IR 05000317/2013004
| ML13309B550 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 11/04/2013 |
| From: | Schroeder D L Reactor Projects Branch 1 |
| To: | Gellrich G H Constellation Energy Nuclear Group |
| Schroeder D L | |
| References | |
| IR-13-004 | |
| Download: ML13309B550 (38) | |
Text
November 4, 2013
Mr. George H. Gellrich, Vice President Calvert Cliffs Nuclear Power Plant Constellation Energy Nuclear Group, LLC 1650 Calvert Cliffs Parkway Lusby, Maryland 20657-4702
SUBJECT: CALVERT CLIFFS NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000317/2013004 AND 05000318/2013004
Dear Mr. Gellrich:
On September 30, 2013, the U.S. 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 October 16, 2013, 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 one NRC-identified finding of very low safety significance (Green). The finding was determined to involve a violation of NRC requirements. Additionally, a licensee-
identified Severity Level IV non-cited violation (NCV) is listed in this report. However, because of their very low safety significance, and because they have been entered into your corrective action program, the NRC is treating these findings as NCVs, consistent with Section 2.3.2 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 Calvert Cliffs. In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at Calvert Cliffs. 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 Publicly Available Records component of NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,/RA/ Daniel L. Schroeder, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Nos: 50-317 and 50-318 License Nos: DPR-53 and DPR-69
Enclosure:
Inspection Report 05000317/2013004 and 05000318/2013004
w/Attachment:
Supplementary Information
cc w/encl: Distribution via ListServ
SUMMARY
IR 05000317/2013004, 05000318/2013004; 07/01/2013 - 09/30/2013; Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2; Post-Maintenance Testing.
The report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. One Green finding, which was a non-cited violation (NCV), was identified. The significance of most findings is indicated by their color (i.e.,
greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process," dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, "Components Within the Cross-Cutting Areas," dated October 28, 2011. All violations of NRC requirements are dispositioned in accordance with the NRC's Enforcement Policy, dated July 9, 2013. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
Cornerstone: Barrier Integrity
Green: The inspectors identified an NCV of Technical Specifications 5.4.1, "Procedures," for the failure of Constellation Energy Nuclear Group (CENG) personnel to establish, implement, and maintain maintenance requirements associated with No. 21 atmospheric dump valve (ADV). Specifically, CENG personnel failed to perform an adequate post-maintenance test (PMT) in accordance with the work instructions for the No. 21 ADV following maintenance and prior to its return to service. As a result, the valve was returned to service in a condition where its containment isolation function was inoperable. Immediate corrective actions included entering this issue into the corrective action program (CAP). Additional corrective actions taken or planned include training Maintenance shop personnel on writing condition reports (CRs) for all failed PMTs and for Operations to ensure that work orders involving ADVs include post-maintenance operability tests for containment closure. The finding is more than minor because it is associated with the human performance attribute of the Barrier Integrity cornerstone and affected the cornerstone objective to provide reasonable assurance that physical design barriers (containment) protect the public from radionuclide releases caused by accidents or events. Specifically, the No. 21 ADV was returned to service in a condition where its containment isolation function was inoperable. In addition, the finding is similar to IMC 0612, Appendix E, Example 5.b, in that, the system was returned to service prior to resolution of the degraded condition. The inspectors evaluated the finding using IMC 0609, Appendix A, "The Significance Determination Process for Findings at Power," Exhibit 3, "Barrier Integrity Screening Questions." The inspectors determined that this finding was of very low safety significance (Green) because the finding does not represent an actual open pathway in the physical integrity of reactor containment.
Specifically, there was no loss of steam generator tube integrity. Also, the finding did not involve an actual reduction of hydrogen igniters in the reactor containment. The inspectors determined that the finding has a cross-cutting aspect in the area of Problem Identification and Resolution, CAP component, because CENG staff did not ensure that issues potentially impacting nuclear safety were promptly identified, fully evaluated, and that actions are taken to address safety issues in a timely manner, commensurate with their safety significance. Specifically, CENG staff did not implement a CAP with a low threshold for identifying issues such as writing a CR following the identification that the ADV was degraded P.1(a). (Section 1R19)
Other Findings
A Severity level IV NCV that was identified by CENG staff has been reviewed by the inspectors. Corrective actions taken or planned by CENG staff have been entered into CENG's CAP. This violation and corrective action tracking number are listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status Unit 1 began the inspection period at 100 percent power. On July 1, July 19, and August 15, 2013, operators reduced power to 85 percent, 80 percent, and 87 percent respectively, to perform main condenser waterbox cleaning. Operators returned the unit to 100 percent power on July 2, July 21, and August 18 respectively. On September 20, operators reduced power to 83 percent to perform main turbine valve testing. Operators returned the unit to full power on September 21. The unit remained at or near 100 percent power for the remainder of the inspection period.
Unit 2 began the inspection period at 100 percent power. On August 1, 2013, operators performed an unplanned power reduction to 85 percent power due to the failure of the No. 21 circulating water pump. Operators returned the unit to 100 percent power the same day. On August 9 and August 17, operators reduced power to 84 percent and 92 percent respectively to perform main condenser waterbox cleaning, returning the unit the 100 percent power the same day. On August 12, operators performed an unplanned power reduction to 83 percent due to the loss of vacuum in the No. 12A main condenser waterbox. Operators returned the unit to 100 percent power on August 14. On September 5, operators performed a technical specifications required shutdown due to control element assembly (CEA) 27 dropping to the bottom of the core. Operators performed a unit reactor startup commenced on September 9.
The unit reached 100 percent power on September 10. The unit remained at or near 100 percent power for the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity 1R04 Equipment Alignment Partial System Walkdowns (71111.04Q - 4 samples)
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems: No. 12 saltwater (SW) header during maintenance on No. 11 SW pump on July 18, 2013 1B emergency diesel generator (EDG) during maintenance on 1A EDG on July 22, 2013 No. 12A service water (SRW) heat exchanger (HX) during maintenance on No. 12B SRW HX on July 23, 2013 No. 23 SW pump during maintenance on No. 21 SW pump on August 9, 2013 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable procedures, system diagrams, the Updated Final Safety Analysis Report (UFSAR), technical specifications, CRs, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether CENG staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization. Documents reviewed for each section of this inspection report are listed in the attachment.
b. Findings
No findings were identified.
1R05 Fire Protection
Resident Inspector Quarterly Walkdowns (71111.05Q - 6 samples)
a. Inspection Scope
The inspectors conducted a tour of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that CENG personnel controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.
Unit 1, turbine building, 12' elevation, room 601 on July 18, 2013 Unit 2, turbine building, 12' elevation, room 607 on July 18, 2013 Unit 1, SRW pump room, fire area 39, room 226 on August 27, 2013 Unit 2, SRW pump room, fire area 40, room 205 on August 27, 2013 Unit 1, auxiliary feedwater (AFW) pump room, fire area 42, room 603 on September 5, 2013 Unit 2, AFW pump room, fire area 43, room 605 on September 5, 2013
b. Findings
No findings were identified.
1R06 Flood Protection Measures
Internal Flooding Review
a. Inspection Scope
The inspectors reviewed the UFSAR, the site flooding analysis, and plant procedures to assess susceptibilities involving internal flooding. The inspectors also reviewed the CAP to determine if CENG staff identified and corrected flooding problems and whether operator actions for coping with flooding were adequate. The inspectors focused on the 1B EDG and 2B EDG rooms to verify the adequacy of equipment seals located below the flood line, floor and water penetration seals, watertight door seals, common drain lines and sumps, sump pumps, level alarms, control circuits, and temporary or removable flood barriers.
b. Findings
No findings were identified.
