Semantic search
Jump to navigation
Jump to search
| Quarter | Site | Title | Description | |
|---|---|---|---|---|
| 05000317/FIN-2007005-01 | 2007Q4 | Calvert Cliffs | Timely NRC Notification of SRO License Restriction | The inspectors review of a licensed SROs medical records revealed that an ongoing condition necessitated a medication that would require a no solo license restriction. The SRO did not report his medical condition change in May 2003 to Constellation or the NRC. The Constellation physician assistant discovered the new medication prescribed to the SRO during a routine physical in January 2005, and determined that it was for a medical condition that required a no solo license restriction. Constellation reported the issue to the NRC and processed the required documentation to have the SROs license amended to include the no solo condition. An Unresolved Item (URI) will track NRC evaluation of this issue until additional NRC review determines whether Constellation personnel failed to timely notify the NRC of a medical condition that resulted in an SRO license restriction and, therefore, was in violation of 10 CFR 50.74. (URI 05000317 & 05000318/2007005-01, Timely NRC notification of SRO license restriction) |
| 05000317/FIN-2008002-01 | 2008Q1 | Calvert Cliffs | Unit 1 Reactor Coolant System Pressurizer Pressure Boundary Leakage | The inspectors determined that additional inspection was required for the inactive leak on the heater sleeve penetration in the pressurizer bottom head. Technical Specifications 3.4.13 RCS Operational Leakage, states that RCS operational leakage shall be limited to no pressure boundary leakage in Modes 1 through 4. Contrary to this requirement, on February 25, 2008, Constellation identified RCS deposits indicated that the sleeve welds had been leaking during the previous operating cycle. The penetration sleeves are part of the RCS pressure boundary. The leak was discovered during scheduled visual examination of the pressurizer head penetration area. Constellation entered this issue into their CAP (CR IRE-029-507) to complete a cause analysis and reportability review. An unresolved item (URI) has been opened to track this issue pending review of Constellations evaluation to determine if a performance deficiency exists. (URI 05000317/2008002-01. Unit 1 Reactor Coolant System Pressurizer Pressure Boundary Leakage) |
| 05000317/FIN-2008002-02 | 2008Q1 | Calvert Cliffs | Inadequate Risk Assessment Associated with the 2A Emergency Diesel Generator | The inspectors identified an NCV of 10 CFR Part 50.65 (a)(4) because Constellation did not assess and manage the increase in risk that resulted from maintenance activities on the alternate feeder breaker for the No. 21 4kV safety bus. On December 5, 2007, operators removed the 2A emergency diesel generator (EDG) from service in preparation for maintenance on the No. 21 4kV bus alternate feeder breaker. However, probabilistic risk analysis (PRA) services personnel were not aware that this maintenance activity affected the ability of the 2A EDG to load on the No. 21 4kV safety bus. As a result, the unavailability of the 2A EDG was not included as part of the risk assessment. Constellation reassessed the risk associated with this maintenance activity and entered this issue into their CAP. Planned corrective action included a re-evaluation of how Constellation models the impact of the work performed on the No. 21 4kV bus alternate feeder breaker and similar breakers. The finding is more than minor because Constellations risk assessment did not consider risk significant structures, systems, and components (SSCs) (i.e. 2A EDG) that were unavailable during the maintenance activity. The finding is associated with the configuration control attribute of the Mitigating Systems cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors determined that the finding is of very low safety significance because the incremental core damage probability (ICDP) was less than 1.0E-6. This finding has a cross-cutting aspect in the area of human performance, because Constellation did not appropriately plan and incorporate risk insights in work activities associated with the No. 21 4kV alternate feeder breaker maintenance (H.3.a) |
| 05000317/FIN-2008002-03 | 2008Q1 | Calvert Cliffs | DID Not Implement Scaffolding Procedure Requirement | The inspectors identified a finding of very low safety significance associated with an NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, because Constellation did not adequately implement scaffolding control requirements contained in MN-1-203, Scaffold Control. Specifically, Constellation did not perform engineering evaluations for scaffolding constructed within the minimum allowed distance of safety-related equipment. Constellation entered this issue into their CAP for resolution, took prompt actions to correct the scaffolds, and provided evaluations to assess the affect of the scaffold on the equipment. The evaluations determined that the scaffolds did not adversely affect the plant equipment. The inspectors determined that this finding is more than minor, because it is similar to example 4.a in Appendix E of IMC 0612 in that Constellation routinely did not perform evaluations for scaffolds constructed within the minimum allowed distance of safety related equipment. It is associated with the external factors and equipment performance attributes of the Mitigating Systems cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The finding is of very low safety significance, because the finding is not a design or qualification deficiency, did not represent a loss of a safety function, and did not screen as potentially risk significant due to external events. This finding has a cross-cutting aspect in the area of human performance because Constellation did not effectively communicate expectations regarding work practices to workers who constructed scaffolding or to supervisors that routinely monitor these activities to follow procedural requirements (H.4.b) |
| 05000317/FIN-2008002-04 | 2008Q1 | Calvert Cliffs | Inadequate Procedures for Draining and Venting the Reactor Coolant System | The inspectors identified an NCV of Technical Specifications (TS) 5.4.1.a, Procedures, because Constellation did not establish and maintain adequate procedures to vent the reactor vessel head (RVH). On February 25, 2008, operators drained the Unit 1 reactor vessel in preparation for removal of the RVH. When the RVH vent line was disconnected, the reactor coolant level unexpectedly decreased approximately 1 foot. Constellation determined that the unexpected change in level was most likely due to a RVH void that developed while draining the reactor coolant system (RCS) following the emptying of the steam generator tubes with compressed air. The inspectors identified that Constellation did not establish and maintain adequate procedures for venting a RVH void that may occur during draining of the RCS. Immediate corrective actions included restoring the reactor vessel level and entering this issue into their corrective action program (CAP) for resolution. This finding is more than minor because it is associated with the procedure quality attribute of the Initiating Events cornerstone and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown operations. Specifically, the inadequate procedures for venting the RVH increased the likelihood of the loss of RCS level control and consequently a loss of decay heat removal initiating event. The inspectors determined that this finding is of very low safety significance because a quantitative assessment was not required since the loss of RCS level control did not occur during mid-loop operations. The inspectors determined that this finding has a cross-cutting aspect in the area of human performance because Constellation did not ensure that the procedures for draining and venting the RCS were complete and accurate (H.2.c per IMC 0305) |
| 05000317/FIN-2008003-01 | 2008Q2 | Calvert Cliffs | Inadequate Design Control Associated with the Safety Related 480V Mccs | The inspectors identified a finding of very low safety significance associated with an NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control, because Constellation did not correctly translate the design basis maximum expected temperature for the west penetration rooms into the specification for the safety related 480 volt (V) motor control centers (MCCs) located on the 45 foot elevation of the auxiliary building of Units 1 and 2. As a result, Constellation did not recognize that the postulated loss of coolant accident (LOCA) temperature exceeded the design temperature limit for the MCCs. Constellations immediate corrective action included entering this condition into their corrective action program (CAP) and de-rating the MCCs to ensure the operability of the MCCs would be maintained during a design basis event. The planned corrective actions include a re-analysis of the maximum expected room temperature for the west penetration rooms. The finding is more than minor because it is similar to example 3.i. in Appendix E of IMC 0612 in that the facility was not consistent with the Updated Final Safety Analysis Report (UFSAR) and the actual specification of the MCCs required that accident analysis calculations be re-performed to ensure that requirements were met. The finding is associated with the design control attribute of the Mitigating Systems cornerstone. The finding is of very low safety significance because the finding is a design or qualification deficiency confirmed not to result in a loss of operability per Part 9900, Technical Guidance, Operability Determination Process for Operability and Functional Assessments |
| 05000317/FIN-2008003-02 | 2008Q2 | Calvert Cliffs | Inadequate Measures to Implement Eals for LOW Bay Water Level | The inspectors identified an NCV of 10 CFR 50.47(b)(4) and Appendix E to 10 CFR 50, Sections IV.B and IV.C because Constellation did not have a clear method to assess and determine the bay water level such that the emergency action level (EAL) classification process would declare an Unusual Event (UE) or Alert in a timely manner. Following a lower than normal tide event which caused high debris loading across the trash racks, the inspectors determined that operators did not have adequate procedure guidance in place and readily available indication to determine actual bay water level. Constellation entered this issue into their CAP for resolution and took actions to establish compensatory measures to monitor the bay water level pending the development of permanent corrective actions. The inspectors determined that this finding is more than minor because it is associated with the Emergency Preparedness cornerstone attributes of procedure quality and equipment, and affects the cornerstone objective to ensure that Constellation is capable of implementing adequate measures to protect the health and safety of the public in the event of an emergency. Specifically, the lack of procedural guidance and readily available indication increases the likelihood of Constellation not being able to make an EAL classification in a timely manner based on bay water level to protect the saltwater pumps and other equipment needed for safe shutdown. The finding is of very low safety significance because the finding did not result in a loss or degraded Risk-Significant Planning Standard (RSPS) Function. It is also similar to examples of green findings in Appendix B of section 4.4 in IMC 0609 in that the EAL classification process would not declare any Alert or Notification of UE that should be declared. This finding has a cross-cutting aspect in the area of problem identification and resolution because Constellation did not thoroughly evaluate problems associated with bay water level measurement such that the resolution addresses causes and extent of conditions, as necessary (P.1.c per IMC 0305 |
| 05000317/FIN-2008003-03 | 2008Q2 | Calvert Cliffs | Licensee-Identified Violation | CCNPP TS LCO 3.6.6, Containment Spray and Cooling System, states, in part, that two CS trains and two containment cooling trains shall be operable. That is with one CS train inoperable, restore the CS train to an operable status within 72 hours. Contrary to this, from September 7, 2007, to September 14, 2007, one CS train was inoperable and Constellation did not restore the CS train to an operable status within 72 hours. Constellation entered this issue in their CAP under IRE-025-517. This finding is of very low safety significance based on a SDP Phase 2 screening utilizing CCNPP Phase 2 pre-solved table for exposure times between 3 and 30 days for one inoperable train of CS |
