IR 05000317/2006004
| ML063130320 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 11/09/2006 |
| From: | Arthur Burritt Reactor Projects Branch 1 |
| To: | Spina J Constellation Generation Group |
| References | |
| IR-06-004 | |
| Download: ML063130320 (34) | |
Text
ber 9, 2006
SUBJECT:
CALVERT CLIFFS NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000317/2006004 AND 05000318/2006004
Dear Mr. Spina:
On September 30, 2006, the US Nuclear Regulatory Commission (NRC) completed an inspection at your Calvert Cliffs Nuclear Power Plant Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on September 29, 2006, with you and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
This report documents two NRC-identified findings of very low safety significance (Green) that were determined to involve violations of NRC requirements. However, because of the very low safety significance and because these issues were entered into your corrective action program, the NRC is treating these violations as non-cited violations (NCVs) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest any NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Calvert Cliffs Nuclear Power Plant.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Arthur L. Burritt, Acting Chief Projects Branch 1 Division of Reactor Projects Docket Nos. 50-317, 50-318 License Nos. DPR-53, DPR-69 Enclosure: Inspection Report 05000317/2006004 and 05000318/2006004 w/Attachment: Supplemental Information cc w/encl:
M. J. Wallace, President, Constellation Generation J. M. Heffley, Senior Vice President and Chief Nuclear Officer President, Calvert County Board of Commissioners C. W. Fleming, Senior Counsel, Constellation Generation Group, LLC Director, Nuclear Regulatory Matters R. McLean, Manager, Nuclear Programs K. Burger, Esquire, Maryland People's Counsel State of Maryland (2)
SUMMARY OF FINDINGS
IR 05000317/2006-004, 05000318/2006-004; 07/01/06 - 09/30/06; Calvert Cliffs Nuclear Power
Plant, Units 1 and 2; Operability Evaluations; Problem Identification and Resolution.
The report covered a three-month period of inspection by resident inspectors and announced inspections performed by reactor and health physicist inspectors. Two Green findings both of which were non-cited violations (NCVs) were identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC)0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a non-cited violation (NCV) for the Service Water (SRW) and Auxiliary Feedwater (AFW) systems being inoperable without completing the actions required by Technical Specifications. Constellation did not declare AFW and SRW trains inoperable when water tight doors providing a High Energy Line Break (HELB) barrier were opened for maintenance or testing. Station personnel wrote condition report (CR) IRE-016-870 to address the control of these HELB barriers and have provided guidance to declare the trains inoperable if the water tight doors are open.
This finding is more than minor because it had a credible impact on the objective for the mitigating system cornerstone and the attribute of component availability during design basis events, specifically HELBs. The SDP phase 1 review determined a phase 2 evaluation was required since both SRW and AFW subsystems could have been impacted with the HELB barrier removed. The phase 2 evaluation yielded a very low safety significance (Green), because of the low exposure time when the watertight doors were open. A contributing cause of the finding is related to the cross-cutting aspect in the area of problem identification and resolution (PI&R) because Constellation did not implement and institutionalize operating experience (OE) related to control of the HELB barriers through changes to station processes or procedures. (Section 1R15)
- Green.
The inspectors identified a NCV of TS 5.4.1.a because Constellation did not initiate a condition report (CR) to document the adverse performance of the service water (SRW) heat exchanger salt water (SW) strainers during high debris loading as required in the Service Water Heat Exchanger Alarm Manual. Constellation also did not assess the operability of the strainers as required by the Corrective Action Program.
Station personnel initiated CR IRE-017-018 to address the issue and assess operability of the strainers.
iii
The finding was more than minor since it had a credible impact on the objective for the mitigating system cornerstone and the attribute of component reliability during design basis events where the SRW system was required. This finding was determined to be a finding of very low safety significance (green) because only one subsystem of the SRW system was inoperable at any time, and the subsystem inoperability time was less than the maximum allowed by TS. A contributing cause of this finding was related to the cross-cutting aspect of PI&R because Constellation did not implement the corrective action program with a low threshold for identifying the problems with the SRW heat exchanger SW strainers. (Section 4OA2)
Licensee-Identified Violations
None.
iv
REPORT DETAILS
Summary of Plant Status
Unit 1 began the inspection period at 100 percent power. On July 7, 2006 during an influx of aquatic life (jellyfish) at the plant intake structure, operators rapidly reduced Unit 1 power to around 35 percent power to facilitate removal of two circulating water pumps. Power was restored to 100 percent on the same day. On August 26, operators reduced power to approximately 85 percent power for planned waterbox cleaning and main turbine valve testing.
Power was restored to 100 percent the next day.
Unit 2 began the inspection period at 100 percent reactor power. On September 1, 2006, operators reduced power to approximately 78 percent due to storm related debris at the intake from tropical storm Ernesto. Power was restored to 100 percent the same day. On September 9, 2006 operators reduced power to approximately 85 percent power for planned waterbox cleaning and main turbine valve testing. Power was restored to 100 percent the next day.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R01 Adverse Weather Protection
.1 Adverse Weather Seasonal Preparations - Hot Weather
a. Inspection Scope
The inspectors reviewed the adverse weather preparations and mitigating strategies for hot weather operations. This review included an assessment of Operations Administrative Policy 94-5, Guidelines for Nuclear Plant Operations Support For Electric System Operation and Planning Department Transmission System Operations. The inspectors assessed the effectiveness of Constellation preparations for hot weather and stressed grid conditions. Risk-significant systems affected by hot weather and a heavily loaded grid were selected for review. The review included the service water, saltwater, and selected auxiliary building ventilation systems. The inspectors performed a partial walkdown of ultimate heat sink components and safety related ventilation systems. The inspectors conducted interviews with control room operators and system engineers to ensure protective measures applicable to these risk-significant systems were available.