1R07 Heat Sink Performance (711111.07A - 1 sample)
a. Inspection Scope
The inspectors reviewed the No. 21 component cooling HX to determine its readiness and availability to perform its safety functions. The inspectors reviewed the design basis for the component and verified CENG's commitments to NRC Generic Letter 89-13. The inspectors observed actual performance tests for the HXs and/or reviewed the results of previous inspections of the No. 21 component cooling HX and similar HXs. The inspectors verified that CENG staff initiated appropriate corrective actions for identified deficiencies. The inspectors also verified that the number of tubes plugged within the HX did not exceed the maximum amount allowed.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Quarterly Review of Licensed Operator Requalification Testing and Training
a. Inspection Scope
The inspectors observed licensed operator simulator testing on September 3, 2013, which included implementation of Abnormal Operating Procedure (AOP)-1A, "Inadvertent Boron Dilution," AOP-3G, "Malfunction of Main Feedwater System," AOP-2A, "Excessive Reactor Coolant Leakage," AOP-7K, "Overcooling Event in Mode One or Two," Emergency Operating Procedure (EOP)-0, "Post Trip Immediate Actions," EOP-4, "Loss of All Feedwater," and EOP-8, "Functional Recovery Procedure." The inspectors evaluated operator performance during the simulated events and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager and the technical specification action statements entered by the shift technical advisor. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.
b. Findings
No findings were identified.
.2 Quarterly Review of Licensed Operator Performance in the Main Control Room
a. Inspection Scope
The inspectors observed and reviewed operator response to a dropped CEA on Unit 2, the implementation of AOP-1B, CEA Malfunctions, and a technical specification required plant shutdown on September 5, 2013 per OP-4, Plant Shutdown from Power Operation to Hot Standby, and OP-5, Plant Shutdown from Hot Standby to Cold Shutdown.
Additionally, the inspectors observed procedure use and adherence, crew communications, and coordination of activities between work groups to verify that established expectations and standards were met.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structures, systems, and components (SSCs) performance and reliability. The inspectors reviewed system health reports, CAP documents, maintenance work orders, and maintenance rule basis documents to ensure that CENG was identifying and properly evaluating performance problems within the scope of the maintenance rule. For each sample selected, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with 10 CFR 50.65 and verified that the (a)(2) performance criteria established by CENG staff was reasonable. As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2). Additionally, the inspectors ensured that CENG staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.
No. 12 charging pump discharge pressure gauge piping leak on August 21, 2013 No. 12 SW pump rotated backwards after shutdown on August 21, 2013 No. 12 emergency core cooling system pump room cooler basket strainer drain line leak on August 22, 2013
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that CENG staff performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that CENG personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When CENG performed emergent work, the inspectors verified that Operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the station's probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.
Unplanned maintenance on 1A EDG on July 22, 2013 Dual unit high risk due to reserve battery modification on No. 11 direct current bus on August 5, 2013 Unit 1 emergent down power due to debris in No. 12A waterbox and No. 12 SW header on August 13, 2013
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed operability determinations for the following degraded or non-conforming conditions: CR-2013-005671, Unit 2, channel "A" reactor coolant system (RCS) low flow trip setpoint voltage found at maximum specification during STPM-212A-2 CR-2013-005710, No. 11 SW pump high thrust bearing temperature CR-2013-006014, 2A EDG high vibrations trend in generator end bearing CR-2013-006914, 1A EDG ventilation damper failed in the open position CR-2013-007019, Unit 2, CEA dropped due to lift coil wire ground CR-2013-007114, No. 21 SW header through wall leak The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether technical specification operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and UFSAR to CENG's evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by CENG. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.
b. Findings
No findings were identified.
1R18 Plant Modifications
Permanent Modifications
a. Inspection Scope
The inspectors evaluated a modification to the 1A EDG implemented by Engineering Change Package 13-000685, "Change motor control center breaker setting from 800 to 900 amps for 1A2 EDG fan 13 breaker 52-12322." The inspectors verified that the design bases, licensing bases, 10 CFR 50.59 screening and performance capability of the affected system was not degraded by the modification. In addition, the inspectors reviewed modification documents associated with the upgrade and design change, including operational impact design evaluation, installation and testing instructions, and drawings changes associated with the modifications.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the PMTs for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability.
The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure were consistent with information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.
Replace 1A2 fan 13 breaker on 1A EDG on July 22, 2013 Replace No. 12 AFW pump speed controller 1/P3989B on August 13, 2013 Repair No. 21 ADV on March 23, 2013 Replace No. 11 AFW control valve current to pressure transducers (1-I/P-4511A and 1-I/P-4511B) on August 21, 2013 Repair air leaks on 2A EDG air start system on August 29, 2013 Replace Unit 2 CEA-27 coil stack on September 8, 2013
b. Findings
Introduction:
The inspectors identified a Green NCV of Technical Specification 5.4.1, "Procedures," for the failure of CENG personnel to establish, implement, and maintain maintenance requirements associated with No. 21 ADV.
Specifically, CENG personnel failed to perform an adequate PMT in accordance with the work instructions for the No. 21 ADV following maintenance and prior to its return to service.
Description:
On March 24, 2013, during Unit 2 plant heat up following the refueling outage, operators used No. 21 ADV to control plant temperature. Operators observed an intermediate indication in the control room on the ADV controller when the valve was taken to the shut position. Operators questioned the actual valve position, determined that the ADV was leaking by its seat, and gave direction to isolate the ADV using manual isolation valve MS-101. Operators entered the technical specifications action statement for containment isolation valves and generated CR-2013-002897.
The inspectors reviewed the evaluation associated with CR-2013-002897 and noted CENG personnel performed maintenance on this valve during the Unit 2 refueling outage. The evaluation for CR-2013-002897 stated that the CR was generated while the work was still in progress, the problem had been resolved, and no further corrective actions were needed. The inspectors reviewed the work order (C91510073) associated with the maintenance on No. 21 ADV during the refueling outage. The PMTs assigned were a stroke test and leak check. The work order stated that on March 21, 2013, during the stroke of the valve, air bleed off could be heard continuously from the valve positioner when the valve was in the shut position. Supervision and Component Engineering personnel were informed. However, no CR was written and Operations personnel were not informed. Subsequently, due to miscommunications, CENG personnel inadvertently changed the ADV work order status to "complete" prior to resolution of the leak.
In accordance with Figure 5-10 in the UFSAR, the No. 21 ADV is a containment isolation valve. Technical Specification limiting conditions for operation 3.6.3, "Containment Isolation Valves," require the valve to be operable in Modes 1 through 4. Operations entered Mode 4 at 3:15 a.m. on March 22, 2013, and discovered the leaking valve on March 24, 2013.
The inspectors concluded that the PMT, as conducted, was inadequate in that it did not verify the containment isolation function of the valve. As a result, the valve was restored to service with the valve in a condition where its containment isolation function was inoperable. The failure to perform an adequate PMT is considered NRC-identified because CENG staff did not identify the inadequate PMT under review of CR-2013-002897. CENG staff subsequently documented the failure to conduct an adequate PMT for the No. 21 ADV under a separate CR (CR-2013-006238).
