine reached 1800 revolutions per minute. The rapid cycling of the control
valves created excessive vibrations in the Electro Hydraulic Control (EHC) piping
system. This excessive vibration was reported to the control room and the operators
immediately tripped and secured the main turbine.
When the main turbine was tripped, the vibration of the EHC piping stopped.
The inspectors assessed the plant response and conditions specific to the event, and evaluated the performance of licensed operators. The inspectors also reviewed control
room procedures and operator logs to determine if operators performed the appropriate
actions in accordance with their training and established station procedures.
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations
(71111.15 - 6 samples)
a. Inspection Scope
The inspectors reviewed six operability determinations to verify that the operability of systems important to safety were proper ly established and that affected components or systems remained capable of performing their intended safety function. The inspectors
reviewed the selected operability determinations to verify they were performed in
accordance with NO-1-106, "Functional Evaluation - Operability Determination," and
QL-2-100, "Issue Reporting and Assessment." The following operability evaluations were
reviewed:*12 containment air cooler repair (reverse flow in fast speed)*11, 12, and 13 high pressure safety injection pumps
- 12 containment spray pump overhaul following pump bearing failure
- 21 control element assembly testing
- 8 control element assembly testing
- 12 component cooling water heat exchanger due to saltwater pin hole leak on temperature probe
b. Findings
No findings of significance were identified1R19Post-Maintenance Testing (71111.19 - 9 samples)
a. Inspection Scope
The inspectors observed and/or reviewed post-maintenance tests associated with the following nine work activities to verify that equipment was properly returned to service
and that appropriate testing was specified and conducted to ensure that the equipment
was operable and could perform its intended safety function following the completion of
maintenance. Post-maintenance testing activities were conducted as specified in station
procedure MN-1-101, "Control Of Maintenance Activities." Post-maintenance test results
associated with the maintenance activities listed below were reviewed.*12 containment air cooler repair (reverse flow in fast speed)*12 auxiliary feedwater pump
- 21 control element assembly testing
- Unit 2 main steam safety valve lift settings test
- 13.8kV during internal inspection and testing of the 2H2103 voltage regulator 7 Enclosure*1A emergency diesel generator for after planned maintenance*Unit 2 containment isolation valves
- 22 switchgear hvac inspection and lubrication
- 23 auxiliary feedwater pump
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing
(71111.22 - 9 samples)
a. Inspection Scope
The inspectors observed and/or reviewed the nine surveillance tests listed below associated with selected risk-significant SSCs to verify TS compliance and that test
acceptance criteria was properly specified. The inspectors also verified that proper test
conditions were established as specified in the procedures, no equipment
preconditioning activities occurred, and that acceptance criteria had been satisfied.*STP O-8A-1, Test Of 1A DG and 11 4KV bus LOCI sequencer*STP O-073G-1, HPSI Pump Large Flow Test
- STP O-073L-1, LPSI Pump Large Flow Test
- STP O-073M-1, Containment Spray Flow Test
- STP O-029-1, Monthly CEA Partial Movement
- STP -662-1, Integrated Leak Rate Test Unit 1 Containment
- STP O-5A-1, Auxiliary Feedwater Sy stem Quarterly Surveillance Test*STP O-035-2, Safety Injection Tank Outlet Isolation Valve Test
- STP M-3A-0, On line main steam safety valve testing
b. Findings
Introduction.
The inspectors identified a non-cited violation of 10 CFR 50.55a, Codes and Standards, because Constellation did not establish new reference values or
reconfirm the previous reference values following maintenance that affected hydraulic or
mechanical parameters on the AFW and emergency core cooling pumps.
Description.
In May of 2002, the NRC granted Constellation a relief request (PR-12) to perform the inservice testing of the AFW and ECCS pumps in accordance with the 1995
Edition of the American Society of Mechanical Engineers (ASME) Code through the
1996 Addenda of the ASME Operation and Maintenance (OM) Code. The ASME OM
Code, Subsection ISTB, requires, in part, that when a reference value or set of reference
values that may have been affected by repair, replacement, or routine servicing of a
pump, a new reference value or set of values shall be determined or previous values
reconfirmed by an inservice test run before declaring the pump operable.
8 Enclosure The inspectors identified maintenance activities that would have affected the hydraulic or mechanical characteristics of the AFW and ECCS pumps. However, no new reference
values were established or the previous values reconfirmed before declaring the pumps
operable. For example, the 12 containment spray (CS) pump was overhauled in May of
2002 and March of 2006 with maintenance activities that affected the hydraulic (larger
impeller) and mechanical (thrust bearing) parameters respectively. Subsequent testing
performed for the 12 CS pump did not establish new reference values or validate
existing values; therefore, Constellation could not demonstrate that the pump
performance curve or the mechanical parameters did not change following maintenance
activities. Furthermore, a number of the ECCS pumps have exceeded inservice testing (IST) acceptance criteria for their surveillance test procedure. This could be contributed
to the fact that new reference values were not established or the existing values
reconfirmed after maintenance that affected the hydraulic or mechanical parameters for
their IST reference values.
Constellation entered this issue into their corrective action program as IRE-014-764.
Additionally, to assess the extent of condition, Constellation conducted a more detailed
review of the maintenance performed prior to May 2002 on all the AFW and ECCS
pumps. This review will determine whether or not the maintenance activities performed
required a new reference value to be developed or if the existing values were valid.
Analysis.
The inspectors concluded that a performance deficiency existed because Constellation did not establish new reference values or reconfirm the previous reference
values following maintenance that affected hydraulic or mechanical parameters on the
AFW and ECCS pumps. The finding is more than minor because the same issue
affected a number of pumps tested, the issue was repetitive and if left uncorrected the finding could become a more significant safety concern due to the potential to not detect pump degradation which could impact pump operability. This finding has a very low safety significance because the conditions did not result in an actual failure of the AFW
and ECCS pumps or result in systems being declared inoperable for greater than their
allowed Technical Specification outage time. The planned corrective actions included a
review of maintenance and IST data to determine whether new reference values are
needed or if there is a need to reconfirm existing reference values for the AFW and
ECCS pumps. The inspectors identified that a contributing cause of this finding was
related to the cross-cutting aspect of PI&R because Constellation did not periodically
trend and assess information to identify programmatic and common cause problems.