| 05000317/FIN-2008003-04 | 2008Q2 | Calvert Cliffs | Pressure Boundary Leakage Caused by Primary Water Stress Corrosion Cracking | On February 25, 2008, dry boric acid was noted on pressurizer heater sleeve C-2 indicating reactor coolant leakage. The leakage was detected during the pressurizer heater sleeve bare metal visual examination which is performed every RFO per the Alloy 600 Program Plan and the Boric Acid Corrosion Control Program. Subsequent ultrasonic examination confirmed the existence of an axial flaw. All other pressurizer heater sleeves were inspected with no additional findings. The licensee determined that the most likely cause of the leak is PWSCC. The heater sleeve was repaired by installing an approved mechanical nozzle seal assembly clamp at heater sleeve location C-2 on the Calvert Cliffs Unit 1 pressurizer prior to restart of Unit 1 from the 2008 RFO. Additional corrective actions planned include repair/replacement of all Unit 1 Pressurizer Heater Sleeves by 2012, which will eliminate their susceptibility to PWSCC. This preventive action was established due to similar events discussed in LERs 318/89-007 and 317/94-003. Calvert Cliffs Unit 1 had several pressurizer heater sleeve failures in 1990 and another in 1994. In 1994, the heater sleeves were nickel plated in Unit 1 to mitigate the known failure mechanism. Between 1994 and 2008 there were no failures identified. Constellation had conducted visual inspections each RFO and formally committed to the NRC to continue these inspections in response to NRC Bulletin 2004-01. Constellation had developed an inspection schedule and approved contingency repair technique for the 2006 and 2008 refueling outages. In addition, a long-term replacement strategy to replace the pressurizer heater sleeves during the 2010 and 2012 RFOs had been planned and approved. Due to the programs put in place for enhanced monitoring, repair contingency and planned replacement of the pressurizer heater sleeves, no performance deficiency was identified. An immediate event notification report was made pursuant to 10 CFR 50.72(b)(3)(ii)(A). CCNPP TS LCO 3.4.13, Reactor Coolant System Operational Leakage, which allows no pressure boundary leakage while in Modes 1 through 4. The discovery of pressure boundary leakage, although in Mode 5, indicates that the flaw existed in Mode 1 most likely for a period longer than the 6-hour completion time allowed under Condition 3.4.13.B. This event did not result in any actual nuclear safety consequences. The risk associated with the issue was determined using IMC 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings. The inspectors screened the issue and determined that RCS leakage was considered a LOCA initiator and was evaluated using the Initiating Event Criteria in Attachment 4. Assuming worst-case degradation, the leakage would not result in exceeding the TS limit for unidentified RCS leakage (1 gpm) nor would the leakage have likely affected other mitigation systems resulting in a total loss of their safety function. As a result, this issue screens as very low safety significance (Green). Because this issue is of very low safety significance and because the inspectors concluded that the RCS pressure boundary leak resulted from an equipment failure that was not avoidable by the implementation of reasonable quality measures or management controls, the NRC has decided to exercise enforcement discretion in accordance with VII.B.6 of the NRC Enforcement Policy and refrain from issuing enforcement action for the violation of TS. |
| 05000317/FIN-2008004-01 | 2008Q3 | Calvert Cliffs | Failure to Identify and Correct a Degraded 12 CCHX SW Outlet Valve Positioner in a Timely Manner | The inspectors identified an NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, because Constellation did not promptly identify and correct a condition adverse to quality (CAQ) related to the Unit 1 No. 12 component cooling (CC) heat exchanger (HX) saltwater (SW) outlet control valve (1-CV-5208). Specifically, Constellation did not promptly identify and correct a degraded condition associated with the valves positioner when 1-CV-5208 did not respond as expected during SW flow verifications on May 13, 2008. Consequently, on May 21, 2008, operators declared the valve inoperable because the valve went from full shut to full open with only 25 percent indicated on the controller. The valve responded erratically because the spindle for the valves positioner corroded and would not rotate to control the position of the valve. The corrosion mechanism was due to SW leaking from the valve packing to the actuator housing and onto the positioner. Constellation entered this issue into their corrective action program (CAP) for resolution as IRE-031-916. The immediate corrective actions following the May 21, 2008 event included the removal, inspection, and refurbishment of the positioner. The planned corrective action includes a modification to prevent SW from leaking outside the actuator housing and to perform preventive maintenance activities to detect degradation of the SW control valve positioners. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating System cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of systems (i.e. component heat removal) that respond to initiating events to prevent undesirable consequences. The inspectors evaluated the significance of this finding using Phase 2 and 3 analyses and determined that the finding is of very low safety significance (Green). This finding has a cross-cutting aspect in the area of problem identification and resolution because Constellation did not thoroughly evaluate SW flow control valve issues (P.1.c per IMC 0305). (Section 1R12) |
| 05000317/FIN-2008004-02 | 2008Q3 | Calvert Cliffs | Failure to Establish and Maintain Adequate Procedures for 4 kV Circuit breaker Maintenance | A self-revealing, NCV of Technical Specification (TS) 5.4.1.a, Procedures, was identified because Constellation did not adequately establish and maintain electrical maintenance procedures for 4 kV circuit breakers such that the procedures incorporated torque values and verification steps to ensure the adjustment setscrew for the trip armature was properly tightened. During a surveillance test, on June 21, 2008, the adjustment setscrew backed out which prevented the 13 SRW pump breaker from opening. Constellation entered this issue into their CAP for resolution as IRE-032-517. The immediate corrective actions following the event included the replacement of the locking setscrew and trip coil. The planned corrective actions included the revision of maintenance orders and procedures to ensure that technicians perform peer verifications and check the tightness of the adjustment setscrew following maintenance activities. This finding is more than minor because it is associated with the procedure quality attribute of the Mitigating System cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The finding is of very low safety significance because it is not a design or qualification deficiency, did not represent a loss of a safety function of a system or a single Train greater than its TS allowed outage time, and did not screen as potentially risk significant due to external events. This finding has a cross-cutting aspect in the area of problem identification and resolution because Constellation did not implement and institutionalize operating experience (OE), including internal and external OE to change station processes, procedures, and training programs when similar issues of internal and external events occurred on 4 kV circuit breakers that involved inadequate maintenance procedures (P.2.b). (Section 1R19) |
| 05000317/FIN-2008005-01 | 2008Q4 | Calvert Cliffs | Inadequate Design Control Associated with the Auxiliary Feedwater Pump Room Temperature | The inspectors identified a finding of very low safety significance associated with an NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control, because Constellation did not provide design control measures for verifying the adequacy of a design calculation used to determine the maximum initial temperature for the auxiliary feedwater (AFW) pump room before operators would start emergency ventilation. The AFW pump room emergency ventilation system must be established prior to exceeding a specified maximum initial room temperature to ensure that the AFW pump room temperature would not exceed the 130F Design Basis Accident (DBA) limit. Specifically, Constellation used non-conservative inputs and assumptions in the design calculation that resulted in Constellation not recognizing that the DBA temperature limit could have been exceeded. Constellation entered this issue into their corrective action program (CAP) for resolution. The immediate corrective actions included establishing compensatory requirements for initiating emergency ventilation and conducting a re-analysis of the design calculation. The planned corrective actions includes a modification to install a new automatic starting emergency ventilation system. This finding is more than minor because it is similar to example 3.j. in Appendix E to IMC 0612 in that the non-conservative inputs and assumptions resulted in a condition where it created reasonable doubt on the operability of the turbine-driven AFW (TDAFW) pumps. The finding is associated with the design control attribute of the Mitigating Systems cornerstone and affects the cornerstone objective to ensure the availability and reliability of systems that respond to initiating events to prevent undesirable consequences. The inspectors determined that the finding is of very low safety significance (Green) because the finding is a design and qualification deficiency confirmed not to result in the loss of operability. There is no crosscutting aspect associated with this finding. (Section 1R04.2 |
| 05000317/FIN-2008005-02 | 2008Q4 | Calvert Cliffs | Untimely Corrective Actions Associated with 480 Volt Power Supply Handswitch Disconnects | A self-revealing NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, was identified because Constellation did not take timely corrective actions following the identification of degraded 480 volt power supply handswitch disconnects. This led to the failure of the Unit 1 No. 13 component cooling (CC) pump to start during performance of a surveillance test. The inspectors noted that Constellation had previously identified handswitch disconnects failures in 2006 and 2007. Immediate corrective actions included replacing the handswitch disconnect for the 13 CC pump, conducting an extent of condition review, and entering this condition into their CAP. The finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors determined that the finding was of very low safety significance because the finding does not represent the loss of system safety function, does not represent actual loss of safety function of a single train for greater than its technical specification allowed outage time, and does not screen as potentially risk significant due to external events. The finding has a cross-cutting aspect in the area of problem identification and resolution because Constellation did not take appropriate corrective actions to address safety issues associated with handswitch disconnects in a timely manner commensurate with their safety significance and complexity (P.1.d per IMC 0305). (Section 1R22 |
| 05000317/FIN-2009002-00 | 2009Q1 | Calvert Cliffs | Auxiliary Feedwater Pump Room Emergency Ventilation Low Flow | The inspectors identified an unresolved item (URI) associated with the performance evaluations (PE-1-36-1-O-M and PE-2-36-2-O-M) used to determine if the AFW emergency ventilation system performs satisfactorily in service for Units 1 and 2. Specifically, the performance evaluation did not incorporate the requirements and acceptance limits contained in the Updated Final Safety Analysis Report (UFSAR). Following the inspectors concerns about the AFW pump room emergency ventilation system configuration, Constellation measured the AFW pump room emergency ventilation flow rates. The results of the tests revealed that the flow rates were less than the design requirement stated in the UFSAR. The UFSAR stated, in part, that the emergency ventilation can circulate 2,000 cubic feet per minute (CFM) of air between the mechanical room of the Auxiliary Building at Elevation 50 and the AFW pump room of the Auxiliary Building at Elevation 120. However, Constellation found that the flow rates for each AFW pump room emergency ventilation fan were less than 2,000 CFM. Constellation entered this issue into their CAP for resolution as CR-2008- 002833 and CR-2009-000650 and performed a re-analysis using the degraded flow rates. As a part of the degraded flow rate review, the inspectors identified that the performance evaluation used to determine the equipment performance of the emergency ventilation fan operation did not incorporate the requirements contained in the UFSAR. The inspectors noted that the monthly performance evaluation only checked for air being drawn into the AFW pump room with no acceptance criteria. The inspectors determined that a performance deficiency existed in that Constellation did not establish an adequate test program to assure that the AFW pump room emergency ventilation system would perform satisfactorily in service. Specifically, the performance evaluation did not contain acceptance limits. This resulted in Constellation not recognizing that the AFW pump room emergency ventilation system did not meet the design requirements stated in the UFSAR. This item is unresolved pending further review and investigation of past operability concerns such that the inspectors can determine if the performance deficiency is more than minor. The inspectors need to review the inputs and assumptions used in the re-analysis to determine if the degraded flow rate adversely affected the Mitigating System cornerstone objective to ensure the availability, reliability, and capability of the AFW steam driven pumps |
| 05000317/FIN-2009002-01 | 2009Q1 | Calvert Cliffs | Did Not Follow MSIV Actuator System Procedure | A self-revealing NCV of TS 5.4.1.a, Procedures, was identified because Constellation did not follow procedures for refilling the No. 11 main steam isolation valve (MSIV) actuator accumulator with nitrogen. On February 6, 2009, while lining up to refill the No. 11 MSIV actuator accumulator, operators removed a blank flange which caused nitrogen gas to be released. This resulted in the No. 11 MSIV being inoperable. Immediate corrective actions included reinstallation of the blank flange, refilling the nitrogen accumulator to the required pressure, and conducting a prompt investigation. Constellation entered this issue into their CAP for further evaluation. The inspectors determined that this finding is more than minor because it is associated with the human performance attribute of the Mitigating System cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). The finding is of very low safety significance because it is not a design or qualification deficiency, did not represent a loss of a safety function of a system or a single train greater than its TS allowed outage time, and did not screen as potentially risk significant due to external events. This finding has a cross-cutting aspect in the area of human performance because Constellation did not effectively communicate human error prevention techniques, such as holding an adequate pre-job brief and performing proper self and peer checking (H.4.a) |