Immediate corrective actions included entering this issue into the CAP as CR-2013-006238. CENG staff conducted an evaluation of CR-2013-006238 and determined that the most probable causes of the failure to perform an adequate PMT prior to restoring the No. 21 ADV following maintenance were the failure to write a CR when the degraded condition was identified and the failure to inform Operations of the degraded condition.
Additional corrective actions taken or planned include repair of the No. 21 ADV, training Maintenance shop personnel on writing CRs for all failed PMTs, and for Operations personnel to ensure that work orders involving ADVs include post-maintenance operability tests for containment closure.
Analysis:
The inspectors determined that the failure to perform an adequate PMT on the No. 21 ADV following maintenance and prior to its return to service was a performance deficiency that was within the CENG staff's ability to foresee and correct, and should have been prevented. The finding is more than minor because it is associated with the human performance attribute of the Barrier Integrity cornerstone and affected the cornerstone objective to provide reasonable assurance that physical design barriers (containment) protect the public from radionuclide releases caused by accidents or events. Specifically, the No. 21 ADV was returned to service inoperable for its containment isolation function. In addition, the finding is similar to IMC 0612, Appendix E, "Examples of Minor Issues," Example 5.b, in that the system was returned to service prior to resolution of the degraded condition. The inspectors evaluated the finding using IMC 0609, Appendix A, "The Significance Determination Process for Findings at Power,"
Exhibit 3, "Barrier Integrity Screening Questions." The inspectors determined that this finding was of very low safety significance (Green) because the finding does not represent an actual open pathway in the physical integrity of reactor containment. Specifically, there was no loss of steam generator tube integrity. Also, the finding did not involve an actual reduction of hydrogen igniters in the reactor containment.
The inspectors determined that the finding has a cross-cutting aspect in the area of Problem Identification and Resolution, CAP component, because CENG staff did not ensure that issues potentially impacting nuclear safety are promptly identified, fully evaluated, and that actions are taken to address safety issues in a timely manner, commensurate with their safety significance. Specifically, CENG staff did not implement a CAP with a low threshold for identifying issues such as writing a CR following the identification that the ADV was degraded P.1(a).
Enforcement:
Technical Specification 5.4.1, "Procedures," states, in part, written procedures shall be established, implemented, and maintained covering the following activities: The applicable procedures recommended by Regulatory Guide (RG) 1.33, Revision 2, Appendix A, February 1978. Section 9.a of Appendix A to RG 1.33 states, in part, maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Contrary to the above, prior to entering Mode 4 on March 22, 2013, CENG personnel did not perform an adequate PMT in accordance with written instructions in the work order C91510073 for the No. 21 ADV. As a result, the valve was returned to service in a condition where the containment isolation function of the valve was inoperable. Immediate corrective actions included entering this issue into the CAP as CR-2013-006238. Additional corrective actions taken or planned include repair of the No. 21 ADV, coaching Maintenance shop personnel on writing CRs for all failed PMTs, and for Operations to ensure that work orders involving ADVs include post-maintenance operability tests for containment closure. Because this violation was of very low safety significance (Green) and was entered into CENG's CAP (CR-2013-006238), the issue is being treated as an NCV, consistent with Section 2.3.2.a of the NRC Enforcement Policy. (NCV-05000318/2013004-01: Inadequate Post-Maintenance Test Associated with an Atmospheric Dump Valve)
1R20 Refueling and Other Outage Activities
a. Inspection Scope
The inspectors reviewed the station's work schedule and outage risk plan for the Unit 2 forced outage to replace CEA No. 27. The forced outage was conducted on September 5 through September 9, 2013.
The inspectors reviewed CENG staff's development and implementation of outage plans and schedules to verify that risk, industry experience, previous site-specific problems, and defense-in-depth were considered. During the outage, the inspectors observed portions of the shutdown and cooldown processes and monitored controls associated with the following outage activities: Configuration management, including maintenance of defense-in-depth, commensurate with the outage plan for the key safety functions and compliance with the applicable technical specifications when taking equipment out of service Status and configuration of electrical systems and switchyard activities to ensure that technical specifications were met Activities that could affect reactivity Repair activities Containment walkdown and closeout prior to reactor startup Reactor and plant startup
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied technical specifications, the UFSAR, and CENG's procedural requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:
Unit 2, I-523-2, Functional Check of No. 24 4 KV Bus Shutdown Sequencer on July 19, 2013 Unit 2, STP-M-212C-2, Reactor Protection System Channel "C" Functional Test on July 26, 2013 Unit 2, STP-M-171-2, Personnel Airlock Gasket Seal Test on August 23, 2013 Unit 2, STP-O-073C-2, Component Cooling Pump Quarterly Test on September 18, 2013 (in-service test)
b. Findings
No findings were identified.
Cornerstone:
Emergency Preparedness 1EP4 Emergency Action Level and Emergency Plan Changes (71114.04 - 1 Sample)
a. Inspection Scope
The Office of Nuclear Security and Incident Response headquarters staff performed an in-office review of the latest revisions of various Emergency Plan Implementing Procedures and the Emergency Plan located under ADAMS accession number ML13198A301 as listed in the Attachment.
CENG staff determined that in accordance with 10 CFR 50.54(q), the changes made in the revisions resulted in no reduction in the effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR 50, "Emergency Planning and Preparedness For Production and Utilization Facilities." The NRC review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, this revision is subject to future inspection.
b. Findings
No findings were identified.
1EP6 Drill Evaluation
Training Observations
a. Inspection Scope
The inspectors observed two simulator training evolutions for licensed operators on August 6, 2013 and September 3, 2013, which required emergency plan implementation by operations crews. CENG staff planned for these evolutions to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crews. The inspectors also attended the post-evolution critiques for the scenarios. The focus of the inspectors' activities was to note any weaknesses and deficiencies in the crews' performance and ensure that CENG evaluators noted the same issues and entered them into the CAP.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstone:
Public Radiation Safety and Occupational Radiation Safety
2RS3 In-Plant Airborne Radioactivity Control and Mitigation
a. Inspection Scope
From July 15 through 18, 2013, the inspectors verified in-plant airborne concentrations were being controlled consistent with 'As Low as is Reasonably Achievable (ALARA)' principles and the adequacy of respiratory protection devices used. The inspectors used the requirements in 10 CFR 20; the guidance in RG 8.15, "Acceptable Programs for Respiratory Protection;" RG 8.25, "Air Sampling in the Workplace;" NUREG-0041, "Manual of Respiratory Protection Against Airborne Radioactive Material;" technical specifications; and CENG's procedures required by technical specifications as criteria for determining compliance.
Inspection Planning
The inspectors reviewed the Respiratory Protection Program. The inspectors reviewed the UFSAR, technical specifications, and emergency planning documents to identify the location and quantity of respiratory protection devices stored for emergency use. The inspectors reviewed the procedures for maintenance, inspection, and use of respiratory protection equipment including self-contained breathing apparatus (SCBA), as well as, procedures for air quality maintenance. The inspectors reviewed reported performance indicators to identify any related to unintended dose resulting from intakes of radioactive material.
Engineering Controls The inspectors reviewed airborne monitoring protocols by evaluating whether the alarms and set-points for one installed system used to monitor and warn of changing airborne concentrations in the plant are sufficient.
Use of Respiratory Protection Devices The inspectors selected one work activity where respiratory protection devices were used to limit the intake of radioactive materials, and assessed whether CENG staff performed an evaluation concluding that further engineering controls were not practical and that the use of respirators is ALARA. The inspectors also evaluated whether CENG staff had established means to determine if the level of protection provided by the respiratory protection devices during use was adequate.
