ML020280505
| ML020280505 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 01/28/2002 |
| From: | Marilyn Evans Reactor Projects Branch 1 |
| To: | Cruse C Constellation Nuclear |
| References | |
| IR-01-012 | |
| Download: ML020280505 (23) | |
See also: IR 05000317/2001012
Text
Mr. Charles H. Cruse
Vice President
Constellation Nuclear
Calvert Cliffs Nuclear Power Plant, Inc.
1650 Calvert Cliffs Parkway
Lusby, MD 20657-4702
SUBJECT: CALVERT CLIFFS NUCLEAR POWER PLANT - NRC INSPECTION REPORT
50-317/01-12, 50-318/01-12
Dear Mr. Cruse:
On December 29, 2001, the NRC completed an inspection at your Calvert Cliffs Nuclear Power
Plant Units 1 & 2. The enclosed report documents the inspection findings which were
discussed on January 18, 2001, with Mr. Katz 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.
Immediately following the terrorist attacks on the World Trade Center and the Pentagon, the
NRC issued an advisory recommending that nuclear power plant licensees go to the highest
level of security, and all promptly did so. With continued uncertainty about the possibility of
additional terrorist activities, the Nation's nuclear power plants remain at the highest level of
security and the NRC continues to monitor the situation. This advisory was followed by
additional advisories, and although the specific actions are not releaseable to the public, they
generally include increased patrols, augmented security forces and capabilities, additional
security posts, heightened coordination with law enforcement and military authorities, and more
limited access of personnel and vehicles to the sites. The NRC has conducted various audits of
your response to these advisories and your ability to respond to terrorist attacks with the
capabilities of the current design basis threat (DBT). From these audits, the NRC has
concluded that your security program is adequate at this time.
Based on the results of this inspection, the inspectors identified three issues of very low safety
significance (Green). Two of these issues were determined to involve a violation of NRC
requirements. However, because of their very low safety significance and because they have
been entered into your corrective action program, the NRC is treating these issues as Non-cited
Violations, in accordance with Section VI.A.1 of the NRCs Enforcement Policy. If you deny
these Non-cited Violation, you should provide a response with the basis for your denial, within
30 days of the date of this inspection report, 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; and the NRC Resident Inspector at
the Calvert Cliffs facility.
Charles H. Cruse 2
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its
enclosure will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of the NRCs document
system (ADAMS). ADAMS is accessible from the NRC Web Site at http://www.nrc.gov/reading-
rm.html (the Public Electronic Reading Room).
Sincerely,
Michele G. Evans, Chief
Projects Branch 1
Division of Reactor Projects
Docket Nos. 50-317
50-318
License Nos. DPR-53
Enclosures: Inspection Report 50-317/01-12 and 50-318/01-12
Attachment 1 - Supplemental Information
cc w/encl: M. Geckle, Director, Nuclear Regulatory Matters (CCNPPI)
R. McLean, Administrator, Nuclear Evaluations
J. Walter, Engineering Division, Public Service Commission of Maryland
K. Burger, Esquire, Maryland People's Counsel
R. Ochs, Maryland Safe Energy Coalition
J. Petro, Constellation Power Source
State of Maryland (2)
Charles H. Cruse 3
Distribution w/encl: H. Miller, RA/J. Wiggins, DRA (1)
T. Bergman, RI EDO Coordinator
D. Beaulieu - SRI - Calvert Cliffs
E. Adensam, NRR (ridsnrrdlpmlpdi)
M. Evans, DRP
W. Cook, DRP
S. Barr, DRP
P. Torres, DRP
R. Junod, DRP
Region I Docket Room (with concurrences)
DOCUMENT NAME: G:\BRANCH1\CCSTUFF\CC0112.WPD
After declaring this document An Official Agency Record it will be released to the Public. To
receive a copy of this document, indicate in the box: "C" = Copy without
attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy
OFFICE RI/DRP RI/DRP
NAME DBeaulieu MEvans
DATE 01/ /02 01/ /02
OFFICIAL RECORD COPY
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket Nos: 50-317, 50-318
Report Nos: 50-317/01-12;
50-318/01-12
Licensee: Calvert Cliffs Nuclear Power Plant, Inc.
Facility: Calvert Cliffs Nuclear Power Plant, Units 1 and 2
Location: 1650 Calvert Cliffs Parkway
Lusby, MD 20657-4702
Dates: November 11, 2001 - December 29, 2001
Inspectors: David Beaulieu, Senior Resident Inspector
Leonard Cline, Resident Inspector
Ron Nimitz, Senior Health Physicist
Nancy McNamara, Emergency Preparedness Inspector
John Caruso, Senior Operations Engineer
Charles Payne, Senior Operations Engineer, Region II
Approved by: Michele G. Evans, Chief, Projects Branch 1
Division of Reactor Projects
SUMMARY OF FINDINGS
IR 05000317/01-12, IR 05000318/01-12, on 11/11-12/29/2001, Calvert Cliffs Nuclear Plant,
Inc.; Calvert Cliffs Nuclear Power Plant, Units 1 & 2. Problem Identification and Resolution.
The report covered a six week period of inspection by resident inspectors, Senior Operations
Engineers, an Emergency Preparedness Inspector, and a Senior Health Physicist. The
inspection identified three Green findings, two which were treated as non-cited violations. The
significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609 Significance Determination Process (SDP). Findings for which the SDP does not apply
are indicated by No Color or by the severity level of the applicable violation. The NRC's
program for overseeing the safe operation of commercial nuclear power reactors is described at
its Reactor Oversight Process website at http://www.nrc.gov/NRR/OVERSIGHT/index.html.