Enforcement.
Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a, Codes and Standards, requires, in part, that testing of safety related pumps meet the
requirements of the ASME OM Code. The ASME Code, Subsection ISTB, states that
when a reference value or set of reference values that may have been affected by
repair, replacement, or routine servicing of a pump, a new reference value or set of
values shall be determined or previous values reconfirmed by an inservice test run
before declaring the pump operable. Contrary to the above, Constellation did not
establish new vibration or hydraulic reference values or reconfirm the previous values
were acceptable following maintenance that affected the reference values of the AFW
and ECCS pumps. This violation is documented in Constellation's corrective action 9 Enclosure program as IRE-014-764 and is being treated as a non-cited violation consistent with Section VI.A.1 of the NRC Enforcement Policy:
NCV 05000317 and 318/2006003-01, Failure to establish appropriate reference values or reconfirm previous values for AFW and ECCS pumps.
Cornerstone:
Emergency Preparedness (EP)1EP4Emergency Action Level and Emergency Plan (E-Plan) Changes (71114.04 - 1 sample)
a. Inspection Scope
During the period of September 2005 - February 2006, the NRC received changes made to Constellation Nuclear's E-Plan in accordance with 10 CFR 50.54(q). Constellation
Nuclear determined the changes did not decrease the effectiveness of the E-Plan and
also that the E-Plan continued to meet the requirements of 10 CFR 50.47(b) and
Appendix E to 10 CFR Part 50. A selected sample of E-Plan changes were reviewed in-
office by the inspector. This review does not constitute approval of the changes and, as
such, the changes and the associated 10 CFR 50.54(q) reviews are subject to future
NRC inspection. The inspection was conducted in accordance with NRC Inspection
Procedure 71114, Attachment 4.
b. Findings
No findings of significance were identified. 1EP6Drill Evaluation (71114.06 - 1 sample )
Simulator Exercises
a. Inspection Scope
The inspectors observed control room simulator training exercises conducted on May 18, 2006, to assess licensed operators' performance in the area of emergency
preparedness. This training exercise focused on equipment failures and operator
challenges that would typically exist dur ing an anticipated transient without scram (ATWS) and total loss of feedwater event. The required procedural transitions and
associated event classification was observed and evaluated by the inspectors.
b. Findings
No findings of significance were identified.
10 Enclosure2.RADIATION SAFETYCornerstone: Occupational Radiation Safety (OS)2OS1Access Control to Radiologically Significant Areas (71121.01 - 7 samples)
a. Inspection Scope
The inspector reviewed radiological work activities and practices and procedural implementation during observations and tours of the facilities and inspected procedures, records, and other program documents to ev aluate the effectiveness of Constellation's access controls to radiologically significant areas. This inspection activity represents the
completion of seven
- (7) samples relative to this inspection area (i.e., inspection procedure sections 02.02.d thru f, 02.03.a, and 02.05.a thru c) and
partially fulfills the annual inspection requirements.
Plant Walk Downs and RWP Reviews (02.02.d, e, and f)
During this inspection and the previous 2006 inspection during the Unit 1 refueling outage the inspector reviewed radiation work permits (RWPs) for airborne radioactivity
areas with the potential for individual worker internal exposures of greater than
50 millirems Committed Effective Dose Equivalent (CEDE). For these selected
airborne radioactive material areas the inspector examined the performance of controls, such as use of containments, ventilation sy stems, and procedural processes. Also, the inspector discussed with radiation protection personnel their experience with uptakes of
radioactive material since the last inspection. The inspector reviewed and assessed the
adequacy of Constellation's internal dose assessment for the highest actual internal
exposure which was less than 50 millirems CEDE. The inspection also examined Constellation's physical and programmatic controls for highly activated or contaminated
materials (non-fuel) stored within spent fuel and other storage pools.
PI&R (02.03.a)
The inspector discussed with Constellation their schedule for self-assessments and audits. The inspector reviewed one recent self-assessment on shutdown source term
management. The inspector also examined the plan for a corporate radiological release
audit which was scheduled for Calvert Cliffs in the near future. The inspector's review of
condition reports in the corrective action program indicated that problems in the
occupational radiation safety area were being identified.
High Risk Significant, High Dose Area and Very High Radiation Area (VHRA) Controls (02.05.a, b, and c)
The inspector met with the Radiation Protection Manager (RPM) and discussed high-dose-rate (HDR) high radiation areas and VHRA's and the procedures and controls for
these areas. The inspector did not identify any significant procedural changes since the 11 Enclosure last inspection which would substantially reduce the effectiveness and level of worker protection. The inspector discussed with several first-line Health Physics (HP)
supervisors the controls in place for special areas that have the potential to become
VHRA's during certain plant operations. Also, during tours inside the radiologically
controlled area during this and the previous inspection, the inspector verified adequate
posting and locking of selected entrances to HDR high radiation areas and VHRA's.
Related Activities The inspector performed a selective examinati on of documents (as listed in the List of Documents Reviewed section) to evaluate the adequacy of radiological controls.
The review in this area was against criteria contained in 10 CFR 19.12, 10 CFR 20 (Subparts D, F, G, H, I, and J), Technical Specifications, and procedures.
b. Findings
No findings of significance were identified.2OS2As Low As Reasonably Achievable (ALARA) Planning and Controls (71121.02 - 6 samples)
a. Inspection Scope
The inspector reviewed the effectiveness of Constellation's program to maintain occupational radiation exposure ALARA. This inspection activity represents the
completion of six
- (6) samples relative to this inspection area (i.e., inspection procedure
sections 02.01.a, c, and d, 02.02.c, and 02.03.a and b) and partially fulfills the biennial
inspection requirements.