The inspectors assessed whether respiratory protection devices used to limit the intake of radioactive materials were certified by the National Institute for Occupational Safety and Health/Mine Safety and Health Administration. The inspectors selected one work activity where respiratory protection devices were used. The inspectors evaluated whether the devices were used consistent with their National Institute for Occupational Safety and Health/Mine Safety and Health Administration certification.
The inspectors reviewed records of air testing for supplied-air devices and SCBA bottles to assess whether the air used in these devices meets or exceeds Grade D quality. The inspectors reviewed plant breathing air supply systems to determine whether they meet the minimum pressure and airflow requirements for the devices in use.
The inspectors selected three individuals qualified to use respiratory protection devices, and assessed whether they were deemed qualified to use the devices by successfully passing an annual medical examination, respirator fit-test and relevant respiratory protection training.
The inspectors selected three individuals assigned to wear a respiratory protection device and observed them donning, doffing, and functionally checking the device. Through interviews with these individuals, the inspectors evaluated whether they knew how to safely use the device and how to properly respond to any device malfunction or unusual occurrence (loss of power, loss of air, etc.).
The inspectors chose ten respiratory protection devices staged and ready for use in the plant. The inspectors assessed the physical condition of the device components and reviewed records of equipment inspection for each type of equipment. The inspectors selected several of the devices and reviewed records of maintenance on the vital components. The inspectors verified that onsite personnel assigned to repair respiratory protection equipment have received vendor-provided training.
SCBA for Emergency Use The inspectors reviewed the status and surveillance records of selected SCBAs staged in-plant for use during emergencies. The inspectors reviewed CENG staff's capability for refilling and transporting SCBA air bottles to and from the control room and the operations support center during emergency conditions. The inspectors selected three individuals on control room shift crews and from designated departments currently assigned emergency duties, to assess whether control room operators and other emergency response and radiation protection personnel were trained and qualified in the use of SCBA. The inspectors evaluated whether personnel assigned to refill bottles were trained and qualified for that task. The inspectors determined whether appropriate mask sizes and types are available for use. The inspectors determined whether on-shift operators had no facial hair that would interfere with the sealing of the mask to the face and whether vision correction mask inserts were available, as appropriate. The inspectors reviewed the past two years of maintenance records for two SCBA units to assess whether any maintenance and repairs on any SCBA units were performed by an individual, or individuals, certified by the manufacturer of the device to perform the work. For those SCBAs that were ready for use, the inspectors verified that the required periodic air cylinder hydrostatic testing was documented and up to date.
Problem Identification and Resolution The inspectors evaluated whether problems associated with the control and mitigation of in-plant airborne radioactivity were being identified by CENG personnel at an appropriate threshold and were properly addressed for resolution in CENG's CAP.
The inspectors assessed whether the corrective actions were appropriate for a selected sample of problems involving airborne radioactivity and were appropriately documented by CENG staff.
b. Findings
No findings were identified.
2RS4 Occupational Dose Assessment
a. Inspection Scope
From July 15 through 18, 2013, the inspectors verified that occupational dose is appropriately monitored, assessed and reported by CENG staff. The inspectors used the requirements in 10 CFR 20, "Standards For Protection Against Radiation;" the guidance in RG 8.13, "Instructions Concerning Prenatal Radiation Exposures;" RG 8.36, "Radiation Dose to Embryo Fetus;" RG 8.40, "Methods for Measuring Effective Dose Equivalent from External Exposure;" technical specifications; and CENG's procedures required by technical specifications as criteria for determining compliance.
Inspection Planning
The inspectors reviewed the most recent National Voluntary Laboratory Accreditation Program report on the principal dosimetry used to establish dose of legal record.
External Dosimetry The inspectors evaluated whether CENG's dosimetry vendor is National Voluntary Laboratory Accreditation Program accredited and if the approved irradiation test categories for each type of personnel dosimeter used are consistent with the types and energies of the radiation present. The inspectors evaluated the onsite storage of dosimeters, during use, and before processing/reading. The inspectors also reviewed the guidance provided to radiation workers.
The inspectors assessed the use of electronic personal dosimeters (EPDs) to determine if CENG staff uses a "correction factor" to correct the response of the EPD as compared to the dosimeter of legal record for situations when the EPD is used to assign dose and whether the correction factor is based on sound radiation protection principles. The inspectors reviewed three dosimetry occurrence reports or CAP documents for adverse trends related to EPDs. The inspectors assessed whether CENG staff had identified any adverse trends and implemented appropriate corrective actions.
Internal Dosimetry Routine Bioassay (In Vivo) The inspectors reviewed procedures used to assess the dose from internally deposited radionuclides using whole body count (WBC) equipment. The inspectors evaluated whether the procedures addressed methods for differentiating between internal and external contamination, the release of contaminated individuals, determining the route of intake, and the assignment of dose.
The inspectors reviewed the WBC process to determine if the frequency of measurements was consistent with the biological half-life of the radionuclides available for intake.
The inspectors reviewed CENG staff's evaluation for use of its portal radiation monitors as a passive monitoring system. The inspectors assessed if the instrument's minimum detectable activities were adequate to determine the potential for internally deposited radionuclides. The inspectors selected two WBCs and evaluated whether the counting system used had sufficient counting time/low background to ensure appropriate sensitivity for the potential radionuclides of interest. The inspectors reviewed the radionuclide library used for the count system to determine if it included the gamma-emitting radionuclides that exist at the site. The inspectors evaluated how CENG staff accounts for hard-to-detect radionuclides in their internal dose assessments.
Special Bioassay (In Vitro)
The inspectors selected two internal dose assessments obtained using WBCs.
There were no internal dose assessments obtained using urinalysis or fecal sample results for the inspector to review.
Internal Dose Assessment - Airborne Monitoring The inspectors reviewed CENG's program for dose assessment based on airborne monitoring and calculations of derived air concentration internal dose. CENG staff had not performed any internal dose assessments using airborne/derived air concentration monitoring during the period reviewed.
Internal Dose Assessment - WBC Analyses The inspectors reviewed two dose assessments performed by CENG staff using the results of WBC analyses. The inspectors determined whether affected personnel were properly monitored with calibrated equipment and that internal exposures were assessed consistent with CENG's procedures Special Dosimetric Situations Declared Pregnant Workers The inspectors assessed whether CENG staff informs workers of the risks of radiation exposure to the embryo/fetus, the regulatory aspects of declaring a pregnancy, and the specific process to be used for (voluntarily) declaring a pregnancy.
The inspectors reviewed the records for two individuals who had declared pregnancy during the current assessment period and evaluated whether CENG's radiological monitoring program (internal and external) for declared pregnant workers is technically adequate to assess the dose to the embryo/fetus. The inspectors reviewed exposure results and monitoring controls that were implemented.
Dosimeter Placement and Assessment of Effective Dose Equivalent for External Exposures The inspectors reviewed CENG staff's methodology for monitoring external dose in non-uniform radiation fields or where large dose gradients exist. The inspectors evaluated CENG staff's criteria for determining when alternate monitoring, such as use of multi-badging, is to be implemented.
The inspectors reviewed selected dose assessments performed using multi-badging to evaluate whether the assessment was performed consistent with requirements. Shallow Dose Equivalent The inspectors reviewed two dose assessments for shallow dose equivalent for adequacy. The inspectors evaluated CENG staff's method for calculating shallow dose equivalent from distributed skin contamination or discrete radioactive particles.
Neutron Dose Assessment The inspectors evaluated CENG's neutron dosimetry program, including dosimeter types and radiation survey instrumentation.
