IR 05000317/2010003
| ML102160653 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 08/04/2010 |
| From: | Glenn Dentel Reactor Projects Branch 1 |
| To: | George Gellrich Calvert Cliffs, Constellation Energy Group |
| Dentel, G RGN-I/DRP/BR1/610-337-5233 | |
| References | |
| IR-10-003 | |
| Download: ML102160653 (44) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION 415 ALLENDALE KING OF PRUSSIA, PA August 4, 2010 George H. Gellrich, Vice Calvert Cliffs Nuclear Power Plant, Constellation Energy Nuclear Group, 1650 Calvert Cliffs Lusby, Maryland CALVERT CLIFFS NUCLEAR POWER PLANT -NRC INSPECTION REPORT 05000317/2010003 AND
Dear Mr. Gellrich:
On June 30,2010, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Calvert Cliffs Nuclear Power Plant (CCNPP) Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on July 16,2010, with you and other members of your staff. The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
This report documents two NRC-identified findings and one self-revealing finding of very low safety significance (Green). Two of these findings were determined to involve violations of NRC requirements.
However, because the findings are of very low safety Significance and because they are entered into your corrective action program (CAP), the NRC is treating these findings as non-cited violations (NCVs) consistent with Section 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 Regulatory Commission, . ATTN.: Document Control Desk, Washington, DC 20555-0001:
with copies to the Regional Administrator, Region 1; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Calvert Cliffs. In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region 1, and the NRC Resident Inspector at CCNPP.
G.
2 In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of 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).
Glenn T. Dentel, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Nos.: 50-317,50-318 License Nos.: DPR-53, DPR-69 Inspection Report 05000317/2010003 and 05000318/2010003
w/Attachment:
Supplemental Information
REGION I 50-317,50*318 DPR*53, DPR-69 05000317/2010003 and 05000318/2010003 Constellation Energy Nuclear Group, LLC Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Lusby, MD April 1, 2010, through June 30, 2010 S. Kennedy, Senior Resident Inspector J. Hawkins, Acting Resident Inspector M. Osborn, Resident Inspector R. Montgomery, Reactor Engineer R. Rolph, Health Physicist S. Pindale, Senior Reactor Inspector K. Mangan, Senior Reactor Inspector Glenn T. Dentel, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure I
SUMMARY OF IR 05000317/2010003,05000318/2010003; 4/1/10 -6/30/10; Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2: Maintenance Risk Assessments and Emergent Work Control; Plant Modifications; and Followup of Events and Notices of Enforcement Discretion The report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors.
Three findings, two of which were cited violations (NCVs), were identified.
The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, QSignificance Determination Process" (SOP). The cross-cutting aspects for the findings were determined using IMC 0310, "Components Within the Cross-Cutting Areas." Findings for which the SOP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006. Cornerstone:
Initiating Events Green. The inspectors identified an NCV of 10 CFR Part 50, Appendix B. Criterion III, "Design Control," because Constellation did not perform adequate design reviews associated with modifications to the turbine control system and the nuclear steam supply system (NSSS). Specifically, Constellation did not adequately evaluate the potential adverse impacts of removal of the power load unbalance (PLU) turbine trip on safety related systems. structures, and components (SSCs) such as the main steam safety valves (MSSVs) and pressurizer power operated relief valves (PORVs). In addition, during Significant changes to plant design such as steam generator replacements and power uprates. Constellation did not conduct an adequate evaluation to determine jf the turbine bypass valve (TBV) and the atmospheric dump valve (ADV) design specification of opening within 3 seconds after receiving the quick open signal would still be sufficient to prevent lifting MSSVs. Immediate corrective actions included entering these issues into their corrective action program (CAP) and performing an immediate operability determination and a probabilistic risk analysiS.
This finding is more than minor because it affected the Initiating Event cornerstone attribute of design control and affects the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations.
Specifically, the removal of the PLU turbine trip and the modifications to the NSSS could challenge primary and secondary overpressure protection devices and result in a stuck open MSSVor PORV. The inspectors evaluated this finding using an SOP phase 2 analysiS and determined that the issue is of very low safety significance.
This finding has a cross-cutting aspect in the area of human performance, decision making. because Constellation did not adequately make significant decisions using a systematic process when faced with uncertain or unexpected plant conditions.
to ensure safety is maintained. (H.1.a of IMC 0310). (Section 1 R18) Green. A self-revealing finding of very low safety Significance was identified because Constellation did not establish an appropriate preventive maintenance (PM) program for the 125 volts direct current (VDC) switchyard distribution panels in accordance with 1, "Maintenance Program." The 125 VDC switchyard distribution system supplies power Enclosure to the switchyard direct current (DC) loads for the operation of switchyard circuit breakers, emergency lights, and protective relays. Immediate corrective actions included entering this issue into the CAP and performing an inspection of all 125 VDC switch yard distribution panels. Long-term corrective actions planned include establishing an adequate PM program for the 125 VDC switch yard distribution panels. The finding is more than minor because it is associated with the equipment performance attribute of the Initiating Events comerstone and affects the comerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety function.
In addition, if left uncorrected, the performance deficiency could lead to a more significant safety concem. SpeCifically, the failure to establish an adequate PM program for the 125 VDC switchyard distribution panels could preclude the identification of equipment defiCiencies, such as loose connections, that could result in a plant transient.
The finding is of very low safety significance because it did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation eqUipment or functions will not be available.
This finding has a cross-cutting aspect in the area of problem identification and resolution, operating experience (OE), because Constellation did not use OE information, including vendor recommendations to support plant safety. Specifically, Constellation did not implement and institutionalize OE through changes to station processes, procedures, equipment.
and training associated with the switch yard PM program (P.2.b of IMC 0305). (Section 40A3) Cornerstone:
Mitigating Systems Green. The inspectors identified an NCVof 10 CFR Part 50.65 (a)(4), "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants,>> because Constellation did not perform an adequate risk assessment, which resulted in an underestimation and lack of awareness of the risk during maintenance activities on the 28 emergency diesel generator (EDG). On June 18, 2010, operators removed the 2B EDG from service and shut the air start valVes in preparation for a maintenance activity.
This prevented the 2B EDG from starting and loading automatically on a safety injection actuation signal (SIAS) or Joss of offsite power. The inspectors determined that Constellation did not inClude the unavailability of the 28 EDG on the risk assessment.
Immediate corrective actions included entering this issue into the CAP and re-performing the risk assessment When re-performed, the core damage frequency (CDF) risk during the 28 EDG maintenance activity would have increased to medium (yellow).
The finding is more than minor because if the overall risk had been correctly assessed, it would have placed Unit 2 into a higher risk category.
The finding is associated with the configuration control attribute of the Mitigating Systems cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.
The inspectors determined that the finding is of very low safety Significance because the incremental core damage probability deficit was less than 1.0E-6. This finding has a cross-cutting aspect in the area of human performance, work control, because Constellation did not appropriately plan and incorporate risk insights in work activities that impacted the availability of the 2B EDG (H.3.a of IMC 0310). (Section 1R13) Enclosure Other Findings None Enclosure REPORT Summary of Plant Status Calvert Cliffs Unit 1 began the inspection period at 100 percent power. On April 24, 2010, operators reduced power to 85 percent to perform power uprate testing. Operators returned the unit to 100 percent on the same day. On May 12, 2010, Unit 1 experienced an automatic reactor trip due to an electrical transient in the 500 kilovolt (kV) switchyard.
Operators returned the unit to 100 percent power on May 19, 2010. On June 25, 2010, operators reduced power to 88 percent to clean condenser waterboxes.
Operators returned the unit to 100 percent power the same day. On June 27,2010, operators reduced power to 92 percent power to clean condenser waterboxes.
Operators returned the unit to 100 percent power the same day. The unit remained at or near 100 percent power for the remainder of the inspection period. Calvert Cliffs Unit 2 began the inspection period at 100 percent power. On May 2,2010, operators performed an unplanned power reduction to 68 percent power due to flow oscillations on the No. 21 steam generator feed pump control oil system. Operators returned the unit to 100 percent power on May 3, 2010. On June 5, 2010, operators reduced power to 65 percent to perform main turbine valve testing and planned maintenance on the No. 21 steam generator feed pump. Operators returned the unit to 100 percent power on June 6,2010. On June 17, 2010, operators reduced power to 82 percent to clean condenser waterboxes and perform data acquisition software cabinet maintenance.
Operators returned the unit to 100 percent power on June 18,2010. The unit remained at or near 100 percent power for the remainder of the inspection period. 1. REACTOR SAFETY Cornerstones:
Initiating Events. Mitigating Systems. Barrier Integrity 1 R01 Adverse Weather Protection (71111.01-Two Samples) a. Inspection Scope The inspectors reviewed the adverse weather preparation and mitigating strategies before the onset of hot weather operations and the high grid loading summer season. 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. This review included an assessment of Constellation's implementation of abnormal operating procedure AOP -7L, "Circulating Water/lntake Malfunctions," and a walk down of the intake structure.
The review included the intake structure, the saltwater (SW) system, and the 1A EDG. The inspectors also performed a partial walk down of the offsite 500 kV electrical system. The inspectors interviewed control room operators and system engineers to ensure protective measures applicable to these risk-significant systems were available.
This inspection satisfied two inspection samples for review of significant systems during seasonal susceptibilities and grid related stress conditions.
Documents reviewed are listed in the Attachment.
Enclosure 7 b. Findings No findings of significance were identified.
1R04 Equipment Alignment Partial Walkdown (71111.04Q-Four Samples) a. Inspection Scope The inspectors conducted partial walkdowns to verify equipment alignment of selected risk significant systems. 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 Constellation had properly identified and resolved equipment alignment problems that could cause initiating events or potentially affect the availability of associated mitigating systems. The inspectors performed a partial walkdown of the following systems: No. 22 emergency core cooling system (ECCS) during maintenance on the No. 21 ECCS ventilation cooler SW outlet valve; 125 VDC reserve battery during planned maintenance on the No. 12A station battery; Diesel fire pump during planned maintenance on the electric fire pump; and, No. 11 ECCS during maintenance on the No. 12 ECCS ventilation cooler SW outlet valve. b. Findings No findings of significance were identified.
