IR 05000317/2007003
Download: ML072180482
Text
August 6, 2007
Mr. James A. Spina, Vice PresidentCalvert Cliffs Nuclear Power Plant, Inc.
Constellation Generation Group, LLC 1650 Calvert Cliffs Parkway Lusby, Maryland 20657-4702
SUBJECT: CALVERT CLIFFS NUCLEAR POWER PLANT - NRC INTEGRATEDINSPECTION REPORT 05000317/2007003 AND 05000318/2007003 AND EXERCISE OF ENFORCEMENT DISCRETION
Dear Mr. Spina:
On June 30, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection atCalvert Cliffs Nuclear Power Plant (CCNPP) Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on July 10, 2007, with Mr. Flaherty and other members of your staff.The inspection examined activities conducted under your license as they relate to safety andcompliance 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 four NRC-identified findings and one self-revealing finding of very lowsafety significance (Green). All of the findings were determined to involve violations of NRC requirements. However, because of the very low safety significance and because they are entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCVs) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest any NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulator Commission, ATTN.:
Document Control Desk, Washington, D.C. 2-0555-0001; with copies to the Regional Administrator, Region 1; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspector at the CCNPP. The enclosed report also documents one noncompliance that was identified during yourtransition period to the National Fire Protection Association (NFPA) Standard 805. The NRC is not taking any enforcement action for this item because the conditions for this noncompliance meet the enforcement discretion criteria specified in the NRC Enforcement Policy, Interim Enforcement Policies, "Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)."
2J. SpinaIn accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, 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 NRC's 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 by James W. Clifford For/David C. Lew, Director Division of Reactor ProjectsDocket Nos.50-317, 50-318License Nos. DPR-53, DPR-69
Enclosure:
Inspection Report 05000317/2007003 and 05000318/2007003 w/
Attachment:
Supplemental Information cc w/encl:M. J. Wallace, President, Constellation Generation J. M. Heffley, Senior Vice President and Chief Nuclear Officer President, Calvert County Board of Commissioners C. W. Fleming, Senior Counsel, Constellation Generation Group, LLC J. Gaines, Director, Licensing Director, Nuclear Regulatory Matters R. McLean, Manager, Nuclear Programs K. Burger, Esquire, Maryland People's Counsel R. Hickok, NRC Technical Training Center G. Aburn, SLO (2)
SUMMARY OF FINDINGS
...................................................iii
REPORT DETAILS
..........................................................1
REACTOR SAFETY
.........................................................11R01Adverse Weather Protection .......................................1
1R02 Evaluations of Changes, Tests, or Experiments ........................21R04Equipment Alignment ............................................2
1R05 Fire Protection..................................................5
1R06 Flood Protection ................................................61R07Heat Sink .....................................................7
1R11 Licensed Operator Requalification Program ...........................7
1R12 Maintenance Effectiveness ........................................81R13Maintenance Risk Assessments and Emergent Work Control ............101R15Operability Evaluations ..........................................111R17Permanent Plant Modifications ....................................111R19Post Maintenance Testing ........................................121R22Surveillance Testing ............................................12
1R23 Temporary Plant Modifications
....................................13 1EP6Drill Evaluation
RADIATION SAFETY
.......................................................142PS1Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems
OTHER ACTIVITIES (OA)
...................................................164OA1Performance Indicator (PI) Verification ..............................16 4OA2Identification and Resolution of Problems ............................174OA3Event Followup ................................................21 4OA5Other Activities.................................................25 4OA6Meetings, Including Exit..........................................25ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
................................................A-1
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED...........................A-1
LIST OF DOCUMENTS REVIEWED
..........................................A-2
LIST OF ACRONYMS
.....................................................A-16
iiiSUMMARY
- OF [[]]
FINDINGSIR 05000317/2007-003, 05000318/2007-003; 04/01/2007 - 6/30/2007; Calvert Cliffs NuclearPower Plant, Units 1 and 2: Equipment Alignment, Maintenance Rule, Problem Identification
and Resolution, and Event Follow-up.The report covered a three-month period of inspection by resident inspectors and announcedinspections performed by regional inspectors. Five Green findings were identified, all of which
were determined to be non-cited violations (NCVs). The significance of most findings is
indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC)
0609, "Significance Determination Process" (SDP). Findings for which the SDP does not apply
may be Green or be assigned a severity level after
NRC's
program for overseeing the safe operation of commercial nuclear power reactors is described in
CFR Part 50, Appendix B, Criterion XVI,"Corrective Action," occurred because Constellation did not implement adequate
corrective actions for a significant condition adverse to quality associated with
the slow closure of a pressurizer power operated relief valve (PORV) due to a
main disc guide being out of round. Specifically, Constellation did not perform
an extent of condition review from a February 2006 event such that corrective
actions would preclude recurrence of the issue. Subsequently, during a Unit 2
reactor trip on November 16, 2006, a
- PO [[]]
RV remained open longer than
expected and resulted in a safety injection actuation signal. Constellation
entered this issue into the corrective action program (CAP) for resolution.
Immediate corrective actions for this issue included replacement of the main disc
guide and an extent of condition review of the remaining
- PO [[]]
RVs on Unit 1 and
Unit 2.This finding is greater than minor because it is associated with the equipmentperformance attribute of the Initiating Events cornerstone and affects the
cornerstone objective to limit the likelihood of those events that challenge critical
safety functions. Inspectors evaluated the significance of the finding using an
SDP Phase 2 analysis and determined the issue was of very low safety
significance (Green). This finding has a cross-cutting aspect in the area of
problem identification and resolution because Constellation did not thoroughly
evaluate an equipment malfunction such that the extent of condition was
considered and the cause resolved (P.1.c of
TS) 5.4.1.a,Administrative Controls, because Constellation did not maintain equipment
alignment in accordance with site procedures during drain and fill of the reactor
coolant system (RCS). Specifically, operations personnel did not verify a reactor
ivlevel instrument inlet valve shut prior to the vacuum fill of the
OP)-7, Shutdown Operations, and Operating Instruction
(OI)-1A, Reactor Coolant System and Pump Operation. This allowed air to enter
the in-service RCS level instrumentation lines causing a loss of all level
indication for a period of approximately five hours while in reduced inventory.
Constellation entered this issue into their
IRE-021-661 and IRE-022-119.
The immediate corrective actions included restoration of RCS level from a
reduced inventory condition and a prompt investigation to determine the cause of
the loss of all level indication.This finding is greater than minor because it is associated with the InitiatingEvent cornerstone attribute of configuration control and affects the likelihood of a
loss of shutdown cooling event. The inspectors evaluated the significance of the
finding using
SDP" and Appendix
H, "Containment Integrity SDP," because it represented an actual loss of level
indication. Based on the results of the Phase 3 analysis, this finding is
determined to have very low safety significance (Green). This finding has a
cross-cutting aspect in the area of human performance because Constellation
did not define and effectively communicate expectations regarding procedural
compliance such that personnel follow procedures (H.4.b). (Section
- NCV of TS 5.4.1.a, Administrative Controls,when Constellation did not maintain an adequate procedure to drain and fill the
OP-7 permitted operation in a reduced RCS inventory
condition without requiring redundant means of reactor level indication available.
This is not in accordance with Nuclear Operations Administrative Procedure
NO-1-103, Lower Mode Operations and Constellation's commitments in
response to
GL) 88-17, Loss of Decay Heat Removal.
Constellation entered this issue into their
IRE-022-121 and immediate
corrective actions included the suspension of OP-7 pending resolution of this
issue.This finding is greater than minor because it is associated with the InitiatingEvent cornerstone attribute of equipment performance and affects the
cornerstone objective to limit the likelihood of those events that upset plant
stability and challenge critical safety functions during shutdown operations.
Specifically, the inadequate procedure for operation in reduced RCS inventory
increased the likelihood of the loss of RCS level indication and consequently a
loss of residual heat removal (RHR) initiating event. The inspectors determined
that this finding was of very low safety significance based on IMC 0609,
Appendix GProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0609,</br></br>Appendix G" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Figure 1. The inspectors determined that this finding had a
cross-cutting aspect in the area of human performance because Constellation
did not ensure that the procedure for operation with the RCS in reduced
inventory was complete and accurate (H.2.c). (Section 4OA3.2)
vCornerstone: Mitigating Systems* Green. The inspectors identified a
CFR 50.65(a)(2) becauseConstellation did not demonstrate that performance monitoring of the main
steam safety valves (MSSVs) was being effectively controlled through the
performance of appropriate preventive maintenance. Specifically, in February
2006, Constellation experienced repetitive and numerous issues associated with
TSs. However, Constellation did not
recognize the unsatisfactory performance monitoring of this system in
accordance with the 10 CFR 50.65(a)(2) and place the system in (a)(1) status.
Constellation entered this issue into their CAP for resolution.The finding is greater than minor because it is associated with the equipmentperformance attribute of the Mitigating Systems cornerstone and affects the
cornerstone objective of ensuring the availability, reliability, and capability of the
- MS [[]]
SVs, which respond to initiating events to prevent undesirable consequences.
The finding is of very low safety significance (Green) because the finding is not a
design or qualification deficiency, does not represent a loss of a system safety
function or safety function of a single train, and does not screen as potentially
risk significant due to external events. The inspectors also determined that this
finding has a cross-cutting aspect in the area of problem identification and
resolution because Constellation did not trend and assess information from the
CAP and other assessments to identify programmatic and common cause
problems with the
- TS 3.6.3, Containment IsolationValves, because Constellation did not implement actions as specified in
TS3.6.3. Specifically, Constellation did not include all containment isolation valves
(CIVs) within the scope of
TS actions
being taken for these valves when they became inoperable. Constellation
entered this issue into their
IRE-021-913. The planned corrective
actions included a review of potential reportable conditions and a standing order
for operation personnel to enter
CIVs as appropriate. This finding is greater than minor because it is associated with the configurationcontrol attribute of the Barrier Integrity cornerstone and affects the cornerstone
objective to provide reasonable assurance that physical design barriers such as
containment protects the public from radio nuclide releases caused by accidents
or events. The inspectors evaluated the significance of this finding using a SDP
Phase 1 and Phase 2 analysis, which required evaluation using IMC 0609,
Appendix HProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0609,</br></br>Appendix H" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., because some of the inoperable valves identified in the reportability
review involved an actual reduction in the defense-in-depth for the atmospheric
pressure control of the reactor containment. Based on the results of the Phase 2
analysis, this finding was determined to have very low safety significance
(Green). This finding has a cross-cutting aspect in the area of problem
identification and resolution because Constellation did not take actions to
viaddress safety issues in a timely manner, commensurate with their significance(P.1.a). (Section 1R04)B.Licensee-Identified ViolationsNone.
EnclosureREPORT
- DETAIL [[]]
SSummary of Plant StatusCalvert Cliffs Unit 1 began the inspection period at 100 percent reactor power. OnMay 25, 2007, Unit 1 reduced power to 85 percent to perform main turbine valve testing.
Following the completion of the test, Unit 1 restored power to 100 percent and remained there
the rest of the inspection period. Calvert Cliffs Unit 2 began the inspection period in a refueling outage (RFO). On April 5, 2007,Unit 2 was in the process of returning to 100 percent reactor power when it experienced
problems with the 21 steam generator feed pump (SGFP). Unit 2 maintained reactor power at
percent while repairs were being performed for the
- 21 SG [[]]
FP. Following the repairs on
April 7, 2007, Unit 2 restored power to 100 percent until the main turbine throttle valve
malfunctioned. As a result, Unit 2 reduced power to 75 percent and performed maintenance on
the valve before returning to 100 percent power on April 8, 2007, and remained there the rest of
the inspection period.1.REACTOR
- SAFE [[]]
TY Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity1R01Adverse Weather Protection (71111.01 - One sample)Adverse Weather Seasonal Preparations - Hot Weather a.Inspection Scope The inspectors reviewed the adverse weather preparations and mitigating strategiesbefore the onset of hot weather operations. This review included an assessment of
Nuclear Operations Administrative Procedure NO-1-119, Seasonal Readiness. The
inspectors assessed the effectiveness of Constellation's preparations for hot weather
and grid related stress conditions to evaluate the site's readiness for seasonal
susceptibilities. Risk-significant systems affected by hot weather and grid related
stresses were selected for review. The review included the 500 kilowatt (kV) system
and the station blackout diesel operations. The inspectors performed a partial
walkdown of the onsite and offsite electrical systems. The inspectors interviewed
control room operators and system engineers to ensure protective measures applicable
to these risk-significant systems were available. This inspection satisfied one inspection
sample for review of risk-significant systems during seasonal susceptibilities.