A. Inspector Identified Findings
Cornerstone: Mitigating Systems
GREEN. A non-cited violation of 10CFR50, Appendix B, Criterion XVI was identified
because the licensee failed to take timely and effective corrective action to mitigate
excessive train unavailability for the switchgear ventilation system. The Unit 1 and Unit
2 switchgear ventilation systems have been classified maintenance rule (a)(1) since the
fourth quarter of 1996, and the systems have exceeded maintenance rule performance
criteria every quarter since 1996. Although the corrective action plan that has been in
place since 1996 specified replacing the pneumatic controls, the fans, and the
compressors, three fans and all four compressors have not yet been replaced.
This issue has a credible impact on safety because the failure of the switchgear
ventilation system to maintain switchgear room temperatures could result in the failure
of safety related electrical busses in the switchgear room, as well as, the safety related
equipment supplied by these busses. The finding was considered to be of very low
safety significance, because the poor performance of this system has not resulted in
switchgear room temperatures in excess of design limits. (Section 4OA2)
GREEN. A non-cited violation of 10CFR50, Appendix B, Criterion XVI, was identified
because the licensee failed to identify and correct a condition adverse to quality on the
12 switchgear ventilation train. On October 8, 2001, the licensee failed to write an issue
report to document that when the failure of both the 11 and 12 switchgear refrigeration
compressors necessitated aligning the system in the fresh air mode, the 12 switchgear
ventilation train was unable to maintain switchgear room temperature. When the
inspector identified during a review of control room logs that no issue report had been
written, the licensee wrote the issue report on October 24, 2001. No corrective action
was taken by the licensee to investigate or correct the degraded condition until it
repeated itself on October 27, 2001, when they found that misadjusted damper
actuators resulted in 50% fresh air rather than 100%.
This issue has a credible impact on safety because the failure of the switchgear
ventilation system to maintain switchgear room temperatures would result in the failure
ii
Summary of Findings (contd)
of several safety significant mitigating systems. The finding was considered to be of
very low safety significance, because following the failure of the 12 switchgear
ventilation unit in the fresh air mode, the 11 switchgear ventilation train was placed in
service and returned switchgear room temperature to normal. (Section 4OA2)
Cornerstone: Occupational Radiation Safety
GREEN. The licensee has not established effective problem resolution for recurring
issues involving failure to conduct adequate radiological surveys to support planning and
conduct of radiological work activities. On July 13, 2001, the licensee failed to conduct
adequate pre-job and ongoing radiological surveys to detect elevated levels of
radioactive contamination within the No. 22 Chemical and Volume Control system ion
exchange pit for work therein. This contributed to elevated airborne radioactivity and
limited intakes of airborne radioactive material by workers during the work activities.
The licensees root cause analysis and NRC review identified that similar inadequate
radiological surveys had been identified on previous events and that some of these
problems were repeated during the event despite the implementation of corrective
actions. The failure to implement effective corrective actions is a cross-cutting issue
determined to be more than minor. The issue was evaluated under the Occupational
Radiation Safety Significance Determination Process (SDP) and determined to be a
finding of very low safety significance. The issue was not an as low as reasonably
achievable (ALARA) finding, did not involve an overexposure or substantial potential,
and did not affect the ability to assess dose. The issue was included in the licensees
corrective action process (IR3-072-016 and Causal Analysis PD200100011). (Section
4OA2)
B. Licensee Identified Findings
A violation of very low safety significance which was identified by the licensee has been
reviewed by the inspector. Corrective actions taken or planned by the licensee appear
reasonable. This violation is summarized in Section 4OA7 of this report.
iii
Report Details
Units 1 and 2 operated at or near 100 percent power for the entire inspection period.
1. Reactor Safety
Cornerstone: Initiating Events, Mitigating Systems, Barrier Integrity and Emergency
Preparedness
1R01 Adverse Weather Protection
a. Inspection Scope
The inspector verified that safety related systems, structures, and components such as
the condensate and refueling water storage tanks would remain functional when
challenged by cold weather and freezing conditions. The inspector reviewed the
Updated Final Safety Analysis Report (UFSAR), Individual Plant Examination of External
Events, Technical Specifications, and Operations Administrative Policy (OAP) 92-09,
"Cold Weather Operations," for cold weather operation requirements. To verify
adequate implementation of these requirements, the inspector observed a plant
operator perform Operations Performance Evaluation, PE 0-102-4-O-M, Revision 7,
Freeze Protected Equipment, on December 18, 2001.
b. Findings
No findings of significance were identified.
1R04 Equipment Alignment
.1 Partial Walkdown
a. Inspection Scope
The inspectors conducted an equipment alignment partial walkdown to evaluate the
operability of a selected redundant train or backup system, while the affected train or
system was inoperable or out of service. The walkdown included a review of system
operating instructions to determine correct system lineup and verification of critical
components to identify any discrepancies which could affect operability of the redundant
train or backup system. The inspectors performed a partial system walkdown on the
following system:
The inspectors reviewed the following Calvert Cliffs Nuclear Power Plant documentation:
- Operating Instruction OI-21B, 2B Diesel Generator
b. Findings
No findings of significance were identified.