| 05000317/FIN-2009002-02 | 2009Q1 | Calvert Cliffs | Inadequate Risk Assessment Associated with the No. 21 Charging Pump | The inspectors identified an NCV of 10 CFR Part 50.65 (a)(4), Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, because Constellation did not assess and manage the increase in risk that resulted from maintenance activities that impacted the availability of the No. 21 charging pump. On February 4, 2009, operators isolated the Unit 2 core flush piping to prevent back-leakage of water from the charging system into one of the safety injection tanks. Isolating the core flush piping also prevented the ability of the No. 21 charging pump to automatically start on a safety injection actuation signal and deliver concentrated boric acid to the reactor coolant system (RCS). The inspectors noted that this function is modeled in the site specific probabilistic risk assessment (PRA) model. However, Constellation did not assess the risk associated with the unavailability of the No. 21 charging pump for an 8 day period. Immediate corrective actions included a re-evaluation of the risk and entering this issue into their CAP for resolution. The finding is more than minor because Constellations risk assessment did not consider risk significant structures, systems, and components (SSCs) (i.e. No. 21 charging pump) that were unavailable during the maintenance activity. The finding is associated with the configuration control attribute of the Mitigating Systems cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors determined that the finding is of very low safety significance because the incremental core damage probability deficit was less than 1.0E-6. This finding has a cross-cutting aspect in the area of human performance, because Constellation did not appropriately plan and incorporate risk insights in work activities associated with maintenance activities that impacted the availability of the No. 21 charging pump (H.3.a) |
| 05000317/FIN-2009002-03 | 2009Q1 | Calvert Cliffs | Did Not Comply with Technical Specification Requirements While Starting Reactor Coolant Pumps | The inspectors identified an NCV of Technical Specifications (TS) 3.4.5, RCS Loops Mode 3, because Constellation did not comply with the required starting conditions for reactor coolant pumps (RCPs) during several plant startups on Unit 1. The inspectors identified a discrepancy between the RCP starting requirements described in the operating instructions (OI) and the RCP starting requirements listed in the TS for loop operability. Specifically, the OI did not provide operators with adequate procedural guidance to meet the Mode 3, 4, and 5 TS RCP starting requirements prior to starting RCPs. Constellation entered this issue into their corrective action program (CAP) for resolution. The immediate corrective actions included revising OI-1A, Reactor Coolant System and Pump Operations, to ensure that the TS starting conditions are met prior to starting any RCPs. This finding is more than minor because it is associated with the procedure quality attribute of the Initiating Events cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, starting a RCP while not meeting the starting requirements could cause a pressure transient and lift a pressurizer PORV. The inspectors determined that the finding is of very low safety significance because it did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions will not be available. This finding has a cross-cutting aspect in the area of human performance because Constellation did not provide complete, accurate, and up-to-date procedures that were adequate to assure nuclear safety. Specifically, OI-1A included requirements that were contrary to the TS and led to the operators failure to comply with the TS when starting RCPs (H.2.c per IMC 0305) |
| 05000317/FIN-2009002-04 | 2009Q1 | Calvert Cliffs | Did Not Follow Radiation Protection Procedures | The inspectors identified an NCV of T.S. 5.4.1.a, Procedures, because Constellation did not implement radiation protection procedural requirements for obtaining airborne radioactivity samples prior to workers entering the Unit 2 steam generators. Specifically, on February 25, 2009, Constellation did not conduct airborne radioactivity samples to evaluate radiological conditions prior to worker entry as required by radiation work permit (RWP) No. 2009-2408. This resulted in workers entering an area in which radiological conditions were not fully characterized. Constellation subsequently obtained air samples and entered the finding into their CAP. The finding is more than minor because it is associated with the Occupational Radiation Safety cornerstone attribute of program and process and affected the cornerstone objective of protecting worker health and safety from exposure to radiation. Specifically, Constellation did not fully characterize airborne radioactivity concentrations in the steam generators prior to worker entries. Using IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the inspectors determined that the finding was of very low safety significance (Green) because it did not involve: (1) as low as reasonably achievable (ALARA) planning and controls; (2) an overexposure; (3) a substantial potential for overexposure; or (4) an impaired ability to assess dose. This finding has a cross-cutting aspect in the area of human performance because Constellation did not effectively communicate expectations to personnel to follow RWP requirements (H.4.b) |
| 05000317/FIN-2009002-06 | 2009Q1 | Calvert Cliffs | Licensee-Identified Violation | 10 CFR Part 50.65(a)(4), Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, states, in part, Before performing maintenance activities (including but not limited to surveillance, post maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. Contrary to this, on August 21, 2008, Constellation removed the Unit 2 motor driven AFW flow path trains to the No. 21 and No. 22 SGs without conducting an adequate risk assessment. Constellation entered this issue in their CAP as CR- 2009-000979. This finding is of very low safety significance based on a SDP Phase 1 screening utilizing IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process. Specifically, the incremental core damage probability deficit was less than 1E-6 |
| 05000317/FIN-2009003-01 | 2009Q2 | Calvert Cliffs | Inadequate Test Control Associated with the Auxiliary Feedwater Pump Room Emergency Ventilation System | The inspectors identified an NCV of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, for Units 1 and 2 because Constellation did not establish an adequate test program to assure that the auxiliary feedwater (AFW) pump room emergency ventilation system would perform satisfactorily in service. Specifically, the performance evaluations used to determine the equipment performance of the emergency ventilation system did not incorporate the requirements and acceptance limits contained in the Updated Final Safety Analysis Report (UFSAR). This resulted in Constellation not recognizing that the AFW pump room emergency ventilation system did not meet the design requirements stated in the UFSAR. Constellation entered this issue into their corrective action program (CAP) for resolution as condition report (CR)-2008-002833. The immediate corrective action included performing an operability determination to verify the operability of the Unit 1 and 2 turbine driven auxiliary feedwater (TDAFW) pumps. The planned corrective actions included the installation of larger ventilation fans to obtain the required flow rate and to create a preventive maintenance task to measure the airflow for each emergency ventilation fan. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affects the cornerstone objective to ensure the availability and reliability of the AFW system, which responds to initiating events to prevent undesirable consequences (i.e., core damage). The inspectors determined that the finding is of very low safety significance because it is not a design or qualification deficiency, did not represent a loss of a safety function of a system or a single train greater than its Technical Specifications (TS) allowed outage time, and did not screen as potentially risk significant due to external events. Since the performance deficiency was determined to be the result of a latent issue and does not reflect current performance, no cross-cutting aspect is assigned |
| 05000317/FIN-2009003-04 | 2009Q2 | Calvert Cliffs | Licensee-Identified Violation | CCNPP TS LCO 3.4.10, Pressurizer Safety Valves, states, in part, that two pressurizer safety valves shall be operable. Contrary to this, from March 2006 to March 2008 one of the two pressurizer safety valves installed in Unit 1 was set above the TS limit and, therefore, was inoperable. Constellation identified the deficiency following the refueling outage while testing the valve as part of the relief valve-testing program. Constellation entered this issue in their CAP under IRE-033-089. This violation was of very low safety significance because the valve would have opened for the events credited to mitigate incidents in the Phase 2 notebooks such that it satisfied the bounding maximum vessel pressure calculations |
| 05000317/FIN-2009004-01 | 2009Q3 | Calvert Cliffs | Saltwater Pump Pit Flooding Event | The inspectors identified an unresolved item (URI) associated with an internal flooding event involving the No. 21 SW pump pit that occurred on December 10, 2008. On December 10, 2008, operators observed several feet of SW in the No. 21 SW pump pit. Operations secured the No. 21 SW pump and requested maintenance personnel to evaluate and perform repairs as necessary. Following the flooding event, maintenance personnel identified a clogged floor drain in the SW pump pit, degraded packing gland bolts and a failed radial bearing. The inspectors reviewed the initial CR describing an excessive packing leakage on the No. 21 SW pump, the maintenance work activity, and the flooding analysis for the intake structure. The inspectors questioned if the submergence event caused the lower radial bearing failure since Constellation did not include this degraded condition in their CAP. The inspectors also questioned the validity of the flooding analysis since the SW pump pits have design considerations and provisions to ensure the pumps would not be submerged. The inspectors reviewed the design considerations and provisions, the maintenance order used to overhaul the No. 21 SW pump, and supporting operability documents for the pump. Constellation provided information about the effect of Intake Structure flooding on the SW pumps. The inspectors reviewed the information and had additional questions on the supporting information used to support the operability basis of the SW pump and the design considerations associated with the SW pump pit. This item is unresolved pending further review and investigation of Constellations design considerations, provisions, and additional supporting information of the intake structure flooding of the SW pump pits such that the inspectors can determine if there is a performance deficiency associated with design control of the pump operating in a submerged environment |
| 05000317/FIN-2009004-02 | 2009Q3 | Calvert Cliffs | Did Not Implement Corrective Action Program Procedure Requirements | The inspectors identified an NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for Unit 2 because Constellation did not adequately implement the corrective action program (CAP) requirements contained in CNG-CA-1.01-1000, Corrective Action Program. Specifically, Constellation did not initiate condition reports (CRs) for conditions adverse to quality during maintenance activities after operators identified that the No. 21 saltwater (SW) pump pit flooded. As a result, Constellation did not initiate CRs for a failed radial bearing, three of the four bearing housing bolts being corroded beyond repair, a clogged floor drain in the SW pump pit, and the No. 21 SW pump pit being flooded. Constellation entered this issue into their CAP for resolution as CR-2009-006077. Constellation corrected these deficiencies when maintenance personnel drained the SW pit and overhauled the No. 21 SW pump on December 22, 2008. This finding is more than minor because, if left uncorrected, this finding would have the potential to lead to a more significant safety concern. Specifically, Constellation relies on their CAP to ensure that issues potentially affecting nuclear safety and equipment reliability are promptly identified, fully evaluated, and actions taken to prevent recurrence. The failure to initiate CRs when required could result in less than adequate corrective action response to nuclear safety issues in a timely manner. The inspectors determined that the finding is of very low safety significance because it is not a design or qualification deficiency, did not represent a loss of a safety function of a system or a single train greater than its Technical Specification (TS) allowed outage time, and did not screen as potentially risk significant due to external events. This finding has a crosscutting aspect in the area of problem identification and resolution because Constellation did not adequately implement the CAP to identify issues completely, accurately, and in a manner commensurate with their safety significance (P.1.a of IMC 0305) |
