IR 05000317/2011010

IR 05000317-11-010, 05000318-11-010, 10/24/2011, 11/18/2011; Constellation Energy Nuclear Group, Llc; 10/24/2011 - 11/18/2011; Calvert Cliffs Nuclear Power Plant, Units 1 & 2, Biennial Baseline Inspection of Problem Identification and Resol

ML11350A236
Person / Time
Site:	Calvert Cliffs
Issue date:	12/16/2011
From:	Dentel G T Reactor Projects Branch 1
To:	Gellrich G H Constellation Energy Nuclear Group, Calvert Cliffs
Dentel G T
References
IR-11-010
Download: ML11350A236 (20)

Text

s** aEcut4b^W;+***i December 16,2011George H. Gellrich, Vice PresidentCalvert Cliffs Nuclear Power Plant, LLCConstellation Energy Nuclear Group, LLC1650 Calvert Cliffs ParkwayLusby, Maryland 20657 -47 02CALVERT CLIFFS NUCLEAR GENERATING STATION - NRC PROBLEMIDENTIFICATION AND RESOLUTION INSPECTION REPORT0500031 7 12011 01 0 AND 0500031 81201 1010

Dear Mr.On November 18,

2011, the United States Nuclear Regulatory Commission (NRC) completedan inspection at your Calvert Cliffs Nuclear Power Plant (CCNPP) Units 1 and 2. The enclosedreport documents the inspection results discussed with Mr. Chris Costanzo, Plant Manager, andother members of your staff.This inspection examined activities conducted under your license as they relate to identificationand resolution of problems, and compliance with the Commission's rules and regulations andconditions of your license. Within these areas, the inspection involved examination of selectedprocedures and representative records, observations of activities, and interviews withpersonnel.Based on the samples selected for review, the inspectors concluded that Constellation wasgenerally effective in identifying, evaluating, and resolving problems. Calvert Cliffs personnelidentified problems and entered them into the corrective action program at a low threshold.Calvert Cliffs personnel, in general, prioritized and evaluated issues commensurate with thesafety significance of the problems and corrective actions were implemented in a timely manner.Based on the results of this inspection, no findings were identified.

G. GellrichIn accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, and your response (if any)will be available electronically for public inspection in theNRC Public Document Room or from the Publicly Available Records (PARS) component of theNRC's document system (ADAMS). ADAMS is accessible from the NRC website athttp://www.nrc.sov/readinq-rm/adams.html (the Public Electronic Reading Room).2Docket Nos.:License Nos.:

Enclosure:

cc w/encl:

Sincerely,/RA/Glenn T. Dentel, ChiefReactor Projects Branch 1Division of Reactor Projects50-317,50-318DPR-53, DPR-69lnspection Report 0500031 7 1201101 0 and 0500031 812011010

w/Attachment:

Supplementary InformationDistribution via ListServDistribution denclW. Dean, RAD. Lew, DRAD. Roberts, DRPD. Ayres, DRPC, Miller, DRSP. Wilson, DRSM. Franke, RIOEDOG. Dentel, DRPN. Perry, DRPJ. Hawkins, DRPK. Cronk, DRPN. Floyd, DRPS. Kennedy, DRP, SRIE. Tones, DRP, RlRidsNrrPMCalvertCl iffs ResourceRidsNrrDorllpl 1 -1 ResourceROPreports ResourceSUNSI Review Complete: TS (Reviewer's lnitials) ML 11350A236DOCUMENT NAME: GTDRP\BRANCH TSAB\lnspection Reports\CalvertClitfs Pl&R 2011\CC PIR Report 20110'10 rev 3.docxAfter declaring this document 'An Official Agency Record', it will be released to the Public.To lecsive aof this document, indicate in the box: 'Q' = Copy without attachmenVenclosure 'E' =with attachmenVenclosure'N' = No copy12116111211411112116111OFFICIAL RECORD COPY G. GettrichIn accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, and your response (if any) will be available electronically for public inspection in theNRC Public Document Room or from the Publicly Available Records (PARS) component of theNRC's document system (ADAMS). ADAMS is accessible from the NRC website athttp ://www.!rc. oouf readinq-llr/adams. html (the Public Electronic Rea d ing Room ).