Inspection Planning (02.01.a, c, and d)
The inspector reviewed pertinent information regarding plant collective exposure history, current exposure trends, and ongoing or planned activities in order to assess current
performance and exposure challenges. The inspector determined the plant's current
3-year rolling average collective exposure.
The inspector examined the source term measurements which Constellation had collected for trending purposes. Additionally, the inspector reviewed the site specific procedures associated with maintaining
occupational exposures ALARA. These procedures covered the processes used to
estimate and track work activity specific exposures.
Radiological Work Planning (02.02.c)
The inspector compared selected person-rem results achieved during the recent Unit 1 refueling outage with the estimated doses established in Constellation's ALARA
planning for these work activities. The inspector selected the refueling outage tasks with
the highest person-rem results and/or with the largest inconsistencies between intended 12 Enclosure and actual work activity doses. For the selected jobs the inspector reviewed documentation and discussed the results with ALARA personnel to determine the
reasons for the inconsistencies.
Verification of Dose Estimates and Exposure Tracking Systems (02.03.a and b)
The inspector reviewed the assumptions and basis for the current annual collective exposure estimate. Also, the inspector discussed Constellation's methodology for
estimating work-activity-specific exposures and the intended dose outcomes with
ALARA personnel. The inspector evaluated both the dose rate and man-hour estimates
for reasonable accuracy. The inspector also reviewed Constellation's method for
adjusting exposure estimates, or re-planning work, when unexpected changes in scope
or emergent work are encountered in order to determine if adjustments to estimated
exposure (intended dose) were based on sound radiation protection and ALARA
principles.
Related Activities The inspector performed a selective examinati on of documents (as listed in the List of Documents Reviewed section) for regulatory compliance and for adequacy of control of
radiation exposure.
The review was against criteria contained in 10 CFR 20.1101 (Radiation protection programs), 10 CFR 20.1701 (Use of process or other engineering
controls) and procedures.
b. Findings
No findings of significance were identified.2OS3Radiation Monitoring Instrumentation and Protective Equipment (71121.03 - 3 samples)
a. Inspection Scope
The inspector reviewed the program for health physics instrumentation and protective equipment to determine the accuracy and operability of the instrumentation and
equipment. This inspection activity represents the completion of three
- (3) samples
relative to this inspection area (i.e., inspection procedure sections 02.04.a and 02.06.a and b) and partially fulfills the
biennial inspection requirements.
13 Enclosure PI&R (02.04.a)
The review of internal exposures was accomplished during the inspection activity documented in Section 2OS1 (02.02.e).
Self-Contained Breathing Apparatus (SCBA) Maintenance and User Training (02.06.a and b)
The inspector reviewed the status and surveillance records of SCBA staged and ready for use in the plant. Also, the inspector examined Constellation's capability for refilling
and transporting SCBA air bottles to and from the control room and operations support
center during emergency conditions. The inspector conducted an examination of records
and had discussions with cognizant personnel to determine that control room operators
and other emergency response and radiation protection personnel (assigned in-plant search and rescue duties or as required by Emergency Operating
Procedures (EOP) or the EP) were trained and qualified in the use of SCBA (including air bottle change-out). The inspector also determined that personnel assigned
to refill bottles were trained and qualified for that task. The inspector determined that
only personnel who possessed manufacturer-certified training/qualifications were
allowed to perform maintenance and repairs on SCBA components vital to the unit's
function. The inspector reviewed selected records for the testing and maintenance of
these SCBA components and checked for the required, periodic hydrostatic testing and
marking for a number of air bottles.
Related Activities The inspector performed a selective examinati on of documents (as listed in the List of Documents Reviewed section) for regulatory compliance and adequacy.
The review was against criteria contained in 10 CFR 20.1501, 10 CFR 20 Subpart H, Technical Specifications (TS), and procedures.
b. Findings
No findings of significance were identified.4.OTHER ACTIVITIES (OA)40A1Performance Indicator Verification (71151 - 8 samples)
a. Inspection Scope
The inspectors reviewed Constellation's program to gather, evaluate and report information on the following four performance indicators (PIs). The inspectors used the
guidance provided in NEI 99-02, Revision 3, "Regulatory Assessment Performance
Indicator Guideline" to assess the accuracy of Constellation's collection and reporting of
PI data for the period April 2005 through March 2006.
The inspectors reviewed licensee 14 Enclosure event reports (LERs), monthly operating reports, Calvert Cliffs Nuclear Power Plant (CCNPP) power history charts, NRC inspection reports, and operator narrative logs. Unit 1 and 2 Unplanned Scrams per 7000 Critical HoursUnit 1 and 2 Unplanned Scrams with Loss of Normal Heat RemovalUnit 1 and 2 Unplanned Power Changes per 7000 Critical HoursUnit 1 and 2 Safety System Functional Failures
b. Findings
No findings of significance were identified.4OA2Identification and Resolution of Problems.1Corrective Action Review by Resident Inspectors
a. Inspection Scope
Continuous Review The inspectors performed a daily screening of items entered into Constellation's corrective action program as required by Inspection Procedure 71152, "Identification and
Resolution of Problems." The review facilitated the identification of potentially repetitive
equipment failures or specific human performance issues for follow-up inspection. It was
accomplished by reviewing each issue report and attending screening meetings, and
accessing Constellation's computerized database.