This inspection satisfied two inspection samples for review of risk-significant systems.
Documents reviewed for each section of this report are listed in the Attachment.
b. Findings
No findings of significance were identified.
.2 Adverse Weather Conditions - Tropical Storm
a. Inspection Scope
On September 1, 2006, Calvert Cliffs entered Emergency Response Plan Implementation Procedure (ERPIP) 3.0, Immediate Actions, for severe weather conditions due to high winds and heavy rains from tropical storm Ernesto. The inspectors reviewed the adverse weather preparations and mitigating strategies for severe weather events. This review included an assessment of Emergency Response Plan Implementation Procedure (ERPIP) 3.0, Immediate Actions, Attachment 20, Severe Weather, Emergency Planning (EP) 1-108, Severe Weather Preparation, 3, Severe Weather Preparation Checklist Operations, and Operations Administrative Policy (OAP) 00-01, Severe Weather Operations. The inspectors conducted discussions with control room operators to verify severe weather mitigating strategies and measures were appropriate for the event. This inspection satisfied one inspection sample for the onset of adverse weather.
b. Findings
No findings of significance were identified.
1R04 Equipment Alignment
.1 Partial Walkdown
a. Inspection Scope
The inspectors performed a partial walkdown of the following four systems to verify the operability of redundant or diverse trains and components when safety equipment was inoperable. The inspectors attempted to identify any discrepancies that could impact the function of the system, and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, walked down system components, and verified that selected breakers, valves, and support equipment were in the correct position to support system operation. The inspectors also verified that Constellation had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program.
- Unit 1 Emergency core cooling system (ECCS) during dewatering of the 22 ECCS pump room cooler
- 2A Emergency diesel generator (EDG) during maintenance on the 2B EDG
b. Findings
No findings of significance were identified.
.2 Complete Walkdown
a. Inspection Scope
The inspectors performed a complete system walkdown of the accessible portions of the service water system. The inspectors determined the correct system lineup using OI-15, Attachment 1, Service Water Valve Alignment (Unit 1 Valves), as well as appropriate piping and instrument drawings. The inspectors reviewed the open maintenance work requests on the system for any deficiencies that could affect the ability of the system to perform its function. Inspectors also reviewed the unresolved design issues such as temporary modifications, operator workarounds, and items tracked by plant engineering to assess their collective impact on system operation. In addition, the inspectors reviewed the condition report database to verify that equipment alignment problems were being identified and appropriately resolved.
b. Findings
No findings of significance were identified.
1R05 Fire Protection
a. Inspection Scope
The inspectors conducted a tour of the six areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that Constellation controlled combustibles and ignition sources in accordance with their administrative procedures and that fire detection and suppression equipment was available for use. The inspectors also verified that station personnel maintained passive fire barriers in good condition and that Constellation implemented compensatory measures for out-of-service, degraded, or inoperable fire protection equipment in accordance with their fire plan.
- Unit 1 Service water pump room (Room 226)
- Unit 2 Service water pump room (Room 205)
- Unit 1 Auxiliary feedwater pump room (Room 603)
- Unit 2 Component cooling water pump room (Room 201)
- Unit 1 Emergency core cooling system pump room (Room 118)
- 2B Emergency diesel generator room (Room 416)
b. Findings
No findings of significance were identified.
1R06 Flood Protection Measures (71111.06 - 1 external flooding sample)
a. Inspection Scope
The inspectors reviewed flood protection measures associated with external flood events. These events were described in the Updated Final Safety Analysis (UFSAR)and the Individual Plant Examination of External Events (IPEEE). The inspectors walked down risk significant areas at the site which included the intake structure and outside areas near plant structures. The inspectors evaluated the integrity of watertight doors, floor drains, and penetrations for these selected areas. The inspectors also walked down external drains identified by the IPEEE to verify their ability to mitigate the effects of external flood events.
b. Findings
No findings of significance were identified.
1R07 Heat Sink Performance
a. Inspection Scope
The inspectors observed the 12 A and 12B service water heat exchanger thermal performance tests. The inspectors reviewed the performance data and evaluated the test acceptance criteria from this completed test to ensure that design basis requirements were satisfied. The inspectors also evaluated existing heat transfer capabilities based on completed flow verification test results to ensure that specific safety functions could be performed in accordance with design specifications. The inspectors also reviewed Calvert Cliffs periodic maintenance methods to verify that they conformed to the guidelines delineated in EPRI Report NP-7552, Heat Exchanger Performance Monitoring Guidelines.
b. Findings
No findings of significance were identified.
