Text

IR 05000317-12-002, 05000318-12-002, on 1/1/2012 - 3/31/2012, Calvert Cliffs Nuclear Power Plant (Ccnpp), Units 1 and 2: Post-Maintenance Testing, and Followup of Events and Notices of Enforcement Discretion
	ML12123A036
Person / Time
Site:	Calvert Cliffs
Issue date:	05/02/2012
From:	Glenn Dentel; NRC Region 1
To:	George Gellrich; Constellation Energy Nuclear Group, Calvert Cliffs
References
	IR-12-002
	Download: ML12123A036 (44)
	v • d • e

UNITED STATES May 2, 2012

SUBJECT:

CALVERT CLIFFS NUCLEAR GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000317/2012002 AND 05000318/2012002

Dear Mr. Gellrich:

On March 31, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on April 20, 2012, 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 one NRC-identified finding and one self-revealing finding of very low safety significance (Green). Both of these findings were determined to involve violations of NRC requirements. However, because of the very low safety significance, and because they are entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCVs) consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest any NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region 1; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Calvert Cliffs.

In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I; and the NRC Resident Inspector at Calvert Cliffs. In accordance with 10 CFR 2.390 of the 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/

Glenn T. Dentel, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Nos.: 50-317, 50-318 License Nos.: DPR-53, DPR-69

Enclosure:

Inspection Report 05000317/2012002 and 05000318/2012002 w/Attachment: Supplemental Information

REGION I==

Docket Nos.: 50-317, 50-318 License Nos.: DPR-53, DPR-69 Report No.: 05000317/2012002 and 05000318/2012002 Licensee: Constellation Energy Nuclear Group, LLC Facility: Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Location: Lusby, MD Dates: January 1, 2012, through March 31, 2012 Inspectors: S. Kennedy, Senior Resident Inspector E. Torres, Resident Inspector K. Cronk, Project Engineer T. Burns, Reactor Inspector R. Rolph, Health Physicist S. Pindale, Senior Reactor Inspector E. Gray, Senior Reactor Inspector Approved by: Glenn T. Dentel, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000317/2012002, 05000318/2012002; 1/1/2012 - 3/31/2012; Calvert Cliffs Nuclear Power

Plant (CCNPP), Units 1 and 2: Post-Maintenance Testing; and Followup of Events and Notices of Enforcement Discretion.

The report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional 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). The cross-cutting aspects for the findings were determined using IMC 0310, Components Within the Cross-Cutting Areas. 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 4, dated December 2006.

Cornerstone: Mitigating Systems

Green: 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]. (Section 1R19)

Green: 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 [H.2.(c) per IMC 0310]. (Section 4OA3)

Other Findings

None

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period at 100 percent power. On February 1, 2012, operators reduced power to 93 percent for AFW pump testing. Operators returned the unit to full power the following day. On February 5, operators shut down the unit for the refueling outage. The unit remained shut down for the remainder of the inspection period.

Unit 2 began the inspection period at 100 percent power. On January 7, operators reduced power to 84 percent for main turbine valve testing. The unit was returned to full power the same day. On February 13, operators performed an unplanned downpower to 57 percent due to speed control problems with the No. 21 steam generator feed pump. Operators returned the unit to full power on February 18. The unit remained at or near 100 percent power for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R01 Adverse Weather Protection (71111.01 - One Sample)

Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

The inspectors performed a review of Constellations readiness for the onset of adverse weather associated with severe weather on February 24, 2012, due to a tornado watch.

The review included an assessment of emergency preparedness procedure EP-1-108, Severe Weather Preparation, and Emergency Response Plan Implementation Procedure 3.0, Immediate Actions, Attachment 20, Severe Weather. The inspectors verified that the actions specified in the associated procedures maintain readiness of essential equipment and systems to preclude weather induced initiating events. In addition, the inspectors performed field walkdowns to verify that equipment required for safe plant shutdown remained functional. Documents reviewed for each section of this inspection report are listed in the Attachment.

b. Findings

No findings were identified.

1R04 Equipment Alignment

Partial Walkdowns (71111.04Q - Five Samples)

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems:

Unit 1 B train emergency core cooling system (ECCS) during A train ECCS maintenance on January 23, 2012

No. 13 AFW pump during No. 11 and No. 12 AFW pumps maintenance on January 27, 2012

Unit 2 B train ECCS during A train ECCS maintenance on January 31, 2012

No. 12 saltwater (SW) header during No. 11 SW header maintenance on February 16, 2012

1A EDG during 2B EDG maintenance on March 1, 2012 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable procedures, system diagrams, the Updated Final Safety Analysis Report (UFSAR), TSs, condition reports (CRs), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Constellation staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.

b. Findings

No findings were identified.

1R05 Fire Protection

Quarterly Inspection (71111.05Q - Six Samples)

a. Inspection Scope

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

Unit 1 main plant exhaust and equipment room, fire area 11, room 524 on January 12, 2012

Unit 2 main plant exhaust and equipment room, fire area 11, room 526 on January 12, 2012

Uni1 1 cable spreading room, fire area 16, room 306 on January 24, 2012

Unit 2 switchgear room, fire area 24, room 401 on February 8, 2012

Unit 2 service water pump room, fire area 40, room 205 on February 16, 2012

Unit 1 containment, fire area CNMT, room 230 on March 6, 2012

b. Findings

No findings were identified.

1R08 Inservice Inspection (71111.08 - One Sample)

a. Inspection Scope

The inspectors conducted an inspection to assess the effectiveness of Constellations Inservice Inspection Program (ISI) for monitoring degradation of the reactor coolant system (RCS) boundary, risk significant piping system boundaries, and the containment boundary. The inspectors assessed the ISI activities using the criteria specified in the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI and applicable NRC regulatory requirements.