.2 Semi-Annual PI&R Review
The inspectors performed an in-depth, semi-annual, PI&R review of Constellation documents written from January 2006 through June 2006 to verify that Constellation is
identifying issues at the appropriate threshold, entering them into the corrective action
program, and ensuring that there are no significant adverse trends outside of the
corrective action program which would indicate the existence of a more significant safety
issue. The inspectors reviewed Constellation PIs, self-assessment reports, quality assurance audit/surveillance reports, corrective action reports, and system health reports and
compared the results of the review with results reported in the NRC baseline inspection
program. Additionally, the inspectors eval uated the reports against the requirements of the Constellation Nuclear's CAP as delineated in QL-2, "Self-Assessment/Corrective
Action Program."
b. Findings
No findings of significance were identified..3Identification and Resolution of Problems - Occupational Radiation Safety (71121.01,
.02 , and .03)
a. Inspection Scope
The inspector selected three issues identified in the CAP for review (i.e., Issue Report (IR) Nos. IRE-012-638, -012-716, and -013-639). The issues were
associated with radiography boundaries, intermittent tele-dosimetry contact, and the
year-end collective radiation exposure goal, respectively. The documented reports for the issues were reviewed to determine whether the full extent of the issues was
identified, an appropriate evaluation was performed, and appropriate corrective actions
were specified and prioritized.
b. Findings
No findings of significance were identified.
.4 Annual sample review - Elevated Levels of Tritium Found in #11 Piezometer Tube
a. Inspection Scope
The inspectors selected the issue of elevated levels of tritium found in a groundwater sample collected on Calvert Cliffs site property for a detailed review. Routine annual
groundwater samples from four piezometer tubes (40 to 50 feet deep) were collected on
December 3, 2005. Three of the four samples did not indicate any radioactivity.
Samples from #11 piezometer tube, however, indicated 1800 picocuries per liter (pCi/l)
of tritium in the groundwater. No gamma-emitting radioactivity was detected in any
samples. The previous annual samples for these four tubes did not identify any plant-
related radioactivity. Issue Report (IR) IRE-010-005 was written to identify this issue, and the NRC was notified. The IR was categorized as requiring an apparent causal
evaluation. The last sample for #11 piezometer tube, which measured positive for
tritium, was taken on December 21, 2005. Monthly samples since then have not
indicated any plant-related radioactivity.
During this inspection, the inspectors discussed this issue with cognizant personnel and reviewed the following:-the Action Plan for Tritium in Groundwater (Updated as of April 17, 2006), -the positive sample results for #11 piezometer tube,
-the negative sample results from the thirteen onsite deep wells (approximately
-460 feet) available for supplying site drinking water and makeup water, from the onsite storm drains, from the onsite subsurface drains (SSDs), and from the
piezometer tubes (other than #11),
16 Enclosure-the input to the 10 CFR 50.75(g) file, -OE21958 - low levels of tritium found in groundwater at Calvert Cliffs,
-the Tritium and Generic Implications Presentation prepared for the site's Nuclear
-Safety Review Board, and
-the Corporate Radiological Release Audit Project Plan.
b. Findings
Introduction.
A Green Non-Cited Violation (NCV) was identified for failure to make surveys of the radioactivity in a large "sink hole" in order to make an evaluation in
accordance with 10 CFR 20.1501(a) to assure compliance with 10 CFR 20.1301(a)(1)
regarding the total effective dose equivalent limit for individual members of the public
from the licensed operations.
Description.
Routine annual liquid samples from four piezometer tubes (40 to 50 feet deep) were collected on December 3, 2005. These piezometer tubes were installed
during the site hydrology study prior to plant construction. Their purpose was for
measurement of ground water depth at the site. A piezometer consists of a small-
diameter steel pipe equipped with a well point or perforated PVC pipe. Three of the four
liquid samples indicated no activity. Multiple samples from #11 piezometer tube, however, indicated 1800 picocuries per liter (pCi/l) of tritium in the groundwater. For
comparison, these sample results are below the Environmental Protection Agency's
drinking water standard for tritium which is 20,000 pCi/l. No gamma-emitting
radioactivity was detected in any samples. The previous annual samples for these four
tubes did not identify any plant-related radioactivity. IR IRE-010-005 was written to
identify this issue and the NRC was notified. The IR was categorized as requiring an
apparent causal evaluation. The last sample for #11 piezometer tube, which measured
positive for tritium, was taken on December 21, 2005. Monthly samples since then have
not indicated any plant-related radioactivity.
Upon identification of this issue Constellation recognized the need to investigate the source of the tritium and effect corrective actions. Their documented action plan for this
issue (updated as of April 17, 2006) included multiple stages, including finding the
leaking component, fixing the leaking component, determining the extent of
contamination, mapping the plume, and evaluating the need for remediation. The plan
included 36 action items, each with an assigned responsible individual and with an
estimated completion date. Action items which have been initiated included increasing
the number of sampling points and sampling frequencies for groundwater monitoring, contracting for the services of an experienced hydrologist/geologist for consultation, attempting to "age" the tritium samples, and obtaining site drawings showing the location
and arrangement of building foundations, tanks, pools, and underground piping to
evaluate systems as potential sources of the tritium.
As of January 3, 2006, the investigation indicated that a previously-ruptured, underground pipe, plugged in 2001, was partially or wholly responsible for the tritium
contamination. By design, the circulating water discharge conduits (CWDCs) accept
normal, permitted, liquid radioactive waste discharges and dilute the liquid waste prior to 17 Enclosure discharges to the Chesapeake Bay. At a point downstream of the liquid radioactive waste connection to the CWDC #22, this conduit, by design, was connected to a
subsurface drain (SSD) system by a section of underground piping. This piping
connection allowed circulating water (containing tritium) to enter the SSD system (essentially a large, industrial French drain) and the circulating water (saltwater)
corroded the metal piping connection to the French drain. The corroded section of
underground piping to the French drain allowed a pathway for circulating water to leak to
the soil approximately 50 feet from # 11 piezometer tube. The circulating water leakage
washed out soil in that area which eventually resulted in a large "sink hole" that opened
and revealed itself on February 26, 2001. This "sink hole" was oval-shaped, measured
approximately 6 feet by 4 feet in cross-section and approximately 11 feet deep, and
required 800 cubic feet of dirt to fill. To stop the circulating water from entering the
corroded section of underground piping to the French drain, the connection to the
CWDC #22 was plugged in April of 2001.