| 05000317/FIN-2010002-01 | 2010Q1 | Calvert Cliffs | Failure to Implement and Maintain Surveillance Procedures Associated with Fire Barrier and Penetration Seal Inspections | The inspectors identified a non-cited violation (NCV) of Calvert Cliffs Renewed Facility Operating License Numbers DPR-53 and DPR-54, License Condition 2. E, because Constellation did not adequately implement and maintain surveillance procedures associated with fire barrier and penetration seal inspections. As a result, Constellation did not identify degraded conditions associated with one fire barrier and three penetration seals. Immediate actions taken included entering the appropriate Technical Requirement Manual (TRM) action statement, establishing an hourly fire tour until temporary repairs were completed, and entering each issue into their corrective action program (CAP) for resolution. The finding is more than minor because it was associated with the external factors attribute (i.e. fire) of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiation events to prevent undesirable consequences. Specifically, the degraded conditions had to be repaired or evaluated to ensure that the barriers/penetrations would meet their design function. In addition, if left uncorrected, the finding could result in a more significant safety concern in that that the condition could continue to degrade such that the barriers/penetrations could no longer perform their specified function and/or result in the inability of Constellation to recognize additional degraded fire barriers/penetrations. The inspectors determined that the finding is of very low safety significance because there was a non-degraded automatic full area water based fire suppression system in the exposing fire area. This finding has a crosscutting aspect in the area of human performance because Constellation did not define and effectively communicate expectations regarding procedural compliance and personnel following procedures for fire penetration seal inspections (H.4.b of IMC 0310) |
| 05000317/FIN-2010003-01 | 2010Q2 | Calvert Cliffs | Inadequate Risk Assessment Associated with the 2B EDG | The inspectors identified an NCV of 10 CFR Part 50.65 (a)(4) , \"Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants,\" because Constellation did not perform an adequate risk assessment, which resulted in an underestimation and lack of awareness of the risk during maintenance activities on the 2B emergency diesel generator (EDG). On June 18, 2010, operators removed the 2B EDG from service and shut the air start valves in preparation for a maintenance activity. This prevented the 2B EDG from starting and loading automatically on a safety injection actuation signal (SIAS) or loss of offsite power. The inspectors determined that Constellation did not include the unavailability of the 2B EDG on the risk assessment. Immediate corrective actions included entering this issue into the CAP and re-performing the risk assessment. When re-performed, the core damage frequency (CDF) risk during the 2B EDG maintenance activity would have increased to medium (yellow). The finding is more than minor because if the overall risk had been correctly assessed, it would have placed Unit 2 into a higher risk category. The finding is associated with the configuration control attribute of the Mitigating Systems cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors determined that the finding is of very low safety significance because the incremental core damage probability deficit was less than 1.0E-6. This finding has a cross-cutting aspect in the area of human performance, work control, because Constellation did not appropriately plan and incorporate risk insights in work activities that impacted the availability of the 2B EDG (H.3.a of IMC 0310). |
| 05000317/FIN-2010003-02 | 2010Q2 | Calvert Cliffs | Inadequate Design Control Reviews of the Turbine Control System and the Nuclear Steam Supply System | The inspectors identified an NCV of 10 CFR Part 50, Appendix B, Criterion III, \\\"Design Control,\\\" because Constellation did not perform adequate design reviews associated with modifications to the turbine control system and the nuclear steam supply system (NSSS). Specifically, Constellation did not adequately evaluate the potential adverse impacts of removal of the power load unbalance (PLU) turbine trip on safety related systems, structures, and components (SSCs) such as the main steam safety valves (MSSVs) and pressurizer power operated relief valves (PORVs). In addition, during significant changes to plant design such as steam generator replacements and power uprates, Constellation did not conduct an adequate evaluation to determine if the turbine bypass valve (TSV) and the atmospheric dump valve (ADV) design specification of opening within 3 seconds after receiving the quick open signal would still be sufficient to prevent lifting MSSVs. Immediate corrective actions included entering these issues into their corrective action program (CAP) and performing an immediate operability determination and a probabilistic risk analysis. This finding is more than minor because it affected the Initiating Event cornerstone attribute of design control and affects the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the removal of the PLU turbine trip and the modifications to the NSSS could challenge prirnary and secondary overpressure protection devices and result in a stuck open MSSV or PORV. The inspectors evaluated this finding using an SDP phase 2 analysis and deterrnined that the issue is of very low safety significance. This finding has a cross-cutting aspect in the area of hurnan performance, decision rnaking, because Constellation did not adequately make safetysignificant decisions using a systematic process when faced with uncertain or unexpected plant conditions, to ensure safety is maintained. (H.1.a of IMC 0310). |
| 05000317/FIN-2010003-03 | 2010Q2 | Calvert Cliffs | Did Not Establish Preventative Maintenance Program for Switchyard Panels | A self-revealing finding of very low safety significance was identified because Constellation did not establish an appropriate preventive rnaintenance (PM) program for the 125 volts direct current (VDC) switchyard distribution panels in accordance with MN- 1, \\\"Maintenance Program.\\\" The 125 VDC switchyard distribution system supplies power hto the switchyard direct current (DC) loads for the operation of switchyard circuit breakers, emergency lights, and protective relays. Immediate corrective actions included entering this issue into the CAP and performing an inspection of all 125 VDC switchyard distribution panels. Long-term corrective actions planned include establishing an adequate PM program for the 125 VDC switchyard distribution panels. The finding is more than minor because it is associated with the equipment performance attribute of the Initiating Events cornerstone and affects the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety function. In addition, if left uncorrected, the performance deficiency could lead to a more significant safety concern. Specifically, the failure to establish an adequate PM program for the 125 VDC switchyard distribution panels could preclude the identification of equipment deficiencies, such as loose connections, that could result in a plant transient. The finding is of very low safety significance because it did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions will not be available. This finding has a cross-cutting aspect in the area of problem identification and resolution, operating experience (OE), because Constellation did not use OE information, including vendor recommendations to support plant safety. Specifically, Constellation did not implement and institutionalize OE through changes to station processes, procedures, equipment, and training associated with the switchyard PM program (P.2.b of IMC 0305). |
| 05000317/FIN-2010004-01 | 2010Q3 | Calvert Cliffs | Untimely Declaration of Notice of Unusual Event | The inspectors identified an NCV of 10 CFR Part 50.47(b)(4) for the failure to implement the emergency classification and action level scheme in a timely manner during an actual event. Specifically, on July 4, 2010, phone communications to St. Mary\'s County were lost which met the conditions requiring declaration of a Notice of Unusual Event (NOUE). However, Constellation did not declare the NOUE in a timely manner. Five hours after the phone communications were lost, Constellation determined that conditions met the declaration criteria for an NOUE. Prior to classifying the event, the phone lines were restored. The off-site phone lines are part of the site\'s communications system that provide means for prompt notification of local, State, and Federal officials of events that may require urgent actions. Constellation entered this issue into their corrective action program (CAP) for resolution. Immediate corrective action included establishing a standing order to provide operators guidance in the event of a loss of communications. The finding is greater than minor because it is associated with the Emergency Preparedness (EP) cornerstone attribute of emergency response organization performance (actual event response) and it adversely affects the cornerstone objective to ensure that Constellation was capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The inspectors determined that the finding is of very low safety significance in that it was associated with an actual event where the operators failed to declare an NOUE in a timely manner during a complete loss of communications to one off-site agency. This finding has a cross-cutting aspect in the area of human performance, decision making, because Constellation did not make a safety significant decision using a systematic process to declare the NOUE in a timely manner. Specifically, Constellation did not use a systematic process such as a standing order or procedure to provide guidance to operators to address a loss of communications. In addition, Constellation did not adequately implement emergency response organization\'s (ERO) roles and authorities as designed to obtain interdisciplinary input on safety significance decisions such as event classification (H.1.a of IMe 0310). |
| 05000317/FIN-2010004-02 | 2010Q3 | Calvert Cliffs | RCS Pressure Boundary Leakage in Valve Leakoff Line Weld | On February 23, 2010, while Unit 2 was in Cold Shutdown (Mode 5) during a forced outage, Constellation identified a pinhole leak on the packing leakoff line of 2HVRC-220 (pressurizer spray bypass valve). Constellation determined that this leakage constituted an RCS pressure boundary leak. Based on visual inspection performed during a routine boric acid walkdown, the leak most likely existed during plant operation. Constellation performed a progressive non-destructive examination of the pinhole leak site to further characterize the flaw in the socket weld. The evaluation concluded that the flaw was a single pore through the socket weld and that the apparent cause of the pinhole was a latent weld defect created during the original valve manufacturing process. The weld was repaired and inspected satisfactorily prior to startup from the Unit 2 forced outage. 2HVRC-220 is not normally accessible by plant personnel during plant operation at power. This LER reported that Calvert Cliffs had been in violation of TS 3.14.13.a, which limits pressure boundary leakage during plant operation to zero. The issue is considered within the traditional enforcement process because there was no performance deficiency identified and IMC 0612, AppendiX B, Issue Screening, directs disposition of this issue in accordance with the Enforcement Policy. The inspectors used the Enforcement Policy, Section 6.1, Reactor Operations, to evaluate the significance of this violation. The inspectors concluded that the violation is more than minor and best characterized as Severity Level IV (very low safety significance) because it is similar to Enforcement Policy, Section 6.1, example d.1. Additionally, the inspectors 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 LOCA initiator, and evaluated it using the Initiating Event criteria in Appendix A. Assuming worst case degradation, the leakage would not result in exceeding the TS 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. As a result, this issue would screen as very low safety significance (Green). Because this issue is of very low safety significance and it has been determined that it was not reasonable for Constellation to be able to foresee and prevent this leakage, and as such no performance deficiency exists, the NRC has decided to exercise enforcement discretion in accordance with Section 3.5 of the NRC Enforcement Policy and refrain from issuing enforcement action for the violation of TS (EA-1 0-188). Further, because Constellation's actions did not contribute to this violation, it will not be considered in the assessment process or the NRC's Action Matrix. |
| 05000317/FIN-2010005-01 | 2010Q3 | Calvert Cliffs | Inadequate Corrective Actions Associated with Submerged SR Cables | The inspectors identified a non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion XVl, Corrective Actions, because Constellation did not establish and take adequate measures for conditions adverse to quality associated with submerged safety related (SR) cables including the 1A diesel generator (DG) cables. As a result, SR cables were subjected to a submerged environment for unknown or extended periods. lmmediate corrective action included entering this issue into their corrective action program (CAP), conducting an operability determination for the 1A DG, and increasing the frequency of manhole inspections. The finding is more than minor because it was associated with the Mitigating Systems cornerstone attribute of equipment performance and affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, repeated submergence of medium voltage cables can cause excessive aging and degradation in the exposed sections of cable, which could significantly shorten its qualified life and cause unexpected failures. The inspectors determined that the finding is of very low safety significance because the finding is a design or qualification deficiency confirmed not to result in a loss of operability. This finding had a cross-cutting aspect in the area of problem identification and resolution, operating experience (OE), because Constellation did not implement and institutionalize OE through changes to station processes and procedures associated with submerged cables. |