The inspectors selected a sample of nondestructive examination (NDE) activities for review and evaluation for compliance with the requirements of ASME Section XI. The inspectors also selected samples of repairs and replacement activities which involved welding on safety related pressure boundary systems. This sample selection was based on the inspection procedure objectives, risk significance and availability. Specifically, the inspectors focused on components and systems where degradation could result in a significant increase in risk of core damage and required welding to affect the repair/replacement. The inspectors reviewed examination procedures, procedure qualifications, personnel qualifications and examination test results. Also, the inspectors reviewed and evaluated the eddy current process and the testing of a sample of the steam generator tubes from both steam generators including data acquisition, analysis, and characterization of reported anomalies.

The inspectors observed the performance the following two nondestructive tests (liquid penetrant and ultrasonic) performed on safety related pressure retaining components.

Ultrasonic test of weld (1-SI-434) of pipe to valve in the safety injection system shown on drawing 91097SH0014, using work order (WO) C120092680. Ultrasonic test procedure NDE-5449-CC, Revision 1 was used for this examination.

Liquid penetrant examination of weld (1-SI-434) of pipe to valve in the safety injection system shown on drawing 91097SH0014, using WO C120092680. Liquid Penetrant test procedure NDE-5240-CC was used for this examination.

In addition to the nondestructive tests observed, the inspectors performed a documentation review of welds examined during a previous outage for systems and components of high safety significance for which degradation could result in a significant increase in risk. The additional welds from the previous outage were selected because of the reduced scope of examinations during this period (First Period, Fourth Inspection Interval, ASME Section XI).

Additional Nondestructive Testing Inspected:

Ultrasonic examination of the upper assembly to transition assembly of steam generator vessel weld, SG-22-4, using Procedure NDE-5455-CC R0.

Magnetic Particle Examination of Shutdown Cooling Heat Exchanger Inlet Nozzle, SCHE-21-N1, using NDE Procedure NDE-5140-CC R1.

The inspectors reviewed procedures used to perform visual examinations for indications of boric acid leaks (active and inactive) from piping and components containing reactor coolant. The inspectors reviewed results of inspections performed in accordance with Constellations boric acid corrosion control program. The inspectors reviewed active leak location at valve 1MOV634 in system 052 (safety injection). This component was scheduled for repair/replacement this outage. The inspectors reviewed inspection reports and results that identified boric acid crystal deposits during plant walk downs performed while the plant was at normal operating temperatures and pressures, and after plant shutdown (cold shutdown).

The inspectors reviewed two rework/repair activities, where welding was performed, to evaluate the control of the welding process and compliance with the requirements of ASME Section XI:

Repair/Replacement plan 2011-1-044, WO C90742741, repair/replacement/

modification of Unit 1 pressurizer heaters, heater sleeves, and bottom instrument nozzles. New penetrations being inserted into the vessel bottom, welded in place and nondestructively tested subject to the acceptance requirements of ASME Section XI.

Repair/Replacement plan 2011-1-098, WO C91385107, Overhaul of main steam isolation valve Unit 1, 1CV-4048, replacement of gasket and disc using weld authorization traveler CAL-1-2011-0009. New parts installed and subject to the acceptance criteria of ASME Section XI, Class 2.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program (71111.11 - Two samples)

.1 Quarterly Review of Licensed Operator Requalification Testing and Training

a. Inspection Scope

The inspectors observed licensed operator simulator training on January 18, 2012, which included a reactor shutdown from full power using plant operating procedures OP-4, Plant Shutdown from Power Operation to Hot Standby; OP-5, Plant Shutdown from Hot Shutdown to Cold Shutdown; and OP-7, Shutdown Operations. The inspectors observed licensed operators response to a loss of RCS inventory with shutdown cooling in service, loss of shutdown cooling with pressurization of the RCS possible, loss of shutdown cooling due to the loss of 4 kilovolt (kV) power supplies, and loss of offsite power while in Modes 3-6. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures.

The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager and the TS action statements entered by the shift technical advisor. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.

b. Findings

No findings were identified.

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

a. Inspection Scope

The inspectors observed and reviewed engineered safety guards features actuation system testing, vacuum fill operations in reduced inventory, and mode 4 preparations including drawing of the pressurizer bubble on Unit 1 on March 22, March 23, and March 27, respectively. The inspectors observed infrequently performed test or evolution briefings, pre-shift briefings, and reactivity control briefings to verify that the briefings met the criteria specified in CNG-OP-1.01-2001, Communications and Briefings. Additionally, the inspectors observed test performance to verify that procedure use, crew communications, and coordination of activities between work groups similarly met established expectations and standards.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness (71111.12Q - One Sample)

a. Inspection Scope

The inspectors reviewed the sample listed below to assess the effectiveness of maintenance activities on systems, structures, and components (SSCs) performance and reliability. The inspectors reviewed system health reports, CAP documents, maintenance WOs, and maintenance rule basis documents to ensure that Constellation was identifying and properly evaluating performance problems within the scope of the maintenance rule. For each sample selected, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with 10 CFR 50.65 and verified that the (a)(2) performance criteria established by Constellation staff was reasonable.

As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2). Additionally, the inspectors ensured that Constellation staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.