As of April 20, 2006, the station is still continuing actions to verify that there are no additional sources contributing to this contamination to determine the extent of
contamination and to map the plume. Also, the station is currently evaluating the need
to drill additional monitoring wells. The investigation is ongoing.
Based on the above and only assessing the time period from December 3, 2005, to the present time the station's problem identification, classification, and prioritization of this
issue and the identification of needed corrective actions appear timely and adequate for
this point in their investigation. Constellation's action plan acknowledged that there were
further evaluations and actions which still needed to be completed.
However, during the time period from the appearance of the "sink hole" to the plugging of the underground pipe connection to CWDC #22 and the backfill of the "sink hole," no
radiation surveys of the contents of the "sink hole" were performed to ascertain the
nature and extent of radioactive contamination or the possibility of a ground water
plume. This was the case even though the "sink hole" was created by the action of
circulating water containing radioactive material from routine, permitted, plant discharges
of liquid radioactive waste. Thus, such a survey would have been reasonable and
appropriate under the circumstances. Thus, for an unknown period of time, some
portions of routine permitted liquid radioactive waste discharges to CWDC #22 were
inadvertently released on site into the ground instead of being released as planned and
permitted into the Chesapeake Bay. Based on information in Section 2.5, Hydrology, of
the site's Undated Final Safety Analysis Report (UFSAR), these portions would flow to
the bay via shallow groundwater flow (i.e., a non-permitted pathway) within the site's
boundaries; the transit time for groundwater flow to the bay is much longer than that for
permitted discharges via the CWDC which transit time is a matter of seconds or minutes.
Analysis.
The performance deficiency was that no radiation surveys of the contents of the "sink hole" were performed. This was a violation of 10 CFR 20.1501 and is more
than minor because it is associated with the cornerstone attribute of maintaining a
program and process to estimate offsite dose due to abnormal releases and to properly
report such releases, and because it affected the Radiation Safety/Public Radiation 18 Enclosure Safety Cornerstone's objective to ensure the adequate protection of public health and safety from exposure to radioactive materials released into the public domain. This
finding did not meet the criteria for traditional enforcement. Using Manual Chapter 0609, Appendix D, the Public Radiation Safety Significance Determination Process (SDP), it
was determined that this violation did not involve the radioactive material control or
environmental monitoring program branches but did involve the SDP's radioactive effluent release program branch. Further, it was determined that this violation was of
very low significance based on the fact that while it did impair Constellation's ability to
assess the timing of dose consequence and the accuracy of the batch and annual
effluent release dose records and reports due to the large difference in transit times for
the permitted and non-permitted discharge pathways to the bay, Constellation did
account for all released radioactivity and did assess the cumulative doses from their
effluent releases. Additionally, the violation is of very low significance because the
involved radioactivity had been addressed in Constellation permits prior to release, the
unanalyzed non-permitted pathway (i.e., via groundwater to the bay) did not impact
private property, and the dose consequences woul d not differ significantly from those calculated in Constellation's release permits, and the assessed doses did not exceed
the dose values in Appendix I to 10 CFR 50. Therefore, the finding is Green.
Enforcement.
10 CFR 20.1501 requires that each licensee make or cause to be made surveys that may be necessary for Constellation to comply with the regulations in Part
20 and that are reasonable under the circumstances to evaluate the extent of radiation
levels, concentrations or quantities of radioactive materials, and the potential radiological
hazards that could be present. Contrary to the above, as of February 26, 2001, Constellation did not make surveys to assure compliance with 10 CFR 20.1301(a)(1)
regarding the dose limit for individual members of the public from licensed operations.
Specifically, for an unknown period of time, some portions, of routine permitted liquid
radioactive waste discharges to CWDC #22, were inadvertently released into the ground
instead of being released as planned and permitted into the Chesapeake Bay. Based on
information in Section 2.5, Hydrology, of the site's UFSAR, these portions would flow to
the bay via shallow groundwater flow (i.e., a non-permitted pathway) within the site's
boundaries. The transit time for groundwater flow to the bay is much longer than that for
permitted discharges via the CWDC's which transit time is a matter of seconds or
minutes and Constellation did not accurately assess, record, and report the annual dose
to individual members of the public during that time period. Because this failure to meet
a survey requirement is of very low safety significance and has been entered into the
corrective action program (CAP) Condition Report (CR) IRE-014-244, this violation is
being treated as a Non-Cited Violation (NCV), consistent with Section VI.A of the NRC Enforcement Policy:
NCV 05000317,05000318/2006003-02, Failure to perform anadequate survey for radioactivity
.
19 Enclosure4OA3Event Followup (Closed) LER 05000317/2006-002 Control Element Assembly Determined to be Untrippable On April 8, 2006, while performing low power physic testing, CEA 21 stopped inserting at approximately 134 inches. Upon further attempts to troubleshoot the situation, CEA 21
was determined to be untrippable. Operators then commenced a shutdown and placed
the unit in Mode 3 in accordance with station procedures and TS Limiting Condition for
Operation (LCO) 3.1.4.F. Following the shutdown, testing was performed on CEA 21
and all other CEAs. The LER was reviewed by the inspectors and no findings of
significance were identified, and no violation of NRC requirements occurred.
Constellation documented the event in their corrective actions program as IRE-013-755.
This LER is closed.4OA5Other Activities Implementation of Temporary Instruction (TI) 2515/165 - Operational Readiness of Offsite Power and Impact on Plant Risk
a. Inspection Scope
The objective of TI 2515/165, "Operational Readiness of Offsite Power and Impact on Plant Risk," was to gather information to support the assessment of nuclear power plant
operational readiness of offsite power systems and impact on plant risk. The inspectors
evaluated Constellation procedures against the specific offsite power, risk assessment
and system grid reliability requirements of TI 2515/165. They also discussed the
attributes with Constellation personnel.
