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05000317/FIN-2016002-0230 June 2016 23:59:59Calvert CliffsNRC identifiedFailure to Report Conditions as Required by 10 CFR 50.73The inspectors identified a Severity Level IV, NCV of 10 CFR 50.73(a)(2) for Exelons failure to report within 60 days of discovery, a condition that could have prevented the fulfillment of the safety function of the service water (SRW) system needed to mitigate the consequences of an accident. Additionally, Exelon failed to report within 60 days of discovery, a single condition that caused two trains of the SRW system, a system designed to mitigate the consequences of an accident, to become inoperable. Exelon entered the issue into their CAP as IR 02688409 and on July 20, 2016, submitted LER 05000317/2016-004-00, High Energy Line Break Barrier Breached Due to Human Performance Error Causing Both Service Water Trains to be Inoperable. The inspectors determined that Exelons failure to report a single condition that caused the inoperability of two trains of SRW and may have prevented SRW from fulfilling its design functions to mitigate the consequences of an accident within 60 days of discovering the condition was a violation of 10 CFR 50.73(a)(2), and could have impacted the regulatory process. The inspectors reviewed IMC 0612, Appendix B, Issue Screening, and the NRC Enforcement Policy, revised February 4, 2015, and determined the violation is of SL-IV because it is most similar to example 6.9.d.9 of the NRC Enforcement Policy, A licensee fails to make a report required by 10 CFR 50.72 or 10 CFR 50.73, which is a SL-IV violation. The inspectors determined that the violation did not have a cross-cutting aspect because it involved the traditional enforcement process only.
05000317/FIN-2016301-0130 June 2016 23:59:59Calvert CliffsNRC identifiedSRO upgrade candidates performing RO duties without completing the requalification programThe NRC identified a Severity Level IV NCV of 10 CFR 50.54(i-1) and 10 CFR 55.59(a)(1), in that Exelon reduced the scope of the requalification program without NRC approval by allowing two SRO upgrade candidates, who were not current in requalification training, to perform RO duties with their qualifications lapsed. Immediate actions by Exelon included relieving one of these individuals from duty and replacing him with a qualified operator, suspending the RO qualifications for both SRO upgrade candidates, and initiating an apparent cause evaluation (CR 02648066). The inspectors determined that this violation was associated with a minor deficiency because the failure to follow training and qualification procedures had no safety impact. However, this violation impacted the regulatory process in that these licensed operators performed licensed duties while in non-compliance with their licenses. According to the Enforcement Policy, operators being in noncompliance with a condition stated on their licenses could be a Severity Level III violation. However, because no operational issues resulted from these individuals performance, the NRC determined that a Severity Level IV violation was more appropriate. In accordance with Inspection Manual Chapter 0612, because this violation involved traditional enforcement and does not have an underlying technical violation that would be considered more than minor, a cross-cutting aspect was not assigned to this violation.
05000317/FIN-2013003-0330 June 2013 23:59:59Calvert CliffsLicensee-identifiedLicensee-Identified ViolationOn May 18, 2012, CENG determined that a condition prohibited by technical specifications existed because SR was not fully met. SR requires the LPSI flow control valve on each unit to be verified in the open position with power removed from the valve operator. Contrary to the above, prior to December 2011, CENG did not remove all sources of power to the air operated CV306 valves. The inspectors determined that removing electrical power only to CV306 was not inconsistent with the licensing documents and submittals which are the basis for SR, and correspondence between CENG and the NRC did not specify a method to remove power from CV306. Therefore, no performance deficiency was identified because it was not reasonable for CENG to foresee and prevent the issue in this case. The inspectors reviewed LER 2012-001-00 and determined that traditional enforcement applies in accordance with IMC 0612, section 0612-09 and 0612-13 and Enforcement Policy section 2.2.4.d, because a violation of NRC requirements existed without an associated significance determination process performance deficiency. Correspondence between CENG and the NRC did not specify a method to remove power from CV306. The inspectors determined that removing electrical power only to CV306 was not inconsistent with the licensing documents. This issue was considered to be a Severity Level IV NCV of Technical Specification SR in accordance with Enforcement Policy section 6.1.d. In addition, IMC 0612, Appendix B, Figures 1 and 2, Issue Screening, were referenced in documenting this Severity Level IV licensee-identified NCV. This severity level IV licenseeidentified NCV was entered into CENGs CAP as CR-2012-005390.