Unit 1 main steam safety valve (1RV3993) lifted above TS limit on February 2, 2012

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - Eight

Samples)

a. Inspection Scope

The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that Constellation performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that Constellation personnel performed risk assessments as required by 10 CFR 50.65(a)(4)and that the assessments were accurate and complete. When Constellation performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the stations probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

Planned maintenance on No. 11 SW header on January 23, 2012

Solar magnetic disturbance warning on January 24, 2012

Unit 1 refueling outage shutdown safety summary schedule review on January 31, 2012

Unplanned loss of the No. 13 charging pump on February 13, 2012

Unplanned loss of the No. 21 charging pump on February 15, 2012

Planned maintenance on No. 11 4 kV bus on February 23, 2012

Unit 1 shutdown risk assessment during planned outage of P-13000-1 transformer on March 6, 2012

Unit 1 shutdown risk assessment during planned outage of 0C diesel generator on March 12, 2012

b. Findings

No findings were identified.

1R15 Operability Determinations (OD) and Functionality Assessments

(71111.15 - Seven Samples)

a. Inspection Scope

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

No. 23 high pressure safety injection (HPSI) pump bearing oil sample appears to contain particulates (CR-2012-000487) on January 16, 2012

Unit 2 pressurizer safety valve may have been set at lower temperature than exists in the plant (CR-2009-003660) on January 20, 2012

Degraded fire barrier between Unit 1 cable spreading room and Unit 1 turbine building (CR-2012-000742) on January 25, 2012

AFW emergency air pressure regulators have not been periodically tested (CR-2012-000894, CR-2012-000895) on January 26, 2012

Foreign material identified in the Unit 1 pressurizer (CR-2012-001587) on February 15, 2012

Gap identified in switchgear rooms high energy line break roll up doors (CR-2012-002141) on February 24, 2012

No. 11 steam generator AFW main steam admission valve bypass valve packing load out of specification (CR-2012-002989) on March 9, 2012 The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the ODs to assess whether TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TSs and UFSAR to Constellations evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by Constellation. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.

b. Findings

No findings were identified.

1R18 Plant Modifications (71111.18 - Two samples)

.1 Permanent Modifications

a. Inspection Scope

The inspectors reviewed the permanent modifications listed below to determine whether the modifications affected the safety functions of systems that are important to safety.

The inspectors verified that the design bases, licensing bases, and performance capability of the affected systems were not degraded by the modification. In addition, the inspectors reviewed modification documents associated with the upgrade and design change, including operational impact design evaluation, installation and testing instructions, and drawings changes associated with the modifications.

Engineering change package 12-000082, Jumper Unit 2 saltwater air compressor (SWAC) air to Unit 2 AFW air loads

Engineering change package 11-000702, Swap function of No. 11 component cooling heat exchanger isolation valves 1CV5206 and 1HVSW-254

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing (71111.19 - Eight Samples)

a. Inspection Scope

The inspectors reviewed the PMTs for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability.

The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure were consistent with information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.

Replace AFW emergency pressure control valves 1PCV4070 and 1PCV4071 (WO C90715182, C90715187) on January 26, 2012

Replace No. 11 HPSI pump bearing on (WO C91719061) on March 7, 2012

Replace No. 13 HPSI pump outboard mechanical seal (WO C90884328) on March 12, 2012

Overhaul 11A loop inlet check valve (1-SI-217) (WO C91189774) on March 8, 2012

Overhaul No. 11 low pressure safety injection pump (WO C120085259) on March 8, 2012

Overhaul refueling water tank isolation valve (WO C120070149) on March 16, 2012

Install loop seal on No. 12 control room heating, ventilation, and air conditioning unit (WO C91735472) on March 30, 2012

Replace solenoid valve for unit 1 turbine building service water No. 11 header isolation valve, 1CV1637, due to inoperable closed stroke (WO C91787029) on March 29, 2012

b. Findings

Introduction:

The inspectors identified a Green 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 AFW AOVs will operate as design with the emergency air accumulators and associated PCVs. Specifically, the inspectors identified that safety related AFW emergency air PCVs were replaced without a functional PMT. The inspectors also identified that the AFW emergency air system had not being tested since the emergency air accumulators were installed in the 1980 and the 1990.

Description:

On January 24, 2012, during review of WOs C90715182 and C90715187 to replace the AFW steam admission valve backup safety-related air supply PCVs (1PCV4070 and 1PCV4071), the inspectors identified that Constellation did not establish an operational PMT for the installed PCVs. The WO only required a leak test of the disturbed fittings and stated that the WO will not request a valve stroke as a PMT because there is not an operating procedure that directs isolation of the normal air supply from the instrument air header to specifically check the backup system. The inspectors determined that the PMT was inadequate because the test did not ensure that the safety-related backup system was properly restored to service following maintenance. As immediate corrective action, Constellation entered the PMT issue into their CAP (CR-2012-00894) and performed an operational check on the installed PCVs satisfactorily for both Units 1 and 2. In addition, Constellation performed an as-found bench test on the replaced PCVs for Unit 1. As-found data ranged from 78.9 to 87.5 pounds per square inch gauge (psig) which were above the minimum design pressure of 60 psig, but in some instances, less than the administrative requirement of 85 +/-1 psig.

As a result of the PMT issues, the inspectors performed a review of the other backup safety related PCVs in the AFW system. In addition to PCV4070 and PCV4071 for the steam admission valves, the AFW backup safety-related air system also contains PCV4510 and PCV4520, which are downstream of their respective safety-related emergency accumulators (RCVR 11A and RCVR 11B for Unit 1 and RCVR 21A and RCVR 21B for Unit 2). These PCVs control air system pressure from the emergency accumulators in the event of a loss of the normal non-safety related air source and support operability of the flow control valves, block valves, and the motor driven AFW pumps cross connect valves that supply AFW between Units 1 and 2. The inspectors identified that Constellation did not have an operational test program to demonstrate that the AFW AOVs would operate satisfactorily as design using the emergency air accumulators and associated PCVs. The inspectors determined that the AFW emergency air system had not being tested since the accumulators were installed in the 1980s for RCVR 11A/21A and RCVR 11B/21B and the 1990s for ACC4070 & ACC4071.