The information gathered while completing this TI was forwarded to the Office of Nuclear Reactor Regulation for further review and evaluation. bFindings No findings of significance were identified..24R01Reactor Vessel Head Replacement Inspection (71007 - 1 sample)
a. Inspection Scope
The scope covers onsite and in-office review of post-installation, testing and storage activities that occurred during the refueling outage.
20 Enclosure Post-Installation Testing Post-installation verification and testing inspections were reviewed in the following areas:-Constellation's post-installation inspections and verifications program and its implementation.-The conduct of reactor coolant system leakage testing and review the test results.-The procedures for equipment performance testing required to confirm the design and to establish baseline measurements and the conduct of testing.-Compliance with regulatory requirements including the incorporation of inservice inspection requirements of 10 CFR 50.55a (g).-Adherence to and reconciliation of code requirements.
Specifically, the inspector reviewed Constellation's inspection results for component alignment, cleanliness, foreign material exclusion (FME) and parts inventory for the new
reactor head and enhanced service structure, as documented in the "Post Construction
Record of Walkdown," and discussed the walkdown with knowledgeable members of
plant staff. In addition, the results of several types of tests conducted at the conclusion
of the outage were reviewed by the inspector, including: the polar crane post
maintenance testing (mechanical and non-destructive examination (NDE), control rod
drop time tests, and visual testing (VT-2) performed on the reactor coolant system (RCS)
to confirm no leakage was observed.
Storage The inspector directly observed the storage package on the old head and the security barriers present at the storage location. The radiological surveys taken for contact and
general area dose rates were reviewed. The inspector verified that access to the
storage area was properly controlled and did not create the potential for an unmonitored
effluent release pathway and that external radiation levels at the perimeter would be
below applicable limits, and dose rates at the perimeter were below applicable limits.
TSP Modifications The last report referenced Constellation's efforts to align the new thimble support plate (TSP) onto the upper guide structure in the vessel. Constellation documented a
condition report on the installation process in their corrective action program (IRE-012-607). During the third phase of onsite inspection the inspector reviewed an
independent assessment of whether the modifications to the TSP could affect design
basis structural analysis and loading conditions. The inspector also reviewed FME
controls implemented during the outage while the TSP was being modified, as well as
the operational decision making checklist. At the time of the inspection exit, Constellation was compiling design and condition report information to incorporate into a
root cause report and determine the applicability of these issues to the upcoming TSP
replacement planned for Unit 2.
b. Findings
No findings of significance were identified.4OA6Meetings, Including Exit
Exit Meeting Summary
On July 12, 2006, the resident inspectors presented the inspection results to yourself and other members of your staff who acknowledged the findings. The inspectors asked
Constellation whether any of the material examined during the inspection should be
considered proprietary. No proprietary information was identified.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Constellation Personnel
- R. Conatser, Chemist
- B. Dansberger, Health Physics Work Leader (Materials Processing Facility)
- S. Etnoyer, Plant Health Physicist
- H. Evans, Health Physics Work Leader (Dosimetry)
- J. Johnson, Engineering Analyst
- V. Johnson, Health Physics Technician
- G. Khouri, Component Replacement Engr
- T. Kirkham, Health Physics Supervisor (Operations)
- T. Konerth, Fab PM/Project Engineer
- W. Lankford, Operations, Fire Brigade
- J. Lenhart, Health Physics Work Leader (Operations)
- P. Lombardi, Maintenance
- K. Prescott, Admin assist
- J. Remenuik, ESS Task Manager/P.E., PMP
- I. Rice, Health Physics Technician
- E. Roach, General Supervisor of Health Physics
- G. B. Rudell, Engineering Programs.Quinn, Installation TM
- J. Branyan, Functional Surveillance Test Coordinator
- M. Flaherty, Engineering Services Manager
- L. Larragoite, Constellation Licensing Director
- D. Bauder, Operations Manager
- A. Simpson, Sr. Licensing Engineer
- M. Stanley, Operations, Fire Brigade
- D. Taylor, Administrative Assistantt
- B. Tench, Acting Director, RVH Projet
- L. Williams, System Manager
- M. Yox, Engineering Analyst
Attachment
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened and Closed
05000317-318/2006003-01NCVFailure to establish appropriate reference