Documents reviewed for each section of this report are listed in the Attachment. b.FindingsNo findings of significance were identified.
2Enclosure1R02Evaluations of Changes, Tests, or Experiments (71111.02 - 25 samples) a.Inspection ScopeThe inspectors reviewed eight safety evaluations (SEs) completed since the previousperformance of this inspection. The SEs reviewed were in the Initiating Events,
Mitigating Systems, and Barrier Integrity cornerstones. The selected SEs were
reviewed to verify that changes to the facility or procedures as described in the Updated
Final Safety Analysis Report (UFSAR) were reviewed and documented in accordance
with 10 CFR 50.59, and that the safety issues pertinent to the changes were properly
resolved or adequately addressed. The reviews also included the verification that the
licensee had appropriately concluded that the changes could be accomplished without
obtaining license amendments. The inspectors also reviewed 17 screened-out evaluations for changes, tests andexperiments for which Constellation determined that SEs were not required. This review
was performed to verify that the site's threshold for performing SEs was consistent with
CFR 50.59. b.FindingsNo findings of significance were identified.1R04Equipment Alignment .1Partial System Alignment (71111.04Q - Four Samples) a.Inspection ScopeThe inspectors verified that selected equipment trains of safety-related and risksignificant systems were properly aligned. The inspectors reviewed plant documents to
determine the correct system and power alignments, as well as the required positions of
critical valves and breakers. The inspectors verified that the licensee had properly
identified and resolved equipment alignment problems that could cause initiating events
or potentially impact the availability of associated mitigating systems. The inspectors
performed a partial walkdown of the following activities:*500 kV system during breaker No. 21 replacement in the electrical switchyardarea;*Unit 2 emergency core cooling system (ECCS) pump room exhaust filtrationsystem during No. 21 and No. 22 exhaust fans filter replacement;*Unit 1 auxiliary feedwater (AFW) system during testing on the Nos. 11 and 13steam and motor driven
EDG) system due to a crack retaining nut for the EDGradiator breaker.
3Enclosureb.FindingsNo findings of significance were identified..2Complete System Alignment (71111.04S - One Sample) a.Inspection ScopeThe inspectors performed a complete system walkdown of accessible portions of thelow pressure safety injection (LPSI) system to identify any discrepancies between the
existing equipment lineup and the specified lineup. During the walkdown, system
drawings and operating instructions were used to verify proper equipment alignment and
operational status. The inspectors reviewed open maintenance orders on the system
for any deficiencies that could affect the ability of the system to perform its safety
function. 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. Additionally, the inspectors reviewed the
condition report (CR) database to verify that equipment alignment problems were being
identified and appropriately resolved. b.FindingsIntroduction. The inspectors identified a very low safety significance (Green)
TS3.6.3, Containment Isolation Valves, because Constellation did not implement TS 3.6.3
required actions. Specifically, Constellation did not include all containment isolationvalves (CIVs) within the scope of TS requirements, which led to inadequate actions
being taken for these valves when they became inoperable. Description. On February 25, 2007, a
SI-615) failed its in-servicesurveillance test in the open stroke direction. Following the failure, operators left the
valve open to satisfy one of its safety-related functions to provide core cooling upon
receipt of a safety injection actuation signal (SIAS). This valve is a dual function valve
that accommodates emergency core cooling flow and provides containment isolation.
When operators left the valve opened, Constellation performed a reasonable
expectation of continued operability (RECO). The inspectors reviewed the
- RE [[]]
CO and
discovered that Constellation did not consider or enter TS Limiting Condition of
Operation (LCO) 3.6.3 for the containment isolation function of the valve. The action in
- TS [[]]
LCO 3.6.3 is to verify containment integrity within four hours for a penetration flow
path with one containment isolation valve inoperable and not in a closed system. With
the valve left in the open position, Constellation did not verify containment integrity
within four hours, had no administrative controls in place, or evaluated the
consequences for its containment isolation function. The inspectors reviewed the
- UFS [[]]
- SI -615 but included an additional 70 containment isolation valves. The inspectors noted that Figure 5.10 of the
- CCNPP [[]]
- CCNPP [[]]
TS 3.6.3. However, Figure 5.10 contained the other list
that included the total population of CIVs in addition to those identified in Table 5.3. The
inspectors determined that for valves listed in Figure 5.10, Constellation did not consider
or enter TS 3.6.3, as appropriate, or evaluate degraded or nonconforming conditions for
the total population of
CAP as IRE-021-
913. The planned corrective actions included a review of potential reportable conditions
and a standing order for operation personnel to enter
CIVs as
appropriate.The performance deficiency is that Constellation did not implement
CIVs were not
included in the scope of TS requirements. Analysis. This finding is greater than minor because it is associated with theconfiguration control attribute of the Barrier Integrity cornerstone and affected the
cornerstone objective to provide reasonable assurance that physical design barriers
such as containment protects the public from radio nuclide releases caused by
accidents or events. Specifically, Constellation did not include all
TS actions taken for CIVs when they became
inoperable. The inspectors evaluated the significance of this finding using SDP Phase 1
of Inspection Manual Chapter (IMC) 0609. The finding required further senior risk
analyst (SRA) evaluation through IMC 0609, Appendix H, because some of the
inoperable valves identified in the reportability review involved an actual reduction in the
defense-in-depth for the atmospheric pressure control of the reactor containment. The
most limiting case involved an inoperable main feedwater isolation valve (MFIV)
because it affected the likelihood of accidents leading to core damage. The dominant
core damage sequence with an initiating event of a main steam line break resulted not
to contribute to the large early release frequency (LERF). Based on the results of the
Phase 2 analysis, this finding was determined to have very low safety significance
(Green). The finding has a cross-cutting aspect in the area of problem identification and
resolution because Constellation did not identify and take actions to address safety
issues in a timely manner, commensurate with their significance (P.1.a).Enforcement.
CIVshall be operable in modes 1, 2, 3, and 4. Contrary to the above, for a 14-year period,
Constellation did not implement required actions of TS 3.6.3 when valves were
inoperable because the total population of CIVs were not included within the scope of
TS requirements. For example, on February 25, 2007, Constellation did not take the
required
LPSI valve. Because this issue is of very low
safety significance (Green) and is entered into Constellation's
IRE-021-913), this
violation is being treated as a
NCV 05000317; 05000318/2007003-01: Failure to ImplementTS 3.6.3 Required Actions for Containment Isolation Valves)
5Enclosure1R05Fire Protection (71111.05Q - 11 Samples) a.Inspection Scope The inspectors conducted a tour of accessible portions of the eleven areas listed below
to assess Constellation's control of transient combustible material and ignition sources,
fire detection and suppression capabilities, fire barriers, and related compensatory
measures when required. The inspectors assessed the material condition of fire
protection suppression and detection equipment to determine whether any conditions or
deficiencies existed which could impair the availability of that equipment. The eleven
areas inspected are as follows:*1A
EDG1A, room 2;*1B EDG room, fire area 30, room 421;
- 0C
EDG0C, room SB202;
- Unit 2 AFW pump room, fire area 43, room 605;
- Unit 1 27' Switchgear room, fire area 19, room 317;
- Unit 2 27' Switchgear room, fire area 18, room 311;
- Unit 1 45' Switchgear room, fire area 34, room 430;
- Unit 2 45' Switchgear room, fire area 25, room 407;
- Unit 1 Battery rooms, fire area 16A, rooms 310 and 304;
- Unit 2 Battery rooms, fire area 17A, rooms 305 and 307; and
- Control room complex, fire area 24, room 405 b.FindingsDuring a fire protection walkdown of the Unit 1 and Unit 2 4kV switchgear rooms, onMay 14, 2007, the inspectors identified a potentially degraded fire barrier between two
fire areas. The inspectors noted that the fire barrier penetration was missing a retaining
angle around the perimeter of a ventilation duct such that there was an open pathway
between the two switchgear rooms. The inspectors also noted that the ventilation duct
installation was not consistent with the inspection criteria in the penetration surveillance
test procedure, STP-F-592, Penetration Fire Barrier Inspection. The inspectors
provided this information to Constellation personnel. On June 6, 2007, Constellation
determined that the fire barriers between the 27' and 45' 4kV switchgear rooms for both
Unit 1 and Unit 2 were inoperable. Constellation entered a Technical Requirement
Manual (TRM) action statement and established hourly fire watches for the inoperable
barriers. Constellation also conducted a functional assessment and established
compensatory action to control transient combustibles and hotwork in the affected fire
areas. Additionally, an extent of condition review discovered that there were additional
degraded fire barriers due to the improperly installed fire dampers, which were located
in different fire areas. The inspectors identified a noncompliance to the Calvert Cliffs Renewed FacilityOperating License Numbers
DPR-54, License Condition 2.E, because the
site's fire dampers were not installed in accordance with vendor instructions as required
by the National Fire Protection Association (NFPA) Standard 90A, Air Conditioning and
6EnclosureVentilating Systems. Specifically, License Condition 2.E, requires, in part, thatConstellation is required to implement and maintain in effect all provisions of the
approved fire protection program as described in the
- UFS [[]]
AR for the facility. Section
9.8.3 of the
- UFS [[]]
AR states, in part, that the work, equipment, and materials conform to
the requirements and recommendations of the
NFPA 90A
states that ventilation containing fire dampers shall be installed in accordance with the
vendor's instructions. Contrary to the above, Constellation did not install fire dampers in
accordance with vendor instructions.The inspectors determined that the above noncompliance of License Condition
NRC Enforcement Policy. The NRC
Enforcement Policy, Interim Enforcement Policies, "Interim Enforcement Policy
Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48),"
states, in part, that enforcement discretion may be exercised if a noncompliance is
identified during the transition period to
- NF [[]]
PA 805 and it is not associated with a finding
of high safety significance (Red). Specifically, although the NRC identified the concern,
it is likely that Constellation would have identified and corrected this issue as part of their
transition to
CAP, implemented
appropriate compensatory measures, determined the violation was not of high safety
significance, and would not likely have identified the issue by routine licensee efforts.
The
NRC will not take any
enforcement actions for this noncompliance because the conditions for this
noncompliance meet the enforcement discretion criteria specified in the NRC
Enforcement Policy.1R06Flood Protection (71111.06 - Two Samples)Internal Flooding a.Inspection ScopeThe inspectors reviewed flood protection measures associated with internal floodevents. These events were described in the Calvert Cliffs' Engineering Standard
(ES)-001, the Individual Plant Examination (IPE), and the
- UFS [[]]
AR. The inspectors
performed a walkdown of the following two areas that contain risk significant systems
and components: Unit 1 27' Switchgear Room, Room 317 and Unit 1 AFW Pump
Room, Room 605. The inspectors observed the condition of watertight doors, drain
systems, penetrations in floors and walls, and safety-related instrumentation located in
these areas. b. FindingsNo findings of significance were identified.