The inspectors determined that a reasonable doubt of operability existed because the capability of the AFW AOVs to operate using backup air supply had not been demonstrated since original installation. In consultation with the vendor, Constellation discovered that these PCVs are recommended to be periodically operated and overhauled because there is potential for the possible build-up of particulate and condensation in the tight clearances of the PCVs which could affect proper operation.

This is similar to the industry operating experience discussed in NUREG-1275, Evaluation of Air Operated Valves in Light Water Reactors, which states that AOVs are vulnerable to common cause failures from contaminants introduced from pneumatic systems because many AOV piece-parts have tight clearances and tolerances.

NUREG-1275 states that the implementation of an effective AOV program, incorporating the use of analysis, diagnostic testing, and lessons learned from operating experience, can minimize the likelihood of AOV failures resulting in risk significant events. Although Constellations instrument air system meets industry standards for air quality, the vendor stated that it could still result in some contamination.

Immediate corrective actions included entering the test program issue into their CAP (CR-2012-000895) and performing an OD to provide the basis for reasonable expectation of operability. The OD discussed Calvert Cliffs air quality program, potential failure mechanisms, and compensatory actions to support operability. As a compensatory measure, Constellation aligned the safety-related SWACs as an additional backup supply to the AFW AOVs. The line up provides an additional source of safety-related air to the AFW AOVs for all events with the exception of a station blackout event. Also, to address the testing program issue, Constellation developed procedure PE-1-36-9-O-R, AFW Air Accumulator Capacity Test, to be performed every refueling outage. The test will cycle all the AFW AOVs using the emergency air accumulators and associated PCVs to ensure that design specifications are met. In addition, Constellation performed an as-found bench test for 1PCV4510 and 1PCV4520.

Both pressure regulators passed the bench test satisfactorily. 1PCV4510 and 1PCV4520 were overhauled during the Unit 1 outage and were tested satisfactorily with the new test procedure. Constellation is planning to test 2PCV4510 and 2PCV4520 during Unit 2 refueling outage in 2013.

Analysis:

Constellations failure to establish a test program that would include periodic operational testing and post maintenance operational testing to ensure that the AFW AOVs would operate as design using the emergency air accumulators and associated PCVs is a performance deficiency. 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 clearances of the PCVs which could impact reliable operation. 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 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]

Enforcement:

10 CFR Part 50, Appendix B, Criterion XI, Test Control, states in part, that a test program shall be established to assure that all testing required to demonstrate that SSCs will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. The test program shall include, as appropriate, proof tests prior to installation, preoperational tests, and operational tests during nuclear power plant operation. Contrary to the above, prior to January 26, 2012, Constellation did not establish a test program, which included periodic operational testing and post maintenance operational testing, to demonstrate that the AFW AOVs will operate as design with the emergency air accumulators and associated PCVs.

Constellations corrective actions included performing a functional test of the installed PCVs, performing an OD for the AFW emergency air system, and developing a testing procedure to periodically verify operation of AFW AOVs using the emergency air system.

Because this violation was of very low safety significance (Green) and Constellation entered the issue into their CAP (CR-2012-000895 & CR-2012-000894), this violation is being treated as an NCV, consistent with the Enforcement Policy. (NCV-05000317/318/2012002-01: Failure to Establish Test Program for Auxiliary Feedwater Emergency Air Accumulators)

1R20 Refueling and Other Outage Activities (71111.20 - One sample)

a. Inspection Scope

The inspectors reviewed the stations work schedule and outage risk plan for the Unit 1 maintenance and refueling outage (C1R21), which commenced on February 5, 2012.

Unit 1 remained in the refueling outage at the end of the inspection period. The inspectors reviewed Constellations development and implementation of outage plans and schedules to verify that risk, industry experience, previous site-specific problems, and defense-in-depth were considered. During the outage, the inspectors observed portions of the shutdown and cooldown processes and monitored controls associated with the following outage activities:

Configuration management, including maintenance of defense-in-depth, commensurate with the outage plan for the key safety functions and compliance with the applicable TSs when taking equipment OOS

Implementation of clearance activities and confirmation that tags were properly hung and that equipment was appropriately configured to safely support the associated work or testing

Installation and configuration of reactor coolant pressure, level, and temperature instruments to provide accurate indication and instrument error accounting

Status and configuration of electrical systems and switchyard activities to ensure that TSs were met

Monitoring of decay heat removal operations

Impact of outage work on the ability of the operators to operate the spent fuel pool cooling system

Reactor water inventory controls, including flow paths, configurations, alternative means for inventory additions, and controls to prevent inventory loss

Activities that could affect reactivity

Maintenance of secondary containment as required by TSs

Refueling activities, including fuel handling and fuel receipt inspections

Fatigue management

Identification and resolution of problems related to refueling outage activities

b. Findings

No findings were identified.

1R22 Surveillance Testing (71111.22 - Eight Samples)

a. Inspection Scope

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

STP-M-212-B-2, Channel B reactor protection system functional test on January 26, 2012

STP-O-67G-1, Safety injection check valve cold shutdown test on February 9, 2012

STM-O-108D-1, Containment penetration local leak rate test on February 10, 2012 (containment isolation valve)

STP-O-73G-1, HPSI large flow test on February 14, 2012 (In-service testing)

STP-O-67-H-1, Safety injection tank out check valve stroke test on February 17, 2012

STP-O-027-2, RCS leakage evaluation on March 2, 2012 (RCS leak)

STP-O-65D-2, Miscellaneous containment isolation valves quarterly test on March 2, 2012

STP-O-67M-2, Safety injection valve leak test on March 7, 2012

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstone: Occupational/Public Radiation Safety

2RS1 Radiological Hazard Assessment and Exposure Controls

The inspection objective is to review and assess Constellations performance in assessing the radiological hazards in the workplace associated with licensed activities and the implementation of appropriate radiation monitoring and exposure control measures for both individual and collective exposures.