| 05000317/FIN-2010005-02 | 2010Q3 | Calvert Cliffs | Failure to Follow Written Procedures During Calibration of the 1A DG SR Ventilation Temperature Controller | A self-revealing non-cited violation (NCV) of Technical Specification (TS) 5.4.1.a, Procedures, was identified because Constellation did not follow written procedures during the calibration of 1TIC10541 temperature controller. As a result, portions of the 1A diesel generator (DG) safety related (SR) ventilation failed to respond as designed, resulting in a low flow condition that challenged the safety function of the 1A DG. Specifically, the incorrect calibration of 1TlC10541 prevented the 1A DG SR ventilation system from fulfilling its design function and caused reasonable doubt whether the 1A DG could fulfill its safety function. Immediate corrective action included declaring the 1A DG inoperable until 1TIC10541 was correctly calibrated and tested and conducting a prompt investigation into the incorrect calibration of 1TIC1041. This finding is more than minor because it was associated with the Mitigating Systems cornerstone attribute of human performance and affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the improper calibration of 1T |
| 05000317/FIN-2010005-03 | 2010Q3 | Calvert Cliffs | Inadequate Functionality Review of 0C Diesel Degraded Condition | The inspectors identified a finding of very low safety significance because Constellation did not conduct an adequate functionality review following failure of the 0C diesel generator (DG) (the station blackout (SBO) diesel) battery charger. Specifically, Constellation did not take into account the Appendix R mission time in the functionality review. As a result, Constellation did not recognize that the 0C diesel was not available for its Appendix R function with its associated battery charger out-of-service (OOS), lmmediate corrective actions included entering this issue in the corrective action program (CAP) and providing instructions to operators to declare the 0C diesel not available anytime its associated battery charger is taken OOS. Additional corrective actions planned include changing 0l-264, 125 Volt Direct Current (VDC) System, to reflect that the battery charger is required to support the 0C diesel functionality. The finding is more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, Specifically, Constellation did not recognize that the 0C diesel generator was not available for its Appendix R function with its associated battery charger OOS. The inspectors determined that the finding is of very low safety significance because it only affected the ability to reach and maintain cold shutdown conditions. The finding has a cross-cutting aspect in the area of human performance, resources, because Constellation did not ensure complete, accurate, and up-to-date procedures (0l-264) were available and adequate to assure nuclear safety (H.2.c of IMC 0310). |
| 05000317/FIN-2010005-04 | 2010Q3 | Calvert Cliffs | Inadequate Corrective Action to Address Equipment Repairs in the Material Processing Facility | The inspectors identified a finding of very low safety significance associated with a non-cited violation (NCV) of Technical Specification 5.4.1 .a, Procedures, involving Constellation\'s failure to implement procedures to calibrate and maintain ventilation and radiation effluent monitoring equipment. Specifically, on December 9,2010, refurbishment of the steam generator (SG) nozzle dams and manway stud tensioners was in progress in the material processing facility; at that time, only one exhaust train of the ventilation system was in operation and a negative pressure of approximately one-half inch of water was not being maintained. lmmediate corrective actions included stopping all work in the building and completing the necessary repairs before restarting activities. The finding was more than minor because the failure to maintain the ventilation and radiation monitoring equipment affects the Radiation Protection cornerstone to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain as a result of routine civilian nuclear reactor operation. The inspectors determined that the finding is of very low safety significance because it did not impair Constellation\'s ability to assess dose. Constellation did assess dose and the limits of 10 CFR 50 Appendix I and 10 CFR 20.1301(e) were not exceeded. The finding also has a cross-cutting aspect in the area of problem identification and resolution, Corrective Action, because appropriate corrective actions were not taken in a timely manner. The exhaust fan was out-of-service (OOS) for eight months, the supply fan was OOS for seven years, and the radiation monitor was OOS for most of four years (P.1.d or IMC 0310). |
| 05000317/FIN-2010005-05 | 2010Q3 | Calvert Cliffs | Failure to Perform Testing of PORVs in Accordance with ASME OM Code | The inspectors identified an unresolved item (URl)associated with the failure to perform inservice testing (lST) for the pressurizer PORVs in accordance with American Society of Mechanical Engineers (ASME) Code for the Operation and Maintenance of Nuclear Power Plants. In 2000, Constellation changed the preventive maintenance requirement for the PORVs at both units such that rather than being removed and overhauled every six years, the valves were removed and overhauled every cycle (every two years). ln 2004, Constellation began to functionally test the PORVs to meet their TS and IST surveillance requirements at the end of a unit\'s operating cycle in accordance with procedure STP-M- 673,\'PORV Response Time Test. This testing was performed on valves which were subsequently replaced by refurbished spares. This was done to reduce the number of actuations the inservice valves were subjected to at a pressure below the normal operating pressure. OE indicated that by testing the PORVs at the lower pressures prescribed by STP-M-673, the potential for seat leakage was increased due to insufficient pressure to fully reseat the main valve disc. The Inspectors\' review of this practice identified that testing established in 2004 was not a proper interpretation of the requirements of the ASME Code. Specifically, ISTC-3310 requires a valve to be stroke time tested to verify that the reference value was still valid, or to set a new reference value following any maintenance which could affect the performance of the valve. The mounting of the solenoid and the setting of the plunger on site may affect the performance of the PORV being installed. IST runs were not performed following replacement of both valves during refueling outages since 2004 for both units (1-ERV-402,1-ERV-404, 2-ERV-402, and 2-ERV-404)to verify or reestablish the valves\' reference values. In response to this inspector-identified concern, Constellation initiated CR-2010-01 1886. This item is unresolved pending inspector review of Constellation\'s completed evaluation and CAs for this issue, and a determination if the performance deficiency associated with this issue is more than minor. (URl 05000317131812010005-05, Failure to Perform Testing of PORVs in Accordance with ASME Code). |
| 05000317/FIN-2011003-01 | 2011Q2 | Calvert Cliffs | Pressure Boundary Leakage Caused by Primary Water Stress Corrosion Cracking | On February 27,2011, while Unit 2 was in a refueling outage (Mode 6), Constellation identified (during a bare metal inspection) dry boric acid on pressurizer heater N3 outer sleeve to weld pad J-Groove weld location (not normally accessible by plant personnel during plant operation at power), indicating reactor coolant leakage. Constellation determined that this leakage constituted an RCS pressure boundary leak. Based on both visual inspection and chemical analysis performed during and after the discovery of boric acid at the N3 penetration, it was determined that the leak most likely existed during plant operation. Constellation performed destructive and non-destructive examinations at the weld. The evaluation concluded that the root cause of the crack was primary water stress corrosion cracking. As part of their corrective actions, in accordance with American Society of Mechanical Engineers (ASME) code, Constellation installed a welded plug at the N3 location. Following the repairs, Constellation conducted visual and surface examinations (dye penetrant testing) as well as pressure testing during Mode 3 at normal operating pressure and temperature, with satisfactory results. This LER reported that Calvert Cliffs had been in a condition prohibited by TS 3.4.13.A, which limits pressure boundary leakage during plant operation to zero. The issue is considered within the traditional enforcement process because there was no performance deficiency identified and IMC 0612, Appendix B, lssue Screening, directs disposition of this issue in accordance with the Enforcement Policy. The inspectors used the Enforcement Policy, Section 6.1, Reactor Operations, to evaluate the significance of this violation. The inspectors concluded that the violation was more than minor and best characlerized as Severity Level lV (very low safety significance) because it is similar to Enforcement Policy, Section 6.1, Example d.1. The inspectors conducted an initial significance determination screening using IMC 0609 Attachment 4, Phase 1 - Initial Screening and Characterization of Findings. Using the Initiating Events cornerstone screening criteria in Table 4a, and assuming worst case degradation the inspector concluded a Phase 3 risk evaluation was warranted. A Region I Senior Reactor Analyst performed a Phase 3 qualitative assessment of the observed RCS leakage condition and concluded the risk to core damage was very low (Green). The basis for this qualitative risk determination was that the observed leakage was minimal (quantified as a few drops per minute), well within the capability of the charging system, and the licensee's analysis confirmed that the ASME Code allowable stress limits for the affected penetration were within all design specifications. In addition, the design capability of RCS boundaries and associated piping systems are premised on the leak before break construction and fabrication methodologies and credits periodic in-service inspections to identify and correct potential or actual RCS boundary defects prior to further degradation or catastrophic failure. This issue is of very low safety significance (Green) and was appropriately identified and corrected per the licensee's ongoing inservice inspection program. Because this issue was of very low safety significance and it was not reasonable for Constellation to have foreseen and prevented the leakage, absent a performance deficiency, the NRC has decided to exercise enforcement discretion in accordance with Section 3, Use of Enforcement Discretion, of the NRC Enforcement Policy and has refrained from issuing enforcement action for the violation of TS (EA-11-164). Further, because Constellation's actions did not contribute to this violation, it will not be considered in the assessment process or the NRC's Action Matrix. |
| 05000317/FIN-2011004-01 | 2011Q3 | Calvert Cliffs | Inadequate Corrective Actions Associated with Submerged Saltwater Pump Motor Cables | The inspectors identified an NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, because Constellation did not promptly identify and correct a condition adverse to quality associated with submerged saltwater (SW) pump motor safety-related medium voltage cables. As a result, safety-related cables were subjected to a submerged or continuously wetted environment for extended periods. Immediate corrective action included entering this issue into their corrective action program (CAP), conducting an operability determination (00), and placing these cables into Constellation\'s Medium Voltage Cable Program. The finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, this condition could lead to cable degradation, increased likelihood of cable failure, and subsequent risk associated with the failure of safety-related equipment. The inspectors determined the finding is of very low safety significance because the finding is a design or qualification deficiency confirmed not to result in a loss of operability. The finding has a cross-cutting aspect in the area of problem identification and resolution, operating experience (DE), because Constellation did not fully implement and institutionalized DE to change station processes and procedures associated with submerged cables (P.2.b per IMC 0310). |