05000317/FIN-2012004-0430 September 2012 23:59:59Calvert CliffsNRC identifiedInattentive Non-Licensed OperatorIn accordance with Inspection Procedure 92702, Followup on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, Confirmatory Orders, and Alternative Dispute Resolution Confirmatory Orders, the inspectors conducted a follow-up inspection of a Severity Level IV NCV which was identified due to the deliberate failure of a non-licensed operator to remain attentive to their duties while performing a maintenance evolution on the 2B EDG on June 15, 2011, contrary to Technical Specification 5.4.1.a, Procedures. This issue was communicated to Constellation in a letter dated April 9, 2012, following the completion of an NRC investigation into this matter. The inspectors reviewed the scope and depth of analysis performed in addressing the identified deficiency. The inspectors also reviewed Constellations assessment of generic implications of the identified violation and evaluated the corrective actions implemented by Constellation personnel to determine whether they were adequate to address the identified deficiency and prevent recurrence. The inspectors reviewed Constellations identified causes and the actions taken to prevent recurrence of those causes.
05000317/FIN-2009005-0431 December 2009 23:59:59Calvert CliffsNRC identifiedInformation Technology Analyst Failure to Disclose Prior Criminal History to Gain Unescorted Access AuthorizationThis severity level IV NCV identified on July 8, 2009, stated that contrary to 10 CFR 50.34(c) and the CCNPP Physical Security Plan, a former ITA deliberately failed to disclose elements of his criminal history when applying for UAA at CCNPP. This violation was documented in a July 8,2009, NRC letter to CCNPP. CCNPP determined that the event occurred because the provisions within NEI 03-01, Nuclear Power Plant Access Authorization Program, used to determine trustworthiness and reliability were not properly applied. This was evident in that the security access procedure, used by the reviewing official, did not identify the expectation to consider the psychologist report and comments, which lead directly to granting the ITA UAA prior to the discovery of potentially disqualifying information. To correct this performance deficiency, several corrective actions were implemented including: communicating the requirements in NEI 03-01 to access investigators that require a review of the psychologist report prior to determination of authorizing UAA, verifying all PADS reports were reviewed to ensure validity and accuracy of the information, issuing Operating Experience (OE) for this event, updating the security procedures and the security access guideline to accurately reflect the NEI 03-01 guidance, and performing a self-assessment of the Security Access Standard to identify vague or interpretive guidance in other processes. Additionally, the CAP opened an action to track and complete an effectiveness review of the security background investigators training material and reviewing official process to evaluate trustworthiness and reliability based on the accumulation of all information, including the psychologist report prior to authorizing UAA. The inspectors reviewed the corrective actions outlined in the August 21, 2009, Apparent Cause Evaluation, and CCNPPs review of previous industry OE dated October 2, 2009. The inspectors concluded that the root cause analysis was thorough and complete. Additionally, corrective actions taken were appropriate and timely. This violation is closed
05000317/FIN-2008007-0131 March 2008 23:59:59Calvert CliffsNRC identifiedFailure to Promptly Report a Senior Licensed Operator Permanent DisabilityThe inspectors identified a Severity Level IV non-cited violation (NCV) of 10 CFR 50.74 for failing to report changes in a medical condition within 30 days. This requirement is implemented in Constellation Procedure NO-1-105, Medical Requirements for Licensed Operators, Revision 4, Section 5.1 (D). As a result, a disqualifying medical condition for a Senior Reactor Operator (SRO) existed and was not reported to the NRC for approximately 18 months. Upon notification, the NRC determined this medical condition required a change to his license. Constellation personnel submitted the medical change documentation when they first became aware of the issue. In response, Region I added a no-solo license restriction for the individuals SRO license. The violation is more than minor because it had the potential to impact the NRCs ability to perform its regulatory function since the NRC would have placed the restriction on the license eighteen months earlier. The issue was evaluated using the traditional enforcement process. This finding was of very low safety significance because at no time did the individual stand watch without additional personnel available, as required by the added license restriction. In addition, Constellation was timely in their reporting of the medical condition to the NRC when they received the updated information from the individuals primary care physician