IR 05000317/2014003
| ML14219A624 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 08/08/2014 |
| From: | Ho Nieh Division Reactor Projects I |
| To: | George Gellrich Exelon Generation Co |
| Schroeder D | |
| References | |
| EA-14-100 IR-2014-003 | |
| Download: ML14219A624 (55) | |
Text
{{#Wiki_filter:ust 8, 2014
SUBJECT:
CALVERT CLIFFS NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000317/2014003 AND 05000318/2014003 WITH PRELIMINARY WHITE FINDING
Dear Mr. Gellrich:
On June 30, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Calvert Cliffs Nuclear Power Plant (CCNPP). The enclosed inspection report documents the results, which were discussed on July 23, 2014, with Mr. Mark Flaherty, Plant General Manager, and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
The enclosed inspection report discusses a Unit 2 finding that has preliminarily been determined to be White, a finding with low to moderate safety significance, which may require additional inspections, regulatory actions, and oversight. As described in Section 1R15 of the enclosed report, the finding is associated with an apparent violation of Title 10 of the Code of Federal Regulations (10 CFR) Part 50.54(q)(2), which requires a licensee to develop and maintain an emergency plan which meets the requirements of 10 CFR 50.47(b), and 10 CFR 50, Appendix E. Contrary to these requirements, from October 11, 2013, through March 4, 2014, CCNPP failed to maintain in effect an emergency plan that met the standards in 10 CFR 50.47(b)(4) for Unit 2. Specifically, during the replacement of the Unit 2 main steam line radiation monitors, CCNPPs staff inaccurately calculated the associated emergency action levels (EALs) effluent threshold values for Alert, Site Area Emergency, and General Emergency, and incorporated these thresholds into Table R-1, Effluent Monitor Classification Threshold, of the EALs. This error could have resulted in an over-classification of an event, an unnecessary protective action recommendation, and caused Offsite Response Organizations to implement unnecessary protective actions for the public. Exelon Generation Company, LLC (Exelon) identified the issue, entered it into their corrective action program, implemented appropriate compensatory actions, and initiated corrective actions to revise the EAL table. The inspectors determined the finding no longer presents an immediate safety concern since appropriate compensatory actions have been implemented. The finding was assessed based on the best available information, using the NRCs Emergency Preparedness Significance Determination Process (SDP). The basis for the NRCs preliminary significance determination is described in the enclosed report. Because the finding is also an apparent violation of NRC requirements, it is being considered for escalated enforcement action in accordance with the Enforcement Policy, which appears on the NRCs Web site at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html.
The NRC will inform you, in writing, when the final significance has been determined. We intend to complete and issue our final safety significance determination within 90 days from the date of this letter. The NRCs SDP is designed to encourage an open dialogue between your staff and the NRC; however, the dialogue should not affect the timeliness of our final determination.
We believe that we have sufficient information to make a final significance determination.
However, before we make a final decision, we are providing you an opportunity to provide your perspective on this matter, including the significance, causes, and corrective actions, as well as any other information that you believe the NRC should take into consideration. Accordingly, you may notify us of your decision within 10 days to: (1) request a regulatory conference to meet with the NRC and provide your views in person; (2) submit your position on the finding in writing; or, (3) accept the finding as characterized in the enclosed inspection report.
If you choose to request a regulatory conference, the meeting should be held in the NRC Region I office within 30 days of the date of this letter, and will be open for public observation.
The NRC will issue a public meeting notice and a press release to announce the date and time of the conference. We encourage you to submit supporting documentation at least 1 week prior to the conference in an effort to make the conference more efficient and effective. If you choose to provide a written response, it should be sent to the NRC within 30 days of the date of this letter. You should clearly mark the response as Response to Preliminary White Finding in Inspection Report No. 05000317 & 05000318/2014003; EA-14-100, and send it to the U.S.
Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, Region I, and a copy to the NRC Senior Resident Inspector at CCNPP.
You may also elect to accept the finding as characterized in this letter and the inspection report, in which case the NRC will proceed with its regulatory decision. However, if you choose not to request a regulatory conference or to submit a written response, you will not be allowed to appeal the NRCs final significance determination.
Please contact Daniel Schroeder at (610) 337-5262 within 10 days from the issue date of this letter to notify the NRC of your intentions. If we have not heard from you within 10 days, we will continue with our significance determination and enforcement decision. Because the NRC has not made a final determination in this matter, no notice of violation is being issued for this inspection finding at this time. In addition, please be advised that the number and characterization of the apparent violation may change based on further NRC review.