1 R05 Fire Protection (71111.050-Five Samples) .1 Fire Protection Tours a. Inspection Scope The inspectors conducted a tour of the areas listed below to assess the material condition and operational status of fire protection features.
The inspectors verified that combustibles and ignition sources were controlled in accordance with Constellation's administrative procedures; the fire detection and suppression equipment was available for use; passive fire barriers were maintained in good material condition; and compensatory measures for out-of-service, degraded, or inoperable fire protection equipment were implemented in accordance with Constellation's fire plan. * OC (Station Blackout)
diesel generator building fire area EDGOC, rooms SBO 202 and S8 102; * Unit 1 cable spreading room, fire area 16, room 306; * Unit 2 cable spreading room, fire area 17, room 302; i I I Enclosure
- Unit 1 battery room, fire area 16A, rooms 301 and 304; and * Unit 1 27 foot switchgear room, fire area 19, room 317. b. Findings No findings of significance were identified . . 2 Fire Protection-Drill Observation (71111.05A-One Sample) a. Inspection Scope The inspectors observed a fire brigade drill scenario conducted on April 15, 2010, that involved a fire in the waterfront fabrication shop office, north of the intake structure.
The inspectors evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that Constellation personnel identified deficiencies, openly discussed them in a self-critical manner at the debrief, and took appropriate corrective actions as required.
The inspectors evaluated specific attributes as follows: (1) proper wearing of turnout gear and self-contained breathing apparatus; (2) proper use and layout of fire hoses; (3) employment of appropriate fire fighting techniques; (4) sufficient fire fighting equipment brought to the scene; (5) effectiveness of command and control; (6) search for victims and propagation of the fire into other plant areas; (7) smoke removal operations; (8) utilization of pre-planned strategies; (9) adherence to the pre-planned drill scenario; and (1 0) drill objectives met. The inspectors verified that fire brigade actions were in accordance with Constellation's fire fighting strategies.
Following the drill, the inspectors reviewed the post drill debriefing conducted between the assessment team and the fire brigade members. b. Findings No findings of Significance were identified.
1 R07 Heat Sink Performance (71111.07A-One Sample) a. Inspection Scope The inspectors reviewed the thermal performance test and inspection activities for the No. 22A service water heat exchanger.
The inspectors reviewed the performance data and evaluated the test acceptance criteria to ensure that the design basis requirements were satisfied.
The inspectors evaluated the heat transfer capabilities based on completed flow Verification tests to ensure that specific safety functions could be performed in accordance with design specifications.
The inspectors also reviewed Constellation's periodic maintenance methods to verify that they conformed to the guidelines delineated in Electric Power Research Institute Report NP-7552, "Heat Exchanger Performance Monitoring Guidelines." b. Findings No findings of significance were identified.
Enclosure 1Licensed Operator Regualification Program Resident Inspector Quarterly Review (71111.11Q-One Sample) Inspection Scope On June 3, 2010, the inspectors observed a licensed operator requalification scenario to assess operator performance and the adequacy of the licensed operator-training program. The scenario included lessons learned associated with the dual unit reactor trip that occurred on February 18. 2010. The inspectors verified the clarity and formality of communications.
the completion of appropriate operator actions in response to alarms. the performance of timely control board operations and manipulations, and that the oversight and direction provided by the shift manager were in accordance with Constellation's administrative and technical procedures. Findings No findings of significance were identified.
1 Maintenance Effectiveness (71111.12Q-Two 8amples) Resident Inspector Quarterly Review Inspection Scope The inspectors reviewed the maintenance effectiveness of the sample listed below for the following:
1) appropriate work practices; 2) identifying and addressing common cause failures; 3) scoping in accordance with 10 CFR Part 50.65(b) of the maintenance rule; 4) characterizing reliability issues for performance; 5) trending key parameters for condition monitoring; 6) recording unavailability for performance; 7) classification and reclassification in accordance with 10 CFR Part 50,65(a)(1)
or (a)(2); and 8) appropriateness of performance criteria for 8SCs classified as (a)(2) and/or appropriateness and adequacy of goals and corrective actions for 88Cs classified as (a){1 ). Unit 1 main steam isolation valves a(1) status (CR-2010-004595);
and Unit 1 reactor trip due to a loose connection in the 125 VDC switchyard power panel 0-005173). Findings No findings of significance were identified.
1 Maintenance Risk Assessments and Emergent Work Control (71111.13-Eight Samples) Inspection Scope The inspectors reviewed the following activities to verify that Constellation performed the appropriate risk assessments for planned maintenance of out of service equipment and emergent work. For the emergent work activities performed by station personnel.
the Enclosure inspectors verified that Constellation promptly reassessed and managed the plant risk. The inspectors compared the risk assessments and risk management actions with CNG* OP-4.01-1000, "Integrated Risk Management," and Constellation's risk assessment tool to the requirements of 10 CFR Part 50.65(a)( 4) and the recommendations of the Nuclear Management and Resources Council 93-01. "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." In addition, the inspectors assessed the adequacy of Constellation's identification and resolution of problems associated with maintenance risk assessments and emergent work activities. Planned maintenance on the No. 21 battery with the reserve battery connected to the No. 21 bus on April 13, 2010; 2A EDG and the station blackout diesel out of service due to relay testing of the No. 21 4KV bus on April 14. 2010; Unplanned maintenance on No. 12 instrument air compressor with No. 11 instrument air compressor out of service on April 21, 2010; Unplanned maintenance on No. 21 heater drain tank normal level control valve CV-1467)and No. 21 steam generator feed pump control oil flow oscillations on April 27,2010; Planned maintenance on the 1A EDG on May 24,2010; No. 23 charging pump out of service due to seal leakage while conducting planned maintenance on the No. 21 steam generator feed pump on June 4, 2010; Planned maintenance on the No. 21 auxiliary feedwater (AFW) pump on June 9. 2010; and Planned maintenance and approved troubleshooting on the 28 EDG on June 18. 2010. b. Findings Introduction:
The inspectors identified a finding of very low safety significance (Green) associated with an NCVof 10 CFR Part 50.65 (a)(4), "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," because Constellation did not perform an adequate risk assessment which resulted in an underestimation and lack of awareness of the risk during maintenance activities on the 28 EDG. Description:
On June 18,2010, operators removed the 28 EDG from service in preparation for troubleshooting a slow speed start issue. The troubleshooting activities included swapping leads on the speed probe, installing test equipment.
conducting two slow speed starts, restoring the speed probe normal configuration, and returning the 28 EDG to an operable status following a fast speed start. Prior to troubleshooting, the operators shut the air start valves to the 2B EDG. This would have prevented the 28 EDG from starting and loading automatically on a SIAS or loss of offsite power. The inspectors noted that the recorded CDF risk was low and questioned the accuracy of the risk assessment.
Following a discussion with engineering and the probabilistic risk assessment group, the inspectors concluded that the 28 EDG was unavailable and that Constellation did not include the unavailability of the 28 EDG on the CDF risk assessment during the maintenance activity.
Immediate corrective actions included entering this issue into the CAP and re-performing the risk assessment.
When performed.
the CDF risk during the 28 EDG maintenance would have increased to medium {Yellow}.
Enclosure I
The inspectors performed a review of the risk management actions (RMAs) that Constellation had in place during the maintenance activity.
The inspectors noted that Constellation had declared the maintenance activity as nuclear medium risk (NMR) due to the potential to lose the associated 4kV safety related bus when paralleling the 2B EDG to the 4kV bus. The inspectors noted that the associated RMAs taken for NMR were similar to RMAs for yellow risk with the exception that not all RMA actions were performed for risk awareness and control associated with the increase in CDF risk. For example, Constellation did not record the increase in CDF risk in the control room logs, plant status documents, and work schedules.
In addition, Constellation did not discuss the increase in CDF risk during shift turnover, the pre-job brief, and the management plan of the day meeting. Analysis:
The performance deficiency is that Constellation did not perform an adequate risk assessment, which resulted in an underestimation and lack of awareness of the risk during maintenance activities on the 2B EDG. Using IMC 0612, "Power Reactor Inspection Reports," Appendix E, Example 7.e, the finding is more than minor because jf the overall risk had been correctly assessed, it would have placed Unit 2 into a higher risk category.
The finding is associated with the configuration control attribute of the Mitigating Systems cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.
Because this finding involves the licensee's assessment and management of risk associated with performing maintenance activities under all plant operating or shutdown conditions, the inspectors used IMC 0609, Appendix K. "Maintenance Risk Assessment and Risk Management Significance Determination Process," to evaluate this finding. The inspectors determined that the finding is of very low safety significance using flowchart 1 because the incremental core . damage probability deficit was less than 1.0E-6. This finding has a cross-cutting aspect in the area of human performance, work control, because Constellation did not appropriately plan and incorporate risk insights in work activities that impacted the availability of the 2B EDG (H.3.a). Enforcement:
10 CFR Part 50.65 (a){4) states, in part, that "the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities." Contrary to the above, on June 18, 2010, Constellation did not adequately assess and manage the increase in risk associated with the maintenance activity on the 28 EDG. This resulted in an underestimation and lack of awareness of the plant CDF risk. Because this violation is of very low safety significance (Green) and Constellation entered the issue into their CAP (CR-2010-006881), this violation is being treated as an NCV consistent with the NRC Enforcement Policy. (NCV 05000318/2010003-01:
Inadequate Risk Assessment Associated with the 28 Emergency Diesel Generator)
1 R15 Operability Evaluations (71111.15-Eight Samples) a. Inspection Scope The inspectors reviewed operability evaluations and/or condition reports (CRs) to verify that the identified conditions did not adversely affect safety system operability or plant safety. The evaluations were reviewed uJ;lng criteria speCified in NRC Regulatory Issue Summary 2005-20, "Revision to Guidance formerly contained in NRC Generic letter Enclosure 12 91-18, Information to Licensees Regarding two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability,>>
and Inspection Manual Part 9900, "Operability Determinations an<,i Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety." In addition, where a component was inoperable, the inspectors verified the Technical Specification limiting condition for operation implications were properly addressed.
The inspectors performed field walkdowns, interviewed personnel.
and reviewed the following items: Minor through-wall leakage on No. 12 SW pump discharge piping downstream of check valve 1-SW-107 (CR-2010-003924); 2A EDG room temperature indicator reads incorrectly (CR-201 0-004032); Loss of level indication for No. 11 B safety injection tank (CR-2010-004557); Several Unit 1 MSSVs wisping (CR-2010-005224); No. 11 charging pump tripped off during low temperature overpressure protection surveillance (CR-201 0-001284); Unit 1 pressurizer safety valve (1-RV-201)
leakage (CR-2010-005182); No. 12 steam generator feed pump did not operate as expected following Unit 1 reactor trip (CR-201 0-005241);
and No. 22 component cooling heat exchanger normal outlet valve (2-CV-5208)
stroke time in the alert range (CR-201 0-006157).
b. Findings No findings of Significance were identified.
1 R18 Plant Modifications (71111.18-Three Samples) a. Inspection Scope The inspectors reviewed the plant modifications listed below to verify that the modifications did not affect the safety functions of systems that are important to safety. The inspectors verified that the system design and licensing bases did not degrade due to the modifications to ensure that the system maintained its availability, reliability, and functional capability.
The inspectors conducted walkdowns of accessible portions of the modifications to verify that the proper configuration control was maintained to ensure that the plant was not placed in an unsafe condition and that the modifications were implemented in accordance with Constellation procedures. Permanent plant modification for power uprate (ES200300421
); Permanent plant modification to replace the Mark I turbine control system with Mark VI turbine control system (ES200300470);
and Permanent plant modification to replace TBVs (FCR-85-0068).
b. Findings Introduction:
The inspectors identified a finding of very low safety significance (Green) associated with an NCVof 10 CFR 50, Appendix B. Criterion III, "Design Control,>>
because Constellation did not perform adequate design reviews associated with modifications to the turbine control system and NSSS. Enclosure 13 Description:
On May 12, 2010, a 500 kV switchyard breaker tripped open while maintenance personnel were restoring DC control power following a wiring modification to the 500 kV switchyard breakers protective relay circuitry.
This disconnected the Unit 1 main generator from the grid. Reactor coolant system (RCS) and secondary pressure rapidly increased until a valid high pressurizer pressure reactor trip occurred.
Both PORVs and several MSSVs lifted as a result of the transient.
The inspectors questioned why the turbine did not trip prior to the reactor trip. DUring review of Constellation's engineering package for the Mark VI turbine control modification, ES200300470, the inspectors determined that the design review was inadequate because Constellation did not properly evaluate the potential adverse impacts of removal of the PLU turbine trip on safety related SSCs, specifically the MSSVs and the pressurizer PORVs. The PLU turbine trip was designed to limit pressure rise in the RCS during a loss of load event. The PLU turbine trip feature senses unbalances between mechanical load and electrical power and initiates a turbine trip if that unbalance reaches a pre-determined setpoint.
The turbine trip signal provides an input into the reactor regulating system that initiates a quick open signal to rapidly open the TBVs and ADVs to limit the pressure rise in both primary and secondary systems. In addition, the turbine trip would cause a loss of load reactor trip. However, for a 100 percent load rejection event without the PLU turbine trip, the reactor would trip on high pressurizer pressure prior to the turbine tripping and the quick opening of the TBVs and ADVs. The inspectors noted that this would unnecessarily challenge both MSSVs and PORVs and could complicate emergency response and plant stabilization.
For example, a high pressurizer pressure reactor trip on Unit 2 on November 16, 2006, resulted in a stuck open PORV for 90 seconds resulting in a SIAS. NRC Generic Safety Issue 70, "PORVand Block Valve Reliability Revision 3" and NRC Generic Letter 06 provide additional operational concerns relating to malfunctions of PORVs. Also, the May 12, 2010, event resulted in the wisping of several MSSVs due to the high-pressure transient that occurred in the secondary system. In addition, the inspectors questioned the performance of the steam dump and turbine bypass system following the May 12, 2010, Unit 1 reactor trip. Section 7.4.6.1 of the Updated Final Safety Analysis Report (UFSAR), states in part, "The steam dump and bypass valves are sized to prevent opening of the MSSVs following a turbine trip at full load." During a review ofthe TBV design calculation, "000-TH-9301,*
Rev. 0, the inspectors identified discrepancies associated with the assumptions.
The inspectors determined that nominal steam generator pressures in the calculation were lower than current operating pressures.
Also, the initial thermal power assumed in the calculation was lower than the current operating thermal power limit. The inspectors determined that during significant changes to plant design such as steam generator replacements and power uprates, Constellation did not perform an adequate evaluation to determine if the TBVlADV design specification of opening within 3 seconds after receiving the quick open signa! would still be sufficient to prevent lifting MSSVs. Calculation stated, "Challenging an MSSV unnecessarily could result in a stuck open MSSV and the possible loss of operator control of the secondary system." Immediate corrective actions included entering these issues into the CAP under CR 2010-006763 and CR 2010-006897, and conducting an immediate operability determination and probabilistiC risk analysis.
Constellation determined that the turbine Enclosure control system and PLU trip were not credited in any UFSAR design basis analysis and the plant remained within its design basis response during Analysis:
The performance deficiency is that Constellation did not perform adequate design reviews associated with modifications to the turbine control system and NSSS. This finding is more than minor because it affected the Initiating Event cornerstone attribute of design control and affects the associated cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations.
Specifically, the removal of the PLU turbine trip and the modifications to the NSSS could challenge primary and secondary overpressure protection devices and result in a stuck open MSSV or PORV. The inspectors evaluated this finding using IMC 0609 Attachment 4, "Phase 1 -Initial Screening and Characterization of Findings." The inspectors determined that a Phase 2 analysis was required because in the worst case if a PORV failed to close following a pressure transient, the resulting loss of primary coolant would exceed the Technical Specifications
{TS} limit for identified RCS leakage. The phase 2 SDP analysis was conducted by the senior reactor analyst (SRA) using the Risk Informed Inspection Notebook for CCNPP's Units 1 and 2, Revision 2.1 a. The SRA made the following assumptions to support the Phase 2 risk assessment:
1) the degraded condition would impact PORV closure safety function only; 2) consistent with the SDP usage rules, this degraded condition is most appropriately modeled by increasing the stuck open PORV (SORV) initiating event frequency by one order of magnitude; 3) since only the PORV closure safety function was impacted, only the stuck open PORV worksheet (Table 3.4) was solved; and 4) the exposure time for this condition was >30 days, The dominant core damage sequences for the stuck open PORV events involved:
the failure to close the block valve with the subsequent failure of high pressure injection; and, the failure to close the block valve with subsequent failure of high pressure recirculation.
The phase 2 analysis determined the issue was of very low safety significance (Green} and estimated an increase in CDF in the mid E-8 range. This finding has a cross-cutting aspect in the area of human performance, decision making, because Constellation did not adequately make safety-significant decisions using a systematic process when faced with uncertain or unexpected plant conditions, to ensure safety is maintained (H.1.a of IMC 0310), This cross-cutting aspect was determined to be consistent with current license performance since the last power up-rate request occurred on August 28,2008. Enforcement:
10 CFR 50, Appendix S, Criterion III, "Design ContrOl," requires licensees to assure deSign control measures include verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculation methods, or by the performance of a suitable testing program. Contrary to the above, on August 29,2008, July 22,2003, and August 15, 2001, Constellation failed to perform an adequate design review during the removal of the PLU turbine trip and modifications to the NSSS system. As a result, Constellation did not recognize that the risk significant changes could unnecessarily challenge operation of the PORVs and MSSVs. Because this violation is of very low safety significance and Constellation entered the issue into their CAP (CR 2010-006763 and CR 2010-006897), this issue is being treated as an NCV, consistent with the NRC Enforcement Policy. (NCV 5000317/318/2010003*02, Inadequate Design Control Reviews ofthe Turbine Control System and the Nuclear Steam Supply System) Enclosure
'I R19 Post-Maintenance Testing (71111.19-Eight Samples) a. Inspection Scope The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability.
The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure was 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. Unit 1 pressurizer safety valve (1-RV-201)
replacement (work order (WO) #C90873154
); Shutdown cooling heat exchanger recirculation stop valve (1-SI-399)
repair (WO #C120052505): Overhaul No, 11 spent fuel pool cooling service water inlet valve (1-CV-1597) (WO #C120001179); No. 12 ECCS pump room air cooler outlet valve (1-CV-5175)
solenoid replacement (roverWO #CR-201 0-005891 0): Inspect relays and perform functional testing of the ADV and TBV quick open (WO #C120085063); Replace No. 14 containment air cooler normal inlet solenoid valve {1-SV-1592} (WO #C12007 4611 ); Replace No. 22 steam generator AFW blocking valve solenoid valve (2-SV-4532) (WO #C220073729);
and No, 21 ECCS pump room air cooler outlet valve (2-CV-5171)
repair (rover WO 2010-004880).
b. Findings No findings of significance were identified.
1 R20Refueling and Other Outage Activities (71111.20 -One Sample) a. Inspection Scope The inspectors reviewed the activities associated with the Unit 1 forced outage due to a reactor trip during switchyard maintenance activities on May 12, 2010. During the outage, the inspectors examined the following activities:
shutdown of the plant; down; heat-up; dilution to criticality; and rise to full power operations.
The inspectors reviewed applicable procedures, observed control room activities, conducted wafkdowns, and interviewed key personnel.
The inspectors evaluated the activities against TS requirements, site procedures, and other applicable guidance and requirements.
Enctosure b. Findings No findings of significance were identified.
1 R22 Surveillance Testing (71111.22-Eight Samples) a. Inspection Scope The inspectors observed and/or reviewed the surveillance tests listed below associated with selected risk-significant SSCs to determine whether the testing adequately demonstrated the ability to perform its intended safety function.
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. No. 12 SW Subsystem Valve Quarterly Operability In-service Test (STP-O-065P-1); Unit 1 RCS Leakage Evaluation (STP-O-27-1); Unit 2 RCS Leakage Evaluation (STP-O-27-2); Reactor Protection System Functional Test (STP-M-212A-1); "An Train Engineered Safety Features Logic Test (STP-O-7A-1); AFW Actuating System Monthly Logic Test (STP-O-009-1); No. 21 AFW Pump Quarterly Surveillance (STP-O-005A-2);
and 28 EDG and 24 kV Bus Loss of Coolant Incident Sequencer (STP-O-OOB-2).
b. Findings No findings of significance were identified.
2. RADIATION SAFETY Comerstone:
Occupational/Public Radiation Safety 2RS05 Radiation Monitoring Instrumentation (71124.05)
a. Inspection Scope During the period May 3 through May 7,2010, the inspectors conducted the following activities to verify that the licensee was ensuring the accuracy and operability of radiation monitoring instrumentation.
Implementation of these controls was reviewed against the criteria contained in 10 CFR Part 20, relevant TS, and Constellation's procedures.
Inspection Planning The inspectors reviewed the UFSAR to identify radiation instruments associated with monitoring area radiological conditions including airborne radioactivity, process streams. effluents, material/articles, and workers; The inspectors obtained a listing of all survey instrumentation including air samplers, small article monitors (SAMs) personnel contamination monitors (PCMs), and other Enclosure 17 monitors used to detect contamination.
The inspectors reviewed the list to determine if an adequate number and type of instruments are available to support operations; The inspectors obtained and reviewed copies of evaluation reports of the monitoring program since the last The inspectors obtained and reviewed copies of procedures used for source checks and The inspectors reviewed area radiation monitor set point values and basis; and The inspectors reviewed the effluent monitor set pOint basis and the methods provided in the Offsite Dose Calculation Manual Walkdowns and Observations The inspectors toured the Auxiliary building and observed the condition of the Unit 1 and Unit 2 liquid discharge tanks and monitor (O-RIT-2201), and the Unit 1 Main Ventilation monitor (1-RI-5415A).
The inspectors verified that these monitor configurations aligned with Calvert Cliffs' aDeM descriptions; The inspectors checked the calibration due dates and source check stickers portable survey instruments ready for issue or in the field. The type of checked included RO-2s, SAC-4, Telepoles, Amp 100s, and The inspectors observed a technician perform instrument source checks. The inspectors verified that the instrument source checks included exposures at each scale. The source check observations included RO-2s, Telepoles, and a SAM-11; and The inspectors verified area radiation monitors (ARMs) and continuous air monitors (CAMs) were appropriately positioned relative to the radiation source(s)
they were intended to monitor. The inspectors compared the monitor response with actual area conditions for several ARMs; and The inspectors observed the daily source checks for PCM-1 B #429 and #417. The inspectors verified the source checks were in accordance with manufacturer's recommendations and Calvert Cliffs' procedures. Calibration and Testing Program Process and Effluent Monitors The inspectors verified for more than four effluent monitor instruments that channel calibration and functional tests were performed consistent with radiological effluent TS. The inspectors verified that the source calibrations used National Institute of Standards and Technology's (NIST) traceable sources or secondary measured have been calibrated to NIST standard. The inspectors verified that the sources represent the plant nuclide mix; The inspectors verified that effluent monitor alarm set pOints are established as provided in the ODCM and station procedures; and There were no changes to effluent monitor set pOints during this inspection period. Enclosure 18 Laboratory Instrumentation The inspectors verified that the daily performance checks and calibration indicate the frequency of calibration is adequate and there is no degradation instrument Whole Body Counter (waC) The inspectors reviewed the methods and sources used to perform the WBC checks prior to daily use. The inspectors verified the checks are appropriate and align with the plant's isotopic mix; and The inspectors reviewed the WBC calibration reports completed since the last inspection.
The inspectors verified the calibration sources and phantoms used were appropriate and representative of the plant source term. Post-Accident Monitoring Instrumentation The inspectors reviewed the February 19 and 25, 2010, calibration records for Unit 1 containment high range monitors, 1-RE-5317A and 1-RE-5317B. inspectors reviewed the February 23,2009, calibration records for the Unit containment high range monitors, 2-RE-5317A and The inspectors verified that an electronic calibration for the containment monitors was performed and included each decade above 1 0 remlhour. inspectors also verified that a source calibration was performed and included exposure for at least one decade below 10 The inspectors verified the acceptance criteria were reasonable; The inspectors reviewed the calibration records and availability for the Unit 1 Range Noble Gas Monitor, the Unit 1 Main Vent Gaseous Radiation Monitor, 5415), and the Unit 2 Main Vent Gaseous Radiation Monitor The inspectors reviewed Calvert Cliffs' capability to collect high-range, post-accident iodine effluent samples; and There were no opportunities to observe electronic or source caJibrations of the high range monitors during this inspection.
Portable Swvey Instruments, ARMs, Electronic Dosimetry, and Air Samplers/CAMs The inspectors reviewed calibration records for an AMS-4, an RO-2, an MP-2. an HD-29, a PM-7, a Telepole, an E-600, and an SAC-4. The inspectors reviewed the detector measurement geometry and calibration methods for ARMs and portable radiation survey instruments.
The inspectors had a technician simulate the use of the instrument calibrator; and The inspectors reviewed the licensee corrective actions taken in response to a failed daily source check for an RM-14. Instrument Calculbrator The inspectors reviewed the current output tables for Calvert Cliffs' portable survey and ARM instrument calibrator unit. The inspectors verified that Calvert Cliffs periodically measures the calibrator output over the range of the instruments; and Enclosure I 19 I * The inspectors verified the calibrator is sent for periodic calibration to a facility that uses NIST traceable sources. I Calibration and Check Sources * The inspectors reviewed Calvert Cliffs' 10 CFR Part 61 source term to verify that the calibration sources used are representative of the types and energies of radiation encountered in the plant. Problem Identification and Resolution
- The inspectors reviewed ten CRs related to radiation monitoring instrumentation and verified that appropriate corrective actions have been taken or initiated.
The inspectors verified that problems are being identified at the appropriate threshold and are properly addressed for resolution.
b. Findings No findings of significance were identified.
2RS06 Radioactive Gaseous and Liquid Effluent Treatment (71124.06)
a. Inspection Scope During the period June 7, 2010, through June 11, 2010, the inspectors conducted the following activities to verify the gaseous and liquid effluent systems are maintained and discharges and conditions are controlled in accordance with applicable regulatory requirements and Calvert Cliffs procedures.
Inspection Planning * The inspectors reviewed the Effluent and Waste Disposal 2008 Annual Report. The inspectors noted no anomalous results and reviewed the effluent monitor operability issues reported;
- The inspectors reviewed the UFSAR and descriptions of the radioactive effluent monitoring systems, treatment systems, and effluent flow paths. The inspectors verified no changes were made to the ODCM since the last inspection.
The inspectors verified there were no systems contaminated with licensed material that were previously uncontaminated;
- The inspectors reviewed reported ground water monitoring results, and changes to the Calvert Cliffs written program for identifying and controlling contaminated spillslleaks to ground water; and * The inspectors reviewed reports and procedures for the effluent program. Walk-downs and Observations
- The inspectors walked down accessible components of the gaseous and liquid discharge systems. The inspectors verified the equipment configuration, equipment physical condition, and flow paths aligned with the UFSAR; Enclosure The inspectors determined no condition surveillance records exist for areas that are not readily accessible; The inspectors walked-down the filtered ventilation systems and verified there were no degraded high efficiency particulate assemblies or charcoal banks, improper alignment, or system installation issues that would impact performance, or the effluent monitoring capability, of the eft1uent system; The inspectors observed sampling and analysis of the Unit 1 main stack ventilation; The Inspectors verified that no changes have been made to effluent release points; and The inspectors observed the sampling and analysis of the 12 reactor coolant waste monitor tank for release. Sampling and Analysis The inspectors verified liquid effluent sampling includes provisions for sample line flushing, vessel recirculation, and composite sampling during a release; The inspectors reviewed three release packages for releases made with monitoring equipment out of service. The inspectors verified that compensatory sampling was performed consistent with the ODCM; The inspectors verified Calvert Cliffs is not routinely relying on the use compensatory sampling in lieu of adequate system maintenance.
The reviewed were during a period when new monitoring equipment was installed; The inspectors reviewed the inter-laboratory comparison program to verify the quality of the radioactive effluent sample analyses and that the program included hard-to-detect isotopes.
Instrumentation and Equipment The inspectors reviewed the methodology Calvert Cliffs uses to determine the effluent stack and vent flow rates. The inspectors verified the flow rates used are consistent with the aDCM values; and The inspectors reviewed surveillance test results for the containment, building, and the spent fuel exhaust to verify they met TS acceptance Dose Calculations The inspectors verified there were no significant changes in the reported values compared to the previous Radiological Effluent Release The inspectors reviewed four liquid and three gaseous release permits to verify that projected doses to members of the public were accurate and based on representative samples; The inspectors reviewed the analysis used to determine radionuclides.
The inspectors verified these radioisotopes were included in source The inspectors reviewed the latest land use census and verified that no were needed to the dose The inspectors verified for the release packages review, the calculated doses within the 10 CFR Part 50, Appendix I and TS dose criteria; Enclosure 21 The inspectors verified there were no abnormal releases during this inspection period. Ground Water Protection Initiative (GPO Implementation The inspectors reviewed the monitoring results of the GPI to verify Calvert Cliffs has implemented their program as intended and to identify any anomalous results; The inspectors verified that no entries were made into the 10 CFR Part 50.75 (g) file during this inspection period; The inspectors verified there were no leaks or spills during this inspection period; The inspectors could not evaluate discharges from onsite surface water bodies because Calvert Cliffs has no onsite surface water bodies; The inspectors verified the results of ground water monitoring are included in the Annual Radiological Environmental Operating Report (AREOR) and the Annual Radiological Effluent Release Report (ARERR); and The inspectors noted that Calvert Cliffs has no new discharge points. Problem Identification and Resolution The inspectors reviewed Calvert Cliffs'
audits, and special reports related to the radiological effluent treatment system to determine if identified problems were entered into the CAP. The inspectors verified that problems identified were put into the CAP and appropriate corrective actions were identified.
b. Findings No findings of Significance were identified.
4. OTHER ACTIVITIES (OA) 40A 1 Performance Indicator (PI) Verification (71151 -Four Samples) Barrier Integrity a. Inspection Scope The inspectors reviewed Constellation's PI program to evaluate, collect, and report information on the following Unit 1 and 2 Pis: RCS specific activity and RCS leak rate. The inspectors reviewed the Pis for the period of April 2009 through March 2010. The inspectors used the guidance provided in Nuclear Energy Institute (NEI) 99-02, "Regulatory Assessment PI Guideline," to assess the accuracy of PI data collected and reported.
The inspectors reviewed RCS sample analysis, control room logs of daily measurements for RCS leakage and compared that information to the data reported by the PI. Additionally, the inspectors observed surveillance activities that determined the RCS identified leakage rate, and chemistry personnel taking and analyzing an RCS sample. Enclosure
.1 No findings of significance were Problem Identification and Resolution (71152 -Three Reviews of Items Entered Into the Inspection Scope The inspectors performed a daily screening, as required by Inspection Procedure (IP) 71152, "Identification and Resolution of Problems," of items entered into Constellation's CAP. The review facilitated the identification of potentially repetitive equipment failures or specific human performance issues for inspection.
The inspectors reviewed the description of each new CR and attended screening meetings. Findings No findings of significance were identified . . 2 Semi-Annual Review Inspection Scope The inspectors performed a review of Constellation's CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors'
review considered the six-month period of October 2009 to March 2010, although some examples expanded beyond those dates when the scope of the trend warranted.
The inspectors compared their results with the results contained in Constellation's quarterly trend reports. operator logs, and CRs. The corrective actions assigned to address select individual issues were reviewed for adequacy. Findings and No findings or observations of significance were identified . Annual Sample: SW Pumps Exceeded Maintenance Rule Unavailability Criteria Inspection Scope This inspection was conducted to assess whether Constellation's corrective actions associated with exceeding the unavailability criteria for two of the three Unit 2 SW pumps were reasonable to correct the identified causes. The inspectors also reviewed equipment performance for additional SW system components, both at Unit 1 and Unit 2. to assess the overall performance of the system. In particular, the inspectors reviewed Constellation's evaluation and corrective actions associated with CR 2009-000630 regarding SW pumps 21 and 23 exceeding the maintenance rule unavailability performance criterion.
The inspectors interviewed station personnel, reviewed component and system performance data, and reviewed procedures to evaluate the Enclosure
.4 performance of the SW system and the effectiveness of Constellation's corrective actions. The inspectors conducted an independent walkdown of selected portions of the SW system to assess the material condition of the system. The inspectors also reviewed system health reports and CRs associated with the SW system to evaluate past performance of the system and determine if Constellation had corrected deficient conditions when identified.
b. Findings No findings of significance were identified.
The inspectors determined that Constellation's actions associated with exceeding the unavailability performance criterion were reasonable to correct the identified causes and return SW pumps 21 and 23 to a 10 CFR 50.65 (a)(2) status. For the CRs reviewed, the associated evaluations were appropriately detailed to identify apparent and/or root causes and to develop suitable corrective actions. During the course of the review, the inspectors noted that the SW system had some equipment challenges (e.g., check and control valve failures), most of which appeared to be attributed to environmental conditions of the system (e.g., silt). Constellation had submitted CRs for the noted deficiencies, and was developing actions to improve equipment performance . Review of Operator Work-Arounds a. Inspection SCORe The inspectors performed an in-depth review of operator work-arounds for CCNPP's Units 1 and 2. This included an evaluation of the potential cumulative affects of all outstanding work-arounds to determine whether they could affect the reliability, availability, and potential for misoperation of a mitigating system, affect multiple mitigating systems, or affect the ability of operators to respond in a correct and timely manner to plant transients and accidents.
The inspectors discussed these potential effects with control room licensed operators.
The inspectors'
evaluation followed the guidelines in IP71152, paragraph 03.02b, and assessed potential work-arounds not evaluated by station personnel, work-arounds that have been formalized as long-term corrective actions, and work-arounds that increase the potential for human performance errors. b. Findings No findings of Significance were identified.
The inspectors determined that operator work-arounds were classified, tracked, and assessed in accordance with Constellation's procedures.
40A3 Followup of Events and Notices of Enforcement Discretion (71153 -One Sample) a. Inspection Scope On May 12, 2010, the inspectors responded to a reactor trip of Unit 1. In the events leading up to the trip, workers were performing a wiring modification to the 500 kV switchyard breakers protective relay circuitry.
While restoring DC control power. a switchyard breaker tripped open and disconnected the Unit 1 main generator from the Enclosure grid. RCS and secondary pressure rapidly increased until a valid high pressurizer pressure trip occurred.
Both PORVs and several MSSVs lifted as a result of the transient.
The cause of the Unit 1 switchyard breaker tripping was determined to be a loose connection located within a 125 VDC switch yard distribution panel that provides DC control power for the switchyard breakers.
The 125 VDC switchyard distribution system supplies power to the switchyard direct current (DC) loads for the operation of switchyard circuit breakers, emergency lights, and protective relays. The inspectors reviewed operator actions to determine if actions taken were in accordance with procedures.
The inspectors also reviewed system indications to verify that system responses were as expected.
In addition, the inspectors reviewed Constellation's initial investigation to assess the adequacy of immediate and interim corrective actions prior to restart. The inspectors compared their observations to the requirements specified in the Constellation procedures.
b. Findings Introduction:
A self-revealing finding of very low safety significance (Green) was identified because Constellation did not establish an appropriate PM program for the 125 VDC switchyard distribution panels in accordance with MN-1, "Maintenance Program." Description:
During a review of Constellation's initial investigation, the root cause analysis report (RCAR), and CRs associated with the May 12, 2010, reactor trip, the inspectors determined that there was no PM program established for the 125 VDC switch yard distribution panels. This is contrary to MN-1, "Maintenance Program," which stated, "A maintenance program shall be developed to maintain structures, systems, and components at the level of quality needed to perform their intended function.
In addition, a PM program shall be used to minimize equipment failure and downtime, and extend equipment life." The inspectors determined that this issue was reasonably within Constellations'
ability to foresee and correct. Under action item IH200400014, Constellation performed an effectiveness review of corrective actions associated with an external organization's recommendations related to grid stability.
One such recommendation stated that all switchyard components that could result in a plant transient should be fully incorporated in the plant's PM program. The inspectors noted that the 125 VDC switchyard distribution panels were scoped into the maintenance rule because the failure of 125 VDC components could result in a plant transient.
However, the effectiveness review did not identify the 125 VDC switchyard distribution panels as equipment that should be included into the plant's PM program. In addition, the vendor technical manual recommended annual inspections of the panels. The RCAR concluded that the loose connection that caused the reactor breaker trip was located in a position in the panel such that a normal PM program would not have identified the equipment deficiency.
The inspectors concluded that there was no direct correlation between the failure to establish a PM program for the 125 VDC distribution panel and the failure to identify the loose connection that caused the May 12, 2010, plant trip. However, the inspectors determined that the failure to establish a PM program for the 125 VDC switchyard distribution panels could preclude the identification of equipment deficiencies that could result in Similar events (i.e. plant transient).
For example, during an extent of condition review following the May 12, 2010, event, Conste.llation identified numerous loose connections in the 125 VDC switchyard distribution panels. Immediate corrective actions included entering this issue into the Enclosure CAP and performing an extent of condition review on similar switch yard panels. term corrective actions planned include establishing an adequate PM program for the 125 VDC switchyard distribution panels. Analysis:
The performance deficiency is that Constellation did not establish an appropriate PM program for the 125 VDC switchyard distribution panels in accordance with MN-1. The finding is more than minor because it is associated with the equipment performance attribute of the Initiating Events cornerstone and affects the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety function.
In addition, if left uncorrected, the performance deficiency could lead to a more significant safety concern. Specifically, the failure to establish a PM program for the 125 VDC panel could preclude the identification of equipment deficiencies, such as loose connections, that could result in a plant transient.
The inspectors evaluated this finding using IMC 0609 Attachment 4, "Phase 1 -Initial Screening and Characterization of Findings." The inspectors determined that the finding is of very low safety significance (Green) because it did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions will not be available.
This finding has a cross-cutting aspect in the area of problem identification and resolution, DE, because Constellation did not use OE information, including vendor recommendations, to support plant safety. Specifically, the licensee did not implement and institutionalize DE through changes to station processes, procedures, equipment, and training associated with the switchyard PM program. (P.2.b of IMC 0305) Enforcement:
This finding does not involve enforcement action because no regulatory violation was identified.