.2 Complete Walkdown
2
a. Inspection Scope
The inspectors performed a complete walkdown of a risk-important support system for
mitigating systems, the Unit 1 Electrical Switchgear Room Air Conditioning and
Ventilation (HVAC) system, to identify any discrepancies between the existing
equipment lineup and the required lineup. Operating Procedure OI-22H, Switchgear
Ventilation and Air Conditioning, the system description number 32, and Drawing No.
60-722-E, Auxiliary Building Ventilation System, were used to verify that electrical power
was available as required; major system components were correctly labeled, lubricated,
cooled, and ventilated; essential support systems were operational; and ancillary
equipment and debris did not interfere with system performance. To assess the
systems material condition, the inspectors reviewed the status of approximately
20 maintenance work orders (MOs) and over 15 issue reports (IRs) written over the
previous two years. Specific attention was focused on IRs written and MOs worked on
Unit 1 switchgear HVAC in September and October 2001, when several 11 and 12
switchgear HVAC compressor trips occurred. The documentation reviewed included:
- ES1996011050, Revision 1, Evaluate the Reliability of Equipment in the 27 foot
Switchgear Room in an Appendix R Fire
- CA04511, Revision 0, Switchgear Room Transient Temperature Analysis
Evaluating Probabilistic Risk Assessment Scenarios
- CA04658, Revision 0, Use of Outside Air Only to Cool the Unit 1 and Unit 2
Switchgear Rooms
- CA00086, Revision 3, Switchgear Emergency Ventilation Fans
- RAN 98-042, Revision 0, Switchgear Room Heat Load Analysis
b. Findings
No findings of significance were identified.
1R07 Heat Sink Performance
a. Inspection Scope
The inspectors reviewed data for the 21A and 21B service water (SRW) heat exchanger
thermal performance test completed on October 3, 2001; the statistical evaluation for
the 11A and 11B SRW heat exchanger thermal performance test completed on June 25,
2001, and; the results of the continuous monitoring thermal performance test conducted
on 12A and 12B, and 22A and 22B SRW heat exchangers. The inspectors analyzed the
data and results to verify that the SRW heat exchangers are capable of removing design
basis heat loads as described in the UFSAR. The inspectors also verified that the
licensees testing methods were consistent with their response to Generic Letter 89-13,
Service Water System Problems Affecting Safety-Related Equipment, and were
sufficient to detect heat exchanger degradation prior to a loss of required heat removal
capabilities. The documentation reviewed included:
- Calculation CA04710, Revision 1, SRW Plate Heat Exchanger Thermal
Performance Test Evaluation Methodology and Software Development
3
- Calculation CA03477, Revision 2, Service Water Plate Heat Exchanger Thermal
Performance Evaluation
- Engineering Test Procedure ETP 99-001R, 21A and 21B SRW Heat Exchanger
Thermal Performance Test
- Statistical Evaluation for Engineering Test Procedure ETP 98-040R, 11A and
11B SRW Heat Exchanger Thermal Performance Test
b. Findings
No findings of significance were identified.
1R11 Licensed Operator Requalification
.1 Requalification Activities Review by Resident Inspector
a. Inspection Scope
On November 13, 2001, the inspector observed licensed operator simulator training to
assess operator performance for a scenario involving a loss of closed cooling water. In
particular, the inspector observed operators trip reactor coolant pumps due to the loss of
cooling water to the seals, which the licensees probabilistic risk assessment has
determined to be an important operator action.
b. Findings
No findings of significance were identified.
.2 Requalification Program Review By Regional Specialist
a. Inspection Scope
A review was conducted of recent operating history documentation found in inspection
reports, licensee event reports, the licensees corrective action program, and the most
recent NRC plant issues matrix. The senior resident inspector was also consulted for
insights regarding licensed operator performance. These reviews did not detect any
operational events that were indicative of possible training deficiencies.
The following inspection activities were performed using NUREG 1021, Revision 8,
"Operator Licensing Examination Standards for Power Reactors," Inspection Procedure
Attachment 71111.11, "Licensed Operator Requalification Program," Appendix A
"Checklist for Evaluating Facility Testing Material.
The inspectors reviewed the quality and performance of operating and written exams
administered the week of November 12, 2001, as well as, a sample of several other
exams administered to crews during prior exam weeks.
The results of the annual operating tests for years 2000 and 2001 and the written exam
for 2001 were reviewed for quality, performance and grading. The inspector assessed
whether failure rates were consistent with the guidance of NUREG-1021, Revision 8,
4
and NRC Manual Chapter 0609, Appendix I, "Operator Requalification Human
Performance Significance Determination Process (SDP)." The SDP review verified the
following:
- Crew pass rates were greater than 80%. (Pass rate was 100%)
- Individual pass rates on the written exam were greater than 80%. (Pass rate
was 98.8%)
- Individual pass rates on the job performance measures of the operating exam
were greater than 80%. (Pass rate was 97.6%)
- More than 75% of the individuals passed all portions of the exam. (97.6% of the
individuals passed all portions of the exam)
Observations were made of the dynamic simulator exams and job performance
measures administered during the week of November 12, 2001. These observations
included facility evaluations of crew and individual performance during the dynamic
simulator exams and individual performance of 5 job performance measures.
The remediation plans for individual failures over the past two year requalification
program cycle were reviewed to assess the effectiveness of the remedial training.
There were no crew failures during this period.