Sincerely.-At*T^9ffiDocket Nos.:License Nos.:

Enclosure:

cc Mencl:Glenn T. Dentel, ChiefReactor Projects Branch 1Division of Reactor Projects50-317,50-318DPR-53, DPR.69lnspection Report 05000317/201 1 010 and 0500031812U1A1AM

Attachment:

Supplementary l nformationDistribution via ListServ Docket Nos.:License Nos.:Report No.:Licensee:Facility:Location:Dates:Team Leader;Inspectors:Approved by:1U.S. NUCLEAR REGULATORY COMMISSIONREGION I50-317,50-318DPR.53, DPR-690500031 7 /201 1 01 0 and 0500031 81201 1 010Constellation Energy Nuclear Group, LLCQalvert Cliffs Nuclear Power Plant, Units 1 and 2Lusby, MDOctober 24,2011 through November 18,2011Thomas C. Setzer, PE, Senior Project Engineer, Division of ReactorProjects (DRP)K, Dunham, Reactor Engineer, DRPC. Newport, Operations Engineer, Division of Reactor Safety (DRS)L. Scholl, Senior Reactor lnspector, DRSGlenn T. Dentel, ChiefReactor Projects Branch 1Division of Reactor ProjectsEnclosure 2

SUMMARY OF FINDINGS

lR 0500031712011010 and 0500031 812011010; 1012412011 - 1111812011; Calvert Cliffs NuclearPower Plant (CCNPP), Units 1 and 2; Biennial Baseline Inspection of Problem ldentification andResolution,This NRC team inspection was performed by four regional inspectors. The NRC's program foroverseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.No findings were identified during this inspection.Problem ldentification and ResolutionThe inspectors concluded that Constellation was generally effective in identifying, evaluating,and resolving problems, Constellation personnel identified problems, entered them into thecorrective action program at a low threshold, and in general, prioritized issues commensuratewith their safety significance. In most cases, Constellation appropriately screened issues foroperability and reportability, and performed causal analyses that appropriately consideredextent of condition, generic issues, and previous occurrences. The inspectors also determinedthat Constellation typically implemented corrective actions to address the problems identified inthe corrective action program in a timely manner.The inspectors concluded that, in general, Constellation adequately identified, reviewed, andapplied relevant industry operating experience to Calvert Cliffs operations. In addition, basedon those items selected for review, the inspectors determined that Constellation's self-assessments and audits were thorough.Based on the interviews the inspectors conducted over the course of the inspection,observations of plant activities, and reviews of individual corrective action program andemployee concerns program issues, the inspectors did not identify any indications that sitepersonnelwere unwilling to raise safety issues nor did they identify any conditions that couldhave had a negative impact on the site's safety conscious work environment.Enclosure