The inspection was conducted from March 5 through 9 and March 19 through 22, 2012, using the requirements in 10 CFR Part 20; guidance in Regulatory Guide (RG) 8.38, Control of Access to High and Very High Radiation Areas for Nuclear Plants; the Calvert Cliffs TSs; and Constellations procedures as criteria for determining compliance.

.1 Inspection Planning (02.01)

a. Inspection Scope

The inspectors reviewed second Quarter 2011 - first Quarter 2012 Constellations performance indicators for the occupational exposure cornerstone for CCNPP. The inspectors reviewed the results of radiation protection program audits. The inspectors reviewed any reports of operational occurrences related to occupational radiation safety since the last inspection.

b. Findings

No findings were identified.

.2 Radiological Hazard Assessment (02.02)

a. Inspection Scope

The inspectors determined if there have been changes to plant operations since the last inspection that may result in a significant new radiological hazard for onsite workers or members of the public. The inspectors evaluated whether Constellation assessed the potential impact of these changes and has implemented periodic monitoring, as appropriate, to detect and quantify the radiological hazard.

The inspectors reviewed the last two radiological surveys from each elevation of the auxiliary building, each elevation of the containment building, and job specific surveys for the pressurizer heater replacements. The inspectors evaluated whether the thoroughness and frequency of the surveys were appropriate for the given new radiological hazard.

The inspectors conducted walk-downs and independent radiation measurements in the facility, including radioactive waste processing, storage, handling areas, and the area outside the Unit 1 butler building to evaluate material and radiological conditions.

The inspectors selected the following radiologically risk-significant work activities that involved exposure to radiation.

Pressurizer heater replacement

Cavity drain line modification

Reactor annulus entry For these work activities, the inspectors assessed whether the pre-work surveys performed were appropriate to identify and quantify the radiological hazard and to establish adequate protective measures. The inspectors evaluated the radiological survey program to determine if radiological hazards were properly identified (e.g.,

discrete radioactive hot particles, alpha emitters contamination, transuranics and hard to detect radionuclides in air samples, transient dose rates and large gradients in radiation dose rate).

The inspectors observed work in potential airborne areas and evaluated whether the air samples from the pressurizer heater replacement, the cavity drain line modification, and the reactor annulus entry locations were representative of the breathing air zone and properly evaluated. The inspectors evaluated whether continuous air monitors such as particulate, iodine and noble gas monitors, were located in areas with low background to minimize false alarms and were representative of actual work areas. The inspectors evaluated Constellations program for monitoring levels of loose surface contamination in areas of the plant with the potential for the contamination to become airborne.

b. Findings

No findings were identified.

.3 Instructions to Workers (02.03)

a. Inspection Scope

The inspectors selected containers in the Lake Davies area with old pressurizer heaters, drums and boxes outside the Unit 1 butler building, and a drum inside the containment on the 10 foot elevation holding non-exempt licensed radioactive materials that may cause unplanned or inadvertent exposure of workers. The inspectors assessed whether the containers were labeled and controlled in accordance with 10 CFR Part 20 requirements.

The inspectors reviewed the following radiation work permits used to access high radiation areas and evaluated if the specified work control instructions and control barriers were consistent with Calvert Cliffs TS requirements for High Radiation Areas.

1401, Steam Generator Hand Holes Work, Revision 0

1406, Reactor Coolant Seal Replacement, Revision 0

1501, Pressurizer Heater Replacement, Revision 1 For these radiation work permits, the inspectors assessed whether allowable stay times or permissible dose for radiological significant work under each radiation work permit were clearly identified. The inspectors evaluated whether electronic personal dosimeter alarm set-points were in conformance with survey indications and plant procedural requirements.

The inspectors reviewed CR-2012-001312, an occurrence where a workers electronic personal dosimeter noticeably malfunctioned or alarmed. The inspectors evaluated whether workers responded appropriately to the off-normal condition. The inspectors assessed whether the issue was included in the CAP and whether compensatory dose evaluations were conducted as appropriate.

For work activities that could suddenly and severely increase radiological conditions, the inspectors assessed Constellations means to inform workers of changes that could significantly impact their occupational dose.

b. Findings

No findings were identified.

.4 Contamination and Radioactive Material Control (02.04)

a. Inspection Scope

The inspectors observed the radiological control area exit (K-line) and the Unit 1 butler building locations where Constellation monitors potentially contaminated material leaving the radiological control area and inspected the methods used for control, survey, and release from these areas. The inspectors observed the performance of personnel surveying and releasing material for unrestricted use and evaluated whether the work was performed in accordance with plant procedures. The inspectors assessed whether the radiation monitoring instrumentation used for equipment release and personnel contamination surveys had appropriate sensitivity for the type(s) of radiation present.

The inspectors reviewed Constellations criteria for the survey and release of potentially contaminated material. The inspectors evaluated whether there was guidance on how to respond to an alarm that indicates the presence of licensed radioactive material.