7Enclosure1R07Heat Sink (7111107A - One Sample) a.Inspection ScopeThe inspectors observed the 22B service water heat exchanger during a routinecleaning and inspection. The inspectors reviewed the performance data and evaluated
the test acceptance criteria from a previous completed test to ensure that design basis
requirements were satisfied. The inspectors also evaluated existing heat transfer
capabilities based on completed flow verification test results to ensure that specific
safety functions could be performed in accordance with design specifications. The
inspectors also reviewed Calvert Cliffs' periodic maintenance methods to verify that they
conformed to the guidelines delineated in Electric Power Research Institute (EPRI)
Report NP-7552, "Heat Exchanger Performance Monitoring Guidelines." b.FindingsNo findings of significance were identified. 1R11Licensed Operator Requalification Program (71111.11Q - One Sample) a.Inspection ScopeOn May 15, 2007, the inspectors observed a licensed operator requalification trainingscenario to assess operator performance and the adequacy of the licensed operator
training program. The training scenario involved component failures such as a
degraded heater drain tank and a dropped control element assembly (CEA) requiring
operators to implement abnormal operating procedures (AOP) -3G and 1B, respectively.
Upon recovery of the dropped CEA, a partial loop occurred resulting in a reactor trip and
two CEAs failed to insert. The inspectors focused on high-risk operator actions
performed during implementation of emergency operating procedures (EOP), AOP, and
classification of the event. The inspectors evaluated the clarity and formality of
communications, the completion of appropriate actions in response to alarms, the
performance of timely control board operations and manipulations, and the oversight
and direction provided by the shift manager. b.FindingsNo findings of significance were identified.
8Enclosure1R12Maintenance Effectiveness .1Quarterly Review (71111.12Q -Two Samples) a.Inspection ScopeThe inspectors reviewed the two samples listed below for items such as: 1) appropriatework practices; 2) identifying and addressing common cause failures; 3) scoping in
accordance with
MR); 4) characterizing
reliability issues for performance; 5) trending key parameters for condition monitoring; 6)
charging unavailability for performance; 7) classification and reclassification in
accordance with 10 CFR 50.65(a)(1) or (a)(2); and 8) appropriateness of performance
criteria for structure, systems, and components (SSCs) classified as (a)(2) and/or
appropriateness and adequacy of goals and corrective actions for SSCs classified as
(a)(1).*No.
NCV of 10CFR 50.65(a)(2) because Constellation did not demonstrate that performance
monitoring of the
- MS [[]]
SVs was being effectively controlled through the performance of
appropriate preventive maintenance. Constellation experienced repetitive and
numerous issues associated with
TSs. However,
Constellation did not recognize the unsatisfactory performance monitoring of this system
in accordance with the
MSSVs on Unit 1 experienced as-found valve liftsettings that exceeded TS limits for valve lift setting. In February 2005, Unit 2
experienced three as-found
TS limits. In
February 2006, Constellation performed the same TS surveillance test as in 2004 and
2005 on the Unit
- 1 MS [[]]
SVs. The as-found setpoints for five of the sixteen valves
exceeded specified TS limits for the individual valve lift setting. These high valve lift
settings were determined to be from improper as-left valve setting. However, the lift
settings did not exceed Constellation's established maintenance rule (MR) performance
criteria for the
- MS [[]]
SVs. The inspectors questioned the technical justification of the
established performance criteria based on industry operating experience and overall
system performance. This issue was tracked as an unresolved item (URI) that needed
additional information. Constellation initiated IRE-019-372 to evaluate the technical
basis for the
- MS [[]]
SVs (a)(2) performance criteria.
9EnclosureConstellation concluded that the
MSSVs should be setbased on the TS limits such that the valves could be effectively controlled and monitored
through appropriate preventive maintenance. As a result, the
- MS [[]]
SVs for Unit 1
exceeded the performance criteria threshold based on the February 2006 TS
surveillance test, with more than three maintenance rule functional failures (MRFF).
The inspectors determined that Constellation had an opportunity to recognize that the
failure of five of the sixteen
- MS [[]]
SVs constituted an unacceptable equipment performance
requiring action in accordance with the maintenance rule. However, Constellation did
not establish goals or monitor the performance of the
CFR 50.65(a)(1) or
justify remaining in (a)(2) at that time. Additionally, in November of 2006, Constellation
conducted an assessment of the
- MS [[]]
SVs performance criteria threshold as a part of
their (a)(3) periodic assessment and concluded that the performance criteria threshold
for the
- MS [[]]
SVs was set at an appropriate level. The inspectors noted that this was
another missed opportunity for Constellation to have identified that the
- MS [[]]
SV warranted
(a)(1) status for five of the sixteen
TS
limits. The inspectors noted that additional opportunities existed to identify the
inadequate performance criteria during
- MS [[]]
SVs high lifts in 2004 and 2005 on both Unit
and Unit 2. On June 11, 2007, Constellation completed an evaluation of the
CFR50.65(a)(1) status and determined that (a)(1) status was not warranted because the
corrective actions for the high lifts had been completed for the
- MR [[]]
FFs that occurred in
February of 2006. Constellation determined the most likely cause was due to as-left
valve setting process error with contributing causes being setpoint drift, disc to seat
oxide bonding, and micro galling. The corrective actions included an adjustment of the
valves, lifting the Unit 2 valves mid-cycle and a change in testing methodology and
vendor. Based on completion of these corrective actions the inspectors determined that
(a)(1) status is not warranted at this time. The performance deficiency is that Constellation did not demonstrate effective control ofthe performance or condition of the
CFR 50.65 (a)(2). Analysis. The finding is greater than minor because it is associated with the equipmentperformance 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
evaluated the significance of this finding using
The inspectors determined that the finding was of very low safety significance (Green)
because the finding is not a design or qualification deficiency, does not represent a loss
of a system safety function or safety function of a single train, and does not screen as
potentially risk significant due to external events. The inspectors also determined that
this finding has a cross-cutting aspect in the area of problem identification and
resolution because Constellation did not trend and assess information from the CAP and
other assessments to identify programmatic and common cause problems with the
- MS [[]]
10EnclosureEnforcement. Paragraph (a)(1) of 10 CFR 50.65, requires, in part, that the holders of anoperating license shall monitor the performance or condition of structures, systems, or
components (SSC)s within the scope of the rule as defined by 10 CFR 50.65 (b),
against licensee-established goals, in a manner sufficient to provide reasonable
assurance that
CFR 50.65(a)(1) is not
required where it has been demonstrated that the performance or condition of an SSC is
being effectively controlled through the performance of appropriate preventive
maintenance, such that the
- SSC remains capable of performing its intended function.Contrary to the above, Constellation did not demonstrate that the performance orcondition of the
MSSVs had been effectively controlled through the performance of
appropriate preventive maintenance and did not monitor against licensee-established
goals. Specifically, repetitive problems associated with the
- MS [[]]
SVs from March 2004 to
February 2006 demonstrated that
- MS [[]]
SV performance was not being effectively
controlled per 10 CFR 50.65 (a)(2). Because this issue is of very low safety significance
(Green) and is entered into Constellation's
IRE-021-
038), this violation is being treated as a
CFR 50.65
(a)(2))1R13Maintenance Risk Assessments and Emergent Work Control (71111.13 - SevenSamples) a.Inspection ScopeThe inspectors reviewed the following seven activities to verify that station personnelperformed the appropriate risk assessments prior to removing equipment for work.
When emergent work was performed, the inspectors verified that the plant risk was
promptly reassessed and managed. The inspectors compared the risk assessments
and risk management actions performed by station procedure NO-1-117, "Integrated
Risk Management," to the requirements of
- NUMA [[]]
RC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at
Nuclear Power Plants," Revision 3, and approved station procedures. In addition, the
inspectors assessed the adequacy of Constellation's identification and resolution of
problems associated with maintenance risk assessments and emergent work activities.*500kV breaker No. 21 replacement in the electrical switchyard area*13kV No.12 bus and cubicle inspection
- 1Y0926 breaker disconnect due to planned maintenance on the radiationmonitors stack*No. 21 4kV transfer to alternate feed due to planned maintenance on theU-4000-12 transformer *Unit 2 voltage regulator transfer of No. 26 4kV bus due to planned maintenanceto support a swap out and inspection on the 152-2506 breaker*Safety injection tank leak-off header relief valves due to missed surveillances
- No. 22 AFW steam driven pump due to planned maintenance on the outboard oillevel
11Enclosure b.FindingsNo findings of significance were identified.1R15Operability Evaluations (71111.15 - Seven Samples) a.Inspection ScopeFor the seven operability evaluations described below, the inspectors evaluated thetechnical adequacy of the evaluations to ensure that Constellation properly justified TS
operability and that the subject component or system remained available such that no
unrecognized increase in risk occurred. The inspectors reviewed the
- UFS [[]]
AR to verify
that the system or component remained available to perform its intended function. In
addition, the inspectors reviewed compensatory measures implemented to verify that
the measures worked as stated and that they were adequately controlled. The
inspectors also reviewed a sample of CRs to verify that Constellation identified and
corrected any deficiencies associated with operability evaluations. *Unit
RTDs (IRE-021-790)*Unit 1 core bypass flow greater than 3.7 percent (IRE-021-445)
- 1A
IRE-022-288)
- 1A
IRE-022-258)*Fairbanks morse diesel engine cam roller bushing material (IRE-022-177)
- No.
IRE-021-806)
- Unit 1 and Unit 2 degraded fire dampers (IRE-023-352) b.FindingsNo findings of significance were identified.1R17Permanent Plant Modifications (71111.17 - Ten Samples) a.Inspection Scope The inspectors reviewed ten plant modification packages selected from the designchanges that were completed since the previous inspection. The review was performed
to verify that the design bases, licensing bases, and performance capability of risk
significant SSCs had not been degraded through the modifications.For the accessible components associated with the modifications, the inspectors walkeddown the systems to detect possible abnormal installation conditions. The inspectors
reviewed the design inputs, assumptions, and design calculations to determine the
design adequacy. For the replacement components, the inspectors verified material
compatibility and seismic qualification. In addition, the inspectors reviewed the post-
modification testing to determine readiness for operations. The 10 CFR 50.59 screens
and evaluations for the modifications were reviewed to verify that the plant changes
were reviewed and documented in accordance with 10 CFR 50.59. Finally, the
inspectors reviewed the affected procedures, drawings, design basis documents, and
- UFS [[]]
AR sections to verify that the affected documents were appropriately updated.
2Enclosure b.FindingsNo findings of significance were identified.
1R19Post Maintenance Testing (71111.19 - Seven Samples) a.Inspection ScopeThe inspectors reviewed the seven post maintenance tests listed below to verify thatprocedures and test activities ensured system operability and functional capability. The
inspectors reviewed the test procedure to verify that the procedure adequately tested
the safety functions that may have been affected by the maintenance activity, that the
acceptance criteria in the procedure were consistent with information in the applicable
licensing basis and/or design basis documents, and that the procedure had been
properly reviewed and approved. The inspectors also witnessed the test or reviewed
test data, to verify that the test results adequately demonstrated restoration of the
affected safety functions. *500 kV breaker due to breaker No. 21 replacement in the electrical switchyard(MO #02000400089)*No. 11 control element drive mechanism (CEDM) motor generator set (MO#1200605510)*No. 22 main steam isolation valve nitrogen pressure switch (MO #2200702585)
- No.
MO #1200605540)
- No.