This report also documents a violation of NRC requirements which was of very low safety significance (Green). Additionally, two licensee-identified violations, which were determined to be of very low safety significance, are listed in this report. 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, consistent with Section 2.3.2.a of the NRC Enforcement Policy. If you contest the non-cited violations 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 I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at CCNPP. In addition, if you disagree with the cross-cutting aspect assigned to any finding, or a finding not associated with a regulatory requirement, 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 I, and the NRC Resident Inspector at CCNPP.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs Agencywide Documents Access and Management 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/ Ho K. Nieh Director Division of Reactor Projects Docket Nos. 50-317 and 50-318 License Nos. DPR-53 and DPR-69
Enclosure:
Inspection Report 05000317/2014003 and 05000318/2014003 w/Attachment: Supplemental Information
REGION I== Docket Nos. 50-317 and 50-318 License Nos. DPR-53 and DPR-69 Report Nos. 05000317/2014003 and 05000318/2014003 Licensee: Exelon Generation Company, LLC (Exelon) Facility: Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Location: Lusby, MD Dates: April 1, 2014 through June 30, 2014 Inspectors: S. Kennedy, Senior Resident Inspector R. Clagg, Senior Resident Inspector E. Torres, Resident Inspector H. Anagnostopoulus, Health Physicist S. Barr, Senior Emergency Preparedness Inspector T. OHara, Reactor Inspector D. Orr, Senior Reactor Inspector A. Rosebrook, Senior Project Engineer Approved by: Daniel L. Schroeder, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure
SUMMARY
IR 05000317/2014003, 05000318/2014003; 04/01/2014 - 06/30/2014; Calvert Cliffs Nuclear
Power Plant Units 1 and 2 (CCNPP); Equipment Alignment and Operability Determination and Functionality Assessments.
This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. The inspectors identified a licensee-identified preliminary low to moderate safety significance (White) finding associated with an apparent violation. Additionally, the inspectors identified a very low safety significance (Green) finding, which was a non-cited violation (NCV). The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP), dated June 2, 2011.
Cross-cutting aspects are determined using IMC 0310, Aspects Within the Cross-Cutting Areas, dated December 19, 2013. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated July 9, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.
Cornerstone: Emergency Preparedness
Preliminary White: The inspectors documented a licensee-identified apparent violation of Title 10 of the Code of Federal Regulations (10 CFR) 50.54(q)(2), which preliminarily has been determined to be of low to moderate safety significance (White). Specifically, 10 CFR 50.54(q)(2) requires a licensee to develop and maintain an emergency plan which meets the requirements of 10 CFR 50.47(b), and 10 CFR 50, Appendix E. Contrary to this requirement, from October 11, 2013, through March 4, 2014, CCNPP failed to maintain in effect an emergency plan that met the standards in 10 CFR 50.47(b)(4) and 10 CFR 50, Appendix E, Section IV.B.1 for Unit 2. CCNPP did not maintain an adequate standard emergency level scheme because inaccurate effluent radiation monitor thresholds were incorporated into Table R-1, Effluent Monitor Classification Threshold. During the replacement of the Unit 2 main steam line radiation monitors (MSLRMs), CCNPPs staff inaccurately calculated the associated emergency action levels (EALs) effluent threshold values for Alert, Site Area Emergency, and General Emergency, and incorporated these thresholds into Table R-1. This error could have resulted in an over-classification of an event and at the general emergency level potentially resulted in an unnecessary protective action recommendation and could cause offsite response organizations to implement unnecessary protective actions. Exelon identified the issue, entered it into their corrective action program (CAP), implemented appropriate compensatory actions, and initiated corrective actions to revise the EAL table. The inspectors determined the finding no longer presents an immediate safety concern since appropriate compensatory actions have been implemented.
The failure to maintain the EAL threshold values in Table R-1 of the site approved emergency plan was a performance deficiency that was within the Exelon staff ability to foresee and correct and should have been prevented. Using IMC 0612, Appendix B, Issue Screening, the performance deficiency was determined to be more than minor because it impacted the procedure quality attribute of the Emergency Preparedness cornerstone and adversely impacts the associated cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, an EAL change was improperly implemented, which could result in an over-classification of an event and at the general emergency level potentially result in unnecessary protective action recommendations and movement of the public. The inspectors utilized IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, to determine the significance of the performance deficiency. The performance deficiency is associated with the emergency classification planning standard and is considered a risk significant planning standard (RSPS) function. This performance deficiency impacts the following required planning standard and RSPS function: 10 CFR 50.47(b)(4), Emergency Classification System. The inspectors were directed by the SDP to compare the performance deficiency with the examples in Section 5.4, 10 CFR 50.47(b)(4), Emergency Classification System, to evaluate the significance of this performance deficiency. Using Table 5.4-1, Significance Examples §50.47(b)(4)," the inspectors determined that the performance deficiency matched an example of a degraded RSPS function, which would be assessed as
- White.