The inspectors reviewed several neutron exposure occurrences and assessed whether (a) dosimetry and/or instrumentation was appropriate for the expected neutron spectra, (b) there was sufficient sensitivity for low dose and/or dose rate measurement, and (c)neutron dosimetry and/or neutron detection instruments were properly calibrated. The inspectors also assessed whether interference by gamma radiation had been accounted for in the calibration and whether time and motion evaluations were representative of actual neutron exposure events, as applicable.
Assigning Dose of Record For the dosimetry evaluations reviewed in this section, the inspectors assessed how CENG staff assigns dose of record for total effective dose equivalent, shallow dose equivalent, and lens dose equivalent. This included an assessment of external and internal monitoring results, supplementary information on individual exposures, and radiation surveys when dose assignment was based on these techniques.
Problem Identification and Resolution The inspectors assessed whether problems associated with occupational dose assessment are being identified by CENG personnel at an appropriate threshold and are properly addressed for resolution in CENG's CAP. The inspectors assessed the appropriateness of the corrective actions for a selected sample of problems documented by CENG involving occupational dose assessment.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
.1 Mitigating Systems Performance Index
a. Inspection Scope
The inspectors reviewed CENG staff's submittal of the Unit 1 and Unit 2 Mitigating Systems Performance Index for the following systems for the period July 1, 2012 through June 30, 2013:
Emergency alternating current power system (MS06) High pressure injection system (MS07) Heat removal system (MS08) Residual heat removal system (MS09) Cooling water system (MS10) To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline,"
Revision 6. The inspectors also reviewed CENG's operator narrative logs, CRs, event reports, system health reports, and NRC integrated inspection reports to validate the accuracy of the submittals.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review of Problem Identification and Resolution Activities
a. Inspection Scope
As required by Inspection Procedure 71152, "Problem Identification and Resolution," the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that CENG personnel entered issues into the CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the CAP.
b. Findings
No findings were identified.
.2 Annual Sample:
Measuring and Test Equipment tolerance variations potentially not evaluated by maintenance for safety-related torque applications
a. Inspection Scope
The inspectors performed an in-depth review of CENG staff's evaluation and corrective actions associated with the use of torque guns on safety-related maintenance applications. Specifically, between February 2012 and June 2013, torque guns were maintained in the Measuring and Test Equipment (M&TE) Calibration Program, and authorized for use in safety-related applications. During this same time, this model of M&TE showed unreliability and repeated failures of calibration, resulting in the September 2012 manufacturer change in specifications from percent of reading to percent of full scale.
The inspectors interviewed plant personnel and performed an in-depth review of the corrective action history related to the calibration performance history of the torque guns. Additionally, the inspectors performed a review of CAP items involving M&TE that had either been used in the improper application or had failed calibration. The inspectors also performed a review of work performed using failed M&TE in order to evaluate the adequacy of CENG staff's usage assessments performed following calibrations failures.
b. Findings and Observations
No findings were identified.
The inspectors determined the final actions taken to remove the M&TE in question from the M&TE Program and limit their use as a tool were appropriate. However, a weakness in the use of the CAP was observed, in that these corrective actions were taken outside of the normal corrective action process per CENG procedure CNG-CA-1.01-1000, "Corrective Action Programs." The use of torque guns that have repeated calibration failures in safety-related applications is a condition adverse to quality because it has the potential to affect CENG staff's ability to ensure M&TE used in safety-related applications is accurate within necessary limits. While corrective actions were assigned to fulfill requirements of CENG procedure MN-2-100, "Control and Calibration of Measuring and Test Equipment," to perform usage assessments of failed M&TE, there were no corrective actions assigned to evaluate the actual use of guns in safety-related applications, and the ultimate decision to remove these torque guns from the M&TE Program was not the result of an official CAP corrective action. The inspectors determined that the failure to identify the condition adverse to quality within the normal CAP was not more than minor because the review of work in question revealed no instances where the use resulted in equipment deficiencies or the failure to meet acceptance criteria. Additionally, the inspectors noted a weakness in the consistency of detail and rigor involved in M&TE usage assessments required per CENG procedure MN-2-100, "Control and Calibration of Measuring and Test Equipment." Specifically, some assessors did not provide the procedurally required basis for determinations that out-of-calibration conditions did not have an effect on plant equipment. This deficiency was not more than minor as the inspectors' review did not determine that the inadequate usage assessment failed to detect such instances where the use of the torque gun resulted in equipment deficiencies or the failure to meet acceptance criteria.
4OA3 Followup of Events and Notices of Enforcement Discretion
.1 Plant Events
a. Inspection Scope
On September 5, 2013, the inspectors observed operator's response when CEA No. 27 on Unit 2 dropped to the bottom of the core during a CEA surveillance. The inspectors reviewed and observed plant parameters; reviewed personnel performance; and evaluated performance of mitigating systems. The inspectors communicated the plant events to appropriate regional personnel, and compared the event details with criteria contained in IMC 0309, "Reactive Inspection Decision Basis for Reactors," for consideration of potential reactive inspection activities. As applicable, the inspectors verified that CENG personnel made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR 50.72 and 50.73. The inspectors reviewed CENG staff's follow-up actions related to the events to assure that CENG staff implemented appropriate corrective actions commensurate with their safety significance.
b. Findings
No findings were identified.
.2 (Closed) Licensee Event Report (LER) 05000317/2012-003-00 and 2012-003-01:
Plant Shutdown Completed Due to Control Element Assembly Misalignment On August 12, 2012, Unit 1 shutdown group CEA 9 dropped to the fully inserted position into the reactor core. At the time of the event, Unit 1 was operating at 100 percent rated thermal power and no planned CEA motions were in progress. Operators entered the applicable technical specifications action statement for the dropped CEA. Operators determined that the CEA alignment could not be restored within the required completion time and entered Technical Specifications limiting conditions for operation 3.1.4.F, which required the unit to be in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The CEA dropped due to the failure of the control element drive mechanism (CEDM) upper gripper coil. CENG staff's initial investigation determined that the upper gripper coil failed due to an internal short circuit most likely caused by a defect in the windings. Corrective actions included replacement of the CEDM coil stack and testing of all coil stacks to identify any additional coil degradation. Subsequent to the issuance of this LER, CENG staff identified through testing the potential degradation of CEA 37. As a result, CENG conducted additional analysis and submitted a revised LER. CENG staff determined that the most probable cause was degradation in the CEDM cooling system. A contributing cause was potential low margin in the CEDM cooling system. Corrective actions included replacement of the CEDM coil stack, adjusting the holding voltage, periodic testing to identify coil degradation, and review of CEDM cooling system operation. The inspectors reviewed the LER for accuracy, the adequacy of proposed and completed corrective actions, and the appropriateness of the extent-of-condition review. The inspectors did not identify any findings or violations of NRC regulatory requirements. This LER is closed.
.3 (Closed) LER 05000318/2013-001-00:
Reactor Coolant System Pressure Boundary Leakage in Valve Leakoff Line Weld On February 17, 2013, while Unit 2 was in Mode 3 during a refueling outage, CENG personnel identified that RCS pressure boundary leakage existed on Unit 2 pressurizer spray valve, 2CV-100F, upper packing leakoff line cap seal weld. CENG staff determined that the source of the leak was a pinhole in the cap seal fillet weld. Based on visual inspection performed during a routine boric acid walkdown, the leak most likely existed during plant operation. The cause of the leak was a latent weld defect created during the installation of the cap seal weld. Corrective actions included replacement of the valve bonnet assembly, which includes the packing leakoff line, and inspection of the new bonnet assembly prior to the startup from the refueling outage. Valve 2CV-100F is not normally accessible by plant personnel during plant operation at power. This LER reported that Calvert Cliffs Nuclear Power Plant had been in violation of Technical Specifications limiting conditions of operation 3.4.13.a, which limits pressure boundary leakage during plant operation to zero. This issue was entered into CENG's CAP as CR-2013-001245.