MO #2200702384)
- 1A
- MO #1200702829)*No. 12 control room supply fan due to loose fan belts (MO#1200702450) b.FindingsNo findings of significance were identified. 1R22Surveillance Testing (71111.22 - Five Samples) a.Inspection ScopeThe inspectors observed and/or reviewed the five surveillance tests listed belowassociated with selected risk-significant
TS compliance and that test
acceptance criteria were properly specified. The inspectors also verified that proper test
conditions were established as specified in the procedures, no equipment
preconditioning activities occurred, and that acceptance criteria had been satisfied. *STP-M-515A-2,
STP-O-27-2, Reactor coolant system (RCS) leakage evaluation (RCS leakage)
13Enclosure*STP-O-73B-1 Service water pump quarterly test (IST)*STP-O-220G-1, Nos. 11 & 14 4kV undervoltage relay functional test b.FindingsNo findings of significance were identified.1R23Temporary Plant Modifications (71111.23 - One Sample) a. Inspection Scope The inspectors reviewed one temporary modification, Unit 2 removed temperatureelement (2-TE-112HC) input to reactor protection system (RPS) channel
C(TA-2-07-0011), to verify that the safety system did not depart from the design basis
and system established criteria. The inspectors reviewed the associated 10 CFR 50.59
screening against the system design bases documentation, including the
- UFS [[]]
AR and
TS. The inspectors walked down the modification to verify that proper configuration
control was maintained to ensure continued system operability. In addition, the
inspectors verified that Constellation controlled the modification in accordance with the
requirements of procedure
- MD -1-100, Temporary Alterations. b.FindingsNo findings of significance were identified.Cornerstone: Emergency Preparedness (
EP)1EP6Drill Evaluation (71114.06 - Two Samples) a.Inspection Scope The inspectors observed an EP exercise on May 30, 2007. The inspectors observed theemergency response organization performance at the technical support center. The
inspectors verified that the classification, notification, and protective action
recommendations were accurate and timely. Additionally, the inspectors assessed the
ability of Constellation's evaluators to adequately address operator performance
deficiencies identified during the exercise. The inspectors observed a control room simulator training exercise conducted onMay 15, 2007, to assess licensed operators performance in the area of EP. This
training exercise focused on equipment failures and operator challenges that would
typically exist during a partial loss of offsite power and stuck opened pressurizer safety
valve. The required procedural transitions and associated event classifications were
observed and evaluated by the inspectors.
14Enclosure b.FindingsNo findings of significance were identified.2.RADIATION
PS1Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (7112201- 11 Samples) a.Inspection ScopeThe inspectors reviewed the most current Radiological Effluent Release Report to verifythat the program was implemented as described in Radiological Effluent TechnicalSpecification/Offsite Dose Calculation Manual (RETS/ODCM); reviewed the report for
significant changes to the
- OD [[]]
CM and to radioactive waste system design and operation;
determined whether the changes to the
- OD [[]]
CM were made in accordance with
- NUR [[]]
EG-0133 and were technically justified and
documented; determined whether the modifications made to radioactive waste system
design and operation changed the dose consequence to the public; verified that
technical and/or 10 CFR 50.59 reviews were performed when required; and, determined
whether radioactive liquid and gaseous effluent radiation monitor setpoint calculation
methodology changed since completion of the modifications. The inspectors assessed
whether anomalous results reported in the current Radiological Effluent Release Report
were adequately resolved. The inspectors reviewed
ODCM to identify the effluent
radiation monitoring systems (RMS) and its flow measurement devices; reviewed
effluent radiological occurrence performance indicator incidents for onsite follow-up;
reviewed licensee self-assessments, audits, and licensee event reports that involved
unanticipated offsite releases of radioactive material; and, reviewed the
- UFS [[]]
to identify the programs for identifying potential contaminated spills and leakage and the
process for control and assessment.The inspectors walked down the major components of the gaseous and liquid releasesystems (e.g., radiation and flow monitors, demineralizers and filters, tanks, and
vessels) to observe current system configuration with respect to the description in the
- UFS [[]]
AR, ongoing activities, and equipment material condition.The inspectors reviewed several radioactive liquid and gaseous waste release permits,including the projected doses to members of the public. The inspectors reviewed the
records of any abnormal releases or releases made with inoperable effluent radiation
monitors and reviewed the station's actions for these releases to ensure an adequate
defense-in-depth was maintained against an unmonitored, unanticipated release of
radioactive material to the environment. For unmonitored releases, the inspectors
reviewed the evaluations of the type and amount of radioactive material that was
released and the associated projected doses to members of the public. Additionally, for
any areas where spills, leaks, or other unusual occurrences have occurred, the
15Enclosureinspectors verified that these areas have been properly documented in the site'sdecommissioning file, as required.The inspectors assessed the station's understanding of the location and construction ofunderground pipes and tanks, and storage pools that contain radioactive contaminated
liquids. The inspectors evaluated if Constellation may have potential unmonitored
leakage of contaminated fluids to the groundwater as a result of degrading material
conditions or aging of facilities. The inspectors appraised the site's capabilities of
detecting spills or leaks and of identifying groundwater radiological contamination both
on-site and beyond the owner controlled area. The inspectors reviewed the site's
technical bases for its onsite groundwater monitoring program. The inspectors
discussed with station personnel their understanding of groundwater flow patterns for
the site, and in the event of a spill or leak of radioactive material, verified that the staff
can estimate the pathway of a plume of contaminated fluid both on site and beyond the
owner controlled area. The inspectors discussed with Constellation representatives
regarding the actions taken to identify, analyze and mitigate the plume of tritium which
developed just northwest of the Unit 1 turbine building. Constellation assessment
determined that this plume most likely occurred in 2000 following the opening of a sink
hole in the area.The inspectors reviewed changes made by Constellation to the
- OD [[]]
CM as well as to theliquid or gaseous radioactive waste system design, procedures, or operation since the
last inspection. For each system modification and each
- OD [[]]
CM revision that impacted
effluent monitoring or release controls, the inspectors reviewed the technical justification
to determine whether the changes affect the station's ability to maintain effluents as low
as reasonably achievable (ALARA) and whether changes made to monitoring
instrumentation resulted in a non-representative monitoring of effluents.The inspectors reviewed a selection of monthly, quarterly, and annual dose calculationsto ensure that the licensee had properly calculated the offsite dose from radiological
effluent releases and to determine if any annual
PI)
report if any quarterly values were exceeded.The inspectors reviewed air cleaning system surveillance test results and site-specificmethodology to ensure that the system is operating within the acceptance criteria. The
inspectors also reviewed surveillance test results and methodology the station uses to
determine the stack and vent flow rates and verified that the flow rates are consistent
with
RMS instrument calibrations performed since thelast inspection for each point of discharge effluent radiation monitor and flow
measurement device. The inspectors reviewed any completed system modifications
and the current effluent radiation monitor alarm setpoint value for agreement with
ODCM requirements. The inspectors also reviewed calibration records of
radiation measurement (i.e., counting room) instrumentation associated with effluent
monitoring and release activities and reviewed quality control records for the radiation
measurement instruments.
16EnclosureThe inspectors reviewed the results of the interlaboratory comparison program to verifythe quality of radioactive effluent sample analyses performed by the licensee; reviewed
the licensee's quality control evaluation of the interlaboratory comparison test and
associated corrective actions for any deficiencies identified; and reviewed the results
from the licensee's Quality Assurance (QA) audits and determined that the licensee met
the requirements of the
- ODCM.T he inspectors reviewed the licensee's even reports (LERs), Special Reports, audits,and self-assessments related to the
ODCM program performed since the last
inspection. The inspectors determined that identified problems were entered into the
corrective action program for resolution. The inspector also reviewed problem
notifications affecting
- 4.OTHER [[]]
ACTIVITIES (OA)Cornerstones: Initiating Events, Mitigating Systems and Barrier Integrity4OA1Performance Indicator (PI) Verification (71151 - Two Samples)Barrier Integrity Cornerstone a.Inspection ScopeThe inspectors reviewed data and plant records from March 2006 to March 2007. Therecords included a review of performance indicator (PI) data summary reports, licensee
event reports, operator narrative logs, and daily measurements of RCS identified
leakage. The inspectors used the guidance provided in NEI 99-02, "Regulatory
Assessment Performance Indicator Guideline," Revision 4, to assess the accuracy of PI
data collected and reported. The inspectors also conducted interviews with the RCS
system engineer and chemistry technicians that are responsible for data collection and
evaluation of
RCS Identified Leak Rate. b.FindingsNo findings of significance were identified.
17Enclosure4OA2Identification and Resolution of Problems (71152 - Three Samples).1Review of Items Entered Into the Corrective Action Program (CAP)The inspectors performed a daily screening of items entered into Constellation's
IP) 71152, "Identification and Resolution of Problems."
The review facilitated the identification of potentially repetitive equipment failures or
specific human performance issues for follow-up inspection. This was accomplished by
reviewing the description of each new condition report and attending screening
meetings..2Semi-Annual Trend Review a. Inspection ScopeThe inspectors performed a semiannual review to identify trends that might indicate theexistence of a more significant safety issue. The inspectors reviewed
- CCN [[]]
PP Units 1
and 2 performance indicator monthly reports, CRs, system health reports, quality
assurance audits, self-assessment reports, maintenance reports, and
- NRC [[]]
IRs and
interviewed key personnel to evaluate if a trend existed. b. Findings and ObservationsNo findings of significance were identified.
The inspectors documented a trend related to problems Constellation has encounteredin maintaining configuration control during tagging related activities in
IR) 2006005. As a result, Constellation instituted several corrective actions
concerning this issue such as challenge boards for complex tagouts, a more rigorous
scope deletion process for scheduling work, and a review of engineering standards used
for tagouts. The inspectors noted that Constellation had a decline in tagging related
issues during this inspection period. .3Annual Sample: Review of Core Exit Thermocouple (CET) Issues a.Inspection ScopeThe inspectors selected
- CR [[]]
- IRE -014-572 as a problem identification and resolution(PI&R) sample for a detailed follow-up review. The
temperature readings dropped approximately 25 degrees Fahrenheit from the previous
fuel cycle following the May 2006, Unit 1 RFO. This phenomenon occurred following the
replacement of the in-core instrumentation (ICI) thimbles and thimble support plates
(TSP) during the reactor vessel head replacement project. The inspectors assessed Constellation's problem identification threshold, causeanalyses, extent of condition reviews, operability determinations, and the prioritization
and timeliness of corrective actions to determine whether Constellation was
appropriately identifying, characterizing, and correcting problems associated with this
issue and whether the planned or completed corrective actions were appropriate.