| 05000317/FIN-2011004-02 | 2011Q3 | Calvert Cliffs | Inadequate Compensatory Actions for Out of Service High Range Effluent Radiation Monitors | The inspectors identified an NCV of 10 CFR Part 50.54, Conditions of Licenses, paragraph (q), because Constellation did not maintain the Emergency Plan to adequately meet the standards in 50.47(b). Specifically, Constellation periodically removed the high range effluent monitors from service without addressing the impact on the site\'s ability to make a timely assessment of radiological releases as discussed in the Emergency Plan. This could result in an unnecessary delay in dose projection for certain radiological events. Immediate corrective actions included entering this issue into the CAP, updating the evaluation to address any potential delays, and protecting equipment required for dose projection. The finding is more than minor because it is associated with the facilities and equipment attribute of the Emergency Preparedness (EP) cornerstone and affected the cornerstone\'s objective to ensure that the licensee is capable of implementing adequate measures to protect public health and safety in the event of a radiological emergency. Specifically, the removal of high range effluent radiation monitors from service that provide a timely assessment capability may result in not immediately recognizing the offsite radiological condition that requires offsite protective actions. The inspectors determined the finding is of very low safety significance because it did not result in a loss or degraded Risk-Significant Planning Standard (RSPS) function. In addition, the finding is similar to examples of Green findings in IMC 0609, Appendix B, Section 4.9, in that the equipment or systems necessary for dose projection are not functional for longer than 24 hours from time of discovery without adequate compensatory measures. This finding has a cross-cutting aspect in the area of problem identification and resolution, CAP, because Constellation did not fully evaluate problems such that the resolution address causes and extent of condition as necessary. Specifically, Constellation did not adequately evaluate the compensatory actions following the removal of the high range effluent monitors from service to ensure that a timely assessment of offsite radiological conditions could be accomplished following a steam generator tube rupture (SGTR) event (P.1.c per IMC 0310). |
| 05000317/FIN-2011004-03 | 2011Q3 | Calvert Cliffs | Failure to Identify Pressurizer Safety Valves Condition Adverse to Quality | The inspectors identified an NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, because Constellation did not promptly identify and correct a condition adverse to quality associated with the Unit 2 pressurizer safety valves (PSVs). Specifically, following determination of a new PSV temperature profile, Constellation did not promptly identify that the valve setpoint would drift outside of the Technical Specification (TS) requirements during the operating cycle. This would have resulted in the PSVs becoming inoperable. Immediate corrective actions included placing this issue into the CAP, performing a re-analysis of PSV setpoints including the expected drift, and revising the 00. Upon re-analysis, Constellation determined that the PSVs currently installed in Unit 2 are conditionally operable until February 8, 2012. Additional corrective actions will be required prior to operating the unit beyond this date. The finding is more than minor because it is similar to examples 3j and 3k in IMC 0612, Appendix E, in that the failure to account for drift in the 00 resulted in a reasonable doubt on the operability of the PSVs. In addition, the finding is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors determined the finding is of very low safety significance because the finding is a design or qualification deficiency confirmed not to result in a loss of operability. This finding has a cross-cutting aspect in the area of problem identification and resolution, CAP, because Constellation did not thoroughly evaluate a problem such that the resolution addressed causes and extent of condition as necessary. Specifically, Constellation did not conduct an adequate operability review of the PSVs following identification of an unexpected temperature profile (P.1.c per IMC 0310). |
| 05000317/FIN-2011004-04 | 2011Q3 | Calvert Cliffs | Lack of Proficiency Evaluating Seismic Recorder Data | A self-revealing NCV of 10 CFR Part 50.54, Conditions of Licenses, paragraph (q), was identified because Constellation did not maintain the Emergency Plan to adequately meet the standards in 50.47(b). Specifically, Constellation did not have an adequate emergency classification and action level scheme in place for the seismic activity initiating condition and Constellation personnel lacked the proficiency necessary to evaluate seismic recorder data in a timely manner during the seismic event on August 23, 2011. The licensee entered this issue into their CAP and implemented compensatory actions, which included training of operators. The finding is more than minor because it is associated with the facilities and equipment attribute of the EP cornerstone and affected the cornerstone objective of ensuring that a licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, incorrect seismic recorder trigger setpoint settings and untimely evaluations of seismic recorder data could result in the failure of Constellation to declare an Unusual Event (UE) or an Alert in a timely manner. The inspectors determined the finding is of very low safety significance because it did not result in a loss or degraded RSPS function. The finding is also similar to examples of Green findings in Section 4.4 of IMC 0609, Appendix 8, in that the EAL classification process would not declare any Alert or Notification of UE that should be declared. This finding has a cross-cutting aspect in the area of human performance, resources, because Constellation did not ensure that the training of personnel was adequate to assure nuclear safety. Specifically, Constellation did not ensure that personnel were proficiently trained to read and evaluate the seismic recorder data which could delay entry into the EALs (H.2.b of IMC 0310). |
| 05000317/FIN-2011005-01 | 2011Q4 | Calvert Cliffs | Did not adequately prescribe and implement procedures associated with protected equipment | A self-revealing NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified, because Constellation did not prescribe and accomplish procedures appropriate to the circumstances associated with protected safety related equipment. As a result, on October 3, 2011, Constellation allowed work on a protected emergency diesel generator (EDG). The work activity inadvertently resulted in the protected EDG becoming inoperable. This led to required Technical Specification (TS) shutdowns of Unit 1 and Unit 2 because the other required EDG was already out of service (OOS) for planned maintenance. Prior to the shutdown being completed, the protected EDG was restored to an operable status and the shutdowns were aborted. Immediate corrective actions included entering this issue into their corrective action program (CAP), issuing a site wide communication stating the expectations regarding work on protected safety equipment, and revising the Operations Administrative Policy (OAP) associated with protected equipment. The 1nding is more than minor because it is associated with the configuration control attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the work activity impacted the availability and capability of the \'1A EDG. The inspectors determined the finding is of very low safety significance because the performance deficiency was not a design or qualification deficiency, did not involve an actual loss of safety function for greater than its individual TS allowed outage time, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. This finding has a cross-cutting aspect in the area of human performance, decision making, because the Constellation did not adequately make a risk significant decision using a systematic process when faced with uncertain or unexpected plant conditions, to ensure safety is maintained. Specifically, Constellation personnel did not follow the integrated work management process for emergent work which ultimately led to the downpower of both units (H.1 .a per IMC 0310) |
| 05000317/FIN-2011005-02 | 2011Q4 | Calvert Cliffs | Annual Operating Tests are not Comprehensive | The inspectors identified an NCV of 10 CFR Part 55.59(aX2Xii) for Constellation\'s failure to administer annual operating tests to licensed operators to accomplish a comprehensive sample of items specified by 10 CFR Part 55.45(a)(7)&(8). Specifically, for the past five years, Constellation\'s annual operating tests have not evaluated licensed operators on important tasks that would be performed inside the auxiliary building. Constellation entered this issue into their CAP to evaluate corrective actions. This finding is more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. This finding is associated with human performance attribute of the mitigating systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, Constellation\'s annual operating tests have not evaluated licensed operators on mitigation tasks that would be performed inside the auxiliary building. The finding is of very low safety significance according to IMC 0609, SDP, Appendix l, Licensed Operator Requalification SDP, because The issue was related to operating test quality. The inspectors determined that this finding had a cross-cutting aspect in the area of human performance, decision making, because Constellation did not use conservative assumptions in decision making that resulted in the development and administration of annual operating tests over the past five years that were not comprehensive (H.1 .b ) |
| 05000317/FIN-2011005-03 | 2011Q4 | Calvert Cliffs | Turbine Building Siding Failure below Design Specification | A self-revealing finding of very low safety significance was identified because Constellation did not ensure the turbine building (TB) siding was installed in accordance with design requirements of ES-005, Civil and Structural Design Criteria. This resulted in wind induced TB siding failures significantly below design wind speeds. Consequently, Unit 1 experienced an automatic trip from 100 percent power due to a phase to-phase short circuit on the main transformer when the main transformer high voltage lines were struck by dislodged TB siding caused by high winds associated with Hurricane lrene. The inspectors determined that Constellation missed multiple opportunities to identify the TB siding installation deficiencies following several high wind events and through the use of operating experience (OE). Immediate corrective actions included entering this issue into their CAP and restricting personnel travel in outside areas with sustained wind speed greater than 40 mph until the TB corner siding on all corners has been verified to be properly installed. Other corrective actions include testing and inspection of the main transformer, repairs to the \'B\' and \'C\' phase high line drops to the main transformer, temporary repairs to the TB siding and development of new installation requirements which meet the design requirements of the TB siding corners. In addition, Constellation\'s planned corrective actions include inspecting all building siding inside the protective area to identify other possible deficiencies. The finding is more than minor because it is associated with the protection against external factors attribute (wind and grid stability) of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. Specifically, the finding resulted in a reactor trip of Unit 1. The inspectors determined that the finding is of very low safety significance because the finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. This finding has a cross-cutting aspect in the area of problem identification and resolution, OE, because Constellation did not use OE information and internally generated lessons learned, to support plant safety and implement changes to station processes, procedures, equipment, and training programs. Specifically, Constellation did not implement and institutionalize OE associated with siding failures through changes to station processes, procedures, and equipment, and training programs (P.2.b per IMC 0310) |