The inspectors reviewed the LER for accuracy as well as CENG staff's evaluation of the cause of the RCS leakage, the adequacy of proposed and completed corrective actions, and the appropriateness of the extent-of-condition review. This event was similar to the event reported in LER 50-318/2010-002-00. The failed seal weld on 2CV-100F was installed prior to the failure identified in the 2010 LER, so corrective actions instituted after the 2010 LER would not have prevented the leakage at 2CV-100F. The enforcement aspects of this issue are discussed in Section 4OA7. The inspectors did not identify any new issues during the review of the LER. This LER is closed.
.4 (Closed) LER 05000318/2013-003-00:
Reactor Trip Due to Intermittent Failure in the Turbine Control System On May 8, 2013, Unit 2 experienced an automatic reactor trip from full power. A reactor protection system high pressurizer pressure condition generated the reactor trip signal, which was the result of a loss of load event when the main turbine steam admission valves closed. CENG staff determined that the most probable cause of the event was an intermittent failure of a component or signal in a main turbine control system cabinet. Plant systems responded as designed for this event. Although the root cause of the suspected main turbine control system intermittent malfunction was not identified, CENG personnel replaced four circuit cards from the turbine overspeed protection control circuitry. The removed cards were sent off for laboratory analysis, which also did not identify a definite root cause (one failed logic gate was identified but was not confirmed to be the cause of the event). Since a root cause was not identified, CENG staff installed test equipment in the main control cabinet and connected recording devices to monitor control system signals in an effort to identify whether intermittent erroneous or spurious signals were apparent (ECP-13-000492, "Temporary Change to Monitor Unit 2 Main Turbine Controls for Perturbations"). In addition, CENG personnel are planning to implement a project plan to replace selected turbine control system circuit cards and/or replace the main turbine control system within the next several years. The inspectors identified no findings or violations of NRC requirements during the review of the LER. This LER is closed.
.5 (Closed) LER 05000318/2013-004-00:
Manual Reactor Trip Due to 22 Steam Generator Feed Pump Trip On May 21, 2013, CENG operators initiated a manual reactor trip on Unit 2 from full power, in response to a trip of No. 22 Steam Generator Feed Pump (SGFP). The cause of the initiating event was the failure of the No. 22 SGFP coupling that connects the pump to its steam turbine driver, effectively disconnecting the pump and the steam turbine. Inspection of the failed coupling identified defects dating to the original component manufacture. The root cause of the failure was determined to be these original defects combined with high cycle stress on the coupling. Corrective actions included examination and replacement of the No. 22 SGFP coupling.
The LER was reviewed by the inspectors. The inspectors identified no findings or violations of NRC requirements. This LER is closed.
4OA5 Other Activities
.1 Temporary Instruction 2515/190 - Inspection of the Proposed Interim Actions Associated with Near-Term Task Force Recommendation 2.1 Flooding Reevaluations
The inspectors independently verified that CENG staff's proposed interim actions would perform their intended function for flooding mitigation.
Visual inspection of the flood protection features were performed if the flood protection features were relevant. External visual inspection for indications of degradation that would prevent its credited function from being performed was performed Reasonable simulation, if applicable to the site Flood protection features functionality were determined using either visual observation or by review of other documents. The inspectors verified that issues identified were entered into the CENG's CAP.
.2 Institute of Nuclear Power Operations (INPO) Report Review
a. Inspection Scope
The inspectors reviewed the final report for the Institute of Nuclear Power Operations plant assessment of Calvert Cliffs Nuclear Power Plant conducted October 2012. The inspectors evaluated this report to ensure that NRC perspectives of CENG staff's performance were consistent with any issues identified during the assessments. The inspectors also reviewed the report to determine whether INPO identified any significant safety issues that required further NRC follow-up.
b. Findings
No findings were identified
.3 Correction to Inspection Report 05000317/2013003 and 05000318/2013003
Inspection Report 05000317/2013003 and 05000318/2013003, Section 1EP6, "Drill Evaluation," inadvertently documented the completion of 2 samples. Only 1 sample was completed. The training observation inspection sample documented was not completed on June 8, 2013. This sample was completed on August 6, 2013, and documented in Section 1EP6 of this report.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On October 16, 2013, the inspectors presented the inspection results to George Gellrich, Site Vice President, and other members of the CENG staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
4OA7 Licensee-identified Violations
The following Severity Level IV violation of NRC requirements was identified by CENG staff and met the criteria of the NRC Enforcement Policy for being disposition as an NCV.
On February 17, 2013, while Unit 2 was in Mode 3 during a refueling outage, CENG personnel identified a pinhole leak at the upper packing leakoff line cap seal weld of pressurizer spray valve 2CV-100F, which constituted RCS pressure boundary leakage. Technical Specifications limiting condition for operation 3.4.13.a, "RCS Operational Leakage," limits pressure boundary leakage during plant operation to zero. With any RCS pressure boundary leakage, the technical specifications require the operating unit to be in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to be in Mode 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Contrary to the above, based on review of boric acid walkdown data, RCS pressure boundary leakage existed sometime after the last boric acid walkdown conducted in Unit 2 2011 refueling outage and continued during operation for a time longer than allowed by the technical specifications. The inspectors determined that no performance deficiency existed because CENG satisfactorily tested the component using appropriate non-destructive testing prior to installation, identified the boundary leakage through the use of an prescribed monitoring program (boric acid leakage monitoring) and the monitoring frequency was appropriate for the system location (component location inside containment is inaccessible during reactor operation).