18Enclosure b.Findings and ObservationsNo findings of significance were identified.During the May
ICI thimbles with a different design. The ICI thimbles design changed from a double
walled tube-in-tube to a single walled "fluted" configuration. After Unit 1 reached 100%
rated thermal power following the
CET temperatures indicated about
degrees Fahrenheit colder than the previous fuel cycle. Constellation initiated a CR
to evaluate this phenomenon and performed an operability review to determine a
reasonable expectation for continued operability (RECO). This phenomenon was also
noted for Unit 2 following the March
ICI thimbles and TSP were
replaced as part of the reactor vessel head replacement project. Constellation engaged
their engineering organization and the CET vendor regarding operability of the system,
engaged other sites that have performed a similar modification, and issued operating
experience to industry regarding their issue. Constellation and Westinghouse believed
the cause of the lower CET temperature readings as experienced in the industry, is due
to the design changes of the replacement ICI thimbles, which altered the reactor coolant
bypass flow seen by the CETs.Implemented or proposed corrective actions included the following: (1) performing anoperability determination review; (2) developing new operability acceptance criteria for
the
STP O-63-1, Remote Shutdown and Post Accident
Monitoring Instrument Channel Check; (3) monitoring and evaluating operability of Unit
and Unit
RECO included, monitoring Unit 2
CET indications for the bypass flow as observed in Unit 1, evaluating the sub-cooled
monitoring alarm function for both units, evaluating the channel check criteria applied in
performance and ensuring operators were trained that CETs may indicate values less
than actual core exit conditions with reactor coolant pumps (RCPs) operating.The inspectors determined that Constellation properly implemented their correctiveaction process regarding this issue. The
- RE [[]]
CO was detailed, thorough and provided
reasonable justification for continued operation. Corrective actions and
recommendations appeared appropriate to understand the new operating scheme for
the post accident monitoring system. Constellation continued to implement scheduled
corrective actions at the time of this inspection. The inspectors noted that during the
review of recent completed surveillance procedures, the CET readings for both units
were within the acceptance criteria of their surveillance requirements..4Annual Sample: Unit 2 - Followup to the Pressurizer Power Operated Relief Valve(PORV) Failure to Close a.Inspection ScopeThe inspectors reviewed Constellation's actions in response to a
- PO [[]]
RV failure to closefollowing a Unit 2 automatic reactor trip. On November 16, 2006, Unit 2 automatically
tripped due to a pressurizer pressure high signal during the performance of a clearance
19Enclosureorder to support scheduled maintenance. As a result of the trip,
- PO [[]]
RV remained open for
longer than expected resulting in a valid safety actuation signal. The inspectors
reviewed Constellation's root cause evaluation of the reactor trip, the apparent cause
evaluation for the
- PO [[]]
RV remaining open, and supporting records. In addition, the
inspectors interviewed applicable system engineers. b.FindingsIntroduction. A self-revealing of very low safety significance (Green)
CFRPart 50, Appendix B, Criterion XVI, "Corrective Action," occurred because Constellation
did not implement adequate corrective actions for a significant condition adverse to
quality associated with the slow closure of a pressurizer power operated relief valve
(PORV) due to a main disc guide being out of round. Specifically, Constellation did not
perform an extent of condition review from a February 2006 event such that corrective
actions would preclude recurrence of the issue. Description. On November 16, 2006, Unit 2 automatically tripped due to a highpressurizer pressure signal during the performance of a clearance order to support
scheduled maintenance. As a result of the trip, RCS pressure increased causing the
two
ERV402) remained open for approximately 90 seconds, which is longer than
expected and resulted in a safety injection actuation signal. Constellation sent
- PO [[]]
- RV [[]]
ERV402 was not possible due
to its condition, however, visual inspection results revealed that the main disc guide was
out of round. Wyle Labs determined that the tolerances between the main disc guide
and the cage had decreased sufficiently to prevent the main disc guide from moving
freely within the guide bushing. Constellation determined that this is the most likely
reason why the
- PORV did not close at the expected pressure.The inspectors noted that a similar event occurred in February 2006. On February 21, 2006, a Unit 1
PORV (1ERV402) remained open for approximately 20 seconds
following completion of the
STP-M-673-1).
Constellation sent the valve to Wyle labs where the main disc guide was found out of
round. Constellation generated a Category
- III [[]]
CR (IRE-011-711) to address the failureof 1ERV402 to immediately close. However, Constellation's procedures do not require
an extent of condition review to resolve a Category
- III [[]]
- II [[]]
CR would have
required an apparent cause evaluation and an extent of condition review. The
inspectors concluded that the adverse condition was not appropriately categorized
commensurate with its safety significance. QL-2-100, Corrective Action Program,
4, Condition Report Categorization Criteria, states that CRs involving
maintenance rule (MR) functional failures shall be categorized as Category
PORV failure to close following the February
2006 surveillance test as a
MR scoping
documents. This missed MR functional failure evaluation was identified by Constellation
months later and was documented in
- CR [[]]
IRE 022-285. In addition, QL-2-100,
4, states that any corrective maintenance on a critical component typically
warrants a Category
- II [[]]
- PO [[]]
RV, which is classified by Constellation as a critical
component, required corrective maintenance to replace the main disc guide prior to
20Enclosurerestoring the valve to service. The performance deficiency is that Constellation did not take corrective actions topreclude recurrence following the identification of a significant condition adverse to
quality (main disc guide being out of round on a Unit
- 1 PO [[]]
RV). Analysis. This finding is greater than minor because it is associated with the equipmentperformance attribute of the Initiating Events cornerstone and affects the cornerstone
objective to limit the likelihood of those events that challenge critical safety functions.
Specifically, an inadequate extent of condition review led to a similar event when the
screening using IMC 0609, Appendix A, and determined that a Phase 2 analysis was
required because in the worst case if 2ERV402 failed to close following a pressure
transient, the resulting loss of primary coolant would exceed the
SDP analysis was conducted by the SRA using the Risk
Informed Inspection Notebook for Calvert Cliffs Nuclear Plant Units 1 and 2, Revision
2.01. The SRA made the following assumptions to support the Phase 2 risk
assessment: 1) the observed
- PO [[]]
RV degraded condition adversely impacted the valve
closure safety function only; 2) consistent with the SDP usage rules, this degraded valve
condition is most appropriately modeled by increasing the stuck open
SORV)
initiating event frequency by one order of magnitude; 3) based upon the degraded valve
closure condition, only the
- SO [[]]
RV worksheet (Table 3.4) was solved; and 4) the
exposure time for this condition was >30 days. The dominant core damage sequences
for the
- SO [[]]
RV were the failure to close the block valve with subsequent failure of high
pressure injection or success of high pressure injection, with a failure of high pressure
recirculation. The Phase 2 analysis determined the issue was of very low safety
significance (Green) and estimated an increase in core damage frequency in the range
of 1 in 16,000,000 years (mid E-8/year). This finding has a cross-cutting aspect in the
area of problem identification and resolution, because Constellation did not thoroughly
evaluate an equipment malfunction such that the extent of condition was considered and
the cause resolved (P.1.c).Enforcement.
XVI, "Corrective Action" states, inpart, that for significant conditions adverse to quality, measures shall be taken to assure
that the cause of the condition is determined and corrective action taken to preclude
repetition. Contrary to the above, following the identification of a main disc guide out of
round being a significant condition adverse to quality for the Unit
- 1 PO [[]]
RV on February
21, 2006, Constellation did not take corrective actions to preclude recurrence. This led
to a stuck open
- PO [[]]
RV due to the same condition during a Unit 2 reactor trip on
November 16, 2006. This issue has been entered in Constellation's
IRE-018-
411. Immediate corrective actions for this issue included replacement of the main disc
guide and an extent of condition review of the remaining
- PO [[]]
RVs on Unit 1 and Unit 2.
Because this issue is of very low safety significance (Green) and is entered into
Constellation's
NCV 05000317, 05000318/2007003-03:Failure to Preclude Recurrence of a Significant Condition Adverse to Quality
Associated with Power Operated Relief Valves).
21Enclosure4OA3Event Followup (71153 - One Sample) a. Inspection ScopeOn March 28, 2007, during the Unit
- 2 RFO while in a reduced inventory condition, theinspectors observed control room operators performing a reactor coolant system (
RCS)
vacuum fill evolution that resulted in a loss of all reactor water level indication. The
control room level indication (LI-4139) and the local level indication (LE-4139) both
increased approximately 6 feet and then slowly decreased while drawing a vacuum on
the RCS in preparation for the vacuum fill of the reactor. Operations investigated and
determined that a reactor level instrument inlet valve, normally used during refueling
outages, had been left open. This allowed air to enter the operating level
instrumentation lines as operators drew a vacuum on the RCS. After operators
identified and corrected the mis-positioned valve, both reactor level indicators returned
to an accurate reading that was consistent with pressurizer level indication. The
inspectors conducted a follow-up inspection to gain an understanding of the event and
to assess the appropriateness of operator actions. The inspectors interviewed
operators and reviewed Constellation procedures, the prompt investigation, and related
supporting documentation. b.Findings
(1)Failure to follow procedures and maintain configuration control during reactor fillIntroduction. The inspectors identified a very low safety significance (Green)
TS5.4.1.a, Administrative Controls, because Constellation did not maintain equipment
alignment in accordance with procedures during drain and fill of the reactor coolant
system (RCS). Specifically, operations personnel did not verify a reactor level
instrument inlet valve shut prior to the vacuum fill of the RCS, contrary to operating
procedures. Description. On March 28, 2007, operations began draining Unit 2 reactor vessel inpreparation for performing a vacuum fill of the
inventory condition and water level was stable in a 'mid-loop' condition at 38.5 feet. In
this condition, Constellation had three wide range level indicators available and
functioning properly (LG-4139,
LI-4140). Normally, Constellation would
have had ultrasonic narrow range indication available to the operators in the control
room (LI-4138), however,
RFO and repairs on the
instrument were unsuccessful. From a stable, reactor level mid-loop condition, operators in preparation for the vacuumfill operation, isolated
OP-7, Shutdown Operations, because
LG-4139) available to
the operators. Additionally, these two indicators share a common variable leg
RCS level indications had unexpectedly increased
and slowly decreased about 20 minutes after initiating a vacuum. The control room
chart recorder indicated that RCS level had increased approximately 6 feet from the
expected value of 38.5 feet. With no accurate means of level indication, operators
2Enclosuremade the decision to continue to draw a vacuum in order to commence injecting waterinto the RCS. In parallel, operations investigated the apparent malfunction of the level
indicators and evaluated potential sources of water to and from the RCS. Operations
also began to monitor "alternate" indications for potential loss of inventory including
water source tank levels and shutdown cooling pump cavitation. Operators completed
drawing a vacuum and commenced RCS fill approximately two hours after initial level
indication problems. Five hours after the initial level indication problems and during the
RC-1238 inlet valve was open
contrary to its expected normal position of closed. This mis-positioned inlet valve
allowed air to enter the level instrumentation lines as operators drew the vacuum and
caused the operating level indicators to respond erroneously since both were from a
common
RC-1238 inlet valve.
Operators immediately shut the mis-positioned valve and both RCS level indicators
responded consistently with expected
- RCS level. The inspectors determined that Constellation did not maintain configuration control asrequired by procedures governing reduced inventory and
RCS vacuum fill. Specifically,
Step 6.16.A.1 of
RCS piping and
associated components are aligned per
RCS and Pump Operations. Contrary to
this step, Constellation did not ensure that 2-RC-1238 was in the proper position. This
valve is typically cycled open/close during refueling outages as an additional level
indicator. Constellation left 2-RC-1238 opened, which resulted in the loss of all direct
means of level indication due to air intrusion for approximately five hours while the
reactor vessel was in a reduced inventory condition.Constellation entered this issue into their
RCS level from a
reduced inventory condition and a prompt investigation to determine the cause of the
loss of all level indication. Inspectors verified during post-event review that there were
no indications that reactor water level had ever decreased below the initial level of 38.5
ft.The performance deficiency is that Constellation did not follow site procedures andmaintain equipment alignment during RCS vacuum and fill operations. Analysis. This finding is greater than minor because it is associated with the InitiatingEvent cornerstone attribute of configuration control and affects the likelihood of a loss of
shutdown cooling event. The inspectors evaluated the significance of the finding using
SDP" and IMC 0609, Appendix H,
"Containment Integrity SDP," because the finding represented an actual loss of level
indication and did not meet the criteria specified in Attachment 1, of Appendix G.
Additionally, the finding required a human error probability (HEP) analysis that was not
addressed in the simplified Phase 2 evaluation and was referred to the division of risk
assessment in Nuclear Reactor Regulation (NRR) for a Phase 3 analysis as directed by
Appendix G, Attachment 2, section 2.2.5. No Low Power/Shutdown (LP/SD)
- SP [[]]
- CCNPP [[]]
- SP [[]]
AR model was modified to
allow analysis of the loss of all level indication condition.
23EnclosureNew event trees were created to analyze the following initiating events:*Loss of level control at mid loop (LOLC);*Loss of inventory (LOI);
- Loss of shutdown cooling (LORHR);
- Shutdown cooling isolation (ISOL);
- Loss of offsite power (LOOP); and
- Loss of
LOAC).The impact of the loss of level indication condition impacted the risk by reducing theoperators ability to respond to an event (e.g. a loss of level) if one were to occur. This
loss of indication was modeled by adjusting the impacted HEPs. The results were
dominated by a
RCS vented and in
reduced inventory with the RCS loops open) the dominant contributor was a loss of level
control initiating event with the operators failing to diagnose the loss of level control. For
this condition that lasted approximately five hours, the cumulative results for all initiators
yielded an incremental conditional core damage probability (ICCDP) of 3.6E-7.
