IR 05000317/2011004

IR 05000317-11-004, 05000318-11-004, on 07/01/2011-09/30/2011; Calvert Cliffs Nuclear Power Plant, Units 1 & 2, Operability Determinations and Functionality Assessments, Surveillance Testing, and Follow-up of Events & Notices of Enforcement

ML11307A459
Person / Time
Site:	Calvert Cliffs
Issue date:	11/03/2011
From:	Glenn Dentel Reactor Projects Branch 1
To:	Spina J Constellation Energy Nuclear Group
DENTEL, GLENN
References
IR-11-004
Download: ML11307A459 (41)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION I

475 ALLENDALE ROAD

SUBJECT:

CALVERT CLIFFS NUCLEAR GENERATING STATION . NRC INTEGRATED I NSPECTTON RE PORT 050003 1 7 t201 1 004 AN D 0500031 8t201 1 004

Dear Mr. Spina:

On September 30, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Calvert Cliffs Nuclear Power Plant (CCNPP) Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed, on October 6,2011, with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

This report documents three NRC-identified findings and one self-revealing finding of very low safety significance (Green). These finding 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 (CAP), the NRC is treating these findings as non-cited violations (NCVs) consistent with Section 2.3.2 of the NRC's Enforcement Policy. lf 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 l; 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 l, and the NRC Resident Inspector at Calvert Cliffs.

J.Spina 2 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 05000317/2011004 and 05000318/2011004 w/Attachment: Supplementary Information

REGION I==

Docket Nos.: 50-317, 50-318 License Nos.: DPR-53, DPR-69 Report No.: 05000317/2011004 and 05000318/2011004 Licensee: Constellation Energy Nuclear Group, LLC Facility: Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Location: Lusby, MD Dates: July 1, 2011, through September 30, 2011 Inspectors: S. Kennedy, Senior Resident Inspector E. Torres, Resident Inspector M. Jennerich, Acting Resident Inspector K. Cronk, Project Engineer J. Hawkins, Project Engineer R. Montgomery, Project Engineer R. Rolph, Health Physicist Approved by: Glenn T. Dentel, Chief Reactor Projects Branch 1 Division of Reactor Projects

SUMMARY OF FINDINGS

IR 05000317/2011004, 05000318/2011004; 7/1/2011 - 9/30/2011; Calvert Cliffs Nuclear Power

Plant (CCNPP), Units 1 and 2, Operability Determinations and Functionality Assessments,

Surveillance Testing, and Follow-up of Events and Notices of Enforcement Discretion.

This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. The inspectors identified three non-cited violations (NCVs) and one self-revealing NCV. 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 XVI,

Corrective Actions, because Constellation did not promptly identify and correct a condition adverse to quality associated with submerged saltwater (SW) pump motor safety-related medium voltage cables. As a result, safety-related cables were subjected to a submerged or continuously wetted environment for extended periods. Immediate corrective action included entering this issue into their corrective action program (CAP), conducting an operability determination (OD), and placing these cables into Constellations Medium Voltage Cable Program.

The finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, this condition could lead to cable degradation, increased likelihood of cable failure, and subsequent risk associated with the failure of safety-related equipment. The inspectors determined the finding is of very low safety significance because the finding is a design or qualification deficiency confirmed not to result in a loss of operability. The finding has a cross-cutting aspect in the area of problem identification and resolution, operating experience (OE), because Constellation did not fully implement and institutionalized OE to change station processes and procedures associated with submerged cables (P.2.b per IMC 0310). (Section 1R15)

• Green: The inspectors identified an NCV of 10 CFR Part 50, Appendix B, Criterion XVI,

Corrective Actions, because Constellation did not promptly identify and correct a condition adverse to quality associated with the Unit 2 pressurizer safety valves (PSVs). Specifically, following determination of a new PSV temperature profile, Constellation did not promptly identify that the valve setpoint would drift outside of the Technical Specification (TS)requirements during the operating cycle. This would have resulted in the PSVs becoming inoperable. Immediate corrective actions included placing this issue into the CAP, performing a re-analysis of PSV setpoints including the expected drift, and revising the OD.

Upon re-analysis, Constellation determined that the PSVs currently installed in Unit 2 are conditionally operable until February 8, 2012. Additional corrective actions will be required prior to operating the unit beyond this date.

The finding is more than minor because it is similar to examples 3j and 3k in IMC 0612,

Appendix E, in that the failure to account for drift in the OD resulted in a reasonable doubt on the operability of the PSVs. In addition, the finding is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors determined the finding is of very low safety significance because the finding is a design or qualification deficiency confirmed not to result in a loss of operability. This finding has a cross-cutting aspect in the area of problem identification and resolution, CAP, because Constellation did not thoroughly evaluate a problem such that the resolution addressed causes and extent of condition as necessary. Specifically, Constellation did not conduct an adequate operability review of the PSVs following identification of an unexpected temperature profile (P.1.c per IMC 0310). (Section 1R22)

Cornerstone: Emergency Preparedness

Green.

The inspectors identified an NCV of 10 CFR Part 50.54, Conditions of Licenses, paragraph (q), because Constellation did not maintain the Emergency Plan to adequately meet the standards in 50.47(b). Specifically, Constellation periodically removed the high range effluent monitors from service without addressing the impact on the sites ability to make a timely assessment of radiological releases as discussed in the Emergency Plan.

This could result in an unnecessary delay in dose projection for certain radiological events.

Immediate corrective actions included entering this issue into the CAP, updating the evaluation to address any potential delays, and protecting equipment required for dose projection.

The finding is more than minor because it is associated with the facilities and equipment attribute of the Emergency Preparedness (EP) cornerstone and affected the cornerstones objective to ensure that the licensee is capable of implementing adequate measures to protect public health and safety in the event of a radiological emergency. Specifically, the removal of high range effluent radiation monitors from service that provide a timely assessment capability may result in not immediately recognizing the offsite radiological condition that requires offsite protective actions. The inspectors determined the finding is of very low safety significance because it did not result in a loss or degraded Risk-Significant Planning Standard (RSPS) function. In addition, the finding is similar to examples of Green findings in IMC 0609, Appendix B, Section 4.9, in that the equipment or systems necessary for dose projection are not functional for longer than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from time of discovery without adequate compensatory measures. This finding has a cross-cutting aspect in the area of problem identification and resolution, CAP, because Constellation did not fully evaluate problems such that the resolution address causes and extent of condition as necessary.