1R11 Licensed Operator Requalification Program
a. Inspection Scope
On September 6, 2006, the inspectors observed a licensed operator simulator training scenario to assess operator performance and the adequacy of the licensed operator training program. The training scenario involved a turbine malfunction requiring operators to perform a manual reactor trip. Following the trip, equipment failures occurred resulting in a loss of all vital 4Kv buses. The inspectors focused on high-risk operator actions performed during implementation of the abnormal and emergency operating procedures, emergency plan implementation, and classification of the event.
The inspectors evaluated the clarity and formality of communications, the implementation of appropriate actions in response to alarms, the performance of timely control board operations and manipulations, and the oversight and direction provided by the shift supervisor. The inspectors also reviewed simulator fidelity to evaluate the degree of similarity to the actual control room, especially regarding recent control board modifications.
b. Findings
No findings of significance were identified.
1R12 Maintenance Effectiveness
Quarterly Review (71111.12Q - 2 samples)
a. Inspection Scope
The inspectors reviewed the two samples listed below for items such as:
- (1) appropriate work practices;
- (2) identifying and addressing common cause failures;
- (3) scoping in accordance with 10 CFR 50.65(b) of the maintenance rule (MR);
- (4) characterizing reliability issues for performance;
- (5) trending key parameters for condition monitoring;
- (6) charging unavailability for performance;
- (7) classification and reclassification in accordance with 10 CFR 50.65(a)(1) or (a)(2); and
- (8) appropriateness of performance criteria for structures, systems, and components (SSCs) classified as (a)(2) and/or appropriateness and adequacy of goals and corrective actions for SSCs classified as (a)(1).
- Unit 2 Wide range nuclear instrumentation power supplies
- Unit 2 21A reactor coolant pump seal flange leakage
b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed the following six activities to verify that station personnel performed the appropriate risk assessments prior to removing equipment for work.
When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed. The inspectors compared the risk assessments and risk management actions performed by station procedure NO-1-117, Integrated Risk Management, to the requirements of 10 CFR 50.65(a)(4), the recommendations of NUMARC 93-01, Revision 2, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, and approved station procedures. In addition, the inspectors assessed the adequacy of Constellations identification and resolution of problems associated with maintenance risk assessments and emergent work activities.
- High grid stress during an electric system operator declaration for maximum emergency generation
- Unit 2 auxiliary feedwater testing
- 1A emergency diesel generator planned maintenance activities
- Unit 1 11 & 14 4kV busses transferred to and from their alternate power source to support maintenance on 11 4kV bus normal feeder breaker
- Unit 2 high pressure safety injection and low pressure safety injection check valve closure test
- 11 and 23 battery chargers planned maintenance activities
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations
a. Inspection Scope
For the five operability evaluations described below, the inspectors evaluated the technical adequacy of the evaluations to ensure that Constellation properly justified TS operability and that the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors reviewed the UFSAR to verify that the system or component remained available to perform its intended function. In addition, the inspectors reviewed compensatory measures implemented to verify that the measures worked as stated and that they were adequately controlled. The inspectors also reviewed a sampling of condition reports to verify that Constellation identified and corrected any deficiencies associated with operability evaluations.
- Unit 1 core exit thermocouple reading lower than hot leg temperatures
- Unit 2 scaffolding in safety related switchgear room
- Unit 2 shutdown cooling heat exchanger inlet throttle valve for component cooling due to difficult valve operation
- Unit 1 auxiliary feedwater pump room water tight door open during test
- 1A emergency diesel generator room fan performance with switches installed improperly
b. Findings
Safety Related Watertight Doors
Introduction.
The inspectors identified a Green NCV of Technical Specifications (TS) for the service water (SRW) and auxiliary feedwater (AFW) systems being inoperable for longer than the allowed time without completion of the actions required by TS, including placing the plant in hot shutdown. Constellation did not declare the associated AFW and SRW trains inoperable when the watertight doors that provide a high energy line break barrier were opened for maintenance or testing.
Description.
On August 30, 2006, during the testing of Unit 1 #12 Turbine-Driven Auxiliary Feedwater (TDAFW) pump, in accordance with STP-O-5A-1, the inspectors noted that the procedure directed operators to open a set of watertight doors for the room that houses the #11 and # 12 TDAFW pumps. These doors are opened to the non-safety related turbine building and are different from the watertight door used for normal ingress and egress. The watertight doors that the procedure requires to be open are maintenance doors, which are larger and do not automatically close and latch.
Station personnel opens these watertight doors to allow for quick egress during testing, and stations a fire watch while the doors are open.
The inspectors discussed the operability of the TDAFW pumps with Operations personnel, since it would be unlikely that the doors could be closed fast enough to mitigate a high energy line break event and prevent a harsh environment in the TDAFW room. This reasoning was consistent with NRC Information Notice (IN) 2000-20, Potential Loss of Redundant Safety Related Equipment Because of A Lack of High Energy Line Barriers and Regulatory Issue Summary (RIS) 2001-009, Control of Hazard Barriers. The inspectors determined that since a HELB was considered a credible design basis accident, and the TDAFW pump had a specified safety function for that accident, then in accordance with the definition of operability in TS section 1.1, both pumps were inoperable. Constellation subsequently determined that both TDAFW pumps were inoperable during this test. The Technical Specification Action Statement (TSAS) 3.7.3c requires, in part, that the remaining operable pump be aligned for automatic initiation and the verification of the other units motor-driven AFW (MDAFW)pump as well as the AFW cross-tie valve to the opposite unit is operable in one hour.