License reactivations for the past two year requalification program cycle were also
reviewed to ensure that 10 CFR 55.53 license conditions and applicable program
requirements were met.
Instructors and training/operations management were interviewed for feedback
regarding the implementation of the licensed operator requalification program.
Simulator performance and fidelity were reviewed for conformance to the reference
plant control room.
A sample of records for requalification training attendance, program feedback, reporting,
and medical examinations were reviewed for compliance with license conditions,
including NRC regulations.
5
b. Findings
The licensees methods and standards used to reactivate staff licensees to support
refueling outages appeared to be inconsistent with the requirements of 10 CFR
55.53(f)(2). The site practice has been to have staff licensees stand one shift of under-
instruction watch in the control room, conduct a tour of refueling equipment, and attend
four hours of pre-refueling classroom training as a basis for reactivation as a limited
refueling senior reactor operator. 10 CFR 55.53(f)(2) requires that the under-instruction
watch be stood in the position to which the individual will be assigned. The under-
instruction time in the control room appears to not have met the intent of the rule. This
item will be treated as unresolved pending further guidance and clarification from the
Operator Licensing Branch, Office of Nuclear Reactor Regulation. (URI 50-317;
50-318/01-012-01)
1R12 Maintenance Rule Implementation
a. Inspection Scope
The inspectors reviewed performance-based problems involving selected in-scope
structures, systems, or components (SSCs) to assess the effectiveness of the
maintenance program. Reviews focused on: (1) proper maintenance rule scoping, in
accordance with 10 CFR 50.65; (2) characterization of failed SSCs; (3) safety
significance classifications; (4) 10 CFR 50.65 (a)(1) and (a)(2) classifications; and (5)
the appropriateness of performance criteria for SSCs classified as (a)(2), and goals and
corrective actions for SSCs classified as (a)(1). The inspectors reviewed the most
recent system health reports and system functional failures of the last two years. The
following SSCs were reviewed:
- Unit 1 and Unit 2 Switchgear ventilation system. The licensee appropriately
classified this system as (a)(1) due to excessive unavailability, and excessive
and repeat functional failures. Recent failures of the Unit 1 No. 11 and No. 12
switchgear HVAC system refrigeration unit compressors, in September and
October 2001, continued the systems poor performance trend. The inspector
evaluated the acceptability of the licensees corrective action plan as
documented in Issue Report IR3-009-491, the evaluation, corrective action, and
goal setting plan for the switchgear HVAC system, and the corrective actions
specified in the recent IRs written in September and October 2001.
- The inspector reviewed the licensee data base of system unavailability for all
equipment from November 20 to December 20, 2001, to verify that out-of-service
times were entered into maintenance rule unavailability tracking as required.
The inspectors also reviewed the following Calvert Cliffs Nuclear Power Plant
documentation:
- Station Procedure MN-1-112, Managing System Performance
- Maintenance Rule Scoping Document, Revision 17
- Maintenance Rule Indicator Report, October 2001
6
b. Findings
Two non-cited violations of very low safety significance (GREEN) of 10CFR50, Appendix
B, Criterion XVI, Corrective Action, were identified during this inspection. The details
of these findings are discussed in section 4OA2 of this report.
1R13 Maintenance Risk Assessments and Emergent Work Evaluation
a. Inspection Scope
For the selected maintenance orders listed below, the inspectors verified: (1) risk
assessments were performed in accordance with Calvert Cliffs procedure NO-1-117,
Integrated Risk Management; (2) risk of scheduled work was managed through the
use of compensatory actions; and (3) applicable contingency plans were properly
identified in the integrated work schedule.
- MO2200002578 Replace 21 Switchgear HVAC fan
- MO1200004788 Replace 12 High Pressure Safety Injection Pump
Outboard Bearing End Cover Gasket
- MO1200101956 Remove Spare Reactor Trip Circuit Breaker and Reinstall
Trip Circuit Breaker 8
b. Findings
No findings of significance were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed post-maintenance test procedures and associated testing
activities for selected risk significant mitigating systems to assess whether: (1) the
effect of testing on the plant had been adequately addressed by control room and
engineering personnel; (2) testing was adequate for the maintenance performed; (3)
acceptance criteria were clear and adequately demonstrated operational readiness,
consistent with design and licensing basis documents; (4) test instrumentation had
current calibrations, range, and accuracy for the application; (5) tests were performed,
as written, with applicable prerequisites satisfied; and (6) that equipment was returned
to the status required to perform its safety function. The following maintenance orders
were reviewed:
- MO2199700801, Replace 21 Switchgear HVAC fan, which was retested by
performing air flow measurements with the fan operating in the maximum
recirculation mode and the 100% outside air mode. The acceptance criteria for
both measurements based on the systems design basis was 12,000 cubic feet
per minute (CFM).
b. Findings
7
No findings of significance were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors witnessed performance of surveillance test procedures and reviewed test
data of the selected risk-significant system to assess whether they satisfied Technical
Specifications, Updated Final Safety Analysis Report, Technical Requirements Manual,
and licensee procedure requirements. The inspectors assessed whether the testing
appropriately demonstrated that the system was operationally ready and capable of
performing its intended safety functions. The following test was witnessed:
Removal Units and Penetration Exhaust Filter was inspected on December 3,
2001.
b. Findings
No findings of significance were identified.