Specifically, Constellation did not adequately evaluate the compensatory actions following the removal of the high range effluent monitors from service to ensure that a timely assessment of offsite radiological conditions could be accomplished following a steam generator tube rupture (SGTR) event (P.1.c per IMC 0310). (Section 1R15)

Green.

A self-revealing NCV of 10 CFR Part 50.54, Conditions of Licenses, paragraph (q),

was identified because Constellation did not maintain the Emergency Plan to adequately meet the standards in 50.47(b). Specifically, Constellation did not have an adequate emergency classification and action level scheme in place for the seismic activity initiating condition and Constellation personnel lacked the proficiency necessary to evaluate seismic recorder data in a timely manner during the seismic event on August 23, 2011. The licensee entered this issue into their CAP and implemented compensatory actions, which included training of operators.

The finding is more than minor because it is associated with the facilities and equipment attribute of the EP cornerstone and affected the cornerstone objective of ensuring that a licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, incorrect seismic recorder trigger setpoint settings and untimely evaluations of seismic recorder data could result in the failure of Constellation to declare an Unusual Event (UE) or an Alert in a timely manner.

The inspectors determined the finding is of very low safety significance because it did not result in a loss or degraded RSPS function. The finding is also similar to examples of Green findings in Section 4.4 of IMC 0609, Appendix B, in that the EAL classification process would not declare any Alert or Notification of UE that should be declared. This finding has a cross-cutting aspect in the area of human performance, resources, because Constellation did not ensure that the training of personnel was adequate to assure nuclear safety.

Specifically, Constellation did not ensure that personnel were proficiently trained to read and evaluate the seismic recorder data which could delay entry into the EALs (H.2.b of IMC 0310). (Section 4OA3)

Other Findings

None

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period at 100 percent power. On August 27, 2011, the reactor tripped due to a transformer fault caused by high winds during hurricane Irene. Operators returned the unit to full power on August 31. On the following dates, operators reduced power to clean condenser waterboxes: July 31, August 19, and September 23. The unit remained at or near 100 percent power for the remainder of the inspection period.

Unit 2 began the inspection period at 100 percent power. On September 1, the unit reduced power to 70 percent for scheduled maintenance on the 21 steam generator feed pump and for main turbine valve testing. On the following dates, operators reduced power to clean condenser waterboxes: July 15, July 23, July 30, August 6, and September 20. 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)

a. Inspection Scope

The inspectors performed a review of Constellations readiness for adverse weather conditions associated with hurricane Irene from August 25 to August 26, 2011. The inspectors performed a review of Constellations readiness for the onset of hurricane conditions. This review included an assessment of what the predicted conditions were and of the actions taken by site personnel. The inspectors verified that the operator actions were in accordance with EP-1-108, Severe Weather Preparation, and the Emergency Response Plan Implementing Procedure (ERPIP) 3.0, Immediate Actions, 20, Severe Weather. This inspection satisfied one inspection sample for impending adverse weather conditions. Documents reviewed for each section of this inspection report are listed in the Attachment.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Partial Walkdown (71111.04Q - Three Samples)

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems:

• No. 13 service water (SRW) pump subsystem during planned maintenance on the No. 11 SRW pump

• No. 11 emergency diesel generator (EDG) fuel oil transfer pump subsystem following failure of the No. 12 fuel oil transfer pump to develop adequate discharge pressure during routine surveillance testing

• Reserve battery placed in service on the No. 11 125 volts direct current (VDC) bus during planned maintenance on the No. 11 station battery 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 corrective action program for resolution with the appropriate significance characterization.

b. Findings

No findings were identified.

.2 Complete Walkdown (71111.04S - One Sample)

a. Inspection Scope

The inspectors performed a complete system walkdown of accessible portions of the Unit 1 and 2 auxiliary feedwater (AFW) systems to verify the existing equipment lineup was correct. The inspectors reviewed system drawings and operating instructions to verify proper equipment alignment and the operational status. Inspectors also reviewed unresolved design issues such as temporary modifications, operator workarounds, and items tracked by plant engineering to assess their collective impact on system operation.

The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related CRs and work orders (WO) to ensure Constellation appropriately evaluated and resolved any deficiencies.

b. Findings

No findings were identified

1R05 Fire Protection

Quarterly Inspection (71111.05Q - Six Samples)

a. Inspection Scope

The inspectors conducted tours of the areas 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, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.

• 2B EDG room, fire area 28, room 416

• Unit 1 cable spreading room, fire area 16, room 306

• Unit 1 west electrical penetration room, fire area 32, room 529

• Unit 1 boric acid storage tank (BAST) room, fire area 11, room 217

• Unit 2 BAST room, fire area 11, room 215

• Common, auxiliary building 5' elevation hot machine shop, fire area 11, room 223

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program (71111.11Q - Two Samples)

a. Inspection Scope

The inspectors observed licensed operator simulator training on July 26, 2011, which included a dropped control element assembly, loss of component cooling (CC), a steam generator tube rupture (SGTR), and various equipment failures. The inspectors observed licensed operator simulator training on September 20, which included a loss of the No. 11 CC pump, loss of the No. 22 125 VDC bus, and a locked rotor on No. 11B reactor coolant pump resulting in a reactor trip. The inspectors focused on high-risk operator actions performed during the implementation of abnormal operating procedures and emergency operating procedures. 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.

1R12 Maintenance Effectiveness (71111.12Q - Three Samples)

a. Inspection Scope

The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on systems, structures, and components (SSCs) performance and reliability. The inspectors reviewed system health reports, corrective action program 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 SSCs were 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.