The inspectors reviewed Constellations procedures and records to verify that the radiation detection instrumentation was used at its typical sensitivity level based on appropriate counting parameters. The inspectors selected 84CS-141 (in calibrator 8189)and S-17 (in calibrator 8124) sealed sources from Constellations inventory records and assessed whether the sources were accounted for and were tested for loose surface contamination. The inspectors evaluated whether any transactions, since the last inspection, involving nationally tracked sources were reported in accordance with 10 CFR 20.2207.

b. Findings

No findings were identified.

.5 Radiological Hazards Control and Work Coverage (02.05)

a. Inspection Scope

The inspectors evaluated ambient radiological conditions and performed independent radiation measurements during the walk-down of the facility. The inspectors assessed whether the conditions were consistent with applicable posted surveys, radiation work permits, and associated worker briefings.

The inspectors evaluated the adequacy of radiological controls, such as required surveys, radiation protection job coverage and contamination controls. The inspectors evaluated Constellations use of electronic personal dosimeters in high noise areas inside high radiation areas.

The inspectors assessed whether radiation monitoring devices were placed on the individuals body consistent with licensee procedures. The inspectors assessed whether the dosimeter was placed in the location of highest expected dose or that Constellation properly implemented an NRC-approved method of determining effective dose equivalent.

The inspectors reviewed the application of dosimetry to effectively monitor exposure to personnel in high-radiation work areas with significant dose rate gradients.

The inspectors reviewed and verified there were no radiation work permits for work within airborne radioactivity areas with the potential for individual worker internal exposures.

The inspectors assessed applicable containment barriers integrity and the operation of temporary high-efficiency particulate air ventilation systems.

The inspectors examined Constellations physical and programmatic controls for highly activated or contaminated materials stored within spent fuel and other storage pools.

The inspectors assessed whether appropriate controls were in place to preclude inadvertent removal of these materials from the pool.

The inspectors examined the posting and physical controls for selected high radiation areas and very high radiation areas to verify conformance with the occupational performance indicator.

b. Findings

No findings were identified.

.6 Risk-Significant High Radiation Area and Very High Radiation Area Controls (02.06)

2RS2 Occupational ALARA Planning and Controls (71124.02 - One sample)

This area was inspected from March 5 through 9 and March 19 through 22, 2012, to assess performance with respect to maintaining occupational individual and collective radiation exposures as-low-as-is-reasonably-achievable (ALARA). The inspectors used the requirements in 10 CFR Part 20; RG 8.8, Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Plants will be As Low As Reasonably Achievable; RG 8.10, Operating Philosophy for Maintaining Occupational Radiation Exposure As Low as Reasonably Achievable; TSs; and Constellations procedures as criteria for determining compliance.

.1 Inspection Planning (02.01)

a. Inspection Scope

The inspectors reviewed pertinent information regarding CCNPP collective exposure history, current exposure trends, and ongoing or planned activities in order to assess current performance and exposure challenges. The inspectors reviewed the plants three year rolling average collective exposure.

The inspectors compared the site-specific trends in collective exposures against the industry average values and those values from similar vintage reactors. In addition, the inspectors reviewed any changes in the radioactive source term by reviewing the trend in average contact dose rate with reactor coolant piping. The inspectors reviewed site-specific procedures associated with maintaining occupational exposures ALARA, which included a review of processes used to estimate and track exposures from specific work activities.

b. Findings

No findings were identified.

.2 Radiological Work Planning (02.02)

a. Inspection Scope

The inspectors selected the following work activities that had the highest exposure significance.

Pressurizer heater replacement

Reactor path minor maintenance

Steam generator 2nd side inspections The inspectors reviewed the ALARA work activity evaluations, exposure estimates, and exposure reduction requirements. The inspectors determined whether Constellation reasonably grouped the radiological work into work activities, based on historical precedence, industry norms, and/or special circumstances.

The inspectors assessed whether Constellations planning identified appropriate dose reduction techniques, considered alternate dose reduction features, and estimated reasonable dose goals. The inspectors evaluated whether Constellations ALARA assessment had taken into account decreased worker efficiency from use of respiratory protective devices and/or heat stress mitigation equipment. The inspectors determined whether Constellations work planning considered the use of remote technologies as a means to reduce dose and the use of dose reduction insights from industry operating experience and plant-specific lessons learned. The inspectors assessed the integration of ALARA requirements into work procedure and radiation work permit documents.

b. Findings

No findings were identified.

.3 Verification of Dose Estimates and Exposure Tracking Systems (02.03)

a. Inspection Scope

The inspectors reviewed the assumptions and basis for the current annual collective exposure estimate for accuracy. The inspectors reviewed applicable procedures to determine the methodology for estimating exposures from specific work activities and for department and station dose goals.

The inspectors evaluated whether Constellation had established measures to track, trend, and if necessary, to reduce occupational doses for ongoing work activities. The inspectors assessed whether dose threshold criteria were established to prompt additional reviews and/or additional ALARA planning and controls.

The inspectors evaluated Constellations method of adjusting exposure estimates, or re-planning work, when unexpected changes in scope or emergent work were encountered.

The inspectors assessed whether adjustments to exposure estimates were based on sound radiation protection and ALARA principles or if they were just adjusted to account for failures to control the work.

b. Findings

No findings were identified.

.4 Source Term Reduction and Control (02.04)

OTHER ACTIVITIES

4OA1 Performance Indicator Verification

Main article: IP 71151

RCS Specific Activity and RCS Leak Rate (Four samples)

a. Inspection Scope

The inspectors reviewed Constellation submittal for the RCS specific activity and RCS leak rate performance indicators for both Unit 1 and Unit 2 for the period of January 2011 through December 2011. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in Nuclear Energy Institute document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6. The inspectors also reviewed RCS sample analysis and control room logs of daily measurements for RCS leakage, and compared that information to the data reported by the performance indicator. Additionally, the inspectors observed surveillance activities that determined the RCS identified leakage rate, and chemistry personnel taking and analyzing an RCS sample.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution (71152 - Two Samples)

.1 Routine Review of Problem Identification and Resolution Activities

a. Inspection Scope

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

b. Findings

No findings were identified.