Therefore, this finding is of very low safety significance (Green) for internal event
contributors. The finding was evaluated for its potential risk contribution due to large early releasefrequency (LERF) in accordance with IMC 0609, Appendix H. According to section 2.0,
only the period within eight days of the beginning of the outage needs to be considered.
After eight days, it is assumed that the short-lived, volatile isotopes that are principally
responsible for early health effects have decayed sufficiently such that the finding would
not contribute to
- LE [[]]
RF. Since the plant was shutdown for approximately 28 days, the
condition did not contribute to
- LE [[]]
RF. This finding has a cross-cutting aspect in the area
of human performance because Constellation did not define and effectively
communicate expectations regarding procedural compliance such that personnel follow
procedures (H.4.b).Enforcement. TS 5.4.1.a requires, in part, that written procedures be established,implemented, and maintained for activities described in Appendix A of Regulatory Guide
(RG) 1.33, Quality Assurance Program Requirements. Specifically, Section 3 of
OP-7,
Shutdown Operations, requires that all RCS piping and associated components are
aligned per
RCS and Pump Operations. Contrary to this step, on March 28,
2007, Constellation did not appropriately implement
OI-1A and verify that
2-RC-1238 was in the proper position as required by OI-1A. Constellation left
2-RC-1238 open, which resulted in the loss of all level indication for approximately five
hours while the reactor vessel was in a reduced inventory condition. This issue was
entered into the
IRE-021-661) for resolution. Immediate corrective actions
included conducting a prompt investigation to determine the cause of the loss of all level
indication. Because this issue is of very low safety significance (Green) and is entered
into Constellation's
NCV05000318/2007003-04, Failure to follow procedures and maintainconfiguration control during reactor fill.)
24Enclosure (2)Failure to adequately maintain the
- RCS reduced inventory procedureIntroduction. The inspectors identified a very low safety significance (Green)
NCV of TS5.4.1.a, Administrative Controls, when Constellation did not ensure an adequate
procedure was maintained to drain and fill the
OP-7 permitted
operation in a reduced RCS inventory condition without ensuring redundant means of
level indication contrary to the requirements of
- NO -1-103, Lower Mode Operations. Description. The inspectors, during post-event follow-up for a loss of reactor levelindication while in a reduced
RCS level inventory condition, determined that
Constellation is committed to providing at least two independent means of RCS level
indication during reduced inventory activities in accordance with GL 88-17, Loss of
Decay Heat Removal. This commitment is expressed as a requirement in NO-1-103,
Lower Mode Operations, which states that at least two redundant means of level
indication shall be provided. The inspectors reviewed OP-7 and identified that it
permitted operation in a reduced inventory condition without redundant means of level
indication contrary to the requirements of
required that only
LG-4139 be in-service during preparation and
performance of the RCS vacuum fill. However, these two indicators share a common
variable leg RCS instrument tap and, therefore, are not redundant because a common
failure has the potential to make both instruments inoperable as evidenced by the March
28, 2007, event. The inspectors also determined that Step 6.3A of OP-7 permitted
several combinations of level indicators that are contrary to NO-1-103 because some of
these combinations only consisted of the indicators that shared a common sensing leg.
Additionally, the inspectors noted that the vacuum fill section of the OP-7 did not provide
the operators with adequate direction on required actions should a level indication
malfunction occur.The performance deficiency is that Constellation did not maintain an adequateprocedure for operating in reduced rector level inventory condition. Analysis. This finding is greater than minor because if left uncorrected it could lead to aloss of all level indication while in reduced inventory. The finding is associated with the
Initiating Event cornerstone attribute of equipment performance and affects the
cornerstone objective to limit the likelihood of those events that upset plant stability and
challenge critical safety functions during shutdown operations. Specifically, the
inadequate procedure for operation in reduced RCS level inventory increased the
likelihood of the loss of
RHR initiating
event. The inspectors evaluated the significance of this finding using IMC 0609,
Appendix GProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0609,</br></br>Appendix G" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., "Shutdown Operations SDP," Figure 1, and determined that this finding
was of very low safety significance (Green) because the finding did not require a
quantitative assessment based on the review by the SRA. The inspectors determined
that this finding had a cross-cutting aspect in the area of human performance because
Constellation did not ensure that the procedure for operation with the RCS in a reduced
level inventory condition was complete and accurate (H.2.c).Enforcement.
- TS 5.4.1.a requires, in part, that written procedures be established,implemented, and maintained for activities described in Appendix A of
RG 1.33, Quality
Assurance Program Requirements. Specifically, section 3 of RG 1.33, Appendix A,
includes draining and filling the RCS. Contrary to the above, the inspectors identified in
25EnclosureApril 2007 that OP-7 was not appropriately maintained and permitted reactor operationin reduced level inventory condition without redundant means of level indication contrary
to the requirements of NO-1-103, Lower Mode Operations. This issue was entered into
the
IRE-021-661) for resolution. Immediate corrective actions included conducting
a prompt investigation to determine the cause of the loss of all level indication and
suspension of the procedure OP-7. Because this issue is of very low safety significance
(Green) and is entered into Constellation's
(NCV05000317/318/2007003-05, Failure to adequately maintain the RCS reduced
inventory procedure)4OA5Other Activities.1(Closed)
- URI 05000317/2006005-01 Main Steam Safety Valves Maintenance RulePerformance Criteria and Monitoring An unresolved item (
- NRC [[]]
IR 05000317/2006005 to evaluateConstellation's pending resolution when inspectors questioned the basis of the
established performance criteria for the
- MS [[]]
SV lift setpoint to determine the acceptability
of the
NCV of 10 CFR 50.65 (a)(2) and is
documented in this report, Section 1R12. This
NRC IR 05000318/2006005 to track the pending resolution of anissue associated with the response of the acoustic monitors following a high pressure
reactor trip on November 16, 2006. One
RCS pressure,
remained open for longer than expected (approximately 90 seconds). In addition, one
pressurizer safety valve potentially simmered. Constellation reported that the
pressurizer safety valve did not open and the associated pressurizer safety valve
acoustic monitoring indication was due to the close proximity of the
- PO [[]]
RV. The
inspectors noted that the acoustic monitors, which are relied on by plant operators
during implementation of
- UFS [[]]
AR states the requirement to provide the operator with unambiguous indication of
RCS safety and relief valve position so that appropriate operator actions can be taken.
The inspectors conducted a followup review of this issue to understand the acoustic
monitor response associated with event. Following the event, the pressurizer safety
valve and the
- PO [[]]
RV were taken to Wyle lab for analysis. During as-found testing in the
lab, the pressurizer safety valve lifted earlier than the lift set point (2415 psia versus
2475 psia). Constellation concluded that it is a good possibility that the safety valve
simmered during the reactor trip. Based on the as-found testing information for the
safety valve, review of the associated apparent cause evaluation, and discussions with
Operations and Engineering, the inspectors determined that the acoustic monitors
responded as expected for the plant conditions during the plant transient on
November16, 2006. This URI is closed.
25Enclosure.2Calvert Cliffs Unit 2 Replacement Reactor Vessel Closure Head (RRVCH) (71007) a.Inspection ScopeThe inspectors reviewed the Unit
- NRC [[]]
- PSI ) and Baseline InspectionsAn inspection was conducted on-site and in-office to evaluate the automated ultrasonictesting (UT) and dye penetrant (PT) baseline examination data records of the Unit 2
- RRV [[]]
CH. The review of selected documentation was to ensure that the non-destructive
examinations (NDE) were performed by qualified NDE technicians and in accordance
with qualified procedures. The inspectors reviewed a sample of baseline inspection
records from the NDE examinations for welds W75-W135 of the Unit 2 reactor vessel
head penetration J-groove welds. The inspectors verified the
ASME) Boiler & Pressure Vessel (B&PV)
Code Section
NRC Order EA-03-009 requirements for dissimilar metal
welds. Additionally, the inspectors performed a direct visual inspection of the Unit 2
- RRVCH [[, penetration nozzles and J-groove welds inside the Pre-Assembly Facility. Post-Modification Testing VerificationThe inspectors reviewed the completed post-modification testing and post-constructionwalkdowns records of the installed component replacements for the Unit 2]]
ESS) to verify that the tests and walkdowns
were conducted in accordance with approved plans, procedures, and work orders and to
verify the functional testing confirmed the design and established baseline
measurements. To verify the modifications were properly installed, inspected, tested
and met the acceptance criteria, the inspectors reviewed the following documents: 1)
repair replacement plan 2006-2-022, Installation of the
- RRV [[]]
CH on the Unit 2 Reactor
Vessel; 2) maintenance WO 2200504104, Installation of New Unit 2 Reactor Vessel
Closure Head; 3)
- CE [[]]
- VT -2 Visual Examinationconducted during a system leakage (Class 1 components) test to verify that no
- 2 RRV [[]]
CH, head vent line piping and components
during Mode 3 walkdowns. b.FindingsNo findings of significance were identified.