• No. 23 high pressure safety injection (HPSI) pump failed to start (CR-2011-003678)

• Unit 2 personnel airlock door failures (CR-2011-006534)

• Units 1 and 2 process plant computer failures (CR-2011-005033)

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - Six 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. The inspectors compared the risk assessments and risk management actions with CNG-OP.4.01-1000, Integrated Risk Management, and Constellations risk assessment tool to the requirements of 10 CFR Part 50.65(a)(4) and the recommendations of the Nuclear Management and Resources Council 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. 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 13 kilovolt service bus No. 21 tie breaker on July 18

• Emergent risk assessment associated with maintenance on Channel A linear range nuclear instrument (LRNI) on July 28

• Emergent risk assessment associated with No. 23 SW pump out of service due to wetted motor on July 20

• Emergent risk assessment associated with No. 12 charging pump out of service due to leaking discharge relief valve on August 6

• Planned maintenance on the No. 13 battery charger on August 11, 2011

• Emergent risk assessment associated with Unit 1 charging pumps declared inoperable on August 12

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments (71111.15 - Six Samples)

a. Inspection Scope

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

• No. 23 SW pump wetted by rain water (CR-2011-007396)

• No. 22 main steam line radiation monitor (MSLRM) 2-RIC-5422 out of service (CR-2011-005615);

• SW system junction box water leakage in the intake structure (CR-2011-006836/

CR-2011-006838)

• Potential defect in velan supplied globe valves (CR-2011-007458)

• No. 11 AFW pump governor high oil level (CR-2011-007752)

• Unit 2 LRNI channel A upper detector noisy (CR-2011-007281)

The inspectors selected these issues based on the risk significance of the associated components and systems. The evaluations were reviewed using criteria specified in NRC Regulatory Issue Summary 2005-20, Revision to Guidance formerly contained in NRC Generic Letter 91-18, Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability, and IMC Part 9900, Operability Determinations and Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety. The inspectors evaluated the technical adequacy of the operability determinations 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

Submerged SW Pump Motor Cables

Introduction.

The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, because Constellation did not promptly identify and correct a condition adverse to quality associated with submerged SW pump motor safety-related medium voltage cables.

Description.

On June 29, 2011, the inspectors identified junction boxes 2J025A and 2J025B on the Unit 2 side of the intake structure that were leaking water from inside the junction box. This discrepancy was reported to the control room shift manager who initiated two CRs (CR-2011-006836 and CR-2011-006838). Initially the leakage was determined to be normal and expected because similar junction boxes in the intake structure for Unit 1 and Unit 2 were labeled with signs that stated Leakage Normal.

The inspectors noted that there are twelve junction boxes in the intake structure of a similar nature, all experiencing various volumes of leakage and junction box degradation. These junction boxes contain medium voltage SW pump motor cables and low voltage cables such as SW system temperature element cables, pressure element cables, valve control cables, and other low voltage cables associated with the safety-related SW system. Drawing 61-230-E, Saltwater Systems Underground Ducts Plan and Sections, Note 1, stated that, All underground runs to be sealed against water seepage. However, groundwater has been known to leak in the SW system underground ducts since at least 1991.

UFSAR, Table 9-17A, Single Failure Analysis, documented the impact to the SW pump motor cables if the cables were to become flooded due to a passive failure. The UFSAR, in part, stated that these cables are suitable for submerged operation during a flooding event caused by a passive failure. However, Constellation did not have a qualification test report or certification from the cable vendor supporting that these cables are designed or qualified to operate in a continuously submerged environment.

NRC Information Notice (IN) 2010-26, Reactor Trips Resulting from Water Intrusion into Electrical Equipment and NRC Generic Letter (GL) 2007-01, Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients, concluded that cables not qualified for continuous submergence, but exposed to continuous wet or submerged environments, have the potential to degrade over time and have an increased risk of failure which could result in the subsequent failure of safety-related equipment as evident from industry operating experience.

The inspectors determined that water leakage from the junction boxes was a non-conforming condition that indicated that the SW pump motor cables had been submerged or continuously wetted for an unknown period. The inspectors noted that Constellation did not fully utilize the CAP to identify, evaluate, and take prompt and adequate corrective actions following the discovery of the submerged cables discussed under NCV 05000317/318/2010005-01: Inadequate Corrective Actions Associated with Submerged SR Cables. Following the issuance of NCV 05000317/318/2010005-01, Constellations extent of condition review did not identify the SW pump motor cable issue as a condition adverse to quality and consequently did not include the cables in their Medium Voltage Cable Program as required by Constellations procedure (CN-AM-1.01-1029, Medium Voltage Cable Program). The inspectors noted that Constellation had additional opportunities to identify this adverse condition using industry OE such as NRC IN 2010-12, GL 2007-01, and other industry correspondence on this subject. Immediate corrective actions included entering this issue into their CAP, conducting an OD, and placing these cables into the stations Medium Voltage Cable Program. Constellation is evaluating additional long-term corrective actions. The violation is an NCV because it was of very low safety significance and Constellation entered the issue into their CAP.

The finding has a cross-cutting aspect in the area of problem identification and resolution, OE, because Constellation did not fully implement and institutionalize OE to change station processes and procedures associated with submerged cables.

Analysis.

The performance deficiency is that Constellation did not promptly identify and correct a condition adverse to quality associated with submerged SW pump motor safety-related medium voltage cables. The finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, this condition could lead to cable degradation, increased likelihood of cable failure, and subsequent risk associated with the failure of safety-related equipment. In accordance with IMC 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, Table 4a, the inspectors determined the finding is of very low safety significance (Green), because the finding is a design or qualification deficiency confirmed not to result in a loss of operability. The finding has a cross-cutting aspect in the area of problem identification and resolution, OE, because Constellation did not fully implement and institutionalize OE to change station processes and procedures associated with submerged cables (P.2.b per IMC 0310).

Enforcement.

10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires that licensees establish measures to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. Contrary to the above, prior to June 29, 2011, Constellation did not promptly identify and correct a condition adverse to quality associated with submerged SW pump motor safety-related medium voltage cables. As a result, the SW pump motor cables were subjected to a submerged environment for extended periods. This condition could lead to cable degradation, increased likelihood of cable failure, and subsequent risk associated with the failure of safety-related equipment. Immediate corrective actions included entering this issue into their CAP, conducting an OD, and placing these cables into the stations Medium Voltage Cable Program. Because this violation was of very low safety significance and Constellation entered the issue into their CAP (CR-2011-006836/006838), this violation is being treated as an NCV, consistent with the Enforcement Policy. (NCV 05000317/318/2011004-01: Inadequate Corrective Actions Associated with Submerged Saltwater Pump Motor Cables)

Inadequate Compensatory Actions for Out of Service High Range Effluent Monitors

Introduction.

The inspectors identified a Green NCV of 10 CFR Part 50.54, Conditions of Licenses, paragraph (q), because Constellation did not maintain the Emergency Plan to adequately meet the standards in 50.47(b). Specifically, Constellation periodically removed the high range effluent monitors from service without addressing the impact on the sites ability to make a timely assessment of radiological releases as discussed in the Emergency Plan.