Station personnel performed the required actions when they determined the TDAFW pumps were inoperable. Constellation initiated a CR to evaluate their control of HELB barriers including an extent of condition evaluation.
As part of the extent of condition evaluation for the last three years, Constellation discovered that the TDAFW pump room doors for both units had been opened periodically for testing and maintenance activities without declaring the associated pumps inoperable. In addition, the Service Water (SRW) rooms for each unit, which contain the three SRW pumps, Salt Water/Service Water heat exchanger components, and the 13 or 23 AFW pump, had watertight doors which had been opened periodically without declaring the associated pumps inoperable. Having all three SRW pumps inoperable on both trains of the service water system would have required entry into shutdown TS 3.0.3.
Analysis.
Failure to declare the SRW and AFW pumps or safety-related train inoperable when its HELB barrier (watertight door) was opened for other than normal ingress and egress was a performance deficiency. The inspectors considered the deficiency was more than minor since it had a credible impact on the objective for the mitigating system cornerstone and the attribute of component availability during design basis events, specifically HELBs. The SDP phase 1 review determined a phase 2 evaluation was required since both SRW subsystems could have been inoperable with the HELB barrier removed. For the AFW system, two cases existed where the opposite units AFW system was impacted due to open watertight doors.
The phase 2 evaluation used an unavailability of both TDAFW pumps in the conservative 3-30 day range. Constellations data shows calculated unavailability times in the last year for unit 1 and 2 of 85 hours9.837963e-4 days <br />0.0236 hours <br />1.405423e-4 weeks <br />3.23425e-5 months <br /> and 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br />, respectively. Inspectors determined that these times were reasonable. To account for possible cases where the opposite units MDAFW may not have been available and some cases where the logs were not complete, the inspectors conservatively assumed only one train of AFW remained. SRW pump or component unavailability was 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> for Unit 1 and three hours for Unit 2. The inspectors used the initiating event of Main Steam Line Break Outside Containment (Table 3.10) of the Risk Informed Inspection Notebook, revision 2, for Calvert Cliffs. The phase 2 worksheet resulted in a very low safety significance (green) for both units because of the low exposure time when the watertight doors were open. Constellation performed their own detailed risk assessment using their risk model and determined the highest Incremental Core Damage Probability was green.
The inspectors identified that a contributing cause of this finding was related to the cross-cutting aspect in the area of PI&R because Constellation did not implement and institutionalize OE related to the control of HELB barriers, from a 2004 site self-assessment, RIS 2001-009 and IN 2000-20, through changes to station processes or procedures.
Enforcement.
With the watertight doors open in the respective rooms, AFW, SRW, and SW subsystems would be inoperable. TS 3.7.3c, Auxiliary Feedwater System, requires, in part, action to verify the other units motor-driven AFW pump is operable within one hour. In addition, the SRW and SW TS require both trains operable in modes 1-4. There is no TS action for both subsystems being inoperable, therefore, TS 3.0.3 is applicable and requires action to be in mode 3 within seven hours.
Contrary to the above, on several occasions on both units, most recently August 30, 2006, Constellation did not verify the other units AFW pump operable in one hour from the inoperability of the TDAFW pumps. Additionally, contrary to the requirements for SRW and SW operability, on December 9, 2004, Unit 1 SRW pump room doors were open for more than nine hours, exceeding TS 3.0.3 requirement to be in mode 3 within seven hours. This violation is documented in Constellations corrective action program as IRE-016-870 and is being treated as a non-cited violation consistent with Section VI.A.1 of the NRC Enforcement Policy: NCV 05000317 and 318/2006004-01, Failure to Comply With TS for SRW and AFW With Watertight Doors Open.
1A EDG Room Fan Performance The inspectors identified that the 1A Emergency Diesel Generator (EDG) room ventilation fan temperature switches were installed with the shipping protectors over the sensing element. On September 24, 2006, while observing a 1A EDG surveillance test, the inspectors noted the temperature in the room slowly rising while the EDG was being loaded. The system design is such that at approximately 85FE, the second ventilation fan starts and around 95FE, the third ventilation fan starts. The inspectors observed the local temperature over 95FE (with a maximum peak of 97FE) with only one fan running.
The inspectors discussed the observation with the Constellation staff, and they subsequently determined the fan temperature switches were installed with the shipping protectors over the sensing element which created a delay in activation of the temperature switch. Station personnel initiated a condition report IRE-017-390 and removed the shipping protectors to restore the EDG to the intended design configuration. This item is unresolved pending an investigation and operability assessment by the station personnel. Unresolved Item (URI 05000317/2006004-03, 1A EDG Ventilation Fan Performance
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the five post-maintenance tests listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety function(s) that may have been affected by the maintenance activity, that the acceptance criteria in the procedure were consistent with information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data, to verify that the test results adequately demonstrated restoration of the affected safety function(s).