1EP2 Alert and Notification System (ANS) Testing
a. Inspection Scope
On November 5, 2001, the licensee notified the NRC (Event Notification 38466) that
while conducting their annual full cycle offsite siren test, all 49 sirens in Calvert County
failed to activate. There are 72 total sirens covering the 10 mile Plume Exposure
Emergency Planning Zone (EPZ). The apparent cause was that an activation icon,
located on a computer at Calvert Countys 911 Center, may have been inadvertently
removed. The other two risk counties emergency operating centers were not affected.
The licensee immediately initiated a task force to review this issue and documented their
results. On November 15, 2001, the licensee reported resolution of the computer
activation problem with a successful siren test which included full siren activation.
During the 10 day period of vulnerability, the licensee was relying on automatic route
alerting for notification of the public in Calvert County in the event of an emergency at
the Calvert Cliffs nuclear plant. The licensees review was to establish how long the
vulnerability existed prior to November 5, 2001. The licensee noted that automatic route
alerting has been in effect since the inception of the system in the early 1980s. On a
periodic basis, the inspector received status reports on the problem from licensee
representatives.
8
b. Findings
Preliminarily, the licensees review established that there was a human error while
attempting to simplify the County 911 Centers computer screen. A contractor hired by
Calvert County inadvertently removed the icon for proper actuation of the sirens in
Calvert County. The licensees backup public notification system is route alerting. The
inspector determined that the Calvert Countys Emergency Plan states that automatic
route alerting would be initiated simultaneously with the activation of the emergency
sirens. Therefore, although the sirens were incapable of being activated during the
period of vulnerability, had a radiological event occurred, the licensee believes that the
public would have been properly notified via route alerting.
At the end of this inspection report period, the inspector was gathering additional
information from the licensee pertaining to the Countys siren activation and route
alerting processes. The inspector was also assessing the adequacy of the capability to
notify the public within the EPZ as required by 10 CFR Part 50, 5.47(b)(5) and Appendix
E.IV.D.3, and system design objectives as noted in FEMA-REP-10. Therefore, this
issue is considered an Unresolved Item pending the completion of the licensees review
and the inspectors assessment. (URI 50-317; 50-318/01-012-02)
1. RADIATION SAFETY
Cornerstone: Occupational Radiation Safety
2OS1 Access Control To Radiologically Significant Areas
a. Inspection Scope
The inspector conducted the following activities and reviewed the following documents
to determine the effectiveness of radiologically controls including access controls to
radiologically significant areas.
The inspector toured portions of Unit 1 and Unit 2 Auxiliary Building and reviewed
access controls to locked High Radiation Areas. Four locked High Radiation Area
access points were physically inspected to determine if access controls were sufficient
to preclude unauthorized entry, as appropriate. Also reviewed was access and egress
control to the radiological controlled area (RCA) including personnel monitoring
practices to detect personnel contamination during RCA egress.
The inspector reviewed the radiological controls provided and accrued occupational
radiation doses received by divers performing underwater work activities in the Unit 1
spent fuel pool on December 5, 2001.
The inspector reviewed the planned reorganization of the radiological controls
organization relative to Technical Specification 5.2.1.
The reviews in this area were against criteria contained in 10 CFR 20 and applicable
licensee radiation protection procedures.
9
b. Findings
No findings of significance were identified.
2OS2 ALARA Planning and Controls
a Inspection Scope
The inspector selectively reviewed the adequacy and the effectiveness of the licensees
program to reduce occupational radiation exposure to ALARA. Specifically, the
inspector reviewed the licensees planning and preparation for the upcoming Unit 1
outage. The review was against criteria contained in 10 CFR 20 and applicable licensee
procedures. The following matters were reviewed:
- The current status of integrated work planning including the status of planned
work, the status of completion of ALARA planning efforts, principal exposure
reduction efforts to be implemented, the radiological risk classification efforts of
selected planned activities, implementation of lessons learned.
- ALARA planning for tasks with projected exposure greater than 5 person-rem
including radiation safety, maintenance activities, scaffolding, reactor assembly
and disassembly and vessel head penetration work, implementation of lessons
learned.
b. Findings
No findings of significance were identified.
2OS3 Radiation Monitoring Instrumentation
a. Inspection Scope
The inspector selectively reviewed elements of the radiation monitoring instrumentation
calibration program to evaluate the adequacy and effectiveness of the program.
Specifically, the inspector reviewed the use, calibration, and source checking of three
laboratory radiation counting systems to verify that the instruments were calibrated and
source checked as required by station procedures. The inspector reviewed applicable
statistical control charts for the instruments. The instruments reviewed were: NMC-
14(Sn. 84-2660-14), SPA-3(Sn.138), and SAC 4(Sn. 578).
The review was against applicable station procedures and 10 CFR 20.
10
b. Findings
No findings of significance were identified.
4 OTHER ACTIVITIES (OA)
40A1 Performance Indicator Verification
a. Inspection Scope
The inspectors reviewed performance indicator (PI) data for the Mitigating Systems
cornerstone, Emergency AC Power System Unavailability, for Units 1 and 2, to verify
individual PI accuracy and completeness. This inspection examined data and plant
records from third quarter of 2000 through the third quarter of 2001, including a review
of PI Data Summary Reports, Licensee Event Reports, operator narrative logs, and
maintenance rule records.
b. Findings
No findings of significance were identified.
4. OTHER ACTIVITIES
4OA2 Identification and Resolution of Problems
.1 Switchgear Ventilation
a. Inspection Scope
The inspector evaluated the acceptability of the licensees corrective action plan to
address the poor performance of the switchgear HVAC system as documented in Issue
Report IR3-009-491, the maintenance rule (a)(1) evaluation, corrective action, and goal
setting plan for the system, and in the issue reports (IRs) written to address the Unit 1
switchgear HVAC compressor trips and damper failures that occurred in September and
October 2001.
b. Findings
Two non-cited violations of very low safety significance (GREEN) of 10CFR50, Appendix
B, Criterion XVI, Corrective Action, were identified. Following a brief discussion of
system operation, the details of each finding are discussed below.
The switchgear HVAC system for Unit 1 and 2 are identical. On each unit the system
provides cooling to the A and B train safety related switchgear rooms. The system
consists of two redundant HVAC units that include a supply fan, cooling coil, and
refrigeration compressor. The HVAC units in each system discharge to a common
supply header for both the A and B train switchgear rooms, and take suction from
outside air and a common exhaust header from the switchgear rooms. The temperature
limits for the switchgear rooms are 104-F for continuous operation, and 150-F for peak
11
operations. The temperature limits are based on ensuring switchgear operability by
maintaining switchgear bus bar hot-spot temperatures less than 185-F.
A non-cited violation of very low safety significance (GREEN) of 10CFR50, Appendix B,
Criterion XVI was identified because the licensee failed to take timely and effective
corrective action to mitigate excessive train unavailability for the switchgear HVAC.
The Unit 1 and Unit 2 switchgear HVAC systems have been classified maintenance rule
(a)(1) since the fourth quarter of 1996. In IR1-050-852, dated October 21, 1996, the
licensee classified the switchgear HVAC systems on both units as (a)(1) under the
maintenance rule. In its (a)(1) Evaluation, Corrective Action and Goal Setting plan for
the system, the licensee attributed the high unavailability to obsolete equipment and
refrigeration system design issues. The corrective action plan specified replacing the
pneumatic controls, the fans, and the compressors. As of December 2001, five years
after the system was classified (a)(1), only the pneumatic control system has been
upgraded for all four switchgear HVAC trains. For fan replacement, the licensee
initiated ES19961674 in January 1996. Only the 21 switchgear HVAC fan has been
replaced. The 22 switchgear HVAC fan is scheduled for installation in May 2002, and
the fans for the 11 and 12 switchgear HVACs will be installed in the Fall 2002. For
compressor replacement, ES199602324 was initiated in November 1996, but currently
no new compressors have been installed. The compressors for 21 and 22 switchgear
HVAC are scheduled for installation in May 2002. The 11 and 12 switchgear HVAC
compressors are scheduled for the fall 2002.
Interim corrective actions, since 1996, have also been ineffective at maintaining system
reliability. Since that time, in every quarter, at least three of the four switchgear HVAC
trains have exceeded the unavailability performance criteria of 250 hours0.00289 days <br />0.0694 hours <br />4.133598e-4 weeks <br />9.5125e-5 months <br /> per train per 2
year period, and in many cases train unavailability has been more than four times the
performance criteria. In addition, the Unit 1 switchgear HVAC system has exceeded the
functional failure performance criteria of less than five functional failures per two year
period every quarter since 1996.
The failure to implement timely and effective corrective action to address the poor
performance of the switchgear HVAC system has a credible impact on safety because
the failure of the switchgear HVAC system to maintain switchgear room temperatures
within the design limits of 104-F and 150-F would lead to switchgear failure. This would
result in the failure of several safety significant mitigating systems. This issue was
assessed as very low safety significance, because the poor performance of this system
has not resulted in switchgear room temperatures in excess of 104-F.
The failure to take timely and effective corrective action to address poor reliability and
unavailability of the switchgear HVAC system is a violation of 10CFR50, Appendix B,
Criterion XVI, Corrective Action, which requires prompt correction of conditions
adverse to quality. This violation is being treated as a Non-cited Violation, consistent
with Section VI.A of the NRC Enforcement Policy, issued on May 1, 2000 (65FR25368)
(NCV 50-317;50-318/01-012-03). The licensee entered the issue into its corrective
action program as IR3-080-027.
12
A second non-cited violation of very low safety significance (GREEN) of 10CFR50,
Appendix B, Criterion XVI was identified because the licensee failed to identify and
correct a condition adverse to quality on 12 switchgear HVAC.
On October 8, 2001, the 12 switchgear HVAC train was placed in service in the fresh air
mode because both switchgear HVAC refrigerant compressors had tripped and were
considered unavailable. At that time outside air temperature was approximately 50-F,
low enough that based on licensee engineering calculations, the fresh air mode could
maintain switchgear room temperature below the design limit of 104-F. Six hours later,
operators received a Unit 1 safety related switchgear room high temperature alarm.
Operators secured the 12 switchgear HVAC train placed the 11 switchgear HVAC in
service in the fresh air mode, and as expected, switchgear room temperature returned
to normal. On that day, no action was taken to investigate the cause of the failure of the
12 switchgear HVAC to perform as expected in the fresh air mode. During a review of
control room logs and meteorological tower data for outside air temperature, the
inspector identified that the licensee did not write an issue report to investigate and
correct the 12 switchgear HVAC problem. On October 24, 2001, the licensee wrote IR3-
050-297 to document the inspectors concern but no immediate corrective action was
taken. On October 27, 2001, after both switchgear HVAC compressors had tripped,
operators again placed the 12 switchgear HVAC in service in the fresh air mode, and at
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> later the 12 switchgear HVAC could no longer maintain switchgear room
temperature. Operators placed 11 switchgear HVAC in service in the fresh air mode to
return switchgear room temperature to normal, and documented the issue in IR3-077-
133. Troubleshooting determined that the cause of the 12 switchgear HVAC problem
was a misadjusted actuator for the mixing dampers resulting in only 50% fresh air rather
than 100%. The condition was corrected on October 29, 2001. The licensee verified
that a similar condition did not exist on the other switchgear HVAC trains.
The failure to identify and correct the degraded condition of the 12 switchgear HVAC
unit on October 8, 2001, had a credible impact on safety because the failure of the
switchgear ventilation system to maintain switchgear room temperatures could result in
the failure of safety related electrical busses in the switchgear room, as well as, the
safety related equipment supplied by these busses. This issue was assessed as very
low safety significance because following the failure of the 12 switchgear HVAC unit in
the fresh air mode, the 11 switchgear HVAC returned switchgear room temperature to
normal.
The failure to identify and correct the degraded condition of the 12 switchgear HVAC fan
on October 8, 2001, was a violation of 10CFR50, Appendix B, Criterion XVI, Corrective
Action, which requires the identification and resolution of conditions adverse to quality.
This violation is being treated as a Non-cited Violation, consistent with Section VI.A of
the NRC Enforcement Policy, issued o May 1, 2000 (65FR25368) (NCV 50-317/01-012-
04). The licensee has entered this issue into its corrective action program as IR3-014-
145.
.2 Radiation Safety
a. Inspection Scope
13
The inspector reviewed the licensees root cause analysis for an airborne radioactivity
event associated with work in the No. 22 Chemical Volume and Control System (CVCS)
ion exchanger pit on July 13, 2001. The radiological controls aspect of the event were
reviewed during NRC Combined Inspection No. 50-317;50-318/2001-006. During the
previous inspection, one Non-cited licensee identified violation was identified and one
inspector identified violation was identified and documented in that NRC report. During
this current inspection, the inspector focused on the adequacy of the licensees
corrective actions for previous events.
b. Findings
GREEN. The licensee has not established effective problem resolution relative to
recurring issues involving failure to conduct adequate radiological surveys to support
planning and conduct of radiological work activities.
On July 13, 2001, the licensee failed to conduct adequate pre-job and ongoing
radiological surveys to detect elevated levels of radioactive contamination within the
No. 22 CVCS ion exchange pit for work therein. This contributed to elevated airborne
radioactivity and limited intakes of airborne radioactive material by workers during the
work activities. The licensees root cause analysis for this event and the inspectors
review indicated that inadequate radiological surveys had been identified on previous
events and that some of these problems were repeated during the event (e.g.,
inadequate job planning, inadequate radiological job coverage). For example, on May 3,
2001, the licensee experienced elevated airborne radioactivity during work in the Unit 2
containment resulting in limited intakes of airborne radioactive material. The licensees
root cause analysis for the May 3, 2001, event (IR3-076-089; RCAR IR2-001-0404)
identified inadequate radiological surveys, lack of specific work permit instructions and
lack of a questioning attitude as contributing causes for this event. Similarly, on April 8,
2000 (IR3-054-967;IR3-044-244), the licensee failed to conduct radiological
contamination surveys of bags of material prior to removing the surface contaminated
bags from the Unit 1 reactor cavity to a non-contaminated area in the Unit 1 Auxiliary
Building. This resulted in personnel and clean area contamination. (These issues were
documented in NRC Inspection Report Nos. 50-317;50-318/2001-006, 2001-005, and
2000-009). Although the licensee recognized the inadequacies in the radiological
surveys, had taken various corrective actions for the previous issues, and none of the
events resulted in significant personnel contamination or intakes of radioactive material,
the occurrence of the July 13, 2001, event indicates that the licensees corrective
actions for previous radiological events (e.g., more thorough planning and provision of
minimum expectations for surveys by technicians for job coverage) has not been
effective in resolving issues involving the conduct of effective radiological evaluations to
support work activities.
The failure to implement effective corrective actions is a cross-cutting issue as defined
in NRC MC 0610* in that the issue has the potential to affect multiple cornerstones.
This issue was determined to be more than minor in that failure to implement effective
corrective actions could be reasonably viewed as a precursor to a more significant
event. Further, the issue is associated with conditions contrary to licensee procedures.
The issue was evaluated under the Occupational Radiation Safety Significance SDP
and determined to be a finding of very low safety significance (GREEN). The issue was
14
not an ALARA finding in that no significant personnel exposures have occurred, the
issue did not involve an overexposure or substantial potential for such an exposure, and
the ability to assess dose was not compromised. The issue was included in the
licensees corrective action process (IR3-072-016 and Causal Analysis PD200100011)
(FIN 50-317;50-318/01-012-05)
4OA5 Steam Generator Replacement (50001)
a. Inspection Scope
The inspector reviewed planned radiological controls for the upcoming steam generator
replacement project (SGRP). The inspector discussed the project with project team
representatives and reviewed various plans and procedures supporting the project. The
following matters were reviewed:
+ ALARA planning
+ project dose estimates and dose tracking
+ project exposure controls including temporary shielding
+ surface and airborne contamination controls including restoration of containment
openings
+ radioactive material management including source term analysis, waste storage,
and disposal plans project radiological work plans and controls
+ project staffing and training plans
+ emergency contingencies
+ radiological safety plans for storage of the steam generators including conduct of
public and potential worker dose assessments plans and radiological
environmental monitoring
+ evaluation of radiological source terms for dose assessment purposes
+ surveillance and planned audits of work activities including resolution of worker
concerns
+ the licensees efforts to identify and implement lessons learned from previous
steam generator replacements at other facilities.