Because this finding does not involve a violation of regulatory reqUirements and has a very low safety significance, it is identified as a finding (FIN). The issue has been entered into Constellation's CAP as CR-2010-005173. (FIN 05000318/2010003-03:
Did Not Establish Preventive Maintenance Program for SWitchyard Panels) 40A5 Other Activities 1. List of Items Opened.
Closed, and Discussed in IR 05000517/518f2010006 The inspectors noted several items in IR 05000517/518/2010006 that were inadvertently listed as "Opened" vice "Opened and Closed." These items are listed as in this inspection report in Attachment 1, List of Items Opened, Closed, and Discussed.
2. NRC Temporary Instruction (TI) 2515/173 a. Inspection Scope During the period June 7,2010, through June 11,2010, the inspectors conducted the following activities to confirm Calvert Cliff's implementation of the voluntary GPI. Enclosure GPI Objective 1.1 -Site Hydrology and Geology The inspectors verified that a hydrology and geologic study was performed by an outside contractor to determine the predominant ground water flow characteristics and gradients.
The contractor issued a report in September 2006; The inspectors verified the study was reviewed by a knowledgeable The inspectors verified that potential pathways have been identified for ground water migration from on-site locations to locations through ground water; The inspectors verified that a five year frequency has been established in Calvert Cliff's procedures for periodic review of the hydro geologic studies; and The inspectors verified that no changes were required to the UFSAR. GPI Objective 1.2 -Site Risk Assessment The inspectors verified that Calvert Cliffs has identified SSCs and work practices that involve or could reasonably be expected to involve licensed material and for which there is a credible mechanism for licensed material to reach ground water; The inspectors verified that Calvert Cliffs has identified leak detection methods for each of the SSCs and work practices that involves or could reasonably be expected to involve licensed material and for which there is a credible mechanism for licensed material to reach ground water; The inspectors verified that potential enhancements to the leak detection systems or programs have been identified; The inspectors verified that potential enhancements have been identified to prevent leaks and spills from reaching ground water; The inspectors verified that Calvert Cliffs'
CAP will be used to identify and corrective The inspectors verified a long-term program has been established to preventative maintenance or surveillance activities to minimize the potential inadvertent releases of licensed materials due to equipment The inspectors verified that a five year frequency has been established in Calvert Cliffs' procedures for periodic review of SSCs and work practices; GPI Objective 1.3 -On-Site Ground Water Monitoring The inspectors verified Calvert Cliffs has considered the placement of wells down gradient from the plant but within the site The inspectors verified that Calvert Cliffs considered placing sentinel wells closer to SSCs that have the highest potential for inadvertent releases that could reach ground water; The inspectors verified that Calvert Cliffs has established sampling and protocols, including analytical sensitivity in site The inspectors verified that a formal written program has been established for long term ground water monitoring.
The inspectors verified that the ODeM has not been revised, per the recommendation of NEI, to include ground water monitoring, as the monitoring locations are not included in the Radiological Environmental Monitoring Program (REMP); Enclosure The inspectors verified that a program has been established in Calvert Cliffs' procedures for the ground water monitoring wells; and The inspectors verified a frequency has been established in Calvert procedures for the periodic review of the ground water monitoring GPI Objective 1.4 -Remediation Process The inspectors verified that written procedures have been established outlining the decision making process for the remediation of leaks and spills or other instances of inadvertent releases; The inspectors verified that an evaluation was performed of the potential detectible levels of licensed material from planned releases of liquids airborne materials; The inspectors verified that an evaluation has been performed and documented on the decommissioning impacts resulting from remediation activities.
GPI Objective 1.5 -Record Keeping The inspectors verified that a record keeping program has been established meet the requirements of 10 CFR Part 50.75 GPI Objective 2.1 -Stakeholder Briefings The inspectors verified Calvert Cliffs has considered including information or updates on ground water protection in the annual reports for state and local officials; Calvert Cliffs is the only nuclear power plant in the State of Maryland and conducted initial briefings with state and local GPI Objective 2.2 -Voluntary Communications The inspectors verified that Calvert Cliffs' procedures establish protocols for communicating leaks and spills to state and local officials; The inspectors verified that the ODCM establishes communication protocols ground or surface water samples exceeding REMP reporting GPI Objective 2.3 -Thirty Day Reports The inspectors verified that ground water samples are analyzed and compared to the standards and limits contained in the ODCM; and The inspectors verified that no thirty-day special reports for ground monitoring have been submitted to the GPI Objective 2.4 -Annual Reporting The inspectors verified that appropriate changes have been made to Calvert Cliffs' procedures to support the 2006 The inspectors verified that all ground water sample results are included in AREOR and the Enclosure The inspectors verified that no ground water samples taken as part of the GPI are part of the REMP program; The inspectors verified that no leaks or spills have been communicated to the state or local officials since the implementation of the GPI; and The inspectors verified that no water sample requests have exceeded REMP reporting thresholds since the implementation of the GPI. GPI Objective 3.1 -Perform a Self-Assessment of the GPI Program The inspectors verified an independent knowledgeable individual performed the initial self-assessment of the ground water program prior to the implementation of the GPI and another self-assessment performed in 2009; The inspectors verified that self-assessments are required every five years per Calvert Cliffs' procedures; The inspectors verified that the self-assessment included an evaluation of at! of the GPI objectives; and The inspectors verified the self-assessments are documented in accordance with Calvert Cliffs' procedures.
GPI Objective 3.2 -Review the Program Under the Auspices of NEI The inspectors verified an independent, knowledgeable individual performed an initial review after the initial assessment; and The inspectors verified that Calvert Cliffs' procedures require periodic review of the GPI program every five years. b. Findings No findings of significance were identified.
This TI is closed. 40A6 Meetings, Including Exit Exit Meeting Summary On July 16, 2010, the resident inspectors presented the inspection results to Mr. George and other members of Constellation staff who acknowledged the findings.
The inspectors asked Constellation whether any of the material examined during the inspection should be considered proprietary.
There was no proprietary information identified.
ATTACHMENTS:
SUPPLEMENTAL INFORMATION Enclosure ATTACHMENT 1 SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Constellation Personnel G. Gellrich, Site Vice President D. Trepanier, Plant General Manager D. Brink, Chemistry Technician C. Conover, Supervisor Chemistry Support D. Frye, Operations Manager R. Fearrington, Radiation Protection Technician J. Gines, System Manager M. Goldman, Engineer Underground Pipes and Tanks G. Helmrich, Chemistry Technician J. Herron, Supervisor Engineering C. Jackson, Senior Engineering Analyst D. Lauver, Director, Licensing C. Ledwich, Radiation Protection Technician S. Loftis, Staff Chemist K. Mills, General Supervisor Shift Operations B. Pickett, Radiation Protection Technician T. Riti, General Supervisor System Engineering A. Simpson, PrinCipal Engineer J. Stanley, Manager, Engineering Services J. Wilson, Supervisor Engineering J. Wynn, Engineer Ventilation LIST OF ITEMS OPENED, CLOSED AND DISCUSSED Ol2ened and Closed 05000318/201 NCV Inadequate Risk Assessment Associated with the 2B EDG (Section 1 R13) 05000317/318/201 NCV Inadequate Design Control Reviews of the Turbine Control System and the Nuclear Steam Supply System (Section 1 R18) 05000317/318/2010003-03 FIN Did Not Establish Preventive Maintenance Program for SWitchyard Panels (Section 40A3) Attachment Closed 05000317/318/2010006-01 NCV Failure to Thoroughly Evaluate and Promptly Correct Degraded Conditions Associated with Auxiliary Building Roof Leakage 05000317/318/2010006-03 NCV Failure to Evaluate Degraded Conditions Associated with CO-8 Relays and Implement Timely and Effective Action to Correct Condition Adverse to Quality 05000317/318/2010006-04 Failure to Translate DeSign Calculation Setpoint of Phase Overcurrent Relay on Feeder Breakers 05000317/318/2010006-05 Failure to Establish Adequate Procedures for Letdown Restoration LIST OF DOCUMENTS REVIEWED Section 1 R01: Adverse Weather Protection Procedures AOP-71-1.
Loss of 4kV, 480V, or 208/120V Instrument Bus Power, Revision 23 AOP-7M. Major Grid Disturbance, Revision 1 ERPIP 3.0, Immediate Actions, Attachment 20, Severe Weather, Revision 44 EP-1-108, Severe Weather Preparation, Revision a NO-1-119.
Seasonal Readiness, Revision 2 OI-22L, Intake Structure Ventilation System, Revision 1 01-28, Operation of 500 kV Switchyard System, Revision 15 OI-38A, Screen Wash System, Revision 23 Miscellaneous FA-10-02, Functional Assessment for 1A EDG SWGR Room Sprinkler System, Revision 0 Seasonal Readiness Status Sheet 2010 Section 1 R04: Equipment Alignment Procedures MN-1-101, Control of Maintenance Activities, Revision 03601, Att. 2 Rover Maintenance Approval and Closeout Form STP-F-77-0, Diesel Fire Pump Staggered Test, Revision 1000 STP M-352-0, Reserve Battery Quarterly Check, Revision 01100 STP M-552(5V)-2, 21 Station Battery Performance Discharge Test, Revision 00901 01-29-2. Saltwater System, Revision 58 Condition Reports CR-2010-004567 CR-2010-000943 CR-2010-004888 Attachment
Maintenance Orders/Work WO WO WO WO Hand-wheel Assembly (SW Valve 5175), Rev.
Inservice Testing Basis Document Section 15 Saltwater Section 1 R05: Fire Protection SA-1, Fire Protection Program, Revision SA-1-i00, Fire Prevention.