254OA6Meetings, Including ExitIntegrated Report Exit Meeting SummaryOn July 10, 2007, the resident inspectors presented the inspection results toMr. M. Flaherty and other members of your staff who acknowledged the findings. The
inspectors asked Constellation whether any of the material examined during the
inspection should be considered proprietary. No proprietary information was identified.ATTACHMENT:
- SUPPLE [[]]
- MENTAL [[]]
- INFORM [[]]
- INFORM [[]]
- POINTS [[]]
- OF [[]]
- CONTAC [[]]
TConstellation PersonnelJ. Spina, Site Vice PresidentJ. Pollock, Plant General Manager
C. Ashley, Engineering Supervisor
D. Bauder, Operations Manager
G. Beasley, Systems Manager
P. Beavers, Engineering supervisor
R. Bleacher, Operations
R. Cameron, Senior Engineering Analyst
K. Dougherty, System Engineer
P. Fatka, Senior System Engineer
M. Flaherty, Engineering Manager
P. Furio, Licensing Supervisor
J. Gaines, Licensing Director
K. Greene, Senior Engineer
S. Henry, Engineering Supervisor
C. Jones, Operations
T. Konerth, Project Engineer
D. Murphy, Engineering Supervisor
K. Nguyen, Systems Engineer
T. Riti, Operations
K. Robinson, Engineering
T. Shearer, Nuclear Fuel Services
A. Simpson, Licensing
L. Wegner, System Engineer
- LIST [[]]
- OF [[]]
- ITEMS [[]]
- CLOSED [[]]
- AND [[]]
- MSS [[]]
VPerformance Was Being Effectively
Controlled per
NCVFailure to Preclude Recurrence of aSignificant Condition Adverse to Quality
Associated with Power Operated Relief
Valves
A-2Attachment05000318/2007003-04NCVFailure to follow procedures and maintainconfiguration control during reactor fill05000317/318/2007003-05NCVFailure to adequately maintain the
URIMain Steam Safety Valves MaintenanceRule Performance Criteria and Monitoring
(Section 40A5.1)05000318/2006005-04URIAcoustic Monitors Response (Section4OA5.2)
- LIST [[]]
- OF [[]]
- DOCUME [[]]
- NTS [[]]
- REVIEW [[]]
EDSection 1R01: Adverse Weather ProtectionProceduresNO-1-119, Seasonal Readiness, Revision 10OI-21C, 0C Diesel Generator, Revision 20
OI-28, Operation of 500kV Switchyard, Revision 14,
1C01-ALM, Main Generator and Switchyard Control Alarm Manual, Revision 40
EOP-02, Loss of Offsite Power, Revision 14
EOP-07, Station Blackout, Revision 16
Operations Administrative Policy 94-5, Guidelines for Nuclear Plant Operations Support ForElectric System Operation and Planning Department Transmission System Operations,
Revision 1MiscellaneousSD-001, 500kV Switchyard and Generator Step-up Transformer, Revision 5Section 1R02: Evaluations of Changes, Tests or Experiments10
- SE 00488, Change in Method of Evaluating Turbine-Generator Missile Probability Risk for NewUnit 1 Turbine Low Pressure Rotors, Revision 0
SE00492, Unit 1 Cycle 17 Reload 50.59 for Batch 1W Fuel Assemblies, Revision 0
ES199701358-001, 2B Diesel Generator Jacket Cooling Setpoint Changes (2PS4810,2PS4811, 2PS4812), Revision 2
A-3AttachmentES200100966-000, Replace Main Turbine Rotors, Revision
MOV 4045 and 1(2)MOV 4052, Revision 0
RIC-5415 to 82,000 uCi/sec., Revision 0
Temporary Modification 1-06-0003, Remove Battery Monitor Relay
Temporary Modification 1-07-0004, Encapsulate #12 Moisture Separator Reheater ManwayCoverTemporary Modification 2-04-0002, Raise Setpoints for
TE5340-9 to 180 °F
Temporary Modification 2-07-0007, #22 Feed Pump Speed Card Failure
Changes to Procedures
- 0ES 200100780 Unit 2 Spent Fuel Pool Criticality Analysis With Soluble Boron and Burnup CreditBut Without Boraflex Credit, Revision 0
CET System, Revision 0
- CA 04747-0001, Uncertainty Calculation for the Sub-cooled Margin Monitor System, Revision 0Corrective Action Reports
IRE-011-234IRE-001-593
SH0001Wiring Diagram For Battery Voltage Monitor System Panel#PONLOD3100/MON, Revision 212147-0050SH0001, Qualified Replacement In-core Instrument Assembly Unit 1, Revision 0
CET's, Revision 14
2676SH0001, Instrument Location In-core Instrumentation Map Unit 2, Revision 2
98616SH0001, Loop Diagram Post Accident Monitoring System Channel A, Revision 0
98616SH0002, Loop Diagram Post Accident Monitoring System Channel B, Revision 0
TSB), Revision 9
A-4AttachmentEN-1-102,
- STP "M-527A-1, Post Accident Monitoring System Channel A Calibration Checks, Completed5/17/06 & 5/18/06STP M-527B-1, Post Accident Monitoring System Channel B Calibration Checks, Completed5/23/06STP M-527A-2, Post Accident Monitoring System Channel A Calibration Checks, Completed4/6/07STP M-527B-2, [[Topic" contains a listed "[" character as part of the property label and has therefore been classified as invalid. System Channel B Calibration Checks, Completed5/25/05STP O-63-1, Remote Shutdown and Post Accident Monitoring Instrument Channel Check,Completed 3/31/07Engineering Service Packages & 50.59 Safety EvaluationsES199900772, Change Operability Criteria for]]
ES200500079-000), 50.59 Evaluation for U2C17 Core Reload (2007 RFO),Revision 1Operator TrainingUnit 2 Cycle 17, Reload Core Design (2007 Refueling Outage)
Operability DeterminationRECO for
- CET Reading Temperature Bias of ~ 25F OnAverage, 9/26/06Operability Evaluation, For Increased Core Bypass Flow (IRE-021-445)System DescriptionSD-78B, In-core Instrumentation System, Revision
IRE-011-711IRE-014-572
IRE-017-174
IRE-017-175
IRE-018-411
IRE-018-803
IRE-018-804
ES200500079-000, U2C17 Core Reload (2007 RFO)
Technical Specification, Section 3.3.10, Post Accident Monitoring Instrumentation
Technical Specification, Section B.3.3.10, Post Accident Monitoring Instrumentation Bases
A-5AttachmentUFSAR, Section 7.5.4, In-core InstrumentationUFSAR, Section 7.5.9, Inadequate Core Cooling Instrumentation
Westinghouse Issue Report, #06-152-W001
Westinghouse Letter, Justification of Past and Continued Operation for Calvert Cliffs 1 Cycle18: 0.2% Increase In-core Bypass Flow, 3/19/07Section 1R04: Equipment AlignmentProceduresOI-28, Operation of 500kV Switchyard, Revision
ECCS Pump Room Ventilation, Revision 9
OI-32A-2, Auxiliary Feedwater System, Revision 17
- OI -03A-1, Safety Injection and Containment Spray, Revision 20Drawings61420, 500kV Switchyard Bay#2 Breaker 21, 22, & 23 Schematic Diagram, Revision 19 61001
SH0001, Electrical Main Single Line Diagram,Revision 42
61419SH0001, 500kV Switchyard Bay#2, Circle #1L Waugh Chapel Line #5051, Revision 12
MO#1200701708CID#2200700187MiscellaneousSD-001, 500kV Switchyard and Generator Step-up Transformer, Revision 5SD-032, Auxiliary Building Ventilation System, Revision 4
SD-052, Safety Injection and Containment Spray, Revision 3
Operability Determination (OD) Number 07-003
Event No. 4147, Final Reportability Review of
- NRC Generic Letter 91-08, Removal of Component Lists From Technical Specifications, datedMay 6, 1991
- NRC Information Notice 1986-38, Deficient Operator Actions Following Dual function ValveFailures, dated May 20,
- 1986NRC Information Notice 2006-29, Potential Common Cause Failure of Motor-Operated ValvesAs A Result of Stem Nut Wear, dated December 14, 2006Operations Script for Breaker 21 Replacement / 12 Service Bus Inspection / P1300-2 RevenueMetering Work
NPOSSO-07-02, Revision 0, Application of Tech Spec 3.6.3 to Expanded Containment IsolationValve List per Figure 5-10 as Compensatory Measure Until Necessary Procedure
Controls Have Been Incorporated
A-6AttachmentSection 1R05: Fire ProtectionProceduresSA-1, Fire Protection Program, Revision 6SA-1-102, Fire Protection/Appendix R Compensatory Actions, Revision 2
SA-1-100, Fire Prevention, Revision 13
- FP -0002, Fire Hazards Analysis Summary Document, Revision 0Fire Fighting Strategies Manual, Revision 0
- STP F-591-1, Inspection of Fire Doors, Watertight Doors, and Dampers in Fire Rated Barriers,Revision
- SH 1, Fire Damper Installation Auxiliary Building, Revision 260-447-B SH10, Fire Damper Installation Auxiliary Building, Revision 0
HELB BarriersCondition ReportsIRE-023-352
MiscellaneousFA-07-001, Functionality Assessment For Unit 1 and Unit 2 Fire DampersCCNPP Updated Final Safety Analysis Report, Revision 35
- NFPA 90A, Standard for the Installation of Air Conditioning and Ventilating Systems, dated1999Renewed Facility Operating License Nos.
- CCNPP [[]]
- UFS [[]]
AR, Revision 37
Section 1R07: Heat Sink PerformanceProceduresEN-1-327, Service Water Reliability Program (Generic Letter 89-13), Revision
- 4SRWHX -4, Service Water Heat Exchanger Cleaning and Inspection, Revision 9Section 1R11: Licensed Operator Requalification Program
- NO -1-200,, Control of Shift Activities, Revision 32NO-1-103, Conduct of Lower Mode Operations, Revision 24
IRE-023-297
A-7AttachmentSection 1R12: Maintenance EffectivenessProceduresNO-1-115, Operations Maintenance Coordination, Revision 7NO-1-203, Operations Section Performance Evaluation, Revision 12
Drawings61403BSH00134, Main Steam Safety Valves, Revision 0Condition Reports
IRE-011-601
IRE-018-931
IRE-019-211
IRE-019-372
IRE-021-038
IRE-021-913
IRE-023-728Work Orders22007024831200606506
200702935Maintenance Rule Documents(A)(3) Periodic Assessment of Maintenance Rule Program, Calvert Cliffs Nuclear Power Plant,October 2004 through September 2006Calvert Cliffs Nuclear Power Plant (CCNPP) Maintenance Rule (MR) Scoping Document,Revision 26Health ReportsAuxiliary Building And Radwaste Heat & Ventilation Systems, Unit 1 & 2, 4th Quarter 2006Auxiliary Feed Water System, Units 1 & 2, 4th Quarter 2006Miscellaneous DocumentsNRC Information Notice 2006-24, Recent Operating Experience Associated with Pressurizerand Main Steam Safety/Relief Valve Lift SetPoints, dated November 14, 2006NRC Information Notice 1986-56, Reliability of Main Steam Safety Valves, dated July 10, 1986
Calvert Cliffs Maintenance Rule Indicator, (a)(1) SSCs, January 2007
List of Risk Significant System Functional Failures That Occurred January 1, 2005 ThroughDecember 30, 2006Maintenance Rule Unavailability Report, dated 1/17/2007 Section 1R13: Maintenance Risk Assessments and Emergent Work ControlProceduresMN-1-123, Integrated Work Planning, Revision 17NO-1-117, Integrated Risk Management, Revision 19
OI-27B, 13.8kV System, Revision 16
OI-27C, 4.16kV System, Revision 23
OI-22F, Control Room and Cable Spreading Room Ventilation, Revision 24
A-8AttachmentIntegrated Work Schedule Integrated Work Schedule Week 715
Integrated Work Schedule Week 716
Integrated Work Schedule Week 717Section 1R15: Operability EvaluationsOperability DeterminationIRE-021-790IRE-021-445
IRE-022-288
IRE-022-258
IRE-022-177
SH0001, Starting Air System Diesel Generator Building 1EDG, Revision 3
CalculationES200100656-000, Total Loop Uncertainty For The Plant ComputerDetermination Of Maintenance Feedwater Flow, Revision 0Calculation No. D-92-014,
- HV [[]]
- ES 200500079, Core Bypass with Thimble Replacement for Calvert Cliffs Units, Revision 0Miscellaneous
- NF -CC1-07-5, Justification of Past and Continued Operation for Calvert Cliffs 1 Cycle 18: 0.2%Increase in Core Bypass Flow, dated March 19,