The review was against criteria contained in 10 CFR 19.12, 10 CFR 20, site Technical
Specifications, and applicable site and project procedures.
b. Findings
No findings of significance were identified.
4OA6 Management Meetings
.1 Exit Meeting Summary
The inspectors presented the inspection results to members of licensee management at
the conclusion of the inspection on January 18, 2001.
The inspectors asked the licensee whether any of the material examined during the
inspection should be considered proprietary. No proprietary information was identified.
15
4OA7 Licensee Identified Violations
The following finding of very low safety significance (GREEN) was identified by the
licensee and is a violation of NRC requirements which meetsSection VI of the NRC
Enforcement Policy, NUREG-1600, for being dispositioned as a Non-Cited Violation.
NCV Tracking Number Requirement Licensee Failed to Meet
50-317;50-318/01-012-06 10 CFR71.87 requires the licensee to load shipments of
radioactive material in accordance with written procedures.
On September 5, 2001, the licensee did not adhere to
procedure RPS 2-231, for the loading of a Type B
shipment of radioactive material. Specifically, the licensee
did not ensure hardware compatibility ratings for hoisting
operations and used a crane hook, rated to 6,000 pounds,
to raise and transfer in air an approximately 7000 pound
container of waste containing approximately 91 curies of
mixed radionuclides. The licensee identified the issue on
November 6, 2001, and subsequently determined the hook
had been load tested to 9,000 pounds. The licensee took
various corrective and preventative actions and placed the
issue into its corrective action process (IR3-059-464).
16
ATTACHMENT 1
a. Key Points of Contact
W. Birney, Supervisor, Requalification Training Unit
C. Cruse, Vice President
P. Katz, Plant General Manager
M. Geckle, Director, Nuclear Regulatory Matters
M. Haney, Radiation Protection Supervisor
D. Holm, Superintendent, Nuclear Operations
J. Hornick, Supervisor, Initial Training Unit
J. Kellum, Senior Operations Instructor
M. Korsnick, Superintendent, Work Management
K. Mills, General Supervisor, Nuclear Plant Operations
M. Navin, Superintendent, Technical Support
K. Nietmann, Manager, Nuclear Performance Assessment Department
T. Pritchett, Manager, Nuclear Engineering Department
E. Roach, Radioactive Waste Supervisor
S. Sanders, General Supervisor-Radiation Safety
J. Sickle, General Supervisor, Nuclear Training
J. Spina, Superintendent, Nuclear Maintenance
R. Szoch, General Supervisor, Plant Engineering
L. Weckbaugh, Manager, Nuclear Support Services
R. Wyvill, ALARA Supervisor
J. York, Assistant General Radiation Supervisor
b. List of Items Opened, Closed, or Discussed
Opened
50-317;50-318/01-012-001 URI Licensees methods and standards used to reactivate staff
licensees to support refueling outages appeared to be
inconsistent with the requirements of 10 CFR 55.53(f)(2).
(IR Section 1.R11)
50-317;50-318/01-012-002 URI During a November 5, 2001, full cycle offsite siren test
none of the 49 sirens in Calvert County activated. It
appears that planning standard 10CFR50.47(b)(5) and the
requirements of 10CFR50 Appendix E.IV.D.3 have been
violated.(IR Section 1EP2)
Opened and Closed
50-317;50-318/01-012-003 NCV Failure to take timely and effective corrective action to
mitigate excessive train unavailability for the switchgear
HVAC in accordance with 10CFR50, Appendix B, Criterion
XVI (IR Section 4OA2)
Attachment 1 (contd) 17
50-317/01-012-004 NCV Failure to identify and correct a condition adverse to
quality on the 12 switchgear HVAC in accordance with
10CFR50, Appendix B, Criterion XVI (IR Section 4AO2)
50-317;50-318/01-012-005 FIN Failure to implement effective corrective actions for issues
involving inadequate radiological evaluations to support
work activities (IR Section 4AO2)
50-317;50-318/01-012-006 NCV Failure to implement 10 CFR71.87 regarding adherence to
cask loading procedures (IR Section 4AO7)
c. List of Acronyms
ALARA As Low As Reasonably Achievable
CFM Cubic feet per minute
CFR Code of Federal Regulations
CVCS Chemical and Volume Control System
DBT Design Basis Threat
EPZ Emergency Planning Zone
FEMA Federal Emergency Management Agency
FIN Finding
HVAC Ventilation System
IR Issue Report
MC Inspection Manual Chapter
MO Maintenance Order
NCV Non-cited Violation
NRC Nuclear Regulatory Commission
OAP Operations Administrative Policy
PI Performance Indicator
RCA Radiologically Controlled Area
SDP Significance Determination Process
SGRP Steam Generator Replacement Project
SRW Service Water System
SSC Structure, System and Component
UFSAR Updated Final Safety Analysis Report
URI Unresolved Item