The inspectors reviewed LER 2013-001-00 and determined that traditional enforcement applies in accordance with IMC 0612, Section 0612-09 and 0612-13 and Enforcement Policy, Section 2.2.4.d, because a violation of NRC requirements existed without an associated significance determination process performance deficiency. This issue was considered to be a Severity Level IV NCV of Technical Specifications limiting condition for operation 3.4.13.a, in accordance with Enforcement Policy, Section 6.1.d. In addition, the inspectors also evaluated this finding using IMC 0609, Attachment 4, "Phase 1 - Initial Screening and Characterization of Findings." The inspectors screened the issue and determined that RCS leakage is considered a loss of coolant accident initiator, and evaluated it using the Initiating Event criteria in Appendix A. Assuming worst case degradation, the leakage would not result in exceeding the technical specifications limit for identified RCS leakage (10 gallons per minute) nor would the leakage have likely affected other mitigation systems resulting in a total loss of their safety function. This severity level IV licensee-identified NCV was entered into CENG's CAP as CR-2013-001245.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
CENG Personnel
- G. Gellrich, Site Vice President
- M. Flaherty, Plant General Manager
- R. Courtney, Radiation Protection Supervisor
- H. Crockett, Supervisor, Engineering
- H. Daman, Manager, Maintenance
- D. Dellario, Manager, Engineering Services
- J. Gaines, General Supervisor, Shift Operations
- K. Gould, General Supervisor, Radiation Protection
- R. Haley, Site Fire Marshall
- S. Henry, Manager, Operations
- D. Lauver, Director, Licensing
- C. Merritt, Senior Project Manager,
- R. Nelson, Engineering Supervisor
- C. Neyman, Senior Engineering Analyst, Licensing
- H. Olsen, Senior Engineering Analyst
- B. Pickett, Radiation Protection Supervisor
- A. Simpson, Supervisor, Licensing
- T. Unkle, Engineering Analyst, Licensing
- J. York, General Supervisor, Chemistry
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened and Closed
- 05000318/2013004-01 NCV Inadequate Post-Maintenance Test Associated with an Atmospheric Dump Valve (Section 1R19)
Closed
- 05000317/LER-2012-003-00 LER Plant Shutdown Completed Due to Control Element Assembly Misalignment (Section 4OA3.2)
- 05000317/LER-2012-003-01 LER Plant Shutdown Completed Due to Control Element Assembly Misalignment (Section 4OA3.2)
- 05000318/LER-2013-001-00 LER Reactor Coolant System Pressure Boundary Leakage in Valve Leakoff Line Weld (Section
- 4OA3.3)
- 05000318/LER-2013-003-00 LER Reactor Trip Due to Intermittent Failure in the Turbine Control System (Section 4OA3.4)
- Attachment
- 05000318/LER-2013-004-00 LER Manual Reactor Trip Due to 22 Steam GeneratorFeed Pump Trip (Section 4OA3.5)
LIST OF DOCUMENTS REVIEWED
Section 1R04: Equipment Alignment
Procedures
- OI-21B-1, 1B Diesel Generator, Revision 20
- OI-21A-1, 1A Diesel Generator, Revision 22
- OI-15-1, Service Water System, Revision 45
- OI-29-1, Saltwater System, Revision 66
- OI-29-2, Saltwater System, Revision 59
Drawings
- 60706Sh0002, Service Water Cooling System Auxilary Building and Containment, Revision 77 60708Sh0002, Circulating Saltwater Cooling System, Revision 113
- 60727Sh0002, Diesel Generator Cooling Water, Starting Air, Fuel, & Lube Oil Diesel No.1B, Revision 63
Section 1R05: Fire Protection
Procedures
- FP-0002, Fire Hazards Analysis Summary Document, Revision 0
- SA-1-100, Fire Prevention, Revision 16
- SA-1-105, Fire Brigade Training, Revision 00101
Miscellaneous
- Fire Fighting Strategies Manual, U-1 Auxiliary Feedwater Pump Room, Revision 1
- Fire Fighting Strategies Manual, U-2 Auxiliary Feedwater Pump Room, Revision 1
Section 1R06: Flood Protection Measures
Miscellaneous
- ES-001, Flooding, Revision 04
Section 1R07: Heat Sink Performance
Procedures
- EN-1-327, Service Water Reliability Program (Generic Letter 89-13), Revision 00500
- OI-16-2, Component Cooling System, Revision 29
Condition Reports
- CR-2011-009223
- CR-2011-009921
Section 1R11: Licensed Operator Requalification Program
Procedures
- OP-03-1, Normal Power Operation, Revision 06206
- Attachment
- AOP1B, CEA Malfunctions, Revision 03002
- AOP-2A-1, Excessive Reactor Coolant Leakage, Revision 02303
- AOP-7K-1, Overcooling Event in MODE One or Two, Revision 0300
- EOP-00-1, Post Trip Immediate Actions, Revision 01201
- EOP-08-1, Functional Recovery Procedure, Revision 03404
Section 1R12: Maintenance Effectiveness
Procedures
- CNG-AM-1.01-1023, Maintenance Rule Program, Revision 00201 NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 2
Condition Reports
- CR-2012-007167
- CR-2013-000254
- CR-2013-006125
- CR-2013-006448
- CR-2013-006737
- CR-2013-006805
- CR-2013-006808 CR-2013-006879
Section 1R13: Maintenance Risk Assessments and Emergent Work Control
Procedures
- Maintenance Rule Risk Assessment Guideline, Revision 7
- CNG-OP-4.01-1000, Integrated Risk Management, Revision 00900
- CNG-OP-4.01-1000 Attachment 9, High Risk Activity Plan, Dated 7/28/2011
- CNG-OM-1.01-1001, Shutdown Safety Management Program" Revision 00200
- NO-1-103, Conduct Lower Mode Operations, Revision 02901
- NO-1-200, Control of Shift Activities, Revision 04902 EOOS Guidelines - Dominant Risk Activities, Revision 0
- OAP 02-02, Protected Equipment Program, Revision 30
- EOOS Risk Monitor Guidelines - Senior Reactor Operators, Revision 1
Condition Reports
- CR-2013-006334
- CR-2013-005993
- CR-2013-006505
Section 1R15: Operability Determinations and Functionality Assessments
Procedures
- CNG-OP-1.01-1002, Conduct of Operability Determinations / Functionality Assessments, Revision 00201
- CNG-CA-1.01-1000, Corrective Action Program, Revision 00900
- Attachment
- STP-M-212A-2, Channel "A" Reactor Protection System Functional Test, Revision 00702
- STP-O-29-2, CEA Free Movement Test, Revision 15/Unit 2
- STP-M-213-1, Calibration of Nuclear Instrumentation by Comparison with Incore Nuclear Instrumentation, Revision 02400
Condition Reports
- CR-2013-005710
- CR-2013-006914
- CR-2013-005671
- CR-2013-006014
- CR-2013-007019
- CR-2013-007114
- CR-2013-007303
- CR-2013-007352
Section 1R18: Plant Modifications
Procedure
- CNG-CM-1.01-1004, Temporary Plant Configuration Change Process, Revision 00201
- NEI 96-07, Guidelines for 10
- CFR 50.59 Implementation, Revision 1
- CNG-CM-1.01-1003, Design Engineering and Configuration Control, Revision 00601
- E-048, Inspection and Testing of ITE, Siemens, Westinghouse, and Cutler Hammer Molded Case Circuit Breakers, Revision 0
Condition Reports
- CR-2013-000289
- CR-2013-005993
Miscellaneous
- ECP-13-000685, Relay Setting and Coordination, Revision 0007
Section 1R19: Post-Maintenance Testing
Procedures
- CNG-OP-1.01-1007, Clearance & Safety Tagging, Revision 01000
- CNG-MN-4.01-GL002, Post Maintenance Test and Post Maintenance Operability Test Requirements Guideline, Revision 00000
- NO-1-208, Calvert Cliffs Operability and Maintenance Testing, Revision 01900