Specifically, the example states, in part, that the performance deficiency would be assessed White if the EAL classification process would result in an over-classification that would lead to off-site response organizations implementing, by procedure, unnecessary protective actions for the public. This condition should also be considered met if the licensee would make a protective action recommendation to the off-site response organizations because of the over-classification.
The inspectors determined that the cross-cutting aspect that contributed most to the root cause is H.12, Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes.
Individuals implement appropriate error reduction techniques. Specifically, Exelon staff did not independently validate the new EAL threshold values prior to revising and implementing the EAL scheme change. (Section 1R15) Green: The inspectors identified a Green NCV of 10 CFR 50.54 (q)(2) and 10 CFR 50.47(b)(4) because Exelon did not maintain the emergency plan to adequately meet the standards in 10 CFR 50.47(b)(4). Specifically, Exelon failed to include Unit 1 and Unit 2 component cooling (CC) rooms under EAL initiating condition HA3.1. As a result, an Alert declaration would have not been made during a hazardous gas event in a vital area. Exelon entered this issue into their CAP as condition report (CR)-2014-004683. Immediate corrective actions included revising EAL initiating condition HA3.1 to include the CC rooms and verify that there are no other areas that need to be included in EAL HA3.1.
The failure to update the EAL scheme the site approved emergency plan following a plant modification was a performance deficiency that was within the Exelon staff ability to foresee and correct and should have been prevented. Using IMC 0612, Appendix B, Issue Screening, the performance deficiency was determined to be more than minor because it impacted the procedure quality attribute of the Emergency Preparedness cornerstone and adversely impacts the associated cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, a plant modification was completed which required operators to be able to enter the CC room in order to bring the plant to cold shutdown and the EAL scheme was not updated to reflect this change. The inspectors utilized IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, to determine the significance of the performance deficiency. The performance deficiency is associated with the emergency classification planning standard and is considered a RSPS function. This performance deficiency impacts the following required planning standard and RSPS function: The inspectors were directed by the SDP to compare the performance deficiency with the examples in Section 5.4, 10 CFR 50.47(b)(4), Emergency Classification System, to evaluate the significance of this performance deficiency. The inspectors determined that the EAL was ineffective because it, in and of itself, no longer resulted in a timely and accurate declaration of an Alert for the initiating condition. Utilizing Figure 5.4.1, an ineffective EAL where an Alert would not be declared when required would screen as a Green finding.
This finding has a cross-cutting aspect in the area of Human Performance, Change Management, because Exelon personnel didnt use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority. Specifically, Engineering personnel did not ensure that the impact to the Emergency Plan was adequately evaluated as a result of the permanent plant change engineering change package (ECP)-11-000983 [H.3]. (Section 1R15)
Other Findings
Two violations of very low safety significance that were identified by the licensee have been reviewed by the inspectors. Corrective actions taken, or planned, by Exelon staff has been entered into Exelons CAP. These violations and corrective action tracking numbers are listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status
Unit 1 began the inspection period at 100 percent power. On May 1, 2014, the unit tripped due to a malfunction in the reactor protection system (RPS) trip circuit breakers testing matrix. On May 2, operators commenced a unit start up. On May 3, operators synchronized the unit to the grid. On May 4, the unit was returned to 100 percent power. The unit remained at or near 100 percent power for the remainder of the inspection period.
Unit 2 began the inspection period at 100 percent power. On June 20, 2014, operators down powered the unit to 82 percent power to conduct main condenser water box cleaning. On June 21, operators returned the unit to 100 percent power. On June 28, operators down powered the unit to 86 percent power to conduct main condenser water box cleaning. On June 29, the unit was returned to 100 percent power. The unit remained at or near 100 percent power for the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 Readiness for Seasonal Extreme Weather Conditions
a. Inspection Scope
The inspectors performed a review of Exelons readiness for the onset of seasonal high temperatures. The review focused on emergency diesel generators (EDGs). The inspectors reviewed the Updated Final Safety Analysis report (UFSAR), technical specifications (TS), control room logs, and the CAP to determine what temperatures or other seasonal weather could challenge this system, and to ensure Exelon personnel had adequately prepared for these challenges. The inspectors reviewed station procedures, including Exelons seasonal weather preparation procedure and applicable operating procedures. The inspectors performed walkdowns of the selected system to ensure station personnel identified issues that could challenge the operability of the systems during hot weather conditions. Documents reviewed for each section of this inspection report are listed in the Attachment.
b. Findings
No findings were identified.
.2 Summer Readiness of Offsite and Alternate Alternating Current (AC) Power Systems
a. Inspection Scope
The inspectors performed a review of plant features and procedures for the operation and continued availability of the offsite and alternate AC power system to evaluate readiness of the systems prior to seasonal high grid loading. The inspectors reviewed Exelons procedures affecting these areas and the communications protocols between the transmission system operator and Exelon. This review focused on changes to the established program and material condition of the offsite and alternate AC power equipment. The inspectors assessed whether Exelon established and implemented appropriate procedures and protocols to monitor and maintain availability and reliability of both the offsite AC power system and the onsite alternate AC power system. The inspectors evaluated the material condition of the associated equipment by reviewing CRs and open work orders, and walking down portions of the offsite and AC power systems including the 500 kilovolt (kV) switchyard.
b. Findings
No findings were identified.