4.40.A23

REPORT DETAILS

orHER ACTTVTflES (OA)Problem ldentification and Resolution (7 11528)This inspection constitutes one biennial sample of problem identification and resolutionas defined by NRC Inspection Procedure 71152. Alldocuments reviewed during thisinspection are listed in the Attachment to this report.Assessment of Corrective Action Proqram Effectivenegslnspection ScopeThe inspectors reviewed the procedures that described Constellation's corrective actionprogram at Calvert Cliffs. To assess the effectiveness of the corrective action program,the inspectors reviewed performance in three primary areas: problem identification,prioritization and evaluation of issues, and corrective action implementation. Theinspectors compared performance in these areas to the requirements and standardscontained in 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," andConstellation procedure CNG-CA-1.01-1000, "Corrective Action Program." For each ofthese areas, the inspectors considered risk insights from the station's risk analysis andreviewed condition reports selected across the seven cornerstones of safety in theNRC's Reactor Oversight Process. Additionally, the inspectors attended multiple Plan-of-the-Day meetings, Condition Report screening meetings, and Management ReviewCommittee meetings. The inspectors selected items from the following functional areasfor review: engineering, operations, maintenance, emergency preparedness, radiationprotection, chemistry, physical security, the Maintenance Rule program, the boric acidcorrosion control program, and oversight programs..1(1) Effectiveness of Problem ldentificationln addition to the items described above, the inspectors reviewed system health reports,a sample of completed corrective and preventative maintenance work orders, completedsurveillance test procedures, operator logs, and periodic trend reports. The inspectorsalso completed field walkdowns of various systems and areas on site, such as theemergency diesel generators, emergency core cooling pump rooms, auxiliary feedwaterpump room, intake structure, turbine building, control room, centralalarm station,secondary alarm station, armory, and switchgear rooms. Additionally, the inspectorsreviewed a sample of condition reports written to document issues identified throughinternal self-assessments, audits, emergency preparedness drills, and the operatingexperience program. The inspectors completed this review to verify that Constellationentered conditions adverse to quality into their corrective action program as appropriate.(2) Effectiveness of Prioritjzation and Evaluation of lssuesThe inspectors reviewed the evaluation and prioritization of a sample of condition reportsissued since the last NRC biennial Problem ldentification and Resolution inspectioncompleted in November 2009. The inspectors also reviewed condition reports that wereassigned lower levels of significance (Category 3 and 4) that did not include formalcause evaluations to ensure that they were properly classified. The inspectors' reviewEnclosure 4included the appropriateness of the assigned significance, the scope and depth of thecausal analysis, and the timeliness of resolution. The inspectors assessed whether theevaluations identified likely causes for the issues and developed appropriate correctiveactions to address the identified causes. Further, the inspectors reviewed equipmentoperability determinations, reportability assessments, and extent-of-condition reviews forselected problems to verify these processes adequately addressed equipmentoperability, reporting of issues to the NRC, and the extent of the issues.(3) Effectiveness of Corrective ActionsThe inspectors reviewed Constellation's completed corrective actions throughdocumentation review and, in some cases, field walkdowns to determine whether theactions addressed the identified causes of the problems. The inspectors also reviewedcondition reports for adverse trends and repetitive problems to determine whethercorrective actions were effective in addressing the broader issues. The inspectorsreviewed Constellation's timeliness in implementing corrective actions and effectivenessin precluding recurrence for significant conditions adverse to quality. The inspectorsalso reviewed a sample of condition reports associated with selected non-cited violations(NCVs) and findings to verify that Constellation personnel properly evaluated andresolved these issues. ln addition, the inspectors expanded the corrective action reviewto five years to evaluate Constellation's actions related to the boric acid corrosion controlprogram (BACCP).b. Assessnlent(1) Effecliveness of Problem ldentificationBased on the selected samples, plant walkdowns, and interviews of site personnel inmultiple functional areas, the inspectors determined that Constellation, in general,identified problems and entered them into the corrective action program at a lowthreshold. Constetlation staff at Calvert Cliffs initiated approximately 21,500 conditionreports between December 2009 and October 2011. The inspectors observedsupervisors at the Plan-of-the-Day meetings, Condition Report screening meetings, andManagement Review Committee meetings appropriately questioning and challengingcondition reports to ensure clarification of the issues. Based on the samples reviewed,the inspectors determined that Constellation trended equipment and programmaticissues, and appropriately identified problems in condition reports. The inspectorsverified that conditions adverse to quality identified through these reviews were enteredinto the corrective action program as appropriate. Additionally, inspectors concludedthat personnelwere identifying trends at low levels.The inspectors performed a walkdown of the Unit 2 service water pump room, andidentified an issue that had not been previously entered into the corrective actionprogram. This included a ladder, fan, and a section of floor grating that were notproperly stored or seismically restrained in accordance with Constellation procedures. Inresponse to the team's discovery of the issue, Constellation removed the materials fromthe room, and performed an operability screening to determine if the items would havecaused the Unit 2 service water system to become inoperable during a seismic event.Constellation determined that the items did not present a concern for operability. Thefailure to properly store or seismically restrain the items in the Unit 2 service water pumproom was determined to be a performance deficiency because Constellation failed toEnclosure 5follow procedural requirements for storing or seismically restraining the items. Theinspectors evaluated this issue for significance in accordance with NRC inspectionmanual chapter (lMC) 0612, Appendix B, "lssue Screening," and IMC 0612, Appendix E,'Examples of Minor lssues." Since the items did not adversely affect the operability ofthe safety-related equipment in the Unit 2 service water pump room, this performancedeficiency was determined to be minor and not subject to enforcement action inaccordance with the NRC's Enforcement Policy. Constellation personnel promptlyinitiated condition reports and took immediate action to address the issues previouslydescribed (CR 201 1 -01 0689, 0107 1 4).