Description.

On May 26, 2011, Operations placed the No. 22 Main Steam Line Radiation Monitor (MSLRM) out of service due to an equipment failure. Operations entered Technical Requirements Manual (TRM) 15.3.1.B, Radiation Monitoring Instrumentation, which requires that the inoperable radiation monitor be returned to service in 7 days or conduct an evaluation per TRM 15.0.3 for continued operations.

The evaluation stated that the indication from 2-RIC-5422 (MSLRM) is used to estimate off-site dose rates following a SGTR. In addition, it stated that there will be minimum impact on the response to a SGTR because ERPIP 821, Accidental Radioactivity Release Monitoring and Sampling Methods, provides alternative methods for monitoring the activity during a main steam release with this monitor out of service. The inspectors determined that the evaluation was not adequate because it did not provide adequate compensatory measures to enable dose projection following a SGTR.

ERPIP 107, Chemistry Shift Technician, credits the MSLRM for dose projection following a SGTR releasing activity to the environment via a stuck open main steam safety valve. If the MSLRM is out of service, ERPIP 821 stated that the backup method is to take a radiation reading at the secondary sample sink drains. ERPIP 821 noted that this radiation reading may be significantly delayed due to support required by Operations and Radiation Protection. The evaluation did not have any controls in place to address this potential delay.

ERPIP 107 credits the wide range noble gas monitor (WRNGM) for dose projection following a SGTR releasing activity to the environment through the main vent via the condenser. If the WRNGM is out of service, ERPIP 821 stated that the backup method is to take a manual radiation reading at 10-meter distance from the main vent. The inspectors reviewed operator logs dating back to April 2009 and noted that the MSLRMs (No. 21 or No. 22) and the WRNGM were secured at the same time on approximately 36 occasions of various lengths, the longest periods of which were 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> and 54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br /> on March 31, 2010, and May 18, 2009, respectively. The inspectors had previously identified that this backup method for the WRNGM was not adequate because of the inability to take manual readings near the main vent due to radiation levels that could exist at the site area emergency and general emergency classification levels (Inspection Report 05000317/318/2009005-03: Failure to Provide for Adequate Compensatory Measures with the Wide Range Noble Gas Monitor Out of Service). Corrective action for this issue included the installation of a radiation meter at 10-meter distance to the main vent that was remotely readable. However, Constellation did not proceduralize this method and/or include this method in the evaluation. Since the method was not proceduralized, there was no assurance that the method could or would be implemented if needed.

The inspectors concluded that having both high range effluent monitors (MSLRM and WRNGM) out of service at the same time adversely affected the sites ability to make a timely assessment of radiological releases as discussed in the Emergency Plan and could result in an unnecessary delay in dose projection for a SGTR event. Immediate corrective actions included entering this issue into the CAP, updating the evaluation to address any potential delays, and protecting equipment required for dose projection.

The inspectors noted that this issue was also applicable to Unit 1. The violation is an NCV because it was of very low safety significance and Constellation entered the issue into their CAP. This finding has a cross-cutting aspect in the area of problem identification and resolution, CAP, because Constellation did not fully evaluate problems such that the resolutions addressed causes and extent of condition as necessary.

Analysis.

The performance deficiency is that Constellation periodically removed the high range effluent monitors from service without addressing the impact on the sites ability to make a timely assessment of radiological releases as discussed in the Emergency Plan.

The finding is more than minor because it was associated with the facilities and equipment attribute of the EP cornerstone and affected the cornerstones objective to ensure that the licensee is capable of implementing adequate measures to protect public health and safety in the event of a radiological emergency. Specifically, the removal of high range effluent radiation monitors from service that provide a timely assessment capability may result in not immediately recognizing the offsite radiological condition that requires offsite protective actions. In accordance with IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, the inspectors determined the finding is of very low safety significance (Green). Utilizing IMC 0609, Appendix B, Section 4.9 and Sheet 1, Failure to Comply, the inspectors determined that the failure to comply with an aspect of the Emergency Plan related to equipment for assessment and monitoring of radiological releases (10 CFR Part 50.47(b)(9)) was a RSPS problem. However, it was not a RSPS functional failure or a degraded RSPS because Constellations Emergency Plan has procedures for basing dose projection on offsite field measurements. In addition, the finding is similar to examples of Green findings in IMC 0609, Appendix B, Section 4.9, in that the equipment or systems necessary for dose projection are not functional for longer than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from time of discovery without adequate compensatory measures. This finding has a cross-cutting aspect in the area of problem identification and resolution, CAP, because Constellation did not fully evaluate problems such that the resolutions addressed causes and extent of condition as necessary. Specifically, Constellation did not adequately evaluate the compensatory actions following the removal of the high range effluent monitors from service to ensure that a timely assessment of offsite radiological conditions could be accomplished following a SGTR event (P.1.c per IMC 0310).

Enforcement.

10 CFR Part 50.54, "Conditions of Licenses," paragraph

(q) requires, in part, that a licensee "shall follow and maintain in effect emergency plans which meet the standards in 10 CFR Part 50.47(b) and the requirements in Appendix E of this part. 10 CFR Part 50.47(b)(9) requires, in part, that "adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use." Contrary to the above, on numerous occasions prior to September 30, 2011, Constellation did not have an adequate method or equipment in place for monitoring potential offsite radiological conditions following a SGTR event with the high range effluent monitors out of service. This could result in an unnecessary delay in determining dose projection during a SGTR event. By failing to meet the requirements of 10 CFR Part 10.47(b)(9), Constellation was in violation of 10 CFR Part 50.54(q) for not properly maintaining the conditions of the Calvert Cliffs Emergency Plan. Immediate corrective actions included entering this issue into the CAP, updating the evaluation to address any potential delays, and protecting equipment required for dose projection. Because this finding was of very low safety significance and was entered into Constellation's CAP (CR-2011-006094) this violation is being treated as an NCV, consistent with the Enforcement Policy. (NCV 05000317/318/2011004-02:

Inadequate Compensatory Actions for Out of Service High Range Effluent Radiation Monitors)

1R18 Plant Modifications (71111.18 - One Sample)

a. Inspection Scope

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

The inspectors reviewed 10 CFR 50.59 documentation and post-modification testing results, and conducted a field walkdown of the modification to verify that the temporary modifications did not degrade the design bases, licensing bases, and performance capability of the affected systems.

• Temporary modification to lower the detector voltage on Unit 2 LRNI Channel A (ECP-11-000645)

b. Findings

No findings were identified.

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

a. Inspection Scope

The inspectors reviewed the post-maintenance tests 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 the 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.

• No. 22 SW pump replacement (WO #C90796252)

• No. 22 instrument air compressor solenoid valve replacement (WO# C220092420)

• Unit 2 LRNI channel A troubleshooting and repair (WO# C91485724)

• No. 12 charging pump discharge isolation valve repair (WO# C91541468)

• No. 11 control room heating ventilation & air conditioning supply fan repair (WO# C91545177)

• 1A EDG following exhaust pipe water intrusion repair and restoration (WO#

C91569244)

• No. 22 HPSI pump motor and breaker maintenance (WO# C91180463)

b. Findings

No findings were identified.

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

a. Inspection Scope

The inspectors reviewed the activities associated with the Unit 1 forced outage due to U-25000-12 transformer damage during hurricane Irene. During the outage, the inspectors examined the following activities: shutdown of the plant, electrical system configuration, shutdown risk, dilution to criticality; and rise to full power operations. The inspectors reviewed applicable procedures, observed control room activities, conducted walkdowns, and interviewed key personnel. The inspectors evaluated the activities against TS requirements, site procedures, and other applicable guidance and requirements.

b. Findings

No findings were identified.

1R22 Surveillance Testing (71111.22 - Six 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 O-8B-1, 1B EDG monthly and quarterly in-service testing

• STP O-73A-2, No. 21 SW pump and check valve quarterly (IST)

• STP-M-002-2, Unit 2 PSV setpoint adjustment

• STP-O-005A, Unit 1 AFW pump quarterly surveillance test

• STP-O-073F, Unit 1 boric acid performance test

• STP-M-552-1, No. 11 station battery service test

b. Findings

Introduction.

The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, because Constellation did not promptly identify and correct a condition adverse to quality associated with the Unit 2 PSVs. Specifically, following determination of a new PSV temperature profile, Constellation did not promptly identify that the valve setpoint would drift outside of the TS requirements during the operating cycle.

Description.

On March 13, 2011, during the startup from the Unit 2 refueling outage, Constellation trended the PSV body temperatures at normal operating temperature (NOT) and normal operating pressure (NOP) to verify that the PSVs pressure lift setpoints were being established at the appropriate temperature at the vendors laboratory. Constellation performed this verification as corrective action for a previous temperature profile issue associated with Unit 2 PSVs (NCV 05000318/2008009-01, Failure to Identify an Inoperable Pressurizer Safety Valve). Constellation observed that the resulting temperature of the PSV body at equilibrium was significantly less than expected. Constellation expected that equilibrium temperature of the PSV body would be approximately 420 °F, which is the temperature used to established the PSVs lift setpoint at the vendor. However, the equilibrium temperature at NOT/NOP was approximately 330 °F and 300 °F for 2RV-200 and 2RV-201 respectively. As discussed in NRC IN 89-90, Supplement 1, Pressurizer Safety Valve Lift Setpoint Shift, potential problems may result from operating PSVs in an environment different from that used to establish the PSV pressure lift setpoint. Specifically, the temperature of the valve body can affect the established pressure lift setpoint. For example, if the temperature of the valve body during plant operation is lower than the temperature used to establish the pressure lift setpoint in the laboratory, then the actual pressure lift setpoint during operation could be higher than the setpoint established in the laboratory. This phenomenon is due to the contraction of the valve body and bonnet at lower temperatures, which increases spring pressure, and increases the lift setpoint of the valve. Upon discovery of the significantly lower than expected temperature, Constellation revised an existing OD to justify full cycle operability of the PSVs.

Constellation determined that the PSVs currently installed in Unit 2 were operable for the operating cycle based on the measured temperature change is not enough to declare the valves inoperable.

The inspectors reviewed the OD for the installed Unit 2 PSVs and determined that Constellation did not account for the potential for the safety valve pressure setpoint to drift during the operating cycle. NRC IN 2006-24, Recent Operating Experience Associated with Pressure and Main Steam Safety/Relief Valve Lift Setpoints, states that, Setpoint drift is the result of many random variables and is usually considered a function of time since calibration and setting. The inspectors noted that an evaluation written for a previous issue (IRE-027-718) stated that the expected drift at Calvert Cliffs was determined to be 1 psi/month. Taking drift into account, the inspectors concluded that the PSVs could drift high outside of the required TS pressure setpoint and result in the PSVs becoming inoperable during the operating cycle. The inspectors concluded that the operability review on March 13, 2011, was inadequate because Constellation failed to recognize that the OD did not support full cycle operability of the PSVs and take appropriate actions.

Immediate corrective actions included placing this issue into the CAP, performing a re-analysis of PSV setpoints including the expected drift, and revising the OD. Upon re-analysis, Constellation determined that the PSVs currently installed in Unit 2 are conditionally operable until February 8, 2012. Additional corrective actions will be required prior to operating the unit past this date. The violation is an NCV because it was of very low safety significance and Constellation entered the issue into their CAP.

This finding has a cross-cutting aspect in the area of problem identification and resolution, CAP, because Constellation did not fully evaluate a problem such that the resolution addressed causes and extent of condition as necessary.

Analysis.

The performance deficiency is that Constellation did not promptly identify and correct a condition adverse to quality associated with the Unit 2 PSVs. Specifically, following determination of a new PSV temperature profile, Constellation did not promptly identify that the valve pressure setpoint could drift outside of the TS requirements during the operating cycle. The finding is more than minor because it is similar to examples 3j and 3k in IMC 0612, Appendix E, in that the failure to account for drift in the OD resulted in a reasonable doubt on the operability of the PSVs. In addition, the finding is associated with the equipment performance attribute of Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. In accordance with IMC 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, Table 4a, the inspectors determined the finding is of very low safety significance (Green), because the finding is a design or qualification deficiency confirmed not to result in a loss of operability. This finding has a cross-cutting aspect in the area of problem identification and resolution, CAP, because Constellation did not fully evaluate a problem such that the resolution addressed causes and extent of condition as necessary. Specifically, Constellation did not conduct an adequate operability review of the PSVs following identification of an unexpected temperature profile (P.1.c per IMC 0310).

Enforcement.

10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires that licensees establish measures to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. Contrary to the above, from March 13, 2011, through September, 30, 2011, Constellation did not promptly identify and correct a condition adverse to quality associated with the Unit 2 PSVs. Specifically, following determination of a new PSV temperature profile, Constellation did not promptly identify that the valve setpoint could drift outside of the TS requirements during the operating cycle. This would have resulted in the PSVs becoming inoperable. Immediate corrective actions included placing this issue into the CAP, performing a re-analysis of PSV setpoints including the expected drift, and revising the OD. Because this violation was of very low safety significance and Constellation entered the issue into their CAP (CR-2011-009785), this violation is being treated as an NCV, consistent with the Enforcement Policy. (NCV 05000318/2011004-03: Failure to Identify Pressurizer Safety Valve Condition Adverse to Quality)

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation (71114.06 - Two Samples)

a. Inspection Scope

The inspectors evaluated the conduct of routine Calvert Cliffs emergency drills on July 26, 2011, and September 20, 2011, to identify any weaknesses and deficiencies in the classification, notification, and protective action recommendation development activities.

The inspectors observed emergency response operations in the simulator to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the station drill critique to compare inspector observations with those identified by Constellation staff in order to evaluate Constellations critique and to verify whether the Constellation staff was properly identifying weaknesses and entering them into the corrective action program.

b. Findings

No findings were identified.

2RS0 1 Radiological Hazard Assessment and Exposure Controls

a. Inspection Scope

During the period August 29, 2011, through September 1, 2011, the inspectors conducted the following activities to verify that Calvert Cliffs properly assessed the radiological hazards in the workplace and implemented appropriate radiation monitoring and exposure controls. Implementation of these controls was reviewed against the criteria contained in 10 CFR Part 20, relevant TSs, and Calvert Cliffs procedures.

Inspection Planning

• The inspector reviewed all licensee performance indicators (PIs) for the Occupational Exposure cornerstone for follow-up and the results of radiation protection program self-assessments and audits.

Radiological Hazard Assessment

• The inspectors verified that there have been no operational occurrences effecting radiological controls.

• The inspectors reviewed the two most recent surveys of the general walkways in the auxiliary building, the waste gas hold-up tanks and the charging pump rooms.

b. Findings

No findings were identified.

2RS0 3 In-Plant Airborne Radioactivity Control and Mitigation

a. Inspection Scope

During the period August 29, 2011, through September 1, 2011, the inspectors conducted the following activities to verify that Constellation was controlling in-plant airborne concentrations consistent with as low as reasonably achievable (ALARA).

Implementation of these controls was reviewed against the criteria contained in 10 CFR Part 20, applicable industry standards, and Calvert Cliffs procedures.

Inspection Planning

• The inspectors reviewed the UFSAR to identify potential airborne areas and the associated ventilation systems or airborne monitoring instrumentation.

• The inspectors reviewed procedures for maintenance, inspection, and use of respiratory protection equipment.

• The inspectors verified there were no reported PIs.

Use of Respiratory Protection Devices

• The inspectors verified the air used in self-contained breathing apparatus (SCBA)was tested and met Grade D quality.

• The inspectors observed demonstrations of an operator donning and doffing an SCBA, a radiation protection technician donning and doffing a powered air hood, and a chemistry technician donning and doffing a negative pressure respirator.

• The inspectors toured several respirator storage areas. The inspectors observed the physical condition of the equipment and reviewed inspection records. The inspectors reviewed maintenance records and verified the training records for maintenance personnel.

SCBAs for Emergency Use

• The inspectors observed the monthly inspection of three SCBAs staged in the outage command center, containment rapid entry/trip kit, and the control room. The inspectors verified Constellations capability to refill and transport bottles to and from the control room and the operations support center during emergency conditions.

• The inspectors verified control room operators and shift radiation protection technicians were trained and qualified in the use of SCBAs. The inspectors also verified personnel assigned to fill bottles were trained and qualified to that task.

• The inspectors verified appropriate mask sizes are available and that the control room operators on duty had no facial hair that would interfere with the sealing surface of the face seal. The inspectors verified that operators on shift who required vision correction have them readily available in the control room.

• The inspectors reviewed maintenance records for the three SCBAs inspected and verified any work performed was done by trained personnel or a contractor with certified training.

Problem Identification and Resolution

• The inspectors verified that problems associated with control and mitigation of in-plant airborne radioactivity were put in the CAP and properly addressed for resolution.

b. Findings

No findings were identified.

2RS0 7 Radiological Environmental Monitoring Program

a. Inspection Scope

During the period July 11 to 15, 2011, the inspectors conducted the following activities to verify the Radiological Environmental Monitoring Program (REMP) is based on sound principles and assumptions. The inspectors verified that the REMP quantifies the impact of the radioactive releases to the environment, monitors non-effluent exposure pathways, and validates that doses to members of the public are within the dose limits of 10 CFR Part 20 and 40 CFR Part 190, as applicable.

Inspection Planning

• The inspectors reviewed the Annual Radiological Environmental Operating Report for January 1 to December 31, 2010. The inspectors noted no anomalous results.

• The inspectors reviewed the Offsite Dose Calculation Manual (ODCM) to identify locations of the environmental monitoring stations. The inspectors verified that the one change made to the ODCM was reviewed and approved by the NRC.

• The inspectors reviewed the UFSAR for information regarding the environmental monitoring program and meteorological monitoring instrumentation.

• The inspectors reviewed quality assurance audit results of the program and the vendors program.

• The inspectors reviewed the 2010 Annual Radioactive Effluent Release Report.

Site Inspection

• The inspectors walked down four air sample collection stations, five thermoluminescent dosimeter stations, and two water composite stations to determine if they were located as described in the ODCM and to determine the material condition of the equipment.

• The inspectors reviewed the calibration records of the air samplers and noted the water composite samplers do not get calibrated. Calvert Cliffs verifies the calibration (factory preset values) by measuring the volume produced during a sampling period at least monthly.

• The inspectors verified that Calvert Cliffs has alternate sampling locations for vegetation if the primary locations have no plants.

• The inspectors observed the collection and preparation of two environmental samples from different environmental media. The inspectors verified the sampling was representative of the release pathways as specified in the ODCM and the sampling techniques were in accordance with the procedures.