- 2007.UFSAR Section 3.5.4, Revision 37Section 1R17: Permanent Plant Modifications Modification Samples
MOV 4045 and 1(2)MOV 4052, Revision 0
RIC-5415 to 82,000 uCi/sec., Revision 0
A-9AttachmentCalculationsCA04747, Uncertainty Calculation for the Subcooled Margin Monitor System, Revision 0CA06250, Qualification of Sub-Panel Within Diesel Panel 1C62B, Revision 0
E-89-005,
SQ00138, Seismic Qualification of a Fairbanks Morse Magnetic Pick-Up (Speed Probe) andBracket Assembly, Revision 0Corrective Action ReportsIRE-014-425IRE-022-222*
IRE-002-369
IRE-007-190
IRE-022-228*
IRE-003-287
IRE-022-244*
IR4-034-185
IRE-006-287
IRE-019-028
IRE-001-114
IR4-033-018
IRE-002-317
IR4-018-402
IR4-023-643
IRE-022-246*
- NRC Identified During InspectionDrawings12310-0009SH0003-2004SH0002, Replace
DC System Bus 15, Revision 3
61030, Single Line Diagram Vital 120V
- DC [[]]
PLC and EGA Systems, Revision 0
61069-2003SH0001, Schematic Diagram Turbine Steam Dump and Bypass Controls, Revision
63069-2005SH0001, Schematic Diagram Turbine Steam Dump and Bypass Controls, Revision
61069-2003SH0002, Schematic Diagram Turbine Steam Dump and Bypass Controls, Revision
63069-2005SH0002, Schematic Diagram Turbine Steam Dump and Bypass Controls, Revision
- SH 001Reactor Regulation System Cabinet Schematic, Unit 1 x 1C31, Revision 262024-ESH3, Diesel Generator Project Single Line Diagram
EDG Alarms, Rev 6
A-10AttachmentMiscellaneousUnit 2 Cycle 17 Reload Core Design - Operator Training Lesson SlidesProcedures1C06-ALM,
MOV) Post-Maintenance Requirements for Flow
Isolable Valves, Revision 3
KV System, Revision 16
LOCI Sequencer, Revision 25
OI-16, Calvert Cliffs Unit 1, Component Cooling System, Revision 31
OI-16, Calvert Cliffs Unit 2, Component Cooling System, Revision 28
Engineered Test Procedure 06-004, 2B
PMT, Revision 0
STP O-4B-2, B Train Integrated Engineered Safety Features Test, Revision 27, Performed
3/29/07.Work Orders1200404948Section 1R19: Post-Maintenance TestingProceduresNO-1-208, Nuclear Operations (NO) Post Maintenance Testing, Revision
HU-1.01-1002, Pre-Job Briefings and Post-Job Critiques, Revision 1
Lube-02, General Lubrication Procedure, Revision 2
- HVAC -3, Inspection and Replacement of V-Belts, Revision 2Drawings63480, 500kV Switchyard Construction One Line Wiring Diagram, Revision 1060723
MO#2200700152MO#1200603098
MO#1200700305
MO#0200700815
MO#2199801933
MO#2200503868
MO#2200503578
A-11AttachmentClearance Orders22007001871200700127
200600974MiscellaneousSD-083A, Main Steam System, Revision 3SD-030, Control Room Ventilation System, Revision 4
- GE [[]]
- CR [[]]
- HV [[]]
STP-O-90-1, AC Sources and Onsite Power Distribution Systems 7 Day Operability Verification,
Revision 22
- STP -M-220G-1, 11 & 14 4kV Undervoltage Relay Functional Test, Revision 1Section 1R23: Temporary Plant ModificationsProcedures
CFR 50.59 / 10 CFR 72.48 Reviews, Revision 10
RTD Time Response Data Collection Test, Revision 4Drawings62729SH001, Reactor Coolant System, Revision 96
Condition ReportsIRE-021-796IRE-022-430Work OrdersMO#2200702388MO#2200702749MiscellaneousTA-2-07-0011, Remove Temperature Element (2-TE-112HC) Input to Reactor ProtectionSystem, Revision 0
SD-058, Reactor Protective System, Revision 4
SD-064A, Reactor Coolant System Instrumentation, Revision 3
2AttachmentSection
NO-1-200, Control of Shift Activities, Revision 32OP-18, Evaluated Scenario, Revision 5
EOP-00, Post Trip Immediate Actions, Revision 10
EOP-02, Loss of Offsite Power, Revision 14
EOP-05, Loss of Coolant Accident, Revision 14
Calvert Cliffs Emergency Plan and Implementing Procedures Condition ReportsIRE-023-297Section
- 2PS 1: Radioactive Gaseous and Liquid Effluent Treatment and MonitoringSystemsCalvert Cliffs Technical Procedures:
STP-M-564-1, Rev 11, Unit 1 Wide Range Noble Gas Monitor Calibration CheckSTP-M-564-2, Rev 13, Unit 2 Wide Range Noble Gas Monitor Calibration Check
STP-M-567-0, Rev 4, Gaseous and Liquid Waste Discharge Radiation Monitors Calibration
Check
STP-M-567-1, Rev 4, Unit 1 Steam Generator Blowdown Recovery Radiation Monitor and Loop
Flow Channel Calibration
STP-M-567-1, Rev 5, Unit 1 Steam Generator Blowdown Recovery Radiation Monitor and Loop
Flow Channel Calibration
STP-M-567-2, Rev 4, Unit 2 Steam Generator Blowdown Recovery Radiation Monitor and Loop
Flow Channel Calibration
STP-M-569-1, Rev 1, Unit 1 Main Vent Gaseous Radiation Monitor Channel Calibration
HEPA)
IRE 013-157IRE 015-129
IRE 020-798
IRE 008-942
IRE 009-325
IRE; 009-703
IRE; 010-929
IRE 017-254
IRE 019-041
IRE 012-979
IRE 017-261
IRE 012-847
IRE 019-931Liquid Radioactive Release Permits: 70023; 70024
A-13AttachmentGaseous Radioactive Waste Release Permits:70037; 70014Tritium Groundwater Protection Action Plan, Rev 0Section
- STP -O-27-2, Reactor Coolant System Leakage Evaluation (RCS Leakage), Revision 17Operator LogsSection
CNG-CA-1.01, Corrective Action Program, Revision 1ER-1-103, Maintenance Rule Program Implementation, Revision 1
- US [[]]
AR), and the Technical
Specification Bases (TSB), Revision 9Condition ReportsIRE-014-572IRE-017-174
IRE-017-175
IRE-021-445
IRE-011-711
IRE-018-411
IRE-018-803
STP M-527A-1, Post Accident Monitoring System Channel A Calibration Checks, Revision 7STP M-527B-1, Post Accident Monitoring System Channel B Calibration Checks, Revision 7
STP M-527A-2, Post Accident Monitoring System Channel A Calibration Checks, Revision 6
STP M-527B-2, Post Accident Monitoring System Channel B Calibration Checks, Revision 6
STP O-63-1, Remote Shutdown and Post Accident Monitoring Instrument Channel Check,
Revision 33
CA 01311-0001, Uncertainty Calculation for the CET System, Revision 1
- CA 04747-0001, Uncertainty Calculation for the Sub-cooled Margin Monitor System, Revision 0Drawings12147-0050
CETs, Revision 14
2676SH0001, Instrument Location In-core Instrumentation Map Unit 2, Revision 2
98616SH0001, Loop Diagram Post Accident Monitoring System Channel A, Revision 0
98616SH0002, Loop Diagram Post Accident Monitoring System Channel B, Revision 0
A-14Attachment98716SH0001, Loop Diagram Post Accident Monitoring System Channel A, Revision
- 098716SH 0002, Loop Diagram Post Accident Monitoring System Channel B, Revision 0Engineering Service Packages & 50.59 Safety Evaluations
ES200500079-000), 50.59 Evaluation for U2C17 Core Reload (2007 RFO),
Revision 1Operator TrainingUnit 2 Cycle 17, Reload Core Design (2007 Refueling Outage)
Operability DeterminationRECO for
CET Reading Temperature Bias of ~ 25oF OnAverage, 9/26/06
Operability Evaluation, For Increased Core Bypass Flow (IRE-021-445)System DescriptionSD-78B, In-core Instrumentation System, Revision
- 2SD -114, Post Accident Monitoring System, Revision 0MiscellaneousConstellation Letter, Closure of 3R2006002210
- UFS [[]]
RFO)
Technical Specification, Section 3.3.10, Post Accident Monitoring Instrumentation
Technical Specification, Section
- UFS [[]]
- UFS [[]]
AR, Section 7.5.9, Inadequate Core Cooling Instrumentation
Westinghouse Issue Report,#06-152-W001
Westinghouse Letter, Justification of Past and Continued Operation for Calvert Cliffs 1 Cycle
18: 0.2% Increase In-core Bypass Flow, 3/19/07
Calvert Cliffs Nuclear Power Plant Maintenance Rule Scoping Document, Revision 26
LER 05000318/2006-001, Reactor Trip During Performance of Maintenance Clearance Order,
Revision 1
Risk Informed Inspection Notebook for Calvert Cliffs Nuclear Plant Units 1 and 2, Revision 2.01
Technical Specification, 3/4.4.10, Pressurizer Safety Valves
Technical Specification, 3/4.4.11, Pressurizer Power-Operated Relief Valves Section
HU-1.01-1002, Attachment 2, Pre-Job Brief Checklist, Revision 1
NO-1-117, Att 9 , High Risk Activity Plan 07-05, Revision 18
NO-1-117, Att 9, High Risk Activity Plan 07-11, Revision 18
NO-1-117, Attachment 13, Determination and Processing of Infrequent Tests or Evolutions,
Revision 18
NO-1-103, Conduct of Lower Mode Operations, Revision 24
A-15AttachmentNO-1-207, Attachment 23, Minimum Essential Equipment for Unit 2 in Reduced Inventory,Revision 38
OI-3B, Shutdown Cooling, Revision 22
OP-7 Shutdown Operations, Revision 32
- ESF [[]]
AS 22 Alarm Manual, Revision 35
IRE-021-661IRE-022-119
IRE-022-121Drawings62731, Safety Injection & Containment Spray Systems, Revision 7962730, Chemical and Volume Control System, Revision 54
2729, Reactor Coolant System, Revision 96MiscellaneousCalvert Cliffs
- UFS [[]]
AR Section 7.5.9.4, Reduced Reactor Coolant Inventory, InstrumentationVarious Letters Relating to Generic Letter 88-17 and Associated Control Room Narrative Log
for Period of Interest.
PC-1, Procedurally Controlled Temporary Configuration Change Form
for Unit-1 RCS Tygon Level Device, Revision 12
HU-1.01-1002, Attachment 2, Pre-Job Brief Checklist (As Completed), , Revision 1
Calvert Cliffs Unit Two Refueling Outage 2007 Water Level Script, , Revision 1
- RCS [[]]
- NUMA [[]]
RC 91-06, Guidelines for Industry Actions to Assess Shutdown Management
Generic Letter 88-17, Loss of Decay Heat Removal
Information Notice 88-70, Reliance on Water Level Instrumentation with a Common Leg
- RCS Narrow Range Level MonitorSection 40A5: Other ActivitiesRepair Replacement Plan 2006-2-022, Installation of the
RRVCH on the Unit 2 Reactor Vessel,dated 2/14/2007
Maintenance Work Order 2200504104, Install New Unit 2 Reactor Vessel Closure Head, step
100, post maintenance testing,
NDE personnel, dated 3/31/2007
Technical Procedure, Engineering Test Procedure 99-015R, Unit 0,
- CE [[]]
DM Performance
Testing, for test dated 4/1/2007, Revision 3
Technical Procedure, Engineering Test Procedure, Unit 2 ETP 06-007, Enhanced Service
Structure Post Modification Test:
- CE [[]]
DM Cooler Air Flow Test, Revision 0, for test dated
3/29/2007
ES200200485/ES200300312, Form 4s, Record of Walkdowns and Form 18,
Modification Turnover Checklist, dated 3/31/2007
Sample of
UT Examination Data Sheets for Weld Numbers W75-W135
A-16AttachmentLIST
- OF [[]]
- ALAR [[]]
- AO [[]]
- ASM [[]]
- B&P [[]]
- CA [[]]
- CCNP [[]]
- CE [[]]
- CED [[]]
- CE [[]]
- CF [[]]
- CI [[]]
VContainment Isolation Valve
- ECC [[]]
- ED [[]]
- EO [[]]
PEmergency Operating Procedure
ESSEnhanced Service Structure
- HE [[]]
- ICCD [[]]
- IC [[]]
- IM [[]]
CInspection Manual Chapter
- IP [[]]
EIndividual Plant Examination
kVKilovolt
- LC [[]]
- LE [[]]
- LER [[]]
- LOA [[]]
- LO [[]]
- LOL [[]]
- LOO [[]]
- LORH [[]]
- LPS [[]]
- MFI [[]]
VMain Feedwater Isolation Valve
MOMaintenance Order
- MSS [[]]
- NC [[]]
- ND [[]]
- NFP [[]]
- NR [[]]
- NR [[]]
- ODC [[]]
MOffsite Dose Calculation Manual
A-17AttachmentOIOperating InstructionOPOperating Procedure
- PAR [[]]
SPublicly Available Records
- POR [[]]
VPower Operated Relief Valve
PTDye Penetrant
- RC [[]]
- RC [[]]
- REC [[]]
- RET [[]]
- RF [[]]
ORefueling Outage
- RH [[]]
- RM [[]]
- RRVC [[]]
- SD [[]]
PSignificance Determination Process
- SGF [[]]
- SOR [[]]
- SR [[]]
- SS [[]]
- TR [[]]
MTechnical Requirement Manual
- TS [[]]
- UFSA [[]]
- UR [[]]
IUnresolved Item