- 22 shutdown cooling heat exchanger component cooling water solenoid valve (2SV3830) replacement
- High pressure safety injection (HPSI) main header isolation motor operated valve (2MOV-654) maintenance
- 22 ECCS pump room cooler
- U-4000-12 transformer out of service (supply to 4kv safety bus)
- Fire system containment isolation motor operated valve (2MOV-620), circuit breaker inspection
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed and/or reviewed the five surveillance tests listed below, associated with selected risk-significant SSCs, to verify TS compliance and that Constellation properly specified test acceptance criteria. The inspectors also verified that station personnel established proper test conditions as specified in the procedures, no equipment preconditioning activities occurred, and that acceptance criteria had been satisfied.
- Unit 1 reactor coolant system leakage surveillance (STP O-27-1)
- 11 auxiliary feedwater pump inservice surveillance test (STP O-5A-1)
- Unit 2 reactor coolant system leakage surveillance (STP O-27-2)
- Unit 1 remote shutdown and post accident monitoring instrumentation channel check (STP O-63-1)
- Unit 2 high pressure safety injection and low pressure safety injection check valve closure test (STP O-65-2)
b. Findings
No findings of significance were identified.
1R23 Temporary Plant Modifications
a. Inspection Scope
The inspectors reviewed one temporary modification to verify that safety systems did not depart from the design basis and system success criteria. The inspectors reviewed the associated 10 CFR 50.59 screening against the system design bases documentation, including the UFSAR. The inspectors walked down each modification to verify that proper configuration control was maintained to ensure continued system operability. In addition, the inspectors verified that the licensee controlled the modification in accordance with the requirements of procedure MD-1-100, "Temporary Alterations."
- Disabling an alarm relay in the 0C diesel generator battery monitor alarm circuit
b. Findings
No findings of significance were identified.
Cornerstone: Emergency Preparedness (EP)
1EP6 Drill Evaluation
a. Inspection Scope
The inspectors observed a site emergency response drill training exercise conducted on July 26, 2006, to assess licensed operators and site Emergency Director performance in the area of emergency preparedness. This training exercise focused on equipment failures and operator challenges that would typically exist during a significant event which resulted in protective action recommendations (PARs) to state and local officials.
The inspectors also observed and evaluated the required procedural transitions and associated event classifications.
b. Findings
No findings of significance were identified.
2. Radiation Safety
Cornerstone: Occupational Radiation Safety (OS)
2OS1 Access Control to Radiologically Significant Areas (71121.01)
a. Inspection Scope
(7 Samples)
The inspectors reviewed radiological work activities and practices and procedural implementation during observations and tours of the facilities and inspected licensee Performance Indicators (PIs) relative to the Occupational Exposure Cornerstone. The licensee had one PI in this cornerstone for the period from October 2005 -
September 15, 2006 (NRC Inspection Report Nos. 5000317/2006002 and
===5000318/2006002)
The inspectors reviewed corrective action reports related to access controls. This review included any high radiation area radiological incidents, identified by the licensee, in high radiation areas <1R/hr that have occurred since the last inspection in this area.
Additionally, the inspector reviewed any pertinent problem identification and resolution issues identified in this area, and assessed the licensees self-assessment activities.
The inspectors reviewed licensee documentation packages relative to possible PI events occurring since the last inspection to determined if any events involved dose rates >25 R/hr at 30 centimeters or >500 R/hr at 1 meter, what barriers failed or remained available to prevent personnel access. The inspectors reviewed unintended exposures >100 mrem Total Effective Dose Equivalent (TEDE) (or >5 rem Skin Dose Equivalent (SDE) or >1.5 rem Lens Dose Equivalent (LDE)), to determine if there were any overexposures or substantial potential for overexposure. There were no licensee events which occurred between October 2005 - September 15, 2006 which met any of the above criteria.
The inspectors conducted radiation worker performance observations during dry storage cask movement and lid welding activities to determine if radiation workers were aware of significant radiological conditions in the work place, the required RWP controls, and to assess the level of radiological hazards present.
The inspectors reviewed radiological problem reports relative to radiation worker errors since the last inspection to examine the licensees cause assessments, including the determination of any observable pattern traceable to a similar cause; and, the effectiveness of the licensees efforts to resolve the reported problems. The inspectors discussed corrective actions with the Radiation Protection Manager (RPM). The inspectors verified the adequacy of postings and verified the integrity of Locked High Radiation Areas, and Very High Radiation Areas (if reasonably accessible).
The inspectors conducted radiation protection technician observations during dry storage cask movement and lid welding activities to determine if job coverage technicians were aware of significant radiological conditions in the work place, the required RWP controls; and to assess their appreciation of the radiological hazards.
The inspectors reviewed any radiological problem reports associated with radiation protection technician performance errors.
b. Findings
No findings of significance were identified.
2OS2 ALARA Planning and Controls (71121.02)
a. Inspection Scope
=
The inspectors reviewed the integration of ALARA requirements in work procedures and RWP documents.
The inspectors evaluated the radiation protection group generated shielding requests with respect to dose rate reduction problem definition and assigning value (dose savings or dollars). In addition, the inspectors evaluated engineering shielding responses for follow through.
The inspector determined if there have been any declared pregnant workers during the current assessment period, and reviewed the exposure results and monitoring controls employed by the licensee with respect to requirements of 10 CFR 20.
b. Findings
No findings of significance were identified.