| 05000317/FIN-2011005-04 | 2011Q4 | Calvert Cliffs | Inadequate Inspection of Floor Drains led to clogging and EDG Failure during hurricane | The inspectors identified a Green NCV of TS 5.4.1, Procedures, because Constellation did not adequately implement the procedural requirements to conduct floor drain inspections. Specifically, operators did not ensure that floor drains were free to drain and clear of debris in the 80 foot elevation of the 1A EDG building. This contributed to the inoperability of the 1A EDG due to clogged floor drains during Hurricane lrene on August 28, 2011. During the evening of August 27, 2011, through the early morning of August 28, 2011, precipitation from Hurricane lrene entered the 1A EDG building top elevation through the air intake openings that allow air flow to support diesel operation. The water accumulated on the top elevation floor, flowed under a door to the 1A EDG combustion air intake piping, leaked through the combustion air intake piping penetration to the floors beneath, and dripped onto the 1A EDG speed switch. The wetted speed switch caused the 14 EDG field flash circuit to attempt to flash the magnetic field in the 1A EDG. Because the generator shaft was not turning, the magnetic field was not established. This condition resulted in a field flash too long alarm. Electrical maintenance personnel removed fuses to de-energize the field flash circuit in order to prevent damage to the circuit, preventing any subsequent 1A EDG start. As a result, Operations declared the 1A EDG inoperable. Electrical maintenance and operations personnel conducted a tour of the 1A EDG building and observed approximately two inches of water on the top elevation floor. The floor drains on the top elevation were backed up due to a paste like material that formed from dust, dirt, and pollen when the drain filters became wetted. After operators removed the drain filters, the drains were able to perform their function thereby eliminating the source of water leaking on the 1A EDG speed switch. Constellation conducted a RCAR to identify the cause of this event. The RCAR stated that the root cause of the event was a failure of combustion intake piping penetration (boot seal) to remain leak tight. The RCAR further stated that a contributing cause was a failure to perform an engineering evaluation when the drain filters were installed in the 1A EDG building in 2005. An engineering evaluation would have identified the need for a PM to clean and inspect the filters on a periodic basis. The inspectors determined that Constellation failed to identify that operators were not adequately implementing housekeeping requirements established in CNG-OP-1.01-20A0, Operations Log keeping and Station Rounds. Paragraph 4 of section 5.3.B, Auxiliary Operator Rounds, in CNG-OP-1.01-2000 stated that Plant Operators shall perform thorough inspections of their assigned area to include the following general inspection items and equipment checks as they conduct their routine duties and take appropriate actions to report and properly correct deficiencies noted. The inspectors noted that the general inspection items included floor drains and sump gratings free to drain and clear of debris. The inspectors interviewed several operations department personnel to verify the expectations regarding floor drains inspections. Discrepancies were identified on how to meet the requirements of CNG-OP-1.A12000. The inspectors concluded that Constellation did not maintain the floor drains clear of debris and free to drain, and determined that this was an additional contributing cause to the failure of the 1A EDG on August 28, 2011. Immediate corrective actions included entering this issue into their CAP, removing all the drain filters from the 1A EDG building, and installation of a curb around the combustion intake penetration. Planned corrective actions include replacing the combustion intake penetration boot seal. Constellation\'s failure to ensure that floor drains in the 1A EDG building were free to drain and clear of debris in accordance with procedures is a performance deficiency. The finding is more than minor because it is associated with the human performance attribute of the Mitigating System cornerstone and affected the cornerstone\'s objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). A phase 3 SDP was required in accordance with IMC 0609, Attachment 4, phase 1- initial Screening and Characterization of Findings, Table 4b question 2c, because the finding degraded the 14 EDG, one train of a safety system, and is therefore potentially risk significant due to a seismic, flooding, or severe weather initiating event. A Region I SRA conducted the Phase 3 assessment of the finding utilizing the Calvert Cliffs Unit 1, Standardized Plant Analysis Risk model, version 8.15, in conjunction with the System Analysis Programs for Hands-On lntegrated Reliability Evaluations, version 8.0.7.17, dated May 1 8,2011, to estimate the severe weather risk contribution. Given that the condition impacted the availability of the 1A EDG during a severe weather event, the SRA made the following modeling changes and assumptions. The only initiating event of concern was a weather related loss of off-site power (LOOPWR). A new basic event, EPS-DGN-FS-H2O, was added to account for the condition in which water intrusion from high wind and rain would challenge the 1A EDG. Given the unique configuration of the building and weather conditions needed to challenge the EDG, a failure probability of 1E-1 was assigned. No adjustments were made to the LOOPWR frequency. This is considered conservative since this frequency also includes all weather related LOOPS. The condition existed for 1 year. Given that the finding did not impact the likelihood of a steam generator tube rupture or inter-system loss of coolant accident, large early release frequency was not impacted. The resulting change in core damage frequency was approximately 1.8E-7. The dominant sequence was a weather related loss of offsite power, with a failure of the emergency power system combined with a failure of turbine driven auxiliary feedwater and recovery of offsite power. Given this, the finding was determined to be Green. The finding has a cross-cutting aspect in the area of human performance, work practices, because Constellation did not ensure that personnel work practices support human performance by defining and effectively communicating expectations regarding procedural compliance and personnel following procedures. Specifically, Constellation did not establish and communicate clear expectations to operators on the implementation of the floor drain inspection in accordance with their procedures (H.4.b per IMC 0310). TS 5.4.1, Procedures, states in part, that written procedures shall be established, implemented and maintained in accordance with Regulatory Guide (RG) 1.33, Revision 2, Appendix A, recommended procedures\' RG 1.33, Appendix A, section 1.b , Administrative procedures, requires procedures for Authorities and Responsibilities for Safe Operation and Shutdown. CNG-OP-1.01-2000 establishes the controls, standards and expectations for the monitoring of plant equipment, components, and the recording of Operating Log readings, including Operating Logs, Narrative Logs, and Station Rounds. Section 5.9.8, step 4.a, states, in part, that plant operators shall perform thorough inspections of their assigned areas to include the inspection of floor drains and sump gratings to ensure they are free to drain and clear of debris. Contrary to this, prior to August 28,2011, Constellation failed to adequately implement the guidance in CNG--OP-1.01-2000 to ensure that floor drains in the 1A EDG building were free to drain and clear of debris. This contributed to the inoperability of the 1A EDG due to clogged floor drains during Hurricane Irene on August 28,2011. Because this violation was of very low safety significance and it was entered into Constellation\'s CAP as CR-201 1-00870b and CR-2012-00051 1, this violation is being treated as an NCV, consistent with the Enforcement Policy. |
| 05000317/FIN-2011005-05 | 2011Q4 | Calvert Cliffs | Single Failure vulnerability for Low Pressure Safety Injection Flow Control Valve CV-306 | An unresolved item (URI) was identified because additional NRC review and evaluation is needed to assess whether a performance deficiency exists associated with a single failure vulnerability for flow control valve CV-306. The LPSI system flow control valve CV-306 is located between the LPSI pumps and the LPSI injection header. It is an air-operated valve (AOV), and is located on a single pipe that branches into four lines for emergency core cooling system (ECCS) injection into the RCS. A flow controller is used during shutdown conditions to throttle CV-306, which would result in sending a portion of the flow through the shutdown cooling heat exchangers before returning to the RCS. An inadvertent full closure of this valve would isolate all LPSI flow to the RCS. Constellation\\\'s normal configuration of CV-306 is key-locked open, which means a control room two position key-lock switch (Auto and Open) is placed in the Open position and the key is removed. This configuration electrically removes the signal from the flow controller to the valve. The incident on December 1, 2010, occurred when a technician bumped his hardhat on the l/P converter during an adjacent instrument calibration activity, and the valve moved from 100 percent open to 75 percent open. Constellation determined that bumping the l/P had caused calibration shift, which caused the valve to partially close. The inspectors noted that the key-lock switch isolates the circuit between the flow controller and the l/P converter, thus any failure of the l/P could reposition the valve. Upon discovery by the control room operators, TS LCO 3.0.3 was entered as it was conservatively concluded that the LPSI f10wpath was inoperable. Subsequently, Constellation performed an engineering analysis, which determined that 75 percent open would have provided sufficient ECCS flow to the RCS during a postulated accident. The inspectors noted that TS Surveillance Requirement (SR) 3.5.2.1 requires operators to verify the following valves are in the listed position with power to the valve operator removed. CV-306 is one of the three valves listed in the associated TS SR and its required position is open. The 12-hour frequency surveillance is performed in the control room (actually performed every six hours) by recording that the key-lock switch is in the Open position and the valve is open (red light illuminated). Regarding the three valves listed in TS SR 3.5.2.1, the associated TS Basis states the following: Misalignment of these valves could render both ECCS trains inoperable; Securing these valves in position by interrupting the control signal to the valve operator, ensures that the valves cannot be inadvertently misaligned; and A 12-hour frequency is considered reasonable in view of other administrative controls ensuring that a mispositioned valve is an unlikely possibility. However, as was observed on December 1, 2010, an inadvertent misposition of CV-306 actually occurred. Further, there is no specific alarm or annunciation that alerts the operators that the valve is not in the full open position. The inspectors noted that typically, the action that accompanies that statement with power to the valve operator removed involves removing the motive force to the valve operator. For example, in the case of a motor-operated valve, the associated breaker is typically opened, and for an AOV, air is isolated to the operator or the valve is locked in the required position. In Supplement 1 to the CCNPP Units 1 and 2 Safety Evaluation (May 1973), the NRC documented that this single locked-open feature and fail-open AOV is provided through a key-lock in the electric control circuit in the control room. It also stated that notwithstanding this feature, a single failure such as a broken valve stem could cause the valve (an active component) to fail in a closed position and block the only LPSI flow path to the reactor coolant system. The applicant committed to modify the design so that no single failure could cause the valve to close. The modification consisted of a plug (jacking screw) that was inserted through the bottom of the valve body and mechanically prevented closure of the valve. In the time period between the licensing of the two units (circa 1974- 1976), a question was raised regarding CCNPP\\\'s ability to prevent boron precipitation during hot leg recirculation. While Supplement 1 above indicated the need for a jackscrew to maintain CV-306 open (to satisfy single failure), the licensee subsequently communicated a need to close CV-306 for establishing hot leg recirculation (it was presented as one of the options in docketed correspondence). In Supplement 5 to the Unit 2 Safety Evaluation (August 1976), Section 7.5.3, the NRC documented that to satisfy the single failure criterion, the applicant has proposed to lock out power to the motor operator of LPSI discharge valve CV-306 in the open position. We (the NRC) will include this requirement in the TSs. The boron precipitation concern appears to be the reason for the difference between the words/assumptions in Unit 1/2 Supplement 1 vs. Unit 2 Supplement 5. The inspectors noted that a jackscrew was originally installed in Unit 1 and then subsequently removed via a 10 CFR 50.59 screen/analysis in 1976. It was never installed in Unit 2. During the onsite inspection, the inspectors identified that, although originally considered as an option, the CV-306 valve is currently not used in establishing hot leg recirculation in the emergency operating procedures. The inspectors determined that a single failure vulnerability remained with Constellation\\\'s existing implementation of TS SR 3.5.2.1, in that, a single failure of a component such as the l/P converter could render all of LPSI inoperable. Further, in response to this concern, Constellation completed a Failure Mode and Effects Analysis, which identified the existence of two possible failure modes that could result in an inadvertent partial or full closure of CV-306 (I/P mechanical agitation, and I/P high output failure). However, Constellation stated they believed that Branch Technical Position ICSB 18, Application of the Single Failure Criterion to Manually-Controlled Electrically Operated Valves, contained a provision that would permit their configuration as meeting TS SR 3.5.2.1. The inspectors were evaluating whether Constellation was in compliance with TS SR 3.5.2.1 and the licensing/design basis of the LPSI system. Constellation stated that based upon the historical written communications and the existing licensing basis documentation, that their CV-306 configuration satisfied TS SR 3.5.2.1 and the licensing bases. Constellation initiated CR-2011-011314 on November 14, 2011, to formally address the concerns for this issue. In the interim, the inspectors noted that Constellation had subsequently isolated air to the CV-306 valve on each unit, and has, therefore, eliminated any immediate safety or TS compliance concerns. This issue will be opened as an URI in order to review and evaluate Constellation\\\'s corrective actions and determine if a performance deficiency exists with respect to the single failure vulnerability for flow control valve CV-306. |