.3 External Flooding
a. Inspection Scope
During the week of June 2, 2014, the inspectors performed an inspection of the external flood protection measures for CCNPP. The inspectors reviewed TS, procedures, design documents, and the UFSAR, Chapter 2.5, which depicted the design flood levels and protection areas containing safety-related equipment to identify areas that may be affected by external flooding. The inspectors conducted a general site walkdown of external areas of the plant, including the auxiliary building and intake structure to ensure that Exelon flood protection measures were in accordance with design specifications.
The inspectors also reviewed operating procedures for mitigating external flooding during severe weather to determine if Exelon planned or established adequate measures to protect against external flooding events.
b. Findings
No findings were identified. ==1R04 Equipment Alignment
.1 Partial System Walkdowns
==
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems: 13 Battery charger with 21 battery charger out of service on April 30, 2014 0C EDG during 1A EDG outage window on May 20, 2014 21B Service water (SRW) heat exchanger (HX) with 21A SRW HX out of service on May 27, 2014 23 Saltwater (SW) pump with 22 SW pump out of service on June 17, 2014 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable procedures, system diagrams, the UFSAR, TS, CRs, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable.
The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Exelon staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.
b. Findings
No findings were identified.
.2 Complete System Walkdown
a. Inspection Scope
On June 4, 2014, the inspectors performed a complete system walkdown of accessible portions of the containment isolation system, to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, emergency operating procedures (EOP), surveillance tests, drawings, equipment line-up check-off lists, and the UFSAR to verify the system was aligned to perform its required safety functions.
The inspectors reviewed CA06453, Steam Generator Tube Rupture using Alternate Source Terms, and maintenance strategies for certain containment isolation valves (CIVs). The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies.
Additionally, the inspectors reviewed a sample of related CRs and work orders to ensure Exelon appropriately evaluated and resolved any deficiencies.
b. Findings
Introduction:
An unresolved item (URI) was identified by the inspectors relating to an issue regarding the failure of Exelon to scope main steam line drains (MSLDs) and CIVs motor operated valves (MOVs) (6611, 6612, 6613, 6615, 6620, and 6621) into their in-service testing (IST) program.
Description:
The inspectors identified an issue of concern involving Exelons scoping of MSLD MOVs into the IST program. The MSLD MOVs are normally open valves with the ability to be remotely-operated from the main control room. The MSLD MOVs are classified as CIVs per UFSAR, Figure 5-10, Containment Structure Isolation Valve Arrangement, Sheet 24 and 25. This figure classifies the main steam penetrations as Type III, and requires the valves to be closed to perform their CIV function. UFSAR, Section 5.2, Isolation System, Subsection 5.2.2, System Design, defines a Type III penetration as a line not directly connected to the reactor coolant system (RCS) or the containment structure atmosphere that has at least one valve, either a check valve or a remotely-operated valve, outside of the containment structure. These valves are classified as American Society of Mechanical Engineers (ASME) Code, Class 2, per drawing 60740, Sheet 0001, Steam Line Drainage System, Revision 39, and M-601, Piping Class Summary Sheets, Revision 49. The ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) 2004, Subsection ISTA, General Requirements, Section ISTA-1100, Scope, states in part, Section IST establishes the requirements for pre-service and IST and examination of certain components to assess their operational readiness in light-water reactor nuclear power plants. These requirements apply to: a) pumps and valves that are required to perform a specific function in shutting down the reactor to the safe shutdown condition, in maintaining the safe shutdown condition, or in mitigating the consequences of an accident. 10 CFR 50.55a(f)(1), Codes and Standards, requires the establishment of OM Code IST test requirements to components which are classified ASME Code Class 1, 2 and 3.
The inspectors require additional information from Exelon to determine if there is a performance deficiency which is more than minor. Specifically, the revision to calculation CA06453, Steam Generator Tube Rupture Accident Using Source Terms; calculation referenced in April 6, 1988, memo from D. S. Elkins to B. B. Mrowca, Impact of the Main Steam Drain Line on the 10CFR100 Limits of the Steam Generator Event; and for CCNPP to research which standard for the design of CIVs the plant was licensed to (equivalent to ANSI N271-1976, Containment Isolation Provisions for Fluid Systems.) The issue is identified as (URI 05000317/318/2014003-01, Main Steam Line Drain Containment Isolation Valves not Scoped in In-Service Testing Program.)
==1R05 Fire Protection