2OS3 Radiation Monitoring Instrumentation (71121.03)
a. Inspection Scope
(1 Sample)
The inspectors verified the calibration expiration and source response check currency on radiation detection instruments staged for use. The inspector interviewed radiation protection technicians and observed technicians select and self verify instrument operability prior to use.
b. Findings
No findings of significance were identified.
Cornerstone: Public Radiation Safety (PS)
2PS3 Radiological Environmental Monitoring Program (REMP)
a. Inspection Scope
(10 Samples)
The inspector reviewed the current Annual Radiological Environmental Monitoring Report and recent licensee assessment results to verify that the REMP was implemented as required by technical specifications (TS) and the offsite dose calculation manual (ODCM). The review included changes to the ODCM and environmental monitoring program commitments concerning sampling locations, monitoring and measurement frequencies, land use census, inter-laboratory comparison program, and data analysis. In addition, the inspector reviewed station self-assessments and audits, licensee event reports, inter-laboratory comparison program results, the UFSAR for information regarding the environmental monitoring program and meteorological monitoring instrumentation, and the scope of the audit program to verify that it met the requirements of 10 CFR 20.1101(c).
The inspector walked down four (of five) air particulate and iodine sampling stations; one (of 3) vegetation sampling locations; one (of one) shoreline sediment location; two (of two) bay water composite sampling locations; and eight (of 23) thermoluminescent dosimeter (TLD) monitoring locations, and determined that these were located as described in the ODCM and determined the equipment material condition to be acceptable.
The inspector observed the collection and preparation of a variety of environmental samples (listed above) and verified that environmental sampling was representative of the release pathways as specified in the ODCM and that sampling techniques were in accordance with procedures.
Based on direct observation and review of records, the inspector verified that the meteorological instruments were operable, calibrated, and maintained in accordance with guidance contained in the UFSAR, NRC Safety Guide 23, and station procedures.
The inspector verified that the meteorological data readout and recording instruments in the control room and at the tower were operable.
The inspector reviewed each event documented in the Annual Environmental Monitoring Report which involved a missed sample, inoperable sampler, lost TLD, or anomalous measurement for the cause and corrective actions. The inspector conducted a review of Constellations assessment of any positive sample results.
The inspector reviewed any significant changes made by the licensee to the ODCM as the result of changes to the land census or sampler station modifications since the last inspection. The inspector also reviewed technical justifications for any changed sampling locations and verified that the licensee performed the reviews required to ensure that the changes did not affect its ability to monitor the impacts of radioactive effluent releases on the environment.
The inspector reviewed the calibration and maintenance records for air samplers, as well as technical descriptions of new air sampling equipment purchased and being introduced into the field by Constellation. The inspector reviewed: the results of Calvert Cliffs interlaboratory comparison program to verify the adequacy of environmental sample analyses performed by the station; the stations quality control evaluation of the interlaboratory comparison program and the corrective actions for any deficiencies; Calvert Cliffs determination of any bias to the data and the overall effect on the REMP; and quality assurance audit results of the program to determine whether the licensee met the TS/ODCM requirements. The inspector verified that the appropriate detection sensitivities with respect to TS/ODCM are utilized for counting samples and reviewed the results of the quality control program including the interlaboratory comparison program to verify the adequacy of the program.
The inspector observed several locations where the station monitors potentially contaminated material leaving the radiologically controlled area, and inspected the methods used for control, survey, and release from these areas, including observing the performance of personnel surveying and releasing material for unrestricted use verifying that the work is performed in accordance with plant procedures.
The inspector verified that the radiation monitoring instrumentation was appropriate for the radiation types present and was calibrated with appropriate radiation sources. The inspector reviewed Constellations criteria for the survey and release of potentially contaminated material; verified that there was guidance on how to respond to an alarm which indicates the presence of licensed radioactive material; and reviewed the licensees equipment to ensure the radiation detection sensitivities were consistent with the NRC guidance contained in IE Circular 81-07 and IE Information Notice 85-92 for surface contamination and HPPOS-221 for volumetrically contaminated material.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES (OA)
4OA1 Performance Indicator (PI) Verification (71151 - 2 Samples)
a. Inspection Scope
Cornerstone: Occupational Radiation Safety
- Occupational Exposure Control Effectiveness (OECE)(02.01)
The inspectors interviewed cognizant personnel and selectively examined records used by the licensee to identify occurrences involving high radiation areas, very high radiation areas, and unplanned personnel exposures for the time period from October 2005 to September 15, 2006. The reviewed records included selected corrective action program records and the periodic PI data records for this PI. This review was conducted against the applicable criteria specified in Nuclear Energy Institutes (NEI) Regulatory Assessment Performance Indicator Guideline No. 99-02 (Revision 3), with an effective date of April 1, 2005.
The inspectors determined that the licensee had one occurrence during the period specified which met the applicable criteria and this event was properly reported as a PI.
This event is documented in NRC Inspection Report Nos. 5000317/2006002; 5000318/2006002. This review and examination did not identify any problems with the PI accuracy or completeness and thus, verified this performance indicator. This inspection activity represents the completion of 1 sample relative to this inspection area (i.e., inspection procedure section 02.01) for one performance indicator (i.e., OECE).