.2 Annual Sample: Quench Tank In-leakage

a. Inspection Scope

The inspectors performed an in-depth review of Constellations apparent cause evaluation and corrective actions associated with CR-2010-002862 and CR-2011-003771, Unit 2 quench tank in-leakage. Specifically, the Unit 2 quench tank required draining approximately every two days, which was determined to be indicative of in-leakage. The inspectors assessed Constellations problem identification threshold, cause analyses, extent of condition reviews, compensatory actions, and the prioritization and timeliness of Constellations corrective actions to determine whether Constellation was appropriately identifying, characterizing, and correcting problems associated with this issue and whether the planned or completed corrective actions were appropriate.

The inspectors compared the actions taken to the requirements of Constellations CAP and 10 CFR Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants. In addition, the inspectors performed field walkdowns and interviewed engineering personnel to assess the effectiveness of the implemented corrective actions.

b. Findings and Observations

No findings were identified.

Constellation determined the most probable cause of quench tank in-leakage was leak-by of the reactor vessel head vent isolation valves. Constellation determined that the Unit 2 tail pipe temperature indicator for the Unit 2 reactor vessel head vent was approximately 15F higher than the same Unit 1 temperature indicator. Constellation determined that there is no online troubleshooting that can be performed on the head vent isolation valves. Constellation has made preparations to overhaul the head vent isolation valves in the 2013 refueling outage.

Constellation conducted a thorough technical review of the quench tank in-leakage, including a comprehensive extent of cause and extent of condition review with no additional issues identified.

The inspectors reviewed maintenance records for each valve providing a path for in-leakage to the quench tank and did not identify any additional issues. The inspectors determined Constellations overall response to the issue was commensurate with the safety significance, was timely, and included appropriate compensatory actions. The inspectors determined that the actions taken were reasonable to manage and resolve the quench tank in-leakage issue.

.3 Annual Sample: Power-Operated Relief Valve Component Tolerance Issues

a. Inspection Scope

On March 13, 2012, the two power operated relief valves (PORVs) removed from Unit 1 during the refueling outage were found to have cage dimensions that were out of tolerance and the PORV valve plug, guide, and cage of both PORVs were tight at ambient temperature. These conditions and related details were documented in CR-2012-003148 and CR-2012-003245.

A problem identification and resolution (PI&R) inspection was performed to establish the significance of the condition and the status of both the PORVs that were in service in Unit 2 and those that had been installed and planned to be placed in service in Unit 1. The primary focus of the PI&R inspection was to examine the technical bases that established the reasonable expectation of continued operability of the PORVs in both Unit 1 and Unit 2.

The inspectors reviewed the background, work in progress, and planned activities that were part of the resolution of the above CRs. The inspectors reviewed a 10 CFR Part 21 report, dated July 13, 2007, which originally identified a reportable defect involving cage deformation for the PORVs. The inspectors also reviewed the PORV drawing and reviewed design, analysis, and test documents to establish how the PORV mechanical components were expected to function at normal operating parameters and the effects of thermal expansion and contraction and from stress relaxation on component clearances.

Additionally, the valve bench disassembly, measurement and inspection records for the installed PORVs in both units and those that were removed from Unit 1 during the recent 2012 refueling outage were examined to determine the condition and internal tolerances associated with the valves. The effect of temperature changes on valve component clearances for these three sets of valves were reviewed to evaluate Constellations predicted behavior of PORV internal components and tolerances at normal operating temperature and pressure.

b. Findings and Observations

No findings were identified.

This PI&R inspection was directed toward determining whether there was a technical basis in establishing a reasonable expectation of continued operability for the installed Unit 1 and Unit 2 PORVs until the next refueling outage for each unit. Constellation initiated an apparent cause evaluation for the PORVs that were removed from Unit 1 during the March 2012 refueling outage and were found to have cage dimensions that were out of tolerance and represented a potential challenge to PORV operation.

The inspectors determined that Constellations analysis and reasonable expectation of continued operation were technically adequate. Specifically, Constellation appropriately considered the available measured critical component (plug, guide, and cage) dimensions, tolerances, and relative thermal movement of the various components, as well as movement due to stress relaxation, in concluding that the PORVs would operate satisfactorily if called upon. Constellation plans to evaluate the need and benefit of performing as-found testing for the Unit 2 PORVs while shutting down during the next (2013) refueling outage shutdown in order to confirm the bases and conclusions in their reasonable expectation of continued PORV operability analysis.

4OA3 Followup of Events and Notices of Enforcement Discretion (71153 - One Sample)

.1 (Closed) Licensee Event Report (LER) 05000317/318/2011-002-00, Technical

Specification 3.0.3 Entry for Inoperable 125 volt direct current (VDC) Channels.

a. Inspection Scope

At 10:35 a.m. on October 3, 2011, Operators entered TS Limiting Condition for Operation (LCO) 3.0.3 for Units 1 and 2. The LCO 3.0.3 entry was due to an emergent failure of 1A EDG battery charger which caused 1A EDG to be inoperable concurrent with planned maintenance on No. 21 SW subsystem which caused 2A EDG to be inoperable. The concurrent inoperability of both A Train EDGs caused the A Train 125 VDC channels for each unit to be declared inoperable and required entry into LCO 3.0.3 on both Units. At 1605 on October 3, 2011, 1A EDG battery charger was returned to service and the 1A EDG and all supported A Train components became operable. LCO 3.0.3 was exited for both units at 1605. The apparent cause of the battery charger failure was age related degradation of its circuit board due to exceeding its expected service life. The human performance issues that contributed to the LCO 3.0.3 entry were discussed in NRC inspection report 2011-005, NCV-05000317/318/2011005-01.