| 05000317/FIN-2012002-01 | 2012Q1 | Calvert Cliffs | Failure to Establish a Test Program for Auxiliary Feedwater Emergency Air Accumulators | The inspectors identified an NCV of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, due to Constellations failure to establish a test program to demonstrate that the auxiliary feedwater (AFW) air-operated valves (AOVs) will operate as design with the emergency air accumulators and associated air pressure control valves (PCVs). Specifically, on January 26, 2012, the inspectors identified that safety related AFW emergency PCVs were replaced without a functional post maintenance test (PMT). The inspectors also identified that the AFW emergency air system had not being tested since the emergency air accumulators were installed in the 1980s and the 1990s. Constellation immediate corrective actions included entering the issues in their corrective action program (CAP), performing a functional test of the installed PCVs, performing an operability determination for the AFW emergency air system, and developing a testing procedure to periodically verify operation of AFW AOVs using the emergency air system. The finding is more than minor because it is associated with the equipment performance attribute of the Mitigating System cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, a reasonable doubt of operability existed because the capability of the AFW AOVs to operate using the backup air supply had not been demonstrated since original installation. In addition, if this issue was left uncorrected, it could have resulted in a greater safety concern because there was potential for build-up of particulate and condensation in the tight fits of the PCVs which could impact reliable operation. The inspectors determined that the finding is of very low safety significance because the performance deficiency was not a design or qualification deficiency, did not involve an actual loss of safety function, did not represent actual loss of safety function of a single train for greater than its TS allowed outage time, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The finding has a cross-cutting aspect in the area of problem identification and resolution, CAP, because Constellation did not ensure that issues potentially impacting nuclear safety were promptly identified, fully evaluated, and actions were taken to address safety issues in a timely manner commensurate with their safety significance. Specifically, Constellation did not implement a CAP with a low threshold for identifying test control issues associated with the AFW system (P.1.(a) per IMC 0310 |
| 05000317/FIN-2012002-02 | 2012Q1 | Calvert Cliffs | Failure to Replace Batter Charger Circuit Board within Its Recommended Service Life | A self-revealing NCV of Technical Specification (TS) 5.4.1, Procedures, was identified for the failure of Constellation to establish, implement, and maintain preventive maintenance (PM) requirements associated with the safety related No. 16 battery charger. Specifically, Constellation did not establish and implement a PM program to replace the current sensing/limiting printed circuit board (PCB) within its 10-year service life. As a consequence, the No. 16 battery charger failed rendering the 1A emergency diesel generator (EDG) inoperable. Constellations immediate corrective actions included entering this issue into their CAP, performing an apparent cause evaluation, performing an extent of condition review, and replacing the No. 16 battery charger PCBs. The finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capacity of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure of the No. 16 battery charger led to the 1A EDG being declared inoperable. The inspectors determined that the finding is of very low safety significance because the performance deficiency was not a design or qualification deficiency, did not involve an actual loss of safety function, did not represent actual loss of safety function of a single train for greater than its TS allowed outage time, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The finding has a cross-cutting aspect in the area of human performance, resources, because Constellation did not ensure that personnel, equipment, procedures, and other resources were available and adequate to assure nuclear safety. Specifically, Constellation did not maintain complete, accurate, and up-to-date procedures associated with the PM program |
| 05000317/FIN-2012003-01 | 2012Q2 | Calvert Cliffs | Failure to Establish Testing Program for ESFAS SDS | The inspectors identified an NCV of 10 CFR 50, Appendix B, Criterion XI, Test Control, because Constellation did not establish an operational test program for the engineered safety features actuation system (ESFAS) shutdown sequencers (SDSs). Specifically, on May 4, 2012, the inspectors determined that the licensee had never performed an operational test on the SDSs. The SDS supports the Loss of Offsite Power (LOOP) event in chapter 14 of the Updated Final Safety Analysis Report (UFSAR). Constellations immediate corrective actions included entering the issue into their corrective action program (CAP), conducting an operability determination (OD), developing a procedure to test the SDSs online, and testing the SDSs. Planned corrective actions include submittal of a license amendment request to include the SDS testing in their technical specification (TS) requirements. The finding is more than minor because it is associated with the equipment performance attribute of the Mitigating System cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, when tested, one of the SDSs did not perform as designed. The SDS logic for the No. 24 4kV bus initiated start of the auxiliary feedwater (AFW) pump on the incorrect step. In addition, if left uncorrected the performance deficiency had the potential to lead to a more safety significant concern, in that, an SDS failure would go undetected until an actual demand during an LOOP. The inspectors evaluated the finding using Phase 1, Initial Screening and Characterization, worksheet in Attachment 4 to IMC 0609, Significance Determination Process, and determined the finding is of very low safety significance (Green) because the performance deficiency was not a design or qualification deficiency, did not involve an actual loss of safety function, did not represent actual loss of safety function of a single train for greater than its TS allowed outage time, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The finding has a cross-cutting aspect in the area of problem identification and resolution, CAP, because Constellation did not identify this issue completely, accurately, and in a timely manner commensurate with its safety significance. Specifically, within the last 3 years, Constellation had several opportunities to completely and accurately identify the SDS test program deficiency as a result of multiple sequencer module replacements and through reviews of the emergency diesel generator (EDG) testing program |
| 05000317/FIN-2012003-02 | 2012Q2 | Calvert Cliffs | Failure to Establish and Maintain Adequate Procedures for Maintenance on Pressurizer Power Operated Relief Valves | A self-revealing NCV of TS 5.4.1, Administrative Controls Procedures, was identified for the failure to establish and maintain adequate procedures for performing maintenance on pressurizer power operated relief valves (PORVs). Specifically, the maintenance procedure (purchase order) did not clearly prescribe acceptance criteria for the minimum acceptable clearances between the cage, guide, and the main disc. This resulted in the as left internal valves clearances being less than the minimum expected requirements. During disassembly, the valve disc of one of the PORVs (serial number BS07325) was stuck and had to be mechanically removed. Immediate corrective actions included entering this issue into the CAP, conducting an OD for the valves currently installed on both units, and conducting a past operability review of the PORVs that were removed. Planned corrective actions include updating the design specification and maintenance procedures to ensure that minimum allowable internal clearances are specified. This finding is more than minor because it is associated with the procedure quality attribute of the Mitigating System cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, when the valve was removed and disassembled, the valve disc was found stuck and had to be mechanically removed, thereby impacting the reliability and operability of the valve during operation at power the previous cycle. A detailed engineering analysis was performed which supported past operability of the valve. The inspectors evaluated the finding using Phase 1, Initial Screening and Characterization, worksheet in Attachment 4 to IMC 0609, Significance Determination Process, and determined the finding is of very low safety significance (Green) because the performance deficiency was not a design or qualification deficiency, did not involve an actual loss of safety function, did not represent actual loss of safety function of a single train for greater than its TS allowed outage time, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The finding has a cross-cutting aspect in the area of human performance, work practices, because personnel work practices did not support human performance. Specifically, Constellation did not ensure supervisory and management of oversight of work activities, including contractors, such that nuclear safety is supported. Critical dimensions affecting contractor work activities were not adequately captured in station processes, procedures, and work packages. |
| 05000317/FIN-2012004-01 | 2012Q3 | Calvert Cliffs | 2A Diesel Generator Ventilation Train 10 CFR 50.65 (a)(2) Performance Demonstration Not Met | An NRC-identified NCV of 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, paragraph (a)(2), was identified because Constellation personnel did not adequately demonstrate that the 2A diesel generator ventilation train (a)(2) performance was effectively controlled through performance of appropriate preventive maintenance. Specifically, Constellation personnel did not identify and properly account for a functional failure of the 2A emergency diesel generator (EDG) ventilation train in June 2012, and thereby did not recognize that the train exceeded its performance criteria and required a Maintenance Rule (a)(1) evaluation. The subsequent evaluation concluded that the 2A EDG ventilation train (a)(2) performance demonstration was no longer justified and therefore the train should be classified as (a)(1), corrective actions specified, and train monitoring completed. Constellation personnel entered the issue into their CAP as CR-2012- 006132. The finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affects the cornerstone objective of ensuring the capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, following a functional failure of the 2A EDG ventilation train in June 2012, Constellation did not identify that the train should be monitored in accordance with 10 CFR 50.65(a)(1) for establishing goals and monitoring against the goals. The inspectors evaluated the significance of this finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings at Power. The inspectors determined that this finding was of very low safety significance (Green) because the finding was not a design or qualification deficiency; did not represent a loss of safety system function; and did not screen as potentially risk significant due to external initiating events. The finding has a cross-cutting aspect in the area of Problem Identification and Resolution because Constellation personnel did not thoroughly evaluate the problem such that the resolution fully addressed causes and extent of conditions, as necessary. This includes properly classifying, prioritizing, and evaluating for operability and reportabililty a condition adverse to quality. Specifically, Constellation personnel did not properly evaluate the impact of the condition of the dampers on the ability of the ventilation train to perform its safety function. |
| 05000317/FIN-2012004-02 | 2012Q3 | Calvert Cliffs | Corrective Actions Not Completed for Drains in the Intake Structure | An NRC-identified finding of very low safety significance was identified because Constellation staff did not follow Procedure CNG-CA-1.01-1000, Corrective Action Program. Specifically, Constellation staff did not complete corrective actions previously prescribed within their Corrective Action Program as a result of root and apparent cause evaluations for drain failures which impacted safety-related equipment. This resulted in a drain line within the intake structure becoming clogged and the 21 saltwater (SW) pump becoming submerged in water. Constellation personnel entered the issue into their CAP as CR-2012-008363, cleaned out the drain line, and implemented a new preventive maintenance (PM) schedule to keep the drain line clear. Planned corrective actions include overhauling the 21 SW pump bearings. The finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely impacted the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, because the intake structure drain piping was clogged, the 21 saltwater pump pit filled with water and caused the pump bearing housings to be contaminated with water, which adversely impacts the long-term reliability of the pump bearings and will cause the pump to be unavailable while the issue is corrected. The inspectors evaluated the significance of this finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings at Power. The inspectors determined that this finding was of very low safety significance (Green) because the finding was not a design or qualification deficiency; did not represent a loss of safety system function; and did not screen as potentially risk significant due to external initiating events. The inspectors determined that the finding has a cross-cutting aspect in the area of Problem Identification and Resolution because Constellation personnel did not take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety significance and complexity. Specifically, Constellation personnel did not perform corrective actions previously prescribed to address and correct drain failures that impacted safety-related equipment. |