- STP-O-5A-1, Auxiliary Feedwater System Quarterly Surveillance Test, Revision 02502
- CNG-MN-4.01-1008, Pre/Post Maintenance Testing, Revision 00100
- STP-O-008A-1, Test of 1A DG and 11 4KV Bus LOCI Sequencer, Revision 28 E-048, Inspection and Testing of ITE, Siemens, Westinghouse, and Cutler Hammer Molded Case Circuit Breakers, Revision 0
Condition Reports
- IRE-007-798
- CR-2010-009510
- CR-2010-009512
- CR-2010-012575
- CR-2012-003044
- CR-2012-003075
- CR-2012-005083
- CR-2013-005868
- CR-2013-002897
- Attachment
- CR-2012-006238
- CR-2012-005083
Work Orders
- C91635275
- C91635285
- C91510073
- C92226552
- C91880819
- C92415425
- C91635287
- C91880819
- C91886380
- C91953207
- C92364627
Section 1R20: Refueling and Outage Activities
Procedure
- OP-3-2, Normal Power Operation, Revision 04910
- OP-4-2, Plant Shutdown from Power Operation to Hot Standby, Revision 01902
- OP-5-2, Plant Shutdown from Hot Standby to Cold Shutdown, Revision 02704
- OP-7-2, Shutdown Operations, Revision 04800
- NO-1-103, Conduct of Lower Mode Operations, Revision 02902
- OI-3A, Safety Injection and Containment Spray, Revision 26
- CNG-OM-1.01-1001, Shutdown Safety Management Program, Revision 00400
- OAP-10-03, Operations Refueling Outage Guidelines, Revision 6
- NO-1-104, Containment Access, Revision 01900
- OI-3B-2, Shutdown Cooling, Revision 25
Section 1R22: Surveillance Testing
Procedures
- I-523-2, Functional Check of No.24 4Kv Bus Shutdown Sequencer, Revision 00001
- STP-M-212C-2, Channel "C" Reactor Protective System Functional Test, Revision 00802
- STP-M-171-2, Personnel Air Lock Gasket Test, Revision 01701
- STP-O-073C-2, Component Cooling Pump Quarterly Test, Revision 11
Work Orders
- C91995763
- Drawing 62710sh0002, Component Cooling System, Revision 28
Section 1EP4: Emergency Action Level and Emergency Plan Changes
Procedures
- Emergency Response Plan, Revision 45, Change 01
- ERPIP-3.0, "Immediate Actions," Revision 52
Section 1EP6: Drill Evaluation
Procedures
- NEI-99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6
- Attachment Condition Report CR-2013-006244
Section 2RS3: In-Plant Airborne Radioactivity Control and Mitigation
Procedures
- 01-20A, Fire Protection Performance Evaluations and Fire System Inspections, Revision 01803
- CNG-RP-1.01-3001, Alpha Monitoring and Control, Revision 00100
- RP-1, Radiation Protection Program, Revision 2
- RP-1-100, Radiation Protection, Revision 01001
- RP-CCRRPM, Radiological Respiratory Protection Manual, Revision 1
- RP-RSMAN, Calvert Cliffs Radiation Safety Manual, Revision 00302
- RSP-1-101, Routine Radiological Surveys, Revision 02900
- RSP-1-104, Area Posting and Barricading, Revision 02500
- RSP-1-115, Radiological Air Sampling Program, Revision 01400
- RSP-1-117, Issuance and Wearing of Respiratory Protection Devices Used to Protect Against Airborne Radioactivity, Revision 01301
- RSP-1-131, Operation of the
- AMS-4, Revision 00500
- RSP-1-132, Job Coverage in Radiologically Controlled Areas, Revision 01601
- RSP-1-200, RWP Preparation, Revision 02800
- RSP 2-301, Respiratory Protection Device Maintenance, Revision 01404
- RSP 2-304, Operation of the Bauer Breathing Air Compressor, Revision 00100
- RSP 3-690, Generation of Control Charts for Counter Scaler Systems, Revision 00500
- Corrective Action DocumentsCR-2012-001417
- CR-2012-001436
- CR-2012-002579
- CR-2013-000097
- CR-2013-001436 CR-2013-005374
Section 2RS4: Occupational Dose Assessment
Procedures
- CNG-RP-1.01-2001, Dosimetry, Revision 00000
- CNG-RP-1.01-2002, Effective Dose Equivalent - External (EDEX), Revision 00000
- PHP-3-301, Internal Dose Calculations, Revision 3
- PHP-1-107, Skin Dose Calculations, Revision 5
- RSP-3-102, Personnel Radiation Dose Control, Revision 01201
- RSP-3-201, Personnel Dosimetry, Revision 00900
- RSP-3-202, Special Dosimetry, Revision 01400
- RSP-3-203, Direct Reading Dosimeter Use, Revision 6
- RSP-3-204, Direct Reading Dosimeter Inventory and Testing, Revision 5
- RSP-3-211, Electronic Personal Dosimeter Use, Revision 00301
- RSP-3-301, Bioassay Assessment Criteria and Requirements, Revision 01300
- RSP-3-350, Bioassay Specimen Controls, Revision 3
- Corrective Action Documents
- CR-2012-000197
- CR-2012-001729
- CR-2012-008445
- CR-2012-009647
- CR-2012-011253
- CR-2013-000149
- Attachment
Section 4OA1: Performance Indicator Verification
Miscellaneous
- Mitigating Systems Performance Index Basis Document, Revision 3 System Health Report, Containment Spray, Unit 1 and 2, 1st Quarter 2013 System Health Report, Electrical 4kV Transformers and Buses, Unit 1 and 2, 1st Quarter 2013 System Health Report, Emergency Diesel Generator Building HVAC, Unit 1, 1st Quarter 2013 System Health Report, Safety Injection, Unit 1 and 2, 1st Quarter 2013 System Health Report, Salt Water Cooling, Unit 1 and 2, 1st Quarter 2013 System Health Report, Service Water, Unit 1 and 2, 1st Quarter 2013 Operator Narrative Logs, Unit 1 and 2, 1/1/13 - 2/28/13
Section 4OA2: Problem Identification and Resolution
- Procedures:
- CNG-CA-1.01-1000, Corrective Action Program, Revision 00901
- MN-2, Measuring and Test Equipment Program, Revision 3
- MN-2-100, Control and Calibration of Measuring and Test Equipment, Revision 00901
- Condition Reports:
- CR-2011-002436
- CR-2012-000420
- CR-2012-000936
- CR-2012-000937
- CR-2012-002128
- CR-2012-004354
- CR-2012-006793
- CR-2012-008701
- CR-2012-009545
- CR-2012-010357
- CR-2013-003998
- CR-2013-004000
- CR-2013-006845
- CR-2013-006886
- Work Order
- C120064715
- C120064715
- C120064794
- C220073802
- C220093681
- C90465729
- C90465729
- C90747849
- C90803246
- C90829283
- C90945918
- C90948742
- C90949446
- C90949446
- C90949743
- C90997309
- C91096975
- C91097065
- C91097719
- C91159035
- C91189903
- C91189903
- C91199883
- C91418444
- C91429873
- C91436720
- C91482046
- C91482532
- C91503677
- C91514712
- C91677828
- C91848840
- C92209188
Section 4OA3: Follow-up of Events and Notices of Enforcement Discretion
Procedure
Condition Reports
- CR-2012-010826
- CR-2013-001245
- CR-2013-003412
- CR-2013-004520
- Attachment Miscellaneous
- ECP-13-000492, Temporary Change to Monitor Unit 2 Main Turbine Controls for Perturbations, Revision 0
Section 4OA5: Other Activities
Condition Reports
- CR-2013-007383
Procedures
- ERPIP 3.0, Attachment 20, Emergency Response Plan Implementation Procedure, Immediate Actions, Severe Weather, Revision 05101
- EP-1-108, Severe Weather Preparation, Revision 00801
Miscellaneous
- Letter from J. A. Spina (CENG) to U.S. NRC, dated March 12, 2013, Flood Hazard Reevaluation Report Letter from M. G. Korsnick (CENG) to U.S. NRC, dated September 6, 2013, Supplement to Flood Hazard Reevaluation Report Regulatory Commitments Letter from M. G. Korsnick (CENG) to U.S. NRC, dated November 27, 2012, Response to 10
- CFR 50.54(f) Request for Information, Recommendation 2.3, Flooding Calculation E-91-03, Assessment of Service Life of GE Model 5K634X
- Attachment
LIST OF ACRONYMS
- LLC [[]]