Revision 01-20, Fire Protection System, Revision Calculation CA02243, Combustible Loading Analysis Report. Revision FP0002, Fire Hazards Analysis Summary Document, Revision SA-1-i05, Fire Drill Scenario, Revision SE-2, Security Program, Revision Fire Fighting Strategies Manual, Revision UFSAR Section 9.9, Calvert Cliffs Power Plant Fire Protection Program, Revision Section 1 R07: Heat Sink Performance Procedures CNG-AM-1.01-i016, Heat Exchanger Program, Revision 0 EN-1-125, Heat Exchanger Program, Revision 0 EN-1-327, Service Water Reliability Program, Revision 4 ETP 99-002R 22A and 226 SRW HX Thermal Performance Test, September 1, 2009 ETP 98-041R 12A and 128 SRW HX Thermal Performance Test, September 2,2009 01-29-1, Saltwater System, Revision 65 System Health Reports Unit 1 Saltwater System 01 2010 System Health Report Unit 2 Saltwater System 01 2010 System Health Report Miscellaneous EPRI-NP-7552, Heat Exchanger Performance Monitoring Guidelines, December 1991 ES-2009-000391
ECP-09-000196, Revision 000 ESR-09-003888 Attachment A-4 Section 1 R11: Licensed Operator Regualification Program Miscellaneous Lesson Plan LOR 300-3-10, Ops Performance CNG-OP-1.01-1000, Conduct of Operations, Revision 00300 Section 1 R12: Maintenance Effectiveness Procedures ER-1-103, Maintenance Rule Program Implementation, Revision 1 CNG-AM-1, 01-1023, Maintenance Rule Program, Revision 0 Condition Reports CR-20 10-004595 CR-2010-005173 CR-2010-004595 Miscellaneous CCNPP Maintenance Rule Scoping Document, Revision 28 Section 1R13: Maintenance Risk Assessments and Emergent Work Control Procedures Maintenance Rule Risk Assessment Guideline, Revision 7 CNG-OP-4.01-1000, Integrated Risk Management, Revision 00600 CNG-OP-1.01-2000, Operations Logkeeping and Station Rounds, Revision 0 l, I', i 01-21 B-2, 2B Diesel Generator, Revision 19 Condition Plant Statusllntegrated Work Schedule for June 18, Section 1 R15: OQerabilit'l Evaluations CNG-OP-1-01-1002, Conduct of Operability Determinations/Functionality Revision 0 NDE-5710-CC,Section XI Visual Examination (VT-2) for Leakage, Revision 8 NO-1-208, Calvert Cliffs Operability and Maintenance Testing ERPIP-821, Accidental Radioactivity Release Monitoring and Sampling Methods, Revision 5 ERPIP-3.0, Immediate Actions, Attachment 1, Emergency Action Level Criteria, Revision 42 01-29-1, Saltwater System -Unit 1, Revision 65 01-29-1, Saltwater System -Unit 2, Revision 58 Condition Reports CR-2010-003924 CR-2010-001181 CR-2010-004032 CR-2010-004557 CR-2010-006157 CR-2010-005182 Attachment CR-2010-004583 CR-2010-003944 CR-2010-001697 CR-2010-005179 CR-2010-005241 CR-2010-005241 CR-2010-001284 CR-2010-004035 CR-2010-004036 Maintenance OrdersJWork Orders WO #C90839252 WO #C020080307 Miscellaneous Loop Diagram 118 Safety Injection Tank Level (1LT321) Drawing No. 98-611-8, Sheet 11, Revision 8 FA-09-003, Functionality Assessment for the Unit 2 Wide Range Noble Gas Monitor 5415), Revision 0 NEI 99-01, Methodology for Development of Emergency Action Levels, Revision 4 Section iRiS: Plant Modifications Procedures CNG-AM-1.01-1023, Maintenance Rule Program, Revision 00000 CNG-OM-1.01-3000, Issue Response Team, Revision 00000 CNG-OP-1.01-1001, Operational Decision Making, Revision 00100 CNG-OP-1.01-1002, Conduct of Operability Determinations/Functionality, Revision 00100 Maintenance Rule Scoping Document, ReviSion 30 MD-1, Modification Program, Revision 3 MD-1-100, Temporary Alterations, Revision 14 PSTP-04 Variable T-avg Testing, Revision 0400 01-29, Saltwater System -Unit 1, Revision 65 STP 0-658-1,11 SRW Subsystem Valve Quarterly Operability Test, Revision 0410 Condition Reports CR-2010-006763 CR-2010-004805 CR-2010-004299 CR-2010-004284 CR-2010-004601 CR-2010-004508 CR-2010-003752 CR-2010-004290 CR-2010-003758 CR-20 1 0-003839 CR-2010-004288 CR-2010-003904 CR-2010-004798 CR-2010-003465 CR-2010-003900 CR-2010-004797 CR-2010-004291 CR-2010-004798 CR-2010-004601 CR-2010-004292 I R4-000-319 CR-2010-004626 CR-2010-004296 IR4-028-083 CR-2010-004676 CR-2010-004293 CR-2010-004795 CR-2010-004298 Maintenance OrderslWork Orders WO #907001957 WO #C 120085873 WO #C90836235 WO #C907003333 WO #C90799265 WO #C120040214 WO #C907001773 WO #C220040146 Miscellaneous Calculation 000-TH-9301, Turbine Bypass Valve Response During a Loss of Load Event, Revision 0 Attachment ES200300421, Appendix K Power Uprate, Revision 0 ES200300470.
Unit I Mark VI Turbine Control Replacement, Revision 009 FCR 85-0068, Turbine Bypass Valves Equivalency Report, Revision 0 FCR 75-1069, Power Load Unbalance Circuit Installation, Revision 0 AOP-3G, Malfunctions of Main Feedwater System, Revision 01200 EC-20080288*000.
Isolate Instrument Air (1-IA-1302)
to Valve (1-CV-5163)
in Order to Fail it in its Safe Position (Open), Revision 0 EC-20090055-000, Change the Fan Sheaves and Motors for the AFW Pump Room Emergency Ventilation Fans. Revision ECP-09-000039, TCP for 12 MSIV Hydraulic Pressure Alarm, Revision OPESS FY 2009-02 Negative Trend and Recurring Events Involving Feedwater TCF# 90836235, Replace "An Path Pulse Width Modulator and Controller Card in 21 LPEHC, Revision TSCF Section 1R19:
Testing M-500 (BGEDRWG 92401) Instrument and Tubing Instailation, Revision CCNPP Main Feedwater System, System Description No. 45A, Revision Steam Generator Feed Pump Turbines Unit 1(2}, System Description No.
Revision 1 (Revision OP-2, Plant Startup from Hot Standby to Minimum Load, Revision STP 0-27-1(2)
Reactor Coolant System Leakage Evaluation,'
Revision 20(18) OP-3 Power Operation, Revision CNG-CA-1.01-1000, Corrective Action Program, Revision CNG-MN-4.01-1008, Pre/Post Maintenance Testing, Revision STP 0-655-1, ECCS LPSI Loop Isolation Valves Quarterly Operability Test, Revision Condition Reports CR-2010-003985 CR-2010-003985 CR-2010-002795 CR-2010-005182 CR-2010-004562 CR-2010-003660 CR-2010-005891 Maintenance OrderslWork Orders WO #C90873154 WO #C120091179 WO #C120052505 WO #C120085063 WO#C120074611 WO #C220073729 Rover WO #CR-201 0-004880 Rover WO #CR-201 0-005891 Miscellaneous EPRI Engineering Technical Training Modules for Nuclear Plant Engineers-Relief and Safety Valves, October 1999 Attachment A-7 TR-105872, Safety ad Relief Valve Testing Guide, August Specification Limits T57501-1, Wyle Laboratories Certified Test Results, May 15, LER 2006-004-00, Reactor Trip Due to Loose Wire During Maintenance on Turbine LER 2008-002-01, Pressurizer Safety Valve Setpoint High Due to Excessive LER 2008-002-00, Pressurizer Safety Valve Setpoint High Due to Low Torque LER 2003-003-00, Reactor Trip Due to Main Turbine Governor Valves LER 2010-002-00, Pressurizer Safety Valves As-Found Settings Outside Specifications Section 1 R20: Refueling and Other Outage Activities OP-1-1, Plant Startup from Cold Shutdown, Revision OP-2-1, Plant Startup from Hot Standby to Minimum Load, Revision OP-3-1, Normal Power Operation, Revision OP-4-1, Plant Shutdown from Power Operation to Hot Standby, Revision OP-5-1, Plant Shutdown from Hot Standby to Cold Shutdown, Revision OP-6, Pre-Startup Checkoff, Revision OP-7-1, Shutdown Operations, Revision Section 1R22: Surveillance Testing Procedures STP-O-065P-1, 12 SW Subsystem Valve Quarterly Operability Test, Revision 0514 STP-O-27-1, Reactor Coolant System Leakage Evaluation, Revision 02001 STP-O-27-2, Reactor Coolant System Leakage Evaluation, Revision 01B01 STP-M-212A-1, Channel "An Reactor Protective System Functional Test, Revision 0800 STP-O-7A-1, "A" Train Engineered Safety Features Logic Test, Revision 06105 STP-O-005A-2, Auxiliary Feedwater System Quarterly Surveillance, Revision 02102 STP-O-OOBB-2, Test of 2B DG and 24 4KV Bus LOCI Sequencer, Revision 02703 EN-4-102, ASME Pump and Valve Inservice Testing Program Requirements, Revision 6 EN-4-104, Surveillance Testing, Revision 6 EN-4-107, ASME Inservice Testing of Pumps, Revision 1 STP-O-73A-2, Saltwater pump and check valve quarterly operability test, Revision 01700 STP-O-11-1, ECCS Pump Room Ventilation System Monthly Test, Revision 0300 STP-O-65Q-1, Safety Injection System Valve Operability Test, Revision 512 Miscellaneous Fourth-Ten-Year-Plan (lSTPP), Pump