values or reconfirm previous values
reference values for the AFW and ECCS
pumps (Section 1R22)05000317-318/2006003-02NCVFailure to perform an adequate survey for
radioactivity (Section 4OA2)
Closed
- 05000317/LER-2006-002LERControl Element Assembly Determined to
be Untrippable (section 4OA3)
LIST OF DOCUMENTS REVIEWED
Section 1R04:
- Equipment Alignment
- 13.8kV during internal inspection and testing of the 2H2103 voltage regulator Maintenance Order (MO) 2200401489
- Operating Instruction (OI) 27B, 13.8 kV System
- Drawing 61001SH001
- Clearance Order
- 2200500173
- Clearance Order
- 2200500602
- 1B emergency diesel generator (EDG) walkdown during maintenance on the 1A EDG
- 4.16kV service transformers Maintenance Order (MO) 1200503371
- SRW pump breaker equipment alignment Operating Instruction (OI) 15-1, Service Water System Maintenance Order (MO) 1200501844
- Drawing 61080SH0003
vital 125 Vdc bus being attached and removed from the 125 Vdc reserve battery Operating Instruction (OI) 26A, 125 Volt Vital DC System Attachment Maintenance Order (MO) 2200502563
Section 1R05: Fire Protection
- IRE-013-795
- Calvert Cliffs UFSAR Section 9.9, CCNPP Fire Protection Program, Rev. 37
- FP-00002, Fire Hazards Analysis Summary Document, Rev. 0
Section 1R06: Flood Protection Measures
- ES-001, Flooding, Rev. 2
- Calvert Cliffs Nuclear Power Plant Probabilistic Risk Assessment Individual Plant Examination
- Summary Report, dated December 1993
- AOP-7A, Unit 1 Loss of Saltwater Cooling, Rev. 14
- AOP-7A, Unit 2 Loss of Saltwater Cooling, Rev. 12
- OI-29, Unit 2 Saltwater System, Rev. 52
- OI-45, Unit 2 Service Water System, Rev. 44
- Information Notice No. 83-44, Supplement 1:
- Potential Damage to Redundant Safety Equipment as a Result of Backflow Through the Equipment and Floor Drain System, dated 8/30/90
- Information Notice No. 83-44: Potential Damage to Redundant Safety Equipment as a Result of
- Backflow Through the Equipment and Floor Drain System, dated 7/1/83
- Section 1R11
- Licensed Operator Requalification Program Licensed Operator Requalification Training Program Manual
- OP-24, Simulator Operating Examination for the Licensed Operator Training Program at the
- Calvert Cliffs Nuclear Power Plant Section 1R12: Maintenance Effectiveness Unit 1 auxiliary feedwater isolation control valves
- CV-4511 and CV-4512
- IRE-015-024
- Maintenance Order (MO) 1200602819
- STP O-5A-1, Auxiliary Feedwater Sy stem Quarterly Surveillance Test condensate storage tank rupture valve
- IRE-009-227
- Maintenance Order (MO)
- 1200504137
- Attachment
Section 1R13:
- Maintenance Risk Assessments and Emergent Work Control
- 11A service water basket strainer cleaning:
- Maintenance Order (MO) 1200504373
- Maintenance Order (MO) 1200504765
- Maintenance Order (MO) 1200503808
- Maintenance Order (MO) 1200603151
- IRE-015-188
containment air cooler repair (reverse flow in fast speed):
- IRE-014-186, U1 containment temperature is relatively high for this time of year
- 10CFR50.59/10CFR72.48 screening form, dated 8/15/2001
- Drawing 61076SH0011D, Schematic Diagr am Containment Cooling Fan 12
- Containment temperature profile graphs (4/28/06 - 5/4/06)
- MN-1-110, Troubleshooting control form, dated 5/10/06
vital 125 Vdc bus being attached and removed from the 125 Vdc reserve battery Maintenance Order (MO) 2200502563
- STP M 552-2, 21 Station Battery Service Test
- 13.8kV internal inspection and testing of the 2H2103 voltage regulator Maintenance Order (MO) 2200401489
- Operating Instruction (OI) 27B, 13.8 kV System
- Drawing 61001SH001
- Clearance Order
- 2200500173
- Clearance Order
- 2200500602
- 1A emergency diesel generator for planned maintenance
- IRE-014-223
- Maintenance Order (MO) 1200602153
- Maintenance Order (MO) 1200500480
- Maintenance Order (MO) 1200504037
- Maintenance Order (MO) 1200504044
- Maintenance Order (MO) 1200504093
switchgear hvac inspection and lubrication Performance Evaluation (PE) 2-023-02-0-M
- Maintenance Order (MO)
- 2200504655
- Attachment Maintenance Order (MO) 2200504679
- Maintenance Order (MO) 2200501668
auxiliary feedwater pump maintenance to replace the breaker hand switch Maintenance Order (MO) 220043186
- Clearance Order
- 2200600130
- Drawing 61087SH0010A
and 14 4kV busses during maintenance on the 14 4kV bus normal feeder breaker Maintenance Order (MO) 1200503371
- Drawing 61052SH0004
Section 1R15: Operability Evaluations
containment air cooler repair (reverse flow in fast speed):
- IRE-014-186
- 10CFR50.59/10CFR72.48 screening form, dated 8/15/2001
- Drawing 61076SH0011D, Schematic Diagr am Containment Cooling Fan 12
- Containment temperature profile graphs (4/28/06 - 5/4/06)
- MN-1-110, Troubleshooting control form, dated 5/10/06
- 21 control element assembly testing Operability Determination (OD)06-002
- License Event Report (LER) 2006-002
- PSTP-02, Initial Approach to Criticality and Low Power Physics Testing, Rev.