- Radiological Effluent Technical Specification/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM REOs)(02.01)
The inspector interviewed cognizant personnel and selectively examined records use by the licensee to identify any occurrences involving gaseous or liquid effluent releases for the time period from October 2005 - September 15, 2006. The reviewed records included selected corrective action program records and the periodic PI data records for this PI. This review was conducted against the applicable criteria specified in Nuclear Energy Institutes (NEI) Regulatory Assessment Performance Indicator Guideline No.
99-02 (Revision 3), with an effective date of April 1, 2005.
This review and examination did not identify any problems with the PI accuracy or completeness and, thus, verified this performance indicator. This inspection activity represents the completion of 1 sample relative to this inspection area (i.e., inspection procedure section 02.01) for one performance indicator (i.e., RETS/ODCM REOs).
b. Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems
.1 Review of Items Entered Into the Corrective Action Program
The inspectors performed a daily screening of items entered into Constellations corrective action program as required by Inspection Procedure 71152, Identification and Resolution of Problems. The review facilitated the identification of potentially repetitive equipment failures or specific human performance issues for follow-up inspection. Inspectors reviewed each issue report, attended screening meetings, and accessed Constellations computerized database.
.2 Annual Sample: Review of Operator Workarounds
a. Inspection Scope
The inspectors performed an in-depth review of workarounds in accordance with IP 71152. This included an evaluation of the cumulative effects of documented workarounds, field walkdown to determine potential undocumented workarounds, review of Condition Reports (CRs) and Control Room walkdowns. The evaluation followed the guidelines in 71152 paragraph 03.02 b and assessed potential workarounds not evaluated by station personnel, workarounds that have been formalized as long-term corrective actions, and workarounds that increase the potential for human performance errors.
b. Findings
No findings of significance were identified.
.3 Annual Sample: Review of Safety Related Salt Water System Performance During
Debris Intrusion
a. Inspection Scope
The inspectors conducted a review of Constellations safety related salt water (SW)system, which takes a suction on the Chesapeake Bay and acts as an ultimate heat sink. Inspectors selected this sample since there were several events which challenged the system. Specifically, in July and August 2006 there was an unusually high number of jellyfish at the traveling screens which remove debris from the suction of the circulating and salt water systems. The jellyfish clogged the traveling screens to the point were circulating water pumps had to be removed from service. In September 2006, there was an excessive amount of debris in the bay caused by high winds. The inspection involved a system evaluation by reviewing logs, procedures, design basis documents, performance monitoring, interviewing site personnel, and walkdowns of plant equipment. The inspection focused on possible common mode failure conditions and susceptible equipment, as well as equipment and personnel performance during this time.
b. Findings
Introduction.
The inspectors identified a Green NCV of TS 5.4.1.a, Administrative Controls - Procedures, for failure to follow the Alarm Manual for the service water (SRW) system. Specifically, the operators did not initiate CRs to address SRW heat exchanger salt water (SW) strainer trouble alarms. Constellation also did not assess system operability as required by the Corrective Action Program.
Description.
During a jellyfish intrusion on July 19, 2006, the inspectors walked down the traveling water screens and noted some carryover of debris from the front side of the screen to the backside of the screen. A review of control room logs for that day identified several SW strainer trouble alarms. Further investigation showed that the 22A SW strainer valve was not in its correct position. The alarm response procedure directs the operator to attempt to reset the circuitry, determine which valve failed, and if the flushing valve is fully or partially open, consider placing the control system to Off for that strainer to allow the other strainer on the same train to function in automatic.
Finally, the alarm response procedure directs initiation of a condition report for equipment deficiencies. Operators performed a manual flush of the strainer and the alarm cleared. The manual flush is not described in this alarm response procedure, no CR was written, and station personnel did not assess system operability. On July 21, 2006, following a discussion with the inspector, Operations personnel initiated CR IRE-016-074. Constellation categorized this CR as a level 4 and closed the CR to trend, with no actions taken. The operability explanation noted that the alarm was apparently caused by influx of jellyfish and was promptly resolved per the Alarm Manual. The inspectors also discussed with engineers that if manual action was required during debris intrusions, then SW strainer operability could be challenged. Constellation created an Incident Response Team (IRT) and performed an apparent cause evaluation for the jellyfish intrusion but did not perform an evaluation on the potential impact to safety-related systems.
On September 1, 2006, following high winds from tropical storm Ernesto inspectors reviewed the control room logs and found several cases where condition reports were not written for SW strainer trouble alarms. The alarms came in and cleared with no action taken on a number of occasions. The system is design for the strainer to autoflush before an alarm is received. In one case, a 12B SW strainer valve was not in its correct position and the control room logs indicate the actions taken for the alarm were unsuccessful. On other occasions operators were dispatched to observed the SW strainer going into an autoflush or to manually flush the strainer following an alarm.
In response to the inspectors observations and discussions regarding strainer performance, the Constellation staff initiated IRE-017-018 to address why no CRs were initiated for these issues. The inspectors concluded that with the SW strainer valve in the wrong position, the automatic backwash feature of the associated subsystem strainer would not function, and therefore the SW strainer was inoperable. The inspectors also concluded that there was an adverse impact to the SW strainers from debris intrusion and that Constellation, by not documenting the adverse conditions in their corrective action process as required by their procedure, missed an opportunity to assess the impact on system operability as well as determine the corrective actions needed to address the issue. The inspectors determined that on July 19, 2006 a SW strainer was inoperable for one subsystem on Unit 2 for less than one hour. On September 1, both subsystems were inoperable, but not at the same time and for less than one hour.