• The inspectors verified the meteorological instruments were operable, calibrated, and maintained.

• The inspectors verified that missed and/or anomalous environmental samples were identified and reported in the annual environmental monitoring report. The inspectors verified for at least one missed sample that the events were captured in the CAP and corrective actions implemented as appropriate.

• The inspectors verified that Calvert Cliffs has implemented a sampling and monitoring program sufficient to detect leakage to groundwater.

• The inspectors verified that records of leaks, spills, and remediation were retained in a retrievable manner.

• The inspectors verified that appropriate detection sensitivities are used for counting samples.

• The inspectors reviewed the results of the inter-laboratory comparison program to verify the adequacy of environmental sample analyses performed by Calvert Cliffs vendor.

Problem Identification and Resolution

• The inspectors verified that problems associated with the REMP were identified by Calvert Cliffs at an appropriate threshold and were properly addressed for resolution in the CAP.

b. Findings

No findings were identified.

4OA1 Performance Indicator Verification (71151 - Ten Samples)

Initiating Events

a. Inspection Scope

The inspectors reviewed Constellations PI program for Units 1 and 2 to evaluate, collect and report information on Mitigating Systems Performance Index (MSPI). The MSPI systems were reviewed for the period of July 2010 through June 2011. The inspectors used the guidance provided in Nuclear Energy Institute 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, to assess the accuracy of PI data collected and reported. The inspectors reviewed system unavailability data, monitored component demands, demand failure data, and the consolidated data entry MSPI derivation reports for both unavailability index and unreliability index. Additionally, the inspectors reviewed the equipment out of service logs, operating logs, and the maintenance rule database to determine the accuracy and completeness of the reported unavailability data.

• High pressure injection system

• Emergency alternating current power system

• Residual heat removal system (i.e. Low pressure safety injection)

• Cooling water systems

• Heat removal system (i.e. AFW)

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

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 corrective action program 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 corrective action program and periodically attended CR screening meetings.

b. Findings

No findings were identified.

4OA3 Follow-Up of Events and Notices of Enforcement Discretion (71153 - Three Samples)

.1 Earthquake

a. Inspection Scope

On August 23, 2011, the inspectors responded to a seismic event detected onsite at 1:54 p.m. The site entered a UE, EAL A.U.6.4.1, for seismic activity being felt onsite and the seismic recorder indicating an event of greater than 0.01 gravity (g). Constellation formed an issue response team and performed comprehensive walkdowns on all site structures, areas and systems, including Units 1 and 2 containments. The inspectors reviewed operator actions to determine if actions taken were in accordance with procedures. The inspectors also reviewed system indications to verify that system responses were as expected. In addition, the inspectors conducted independent walkdowns of safety-related components and site structures. The inspectors compared their observations to the requirements specified in the Constellation procedures. The inspectors communicated the plant event to appropriate regional personnel, and compared the event details with criteria contained in IMC 0309, Reactive Inspection Decision Basis for Reactors, for consideration of potential reactive inspection activities.

As applicable, the inspectors verified that Calvert Cliffs made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR Parts 50.72 and 50.73.

b. Findings

Introduction:

A self-revealing Green NCV of 10 CFR Part 50.54, Conditions of Licenses, paragraph (q), was identified because Constellation did not maintain the Emergency Plan to adequately meet the standards in 50.47(b). Specifically, Constellation did not have an adequate emergency classification and action level scheme in place for the seismic activity initiating condition and Constellation personnel lacked the proficiency necessary to evaluate seismic recorder data in a timely manner.

Description:

The site experienced an earthquake on August 23, 2011, at 1:54 p.m. The control room felt the earthquake and received the seismic event annunciator. The EALs for Hazards - Natural Events (UE EAL A.U.6.4.1 and Alert EAL A.A.6.4.4) require declaration of an emergency event when an earthquake is felt at the site and the seismic recorder indicates a seismic event. An Unusual Event is entered when the seismic recorder indicates greater than 0.01g and an Alert is entered when the seismic recorder indicates greater than an Operating Basis Earthquake (0.08g horizontal, 0.053g vertical).

The seismic recorder is triggered to record if ground acceleration of greater than 0.02g is detected. The inspectors noted that the seismic recorder alarm is set above the EAL threshold for a UE and questioned the ability of Constellation to make an EAL declaration for a seismic event between 0.01g and 0.02g. The licensee entered this issue into their CAP (CR-2011-008515), performed an evaluation and implemented compensatory actions, which included having Operations using the Modified Mercalli Scale and information from offsite sources to determine ground acceleration below 0.02g. In addition to the trigger setpoint, the inspectors noted that Constellation site personnel lacked proficiency in quantifying the seismic recorder data in a timely manner.

The control room operators estimated ground acceleration at 0.013g around 5:00 p.m.

(over 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> after the initial event) on August 23, 2011. Later that evening at 9:21 p.m.

(over 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> after the initial event), the site personnel determined that onsite vertical and horizontal ground accelerations were 0.036g, significantly higher than the original estimate. Due to this lack of proficiency, Constellation would not be able to make a timely assessment of seismic activity using the seismic recorder. This could ultimately delay declaration of an Alert. Constellation entered this issue into the sites CAP (CR-2011-008514) and conducted the appropriate training on each operating shift. The violation is an NCV because it was of very low safety significance and Constellation entered the issue into their CAP. This finding has a cross-cutting aspect in the area of human performance, resources, because Constellation did not ensure that the training of personnel was adequate to assure nuclear safety.

Anaysis: The performance deficiency is that Constellation personnel lacked the proficiency necessary to evaluate the seismic recorder data in a timely manner such that appropriate initial onsite and offsite response can be determined. In addition, Constellation did not have an adequate emergency classification and action level scheme in place for the seismic activity initiating condition. The performance deficiency is more than minor because it is associated with the facilities and equipment attribute of the EP cornerstone and affected the cornerstone objective of ensuring that a licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, the incorrect seismic recorder trigger setpoint and untimely evaluations of seismic recorder data could result in the failure to declare a UE or Alert. The inspectors evaluated this finding using IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, Sheet 1, Failure to Comply, and determined that the failure to comply with an aspect of the Emergency Plan related to event classification (10 CFR Part 50.47(b)(4)) and was an RSPS problem. However, the inspectors determined that the performance deficiency was not an RSPS failure or degraded RSPS because it is consistent with the guidance in Section 4.4 of IMC 0609, Appendix B for a finding of very low safety significance (Green). Specifically, Section 4.4 provides examples for use in assessing EP findings.