- Maintenance Order (MO) 1200601808
- IRE-013-755
Section 1R19: Post-Maintenance Testing
containment air cooler repair (reverse flow in fast speed):
- IRE-014-186, U1 containment temperature is relatively high for this time of year
- 10CFR50.59/10CFR72.48 screening form, dated 8/15/2001
- Drawing 61076SH0011D, Schematic Diagr am Containment Cooling Fan 12
- Containment temperature profile graphs (4/28/06 - 5/4/06)
- MN-1-110, Troubleshooting control form, dated 5/10/06
- Attachment
Section 1R22: Surveillance Testing
- HPSI Pump Large Flow Test
- IRE-011-980
- IRE-011-986
- IRE-011-991
(ES) 2004000048-000
- LPSI Pump Large Flow Test
- IRE-014-764
- Containment Spray Flow Test
- IRE-014-764
- Monthly CEA #21 Partial Movement
- IRE-013-755
- Integrated Leak Rate Test Unit 1 Containment Maintenance Order (MO) 1200404741
- Integrated Leak Rate Outage Plan 2006
- Auxiliary Feedwater System Quarterly Surveillance Test
- IRE-015-024
- Maintenance Order (MO) 1200602819
- Safety Injection Tank Outlet Isolation Valve Test
- IRE-014-969
- Maintenance Order (MO) - 2200602819Section EP4: Emergency Action Level and Emergency Plan (E-Plan) Changes Calvert Cliffs Emergency Plan and Implementing Procedures
Section 2OS1: Access Control to Radiologically Significant Areas
Procedure
- RSP-1-101, Rev. 22, Routine radiological surveys
Procedure
- RSP-1-106, Rev. 10, Special work permit administration
Procedure
- RSP-1-117, Rev. 11, Issuance and wearing of respiratory protection Attachment devices used to protect against airborne radioactivity
Procedure
- RSP-1-132, Rev. 9, Job coverage in radiologically controlled areas
- Focused self-assessment on shutdown source term management at Calvert Cliffs
Section 2OS2: ALARA Planning and Controls
Procedure
- RP-1-100, Rev. 8, Radiation Protection
Procedure
- RSP-1-200, Rev. 22, ALARA planning and SWP preparation
- ALARA packages for SWPs
- 20061351, Rev. 2, Demolish thimble support pate/guide tubes
- 20061358, Rev. 0, Surface destruction activities to remove interference
from new TSP
- 20061373, Rev. 0, Remove TSP cut up station
- 20061420, Rev. 2, Half nozzle replacements on the reactor coolant
system hot legs
- 20061423, Rev. 2, Mechanical stress improvement process
Section 2OS3: Radiation Monitoring Instrumentation and Protective Equipment
Procedure
- RSP-2-301, Rev. 14, Respiratory protection device maintenance
Procedure
- RSP-2-304, Rev. 0, Operation of the Bauer breathing air compressor
Procedure
- OI-20A, Rev. 12, Fire protection performance evaluations and fire
system inspections Section 4OA2: Identification and Resolution of Problems (paragraph 02.02 - SelectedIssue Follow-up Inspection)
- Action Plan for Tritium in Groundwater (Updated as of April 17, 2006), OE21958 - Low Levels of Tritium Found in Groundwater at Calvert Cliffs, Tritium and Generic Implications Presentation prepared for the site's Nuclear
- Safety Review Board, and
- Corporate Radiological Release Audit Project Plan.
Procedure
- CP-224, Rev. 13, Monitoring radioactivity in systems normally
uncontaminated
Procedure
- CP-501, Rev. 10, Liquid and steam sampling techniques
Procedure
- QL-2-100, Rev. 20, Corrective Action Program Section 4OA5: Other Activities Implementation of Temporary Instruction (TI) 2515/165 - Operational Readiness of Offsite Power and Impact on Plant Risk
- AOP-7M, "Major Grid Disturbances", Rev 1
- OAP 91-09, "Communications for Load Reduction or Outage"
- OAP 94-5, "Guidelines for Nuclear Plant Operat ions Support for Electric System Operation and Planning Department", Rev 10
- OCP--3, "Planning and Scheduling", Rev 0
- Attachment Operations Coordination and Interconnection Agreement between Baltimore Gas and Electric Company and Constellation Power Source Generation, INC., May 1 2003
- NO-1-117, "Integraded Risk Management", Rev 15
- 4R01Reactor Vessel Head Replacement Inspection Post-Installation Testing:
- MO#
- 1200404115, Containment Polar Crane 180/25 TON/Periodic Inspection
- CCNPP Technical Procedure HE-05
- CCNPP Technical Procedure HE-55
- Visual Examination for Leakage(VT-2), Report No. CC06-BV-079
- ESP No. ES200200485/ES200300312, various supplements, Form 4, Record of Walkdown Storage: Storage of U-1 Old Reactor Vessel Head (ORVH), Map Rev. 0
- TSP Modifications:
- Presentation, RV
- MPR Associates Inc., April 4, 2006 letter to Constellation Energy Group, Calvert Cliffs Unit 1
- Closeout Letter for Independent Review of Thimble Support Plate Modifications
- Constellation letter, 3/31/2006, Exemption of Class B Requirements for the RCS
Procedure
- Field Change Request, Field Change No.
- FCR-013, Traveler for Installation of the
- Replacement TSP and Thimble at Calvert Cliffs Condition Reports:
- IRE-012-607
- IRE-012-644
- IRE-012-737
- IRE-013-293
- IRE-012-917
- IRE-011-923
- Other: Calvert Cliffs UFSAR, Table 4-2, Reactor Vessel Parameters
- AREVA Letter of Qualification Waiver, 3/10/2006
- Attachment
LIST OF ACRONYMS
ADAMSAgencywide Documents
Access and Management SystemASMEAmerican Society of Mechanical Engineers
AOPAbnormal Operating Procedure
ATWSAnticipated Transient Without Scram
CAPCorrective Action Program
CCNPPCalvert Cliffs Nuclear Power Plant
CEAControl Element Assembly
CEDECommitted Effective Dose Equivalent
CEDMControl Element Drive Mechanism
CFRCode of Federal Regulations
CRCondition Report
CROControl Room
CWDCCirculating Water Discharge Conduit
ECCSEmergency Core Cooling System
EDGEmergency Diesel Generator
EHCElectro Hydraulic Control
EOPEmergency Operating Procedure
EPEmergency Preparedness
EPEmergency Plan
E-PlanEmergency Plan
FMEForeign Material Exclusion
HDRHigh Dose Rate
HPHealth Physics
HVACHeating, Ventilation, and Air Conditioning
IMCInspection Manual Chapter
IPEIndividual Plant Examination
IRIssue Report
ISTInService Testing
LERLicensee Event Report
LCOLimiting Condition Operation
NRCNuclear Regulatory Commission
OAOther Activities
OSOccupational Safety
PARSPublicly Available Records
PIPerformance Indicators
PI&RProblem Identification & Resolution
pCi/lPico-curies per Liter
AttachmentRCS Reactor Coolant SystemRPMRadiation Protection Manager
RWPRadiation Work Permit
SCBASelf-Contained Breathing Apparatus
SDPSignificance Determination Process
SRWService Water
SSCSystems, Structures, and Components
SSDSub-Surface Drain
TSTechnical Specifications
UFSARUpdated Final Safety Analysis Report