The inspectors reviewed the LER for accuracy as well as Constellations evaluation of the No. 16 battery charger failure, the adequacy of proposed and completed corrective actions, and the appropriateness of the extent-of-condition review. Independent reviews of design documents, drawings, surveillance testing, and field walk-downs were performed by the inspectors to evaluate the cause of the No. 16 battery charger failure.

In addition, the inspectors reviewed Constellations PM history and associated PM programs.

b. Findings

Introduction:

A Green self-revealing NCV of TS 5.4.1, Procedures, was identified for the failure of Constellation to establish, implement, and maintain preventive maintenance 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 PCB within its 10-year service life. As a consequence, the No. 16 battery charger failed rendering the 1A EDG inoperable.

Description:

On October 3, 2011, technicians were performing routine PM on the safety-related No. 16 battery charger when the charger failed rendering the 1A EDG inoperable. The battery charger failed as technicians were adjusting the battery charger float voltage. Constellation determined that the apparent cause of the battery charger failure was age related degradation of its current sensing/limiting PCB due to exceeding its expected service life. The No. 16 battery charger was placed in service in 1995 as original equipment. In 2007, Constellation performed a review of the vendor technical manual 15665-730 and identified that the PCBs for the battery charger contain electrolytic and tantalum capacitors. Constellation identified that the industrial standard shows electrolytic capacitors have a 10 year service life. Constellation initiated a preventive maintenance change request (PMCR), (AIT PM200700402) in October 2007, to change the repetitive task in the PM template to replace the PCBs vice test the PCBs.

Consequently, the PMCR was closed in 2008 stating that revisions were made per the PM change request but no changes were made to repetitive task (Reptask) 10020069 in the next scheduled WO C120065599. The PM for the battery charger was completed in May 2010 and the WO did not include the required PCB replacement task. Constellation determined that CNG-AM-1.01-1018, Preventive Maintenance Program, did not provide specific guidance to have the WO placed on planning hold to revise the job plan per the PMCR. At the time of the battery charger failure, Constellation determined that the PCB for battery charger was original equipment and had been in service for 16 years. Constellation noted a weakness within CNG-AM-1.01-1018 in that the procedure did not provide specific direction to have the WO placed on planning hold to revise the job plan per the PMCR.

The inspectors concluded that Constellation did not establish and implement a PM program to replace the current sensing/limiting PCB within its 10-year service life.

Constellations immediate corrective actions included entering this issue into their CAP (CR-2011-009922 and CR-2011-010294), performing an apparent cause evaluation, performing an extent of condition review, and replacing the No. 16 battery charger PCBs.

Analysis:

Constellations failure to replace the No. 16 battery charger PCB within its 10-year service life is a performance deficiency. 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 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 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. [H.2.(c) per IMC 0310]

Enforcement:

TS 5.4.1 states, in part, that written procedures specified in RG 1.33 Revision 2, Appendix A, February 1978, shall be established, implemented, and maintained. Section 9.b. of Appendix A to RG 1.33 states, in part, that preventative maintenance schedules should be developed to specify replacement of parts that have a specific service life. Contrary to the above, prior to October 3, 2011, Constellation failed to establish and implement a PM program to replace the No. 16 battery charger PCB within its 10 year service life. As a result the battery charger failed due to age related degradation of its PCB. Constellations immediate corrective actions included entering this issue into their CAP (CR-2011-009922 and CR-2011-010294), performing an apparent cause evaluation, performing an extent of condition review, and replacing the No. 16 battery charger PCBs. Because this violation was of very low safety significance and Constellation entered the issue into their CAP, this violation is being treated as an NCV, consistent with the Enforcement Policy. (NCV-05000317/31812012002-02:

Failure to Replace Batter Charger Circuit Board within Its Recommended Service Life)

4OA6 Meetings, Including Exit

Exit Meeting Summary

On April 20, 2012, the inspectors presented the inspection results to Mr. George H. Gellrich, Vice President, and other members of Constellation staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Constellation Personnel

G. Gellrich, Site Vice President

C. Costanzo, Plant General Manager

A. Ball, Radiation Protection Supervisor

K. Bodine, Supervisor, Engineering

H. Crocket, Senior Engineer

L. Friant, Principle Engineer

P. Furio, Engineering Analyst, Licensing

M. Giacini, Manager, Operations

R. Gines, Senior Engineer

K. Gould, General Supervisor, Radiation Protection

D. Lauver, Director, Licensing

C. Ledwich, Radiation Protection Technician

K. Mills, General Supervisor, Shift Operations

C. Neyman, Senior Engineering Analyst, Licensing

A. Simpson, Supervisor, Licensing

J. Stanley, Manager Engineering Services

M. Thompson, Radioactive Waste Processor

J. Wilson, III, Supervisor, Engineering

J. York, General Supervisor, Chemistry

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

Opened and Closed

05000317/318/2012002-01 NCV Failure to Establish a Test Program for Auxiliary Feedwater Emergency Air Accumulators (Section 1R19)

05000317/318/2011002-02 NCV Failure to Replace Batter Charger Circuit Board within Its Recommended Service Life (Section 4AO3.1)

Closed

0500317/318/2011-002-02 LER Technical Specification 3.0.3 Entry for Inoperable 25 Volt Direct Current Channels (Section 4AO3.1)

LIST OF DOCUMENTS REVIEWED