One example of a Green finding states, The EAL classification process would not declare any Alert or Notification of Unusual Event that should be declared. This finding has a cross-cutting aspect in the area of human performance, resources, because Constellation did not ensure that the training of personnel was adequate to assure nuclear safety. Specifically, Constellation did not ensure that personnel were proficiently trained to read and evaluate the seismic recorder data which could delay entry into the EALs (H.2.b per IMC 0310).

Enforcement:

10 CFR Part 50.54, "Conditions of Licenses," paragraph

(q) requires, in part, that a licensee "shall follow and maintain in effect emergency plans which meet the standards in 10 CFR Part 50.47(b) and the requirements in Appendix E of this part. 10 CFR Part 50.47(b)(4) requires, in part, that emergency response plans include a standard emergency classification and action level scheme, the bases of which include a standard facility system and effluent parameters. The emergency classification and action level scheme required to be used by the nuclear facility licensee, and state and local response plans, rely on information provided by facility licensees for determination of minimum initial offsite response measures. Contrary to this requirement, prior to August 23, 2011, Constellation did not have an adequate emergency classification and action level scheme in place for the seismic activity initiating condition and Constellation personnel lacked the proficiency necessary to evaluate seismic recorder data in a timely manner. This could ultimately delay declaration of an Alert or an Unusual Event and impact the ability of the state and local officials to determine initial offsite response measures. Immediate corrective actions included entering this issue into their CAP, performing an evaluation and implementing compensatory actions, which included having Operations using the Modified Mercalli Scale and information from offsite sources to determine ground acceleration below 0.02g. Because this violation was of very low safety significance (Green) and Constellation entered the issues into their CAP (CR-2011-008515 and CR-2011-008514), this violation is being treated as an NCV consistent with the Enforcement Policy. (NCV 05000317/318/2011004-04: Lack of Proficiency in Evaluating Seismic Recorder Data)

.2 Hurricane Irene

a. Inspection Scope

On August 27, 2011, the inspectors responded to a reactor trip of Unit 1. In the events leading up to the trip, hurricane Irene was passing through the southern Maryland area and wind gusts up to 55 miles per hour caused a piece of the turbine building siding to separate from the building and contact the Unit 1 Main Transformer causing a turbine trip followed by a reactor trip. The inspectors reviewed operator actions to determine if actions taken were in accordance with procedures. The inspectors also reviewed system indications to verify that system responses were as expected. In addition, the inspectors reviewed Constellation's initial investigation to assess the adequacy of immediate and interim corrective actions prior to restart. The inspectors compared their observations to the requirements specified in the Constellation procedures. The inspectors communicated the plant event to appropriate regional personnel, and compared the event details with criteria contained in IMC 0309, Reactive Inspection Decision Basis for Reactors, for consideration of potential reactive inspection activities.

As applicable, the inspectors verified that Calvert Cliffs made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR Parts 50.72 and 50.73.

b. Findings

No findings were identified.

.3 Loss of Site Self Power

a. Inspection Scope

On September 7, 2011, the inspectors responded to a dual unit electrical transient that resulted in the loss of No. 13 and No. 14 Containment Air Coolers (CACs) for Unit 1 and the No. 24 CAC for Unit 2. Additional anomalies during the transient were observed on balance of the plant equipment. Constellation staff personnel manned the Outage Control Center to investigate the cause, troubleshoot and correct the problem.

Constellation determined that an approximate 30 kilo-amp fault occurred on the primary side of the Unit 2 site self power 0X04 transformer, a non-safety related transformer.

The inspectors reviewed Constellation actions to determine if actions taken were in accordance with procedures. The inspectors communicated the plant event to appropriate regional personnel, and compared the event details with criteria contained in IMC 0309, Reactive Inspection Decision Basis for Reactors, for consideration of potential reactive inspection activities. As applicable, the inspectors verified that Calvert Cliffs made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR Parts 50.72 and 50.73.

b. Findings

No findings were identified.

4OA5 Other Activities

Independent Spent Fuel Storage Installation (ISFSI) (60588 - One Sample)

a. Inspection Scope

The inspectors evaluated Calvert Cliffs effectiveness for controlling radiological activities at the ISFSI.

On Site Inspection The inspectors reviewed the ALARA review and the radiation work permit used for ISFSI activities. The inspector walked down the ISFSI area during the transfer of a dry fuel canister into a storage module. The inspectors observed the radiological job coverage and the radiation workers performance. The inspectors verified the condition of the radiological postings. The inspectors reviewed surveys from the current transfer of the cask to the ISFSI.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On October 6, 2011, the inspectors presented the inspection results to Mr. James A.

Spina, Vice President, and other members of the Calvert Cliffs Nuclear Power Plant 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

J. Spina, Acting Site Vice President

C. Constanzo, Plant General Manager

K. Bodine, Supervisor, Engineering

M. Fick, Director, Emergency Preparedness

D. Frye, Manager, Operations

R. Gines, Engineer

K. Gould, General Supervisor, Radiation Protection

J. Herron, Supervisor, Engineering

D. Lauver, Director, Licensing

S. Loeper, Principal Engineer

K. Mills, General Supervisor, Shift Operations

B. Nuse, Senior Environmental Specialist

T. Riti, General Supervisor, System Engineering

A. Simpson, Licensing Supervisor

J. Stanley, Manager, Engineering Services

M. Stanley, Fire Marshal

C. Thomas, Engineer

D. Williams, Safety Director

J. Wilson, Supervisor, Engineering

J. York, General Supervisor, Chemistry

LIST OF ITEMS

Opened and Closed

05000317/318/2011004-01 NCV Inadequate Corrective Actions Associated with Submerged Saltwater Pump Motor Cables (Section 1R15)

05000317/318/2011004-02 NCV Inadequate Compensatory Actions for Out of Service High Range Effluent Radiation Monitors (Section 1R15)

05000318/2011004-03 NCV Failure to Identify Pressurizer Safety Valves Condition Adverse to Quality (Section 1R22)

05000317/318/2011004-04 NCV Lack of Proficiency Evaluating Seismic Recorder Data (Section 4OA3)