Analysis.
The failure to follow the Alarm Response Manual for the salt water system is the performance deficiency in that the Constellation staff did not initiate CRs to address salt water strainer trouble alarms or assess system operability as required by the procedure. The performance deficiency more than minor since it had a credible impact on the objective for the mitigating system cornerstone and the attribute of component reliability during design basis events where the SW system was required. The finding was determined to be of very low safety significance, Green, using phase 1 of the SDP since the TS allowed outage time for one subsystem inoperable was not exceeded. The inspectors identified that a contributing cause of this finding was related to the cross-cutting aspect of PI&R because Constellation did not implement the corrective action program with a low threshold for identifying the problems with the SW strainers.
Enforcement.
TS 5.4.1a, Administrative Controls - Procedures, requires, in part, that written procedures be established and implemented for activities recommended in Regulatory Guide 1.33, revision 2, Appendix A of February 1978. Paragraph 6 of Appendix A requires procedures for safety-related alarm conditions. The SW strainers are safety-related and have alarm response procedures associated with each of its service water heat exchangers. Contrary to the above, on July 19 and September 1, 2006, Constellation failed to adequately implement the alarm response procedures because no condition report was written. This violation is documented in Constellations corrective action program as IRE-017-018 and is being treated as a non-cited violation consistent with Section VI.A.1 of the NRC Enforcement Policy: NCV 05000317 and 318/2006004-02, Failure to comply with TS 5.4.1 for Salt Water Strainers.
.4 Radiological Environmental Monitoring Program
a. Inspection Scope
The inspector reviewed the Constellations Licensee Event Reports, Special Reports, and audits related to the radiological environmental monitoring program performed since the last inspection. The inspector determined that identified problems were entered into the corrective action program for resolution. The inspector also reviewed corrective actions affecting environmental sampling, sample analysis, or meteorological monitoring instrumentation.
b. Findings and Observations
No findings of significance were identified.
4OA3 Event Followup
Reduction of Power Generation due to Jellyfish Intrusion The inspectors assessed operator performance associated with a Unit 1 event that involved a rapid reduction of power. On July 7, 2006, at approximately 4:30 p.m., a large number of jellyfish entered the intake basin of the plant. The jellyfish challenged the circulating water and screen wash systems. Unit 1 control room operator (CRO)received high differential pressure (D/P) alarms on several traveling screens in the control room. The CRO immediately dispatched outside operators to investigate the cause and subsequently gave directions to clear the traveling screens. The outside operators used fire hoses to deflect the jellyfish away from the intake. At approximately 4:59 p.m., The Unit 1 CROs implemented Abnormal Operating Procedure (AOP) - 7L, Circulating Water / Intake Malfunction, due to continuos high D/P alarms on the traveling screens and securing two circulating water pumps. Unit 1 required a rapid reduction of power in accordance with AOP-7L. The inspectors observed plant operation, procedure adherence and system performance during this time. The inspectors assessed the plant response and conditions specific to the event, and evaluated the performance of licensed operators. The inspectors reviewed control room procedures and operator logs to determine if operators performed the appropriate actions in accordance with their training and established station procedures.
b. Findings
No findings of significance were identified.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On September 29, 2006, the resident inspectors presented the inspection results to Mr Spina and other members of his staff who acknowledged the findings. The inspectors asked the licensee whether any of the material examined during the inspection should be considered proprietary. No proprietary information was identified.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Constellation Personnel
- J. Spina, Vice President
- J. Pollock, Plant General Manager
- D. Bauder, Operations Manager
- A. Barnett, REMP Laboratory, Ft. Smallwood
- L. Bartal, Laboratory Supervisor, Ft. Smallwood
- J. Branyan, Functional Surveillance Test Coordinator
- R. Conatser, Senior Chemist, REMP Program Manager
- S. Dean, General Supervisor Operations
- J. Detechemundy, Health Physics Technician
- B. Erdman, Radiological Engineering Supervisor
- S. Etnoyer, Plant Health Physicist
- H. Evans, Health Physics Leader
- M. Flaherty, Engineering Services Manager
- P. Furio, Supervisor Licensing
- J. Gaines, Director Calvert Cliffs Licensing
- D. Geneva, General Supervisor, Chemistry
- T. Hickey, Welder
- J. Johnson, Licensing
- P. Jones, Senior Plant Health Physicist
- R. Kellner, Senior Plant Health Physicist
- T. Kirkham, Principle Plant Health Physicist
- L. Larragoite, Constellation Licensing Director
- R. Marshall, Health Physics Technician
- K. Mills, System Engineering General Supervisor
- S. Marie Reichard, Engineering Analyst
- C. Neyman, Engineering Analyst
- E. Roach, General Supervisor of Health Physics
- D. Scroggy, Health Physics Technician
- A. Simpson, Sr. Licensing Engineer
- B. Snuse, Licensing
- M. Stanley, Operations, Fire Brigade
- L. Williams, System Manager
- M. Yox, Engineering Analyst
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened
- 05000317/2006004-03 URI 1A EDG Ventilation Fan Performance