and Valve Inservice Testing (1ST) Program Year Interval, Revision 2 Section 2RS05: Radiation Monitoring Instrumentation Procedures ITEC-618, Calibration of Eberline Ion Chamber Models RO-2 and RO-2A, Revision 2 ITEC 668, Generic Calibration Process for Radiation Instrumentation, Revision 0 RSP 1-102, Pre-Operational Checks of Portable Survey Instruments, Revision 19 ETP 09-004, Common Liquid Waste Discharge Monitor, O-RIT-2201 Functional Check, ReVision o Attachment STP M-562-1, Containment High Range Radiation Monitor Alignment Check, Revision 00800 STP M-562-2, Containment High Range Radiation Monitor Alignment Check, Revision 00700 STP-M-563-1, Unit 1 Containment High Range Radiation Monitor Source Check, Revision 0501 STP-M-563-2, Unit 2 Containment High Range Radiation Monitor Source Check, Revision 4 STP-M-564-1, WRNGM Calibration Check, Revision 01203 STP M-564-2, WRNGM Calibration Check, Revision 01403 STP-M-567-0, Gaseous and Liquid Discharge Radiation Monitors Calibration Check, Revision 4 STP M-567-1, Steam Generator Slowdown Recovery Radiation Monitor and Loop Flow Channel Calibration, Revision 00700 STP M-567-2, Steam Generator Blowdown Recovery Radiation Monitor and Loop Flow Channel Calibration, Revision 00600 STP M-567-2, Steam Generator Blowdown Recovery Radiation Monitor and Loop Flow Channel Calibration, Revision 00601 STP-M-569-1, Main Vent Gaseous Radiation Monitor Channel Calibration, Revision 1 STP-M-569-2, Main Vent Gaseous Radiation Monitor Channel Calibration, Revision 1 Condition Reports CR-2010-000382 CR-2010-001995 CR-2010-004148 CR-2010-000733 CR-2010-004397 CR-2010-004937 CR-2010-001300 CR-2010-003862 CR-2010-001712
CR-2010-004062 Calibration Records Portable Radiation Survey Instruments Instrument Type Serial # Calibration Date AMS-4 790 2/16/2010 RO-2 4764 1/23/2010 Telepole 79 1/30/2010 E-520 1006 11/28/2009 Contamination Monitors PM-7 250 611312009 RM-14 1618 10/31/2009 Air Sampler Flow Gauge Gilair 5 1021 117/2010 HD-29 689 6/5/2009 Audits and Self-Assessments SA-RP-007, Self Assessment on Half Body Beta Monitors SA-RP-008, Self Assessment on Gamma Portable Monitors SA-RP-009, Self Assessment on Gamma Sensitive Tool Monitors Attachment Other Report # S92976 Radcal Corporation Section 2RS06: Radioactive Gaseous and Liguid Effluent Treatlment Procedures; CP-422, Waste Processing Sampling System, Revision 00402 CP-601, Liquid Radioactive Waste Release Permit, Revision 01403 CP-604, Radioactive Gaseous Waste Permits, Revision 01800 CP-614. Unmonitored Liquid Radioactive Waste Release Permit, Revision 7 CP-615, Plant Main Vent Releases, Revision 00601 CP-0977, Operation of the Gamma Spectroscopy Counting System. Revision 07 Condition Reports: CR-2009-001693 CR-2009-008224 CR-2009-006112 CR-2009-008227 CR-2009-006712 CR-2010-000733
CR-2009-007583 CR-2010-005219 Audits and Assessments:
CHE-09-01-C, Chemistry Program 5/17/09 10-1 P-C, Calvert Cliffs NPP Periodic Assessment Report for 1/1110 to 4/30/10, 5/25/10 09-3P-C, Calvert Cliffs NPP Periodic Assessment Report for 9/1/09 to 12131/09, 1/27/10 09-2P-C, Calvert Cliffs NPP Periodic Assessment Report for 5/1/09 to 8/31/09,9/25/09 09-1 P-C, Calvert Cliffs NPP Periodic Assessment Report for 1/1109 to 4/30/09, 6/2109 SA-2009-000174, RETS Program, 11/20/09 FSA-2006-79.
Fleet Focused Self Assessment of H3 Ventilation Surveillances STP-M-542-0, SFP HEPA, 8/22108 STP-M-543-, SF Storage Filter Test (Charcoal), 8/31/08 STP-M-545A-1
- 12 Penetration Room Exhaust Filter Test (HEPA and Charcoal.
2/1/08 STP-M-547-1, ECeS Pump Room Exhaust Filter Test (Charcoal), 5/18/09 STP-M-546-1, EeCS Pump Room Exhaust Filter Test (HEPA), 4/30109 1-130, Auxiliary BuHding and Radwaste Area Ventilation Exhaust System HEPA Filter Test, 10/28/09 Release Permits Gaseous 90005 90009 90010 Liquid 90001 90002 90007 90010 Liquid with Monitors OOS 90078 90083 90093 Attachment Section 40A1: Performance Indicator Verification Condition Section 40A2: Problem Identification and Resolution CNG-AM-1.01-1023, Maintenance Rule Program, Revision CNG-CA-1.02-1000, Corrective Action Program, Revision CNG-OP-1.01-1005, Temporary Notes Operator Aids and Permanent Labels, Revision CNG-MN-4.01-1002, Work Order Screening and Prioritization, Revision NO-1-200, Control of Shift Activities, Revision Maintenance Rule Scoping Document, Revision 01-29, Saltwater System -Unit 1, Revision 01-29, Saltwater System -Unit 2, Revision NEI 99-02, Regulatory Assessment Performance Indicator, Revision STP-0-027-1, Reactor Coolant System leakage Evaluation, Revision STP-0-027-2, Reactor Coolant System leakage Evaluation, Revision CP-204, Specification and Surveillance Primary Systems, Revision AOP-6A, Abnormal Reactor Coolant Chemistry/Activity, Revision OI-1A, Reactor Coolant System and Pump Operations, Section 6.9 High RCS Revision WCAP-16465-NP, Pressurized Water Reactor Owners Group Standard RCS leakage Levels and Response Guidelines for PWR's, Revision 0 WCAP-16423-NP, Pressurized Water Reactor Owner's Group Standard Process for Calculating RCS leakage Rate for PWR's, Revision 0 Condition Reports CR-2009-000630 CR-2009-000630
CR-2008-002321 CR-2009-005328 CR-2008-000664 CR-2010-005203 CR-2009-002888 CR-2008-003019 CR-2009-007250 CR-2009-000846 CR-2009-007249 Drawings 62708, Circulating Water Cooling System, Sh. 2, Revision 106 62708, Circulating Saltwater System, Sh. 3, Revision 7 Miscellaneous System Report, Nuclear Saltwater System -Unit 1, 3009, 4010 System Report. Nuclear Saltwater System -Unit 2, 3009, 4010 Calvert Cliffs Unit 1 and Unit 2 Monthly PI Data Attachment Calvert Cliffs Unit 1 and Unit 2 Operator Narrative Logs Site Roll Up 1 51 Quarter 2010 Trend Report Section 40A3: Followup of Events and Notices of Enforcement Discretion Condition Reports CR-2010-005173 CR-2010-005191 CR-2010-005182 CR-2010-006143 CR-2010-006068 CR-2010-006318
CR-2010-005304 CR-2010-005257 CR-2010-005328 CR-2010-005393 IRE-032-680 Miscellaneous STM-0002-0001, 125 VDC Distribution Panels System Technical Manual, Revision 1 BGE Drawing No. 61416E, 500 KV Switchyard 125 VDC Station Service Single-Line Diagram, Revision 13 Section 40A5: Other Activities Procedures EV-1-109, Ground Water Protection Program, Revision 00000 Condition Reports IRE-016-039 CR-2009-004589 CR-2009-004594 CR-2009-004585 CR-2009-004590 CR-2009-003570 CR-2009-004587 CR-2009-004592 CR-2009-004588 CR-2009-004593 Reports Ground Water Flow Evaluation, Calvert Cliffs Nuclear Power Plant, O'Brien and Gere, September 2006 . Attachment A-12 ADAMS ADV ARM AFW AREOR ARERR CAM CAP CCNPP CDF CFR CR DC ECCS EDG FIN GPI IMC IP kV MSSV NCV NEI NIST NSSS "NRC NMR. OE ODCM PARS PCM PM PI PLU PORV RCAR RCS REMP RMA SAM SDP SIAS SRA SSC SW TBV TI LIST OF ACRONYMS Agency-Wide Documents Access and Management System Atmospheric Dump Valve Area Radiation Monitor Auxiliary Feedwater Annual Radiological Environmental Operating Report Annual Radiological Effluent Release Report Continuous Air Monitor Corrective Action Program Calvert Cliffs Nuclear Power Plant Core Damage Frequency Code of Federal Regulations Condition Report Direct Current Emergency Core Cooling System Emergency Diesel Generator Finding Ground Water Protection Initiative Inspection Manual Chapter Inspection Procedure Kilovolt Main Steam Safety Valve Non-Cited Violation Nuclear Energy Institute National Institute of Standards and Technology Nuclear Steam Supply System Nuclear Regulatory Commission Nuclear Medium Risk Operating Experience Offsite Dose Calculation Manual Publicly Available Records Personnel Contamination Monitor Preventive Maintenance Performance Indicator Power Load Unbalance Power Operated Relief Valve Root Cause Analysis Report Reactor Coolant System Radiological Environmental Monitoring Program Risk Management Action Small Article Monitor Significance Determination Process Safety Injection Actuation Signal Senior Reactor Analyst System, Structure and Component Saltwater Turbine Bypass Valve Temporary Instruction Attachment A-13 TS Technical Specifications UFSAR Updated Final Safety Analysis Report VDC Volts of Direct Current WBC Whole Body Counter Attachment