(2) Effectiveneqs of Prioritization and Evalglltion of lssuesThe inspectors determined that, in general, Constellation appropriately prioritized andevaluated issues commensurate with the safety significance of the identified problem.Constellation screened condition reports for operability and reportability, prioritized thecondition reports by significance (Category 1 - most significant, through Category 4 -least significant), and assigned actions to the appropriate department for evaluation andresolution. The condition report screening process considered human performanceissues, radiological safety concerns, repetitiveness, adverse trends, applicability ofrelevant operating experience, and potential impact on the safety conscious workenvironment.Operability and reportability determinations were generally performed when conditionswarranted and the evaluations supported the conclusion. Causalanalyses appropriatelyconsidered the extent of condition or problem, generic issues, and previous occurrencesof the issue. However, the inspectors did note some observations in Constellation'sprioritization and evaluation of the following issues.Cateoory 3 Condiiion Report Closure Docum,entationDuring the review of corrective action closure documentation contained in conditionreports, the inspectors identified that there were numerous Category 3 condition reportevaluations which lacked sufficient detail to determine the full scope of actions taken byConstellation. This required Constellation staff to research and retrieve the additionalinformation needed to fully describe the actions taken. A weakness in closuredocumentation had been previously identified by the Constellation Quality Assurance(OPA) department in December 2010 (OPA Assessment Report 2010-103)forCategory 2 condition reports; in that, corrective actions were noted to be absent ofobjective evidence of the actions performed, and that the traceability and auditing of thecompleted actions could not be easily accomplished. Constellation procedure CNG-CA-1.01-1000, "Corrective Action Program," requires that Category 3 condition reports willbe evaluated to the extent required at the discretion of the supervisor; however, for theexamples reviewed by the inspectors, the extent of closure documentation was notadequate to fully understand the corrective actions taken, and impeded the traceabilityand auditing of corrective actions, The inspectors determined that this issue did notrepresent a violation of NRC requirements, Constellation entered this issue in thecorrective action program (CR 2011-010801).Enclosure 6Annunciator Card Failures Not Evaluated Within th-e Maintenance RuleThe team reviewed condition reports pertaining to Constellation's Maintenance Ruleprogram which described numerous control room annunciator card failures that occurredin 2008 and 2009. Annunciator cards are scoped within the Constellation MaintenanceRule program and their performance is classified in accordance with 10 CFR 50.65paragraph (aX2). Failures of the annunciator cards are required to be evaluated aspotential Maintenance Rule Functional Failures (MRFFs) or Maintenance PreventableFunctional Failures (MPFFs) to determine if continued classification in 10 CFR 50.65paragraph (aX2) is appropriate. The inspectors reviewed the evaluations containedwithin the condition reports and were unable to find any documented evidence ofMaintenance Rule failure screening evaluations. Constellation procedure CNG-CA-1.01-1000, "Corrective Action Program," requires every condition report to be reviewed by theMaintenance Rule coordinator so that the performance of a Maintenance Ruleevaluation may be completed for components which are scoped in the MaintenanceRule. The inspectors determined that the failure to document the Maintenance Ruleevaluation of the annunciator card failures in 2008 and 2009 did not meet therequirements of Constellation procedure CNG-CA-1.01-1000. A subsequent review andevaluation performed by Constellation revealed that all of the 2008 and 2009 failureswere appropriately classified and did not represent any additional MPFFs or MRFFswhich would have required Constellation to have classified the system in accordancewith 10 CFR 50.65 paragraph (aX1). Since classification in 10 CFR 50.65 paragraph(aX2) was appropriate and there were no unaccounted MRFFs or MPFFS, the inspectorsdetermined this issue was of minor significance and therefore not subject to enforcementaction in accordance with the NRC's Enforcement Policy. Constellation entered theissue into the corrective action program (CR 2011-01 1385)CR 2010-001378. Failure to Establish Adequate Procedures for Letdown Restoratign(Cateqorv 3)The vast majority of condition reports reviewed by the team were adequately categorizedfor evaluation. Constellation procedure CNG-CA-1.01-1000, "Corrective ActionProgram," Attachment 3, "Condition Report Categorization Criteria," defines eachcondition report category in terms of how acceptable or unacceptable occurrence of thedegraded condition should be. The following definitions are listed in the procedure:o Category 1 - "Recurrence is unacceptable"o Category 2Tier l - "Rare occurrence is undesirable"r Category 2Tier ll - "Rare occurrence may be acceptable"r Category 3 - "Occasional occurrence is acceptable"o Category 4 - "Trend Only"The procedure also provides typical examples for each category, and further states thatthe list is not all inclusive and as such, a higher or lower category may be appropriate.This guidance provides the condition report screener flexibility to either increase ordecrease the condition report category level. The inspectors determined that the staff'suse of the flexibility allowed by the procedure could lead to a lower than appropriatecategory being assigned. The inspectors identified the following example where a lowerthan appropriate category level was chosen for a degraded condition.Enclosure 7On February 18, 2010, a phase to ground over-current fault on the 128 reactor coolantpump switchgear resulted in an automatic reactor trip on Unit 1. As a result, protectiverelaying isolated the letdown portion of the chemical and volume control system (CVCS).Operators worked to stabilize pressurizer level, which approached and later exceededplant emergency operation procedure (EOP) high level limits. Operators were unable toimmediately restore letdown because of a closed excess flow check valve. Due toinadequate procedural guidance, letdown was not reestablished until approximately fivehours after event initiation. A Category 3 condition report was written by Constellation,which later established procedural guidance relating to letdown restoration followingclosure of the excess flow check valve.The inspectors determined that the operator challenges in controlling pressurizer level,which eventually led to the EOP high level limit being exceeded, and the inadequateprocedural guidance which prevented operators from re-opening the excess flow checkvalve represented a condition that was not suitable to be categorized as "occasionaloccurrence is acceptable" (Category 3). Discussions with Constellation revealed that theCategory 3 categorization was deemed appropriate and allowed by procedure throughthe guidance describing that a higher or lower category may be selected for anycondition report. The inspectors determined that a Category 2 apparent causeevaluation would have been the appropriate category level to adequately investigate andexplore the extent of condition, extent of cause, and generic issues surrounding theevent.The inspectors evaluated the example of inappropriate categorization noted above forsignificance in accordance with the guidance in IMC 0612, Appendix B, "lssueScreening," and Appendix E, "Examples of Minor lssues." While the inspectorsconcluded the condition report was not categorized appropriately, the issues wereresolved adequately by Constellation staff. Furthermore, the vast majority of conditionreports reviewed by the team throughout the inspection were categorized properly.Specifically, the team did not identify any Category 1 or 2 condition reports that hadbeen prioritized inappropriately, and all Category 3 condition reports reviewed with theexception of the example above were prioritized appropriately. The inspectorsconcluded that the above example did not represent a programmatic weakness inConstellation's ability to properly categorize condition reports. Therefore, the inspectorsdetermined this issue was of minor significance and therefore not subject to enforcementaction in accordance with the NRC's Enforcement Policy. The technical aspects of thisissue pertaining to the failure to establish adequate procedures for the restoration ofCVCS letdown flow was previously documented as an NCV in NRC Special InspectionReport 050003 1 7 &31 81 2010006 (ADAMS accession num ber ML 1 0 1 650723).Constellation entered the issue into the corrective action program (CR 2011-011375).(3) Effectivqngss of Corrective ActionsThe inspectors concluded that corrective actions for identified deficiencies weregenerally timely and adequately implemented. For significant conditions adverse toquality, Constellation identified actions to prevent recurrence. The inspectors concludedthat corrective actions to address the sample of NRC NCVs and findings since the lastProblem ldentification and Resolution inspection were timely and effective. However,the inspectors identified the following examples in which a corrective action was not fullyeffective in addressing a potential degraded condition.Enclosure 8CR 2010-006331 . Pos.sible Corrosion of Uncoated Carbon Steel Pipino Under lnsulationConstellation staff reviewed operating experience (OE) item OE30955, which identified acondition in which a leak developed in insulated, uncoated carbon steel piping exposedto outdoor elements at South Texas Project Electric Generating Station. Constellationscreened this OE item and concluded that the condition was applicable to Calvert Cliffs,specifically to piping residing in the tank farm (condensate storage tanks). The evaluatorrecommended that the details of this OE item be provided to system managers whowould determine if any issues exist within their system's piping, and that correctiveactions be assigned to perform any necessary coating and repairs. CR 2010-006331was written with one corrective action to review and revise piping specifications. Thiscorrective action was closed with no work performed. No corrective actions wereassigned to system managers to evaluate their system's piping for the issue described inthe OE item. The inspectors questioned the closure of this condition report anddetermined that there was no other condition report written to carry out therecommendations described by the OE item evaluator. As a result of the inspectors'issue, Constellation staff wrote condition reports to have the condition evaluated byengineering to determine if insulated, uncoated carbon steel piping exposed to outdoorelements at Calvert Cliffs had any degraded issues or needed to be coated to preventdegradation.Although the corrective action as originally assigned was not fully effective in exploring apotential degraded condition, there have been no adverse impacts to componentoperability or safety as a result of the issue. Therefore, the inspectors considered thisissue to be of minor significance, and, as a result, it is not subject to enforcement actionin accordance with the NRC's Enforcement Policy. Constellation entered this issue intothe corrective action program (CR 2011-010851, 010820).CR 2011-005200. Review of Outside Radioactive Material Storaqe AreasThe inspectors reviewed CR 2011-005200 which required a review of outside radioactivestorage areas against design criteria because Constellation had identified severalpotential discrepancies between the 10 CFR 50.59 evaluation of the areas and theactual practices and conditions. The radioactive storage areas are used for storage ofradioactive spent resins and filters, and in accordance with the 10 CFR 50.59 safetyanalysis the storage of these items is limited to a specific timeframe of five years.Constellation created corrective action CA-2A11-000614 to review both the Lake Daviesinterim storage area and the West Road Cage storage areafor compliance with the 10CFR 50.59 evaluation. The inspectors reviewed this corrective action and determinedthe review was completed for only the Lake Davies interim storage area. The inspectorsdetermined the failure to review the West Road Cage storage area was of minorsignificance because a subsequent review of the operation of the West Road Cagestorage area was found to remain in compliance with the 10 CFR 50.59 evaluation andNRC regulations. Therefore, the inspectors consider this issue to be of minorsignificance, and, as a result, it is not subject to enforcement action in accordance withthe NRC's Enforcement Policy. Constellation entered the issue into the corrective actionprogram (CR 201 1-01 1397).FindinqsNo findings were identified.Enclosure

.2 Assessment ofJhe Use of Operatinq Experiencelnspection ScopeThe inspectors reviewed a sample of condition reports associated with the review ofindustry operating experience to determine whether Constellation appropriatelyevaluated the operating experience information for applicability to Calvert Cliffs and hadtaken appropriate actions, when warranted. The inspectors also reviewed evaluations ofoperating experience documents associated with a sample of NRC genericcommunications to ensure that Constellation adequately considered the underlyingproblems associated with the issues for resolution via their corrective action program. Inaddition, the inspectors observed various plant activities to determine if the stationconsidered industry operating experience during the performance of routine andinfreq uently performed activities.AssessmentThe inspectors determined that Constellation appropriately considered industryoperating experience information for applicability, and used the information for correctiveand preventive actions to identify and prevent similar issues when appropriate. Theinspectors determined that operating experience was appropriately applied and lessonslearned were communicated and incorporated into plant operations and procedureswhen applicable. The inspectors also observed that industry operating experience wasroutinely discussed and considered during the conduct of Plan-of-the-Day meetings,Condition Report screening meetings, and in maintenance work orders.The inspectors identified one issue in which the corrective action assigned to addressthe issues identified in an OE item was closed with no work performed. The evaluationby Constellation resulted in a corrective action that was not fully effective in addressing apotential degraded condition. The details of this issue are described in the assessmentsection for the Effectiveness of Corrective Actions, Section 4OA2.1b(3) above.FindinosNo findings were identified.Assessment of Self-Assessments and Auditslnspection ScopeThe inspectors reviewed a sample of audits, including the most recent audit of thecorrective action program, departmental self-assessments, and assessments performedby independent organizations. Inspectors performed these reviews to determine ifConstellation entered problems identified through these assessments into the correctiveaction program, when appropriate, and whether Constellation initiated corrective actionsto address identified deficiencies. The inspectors evaluated the effectiveness of theaudits and assessments by comparing audit and assessment results against self-revealing and NRC-identified observations made during the inspection.b.c..3Enclosure

c.10AssessmentThe inspectors concluded that self-assessments, audits, and other internal Constellationassessments were generally critical, thorough, and effective in identifying issues. Theinspectors observed that Constellation personnel knowledgeable in the subjectcompleted these audits and self-assessments in a methodical manner. Constellationcompleted these audits and self-assessments to a sufficient depth to identify issueswhich were then entered into the corrective action program for evaluation. In general,the station implemented corrective actions associated with the identified issuescommensurate with their safety significance.The inspectors identified one instance in which guidance for performing self-assessments for the boric acid corrosion control program was deficient. Specifically,Constellation procedure MN-3-123,"Boric Acid Corrosion Control Program," step 5.98,requires Engineering Programs to perform periodic self-assessments of the boric acidcorrosion control program. The guidance does not define the periodicity or the type ofself-assessment (i.e. snapshot, focused) to be completed. The inspectors determinedthat this was a minor procedure deficiency issue since snapshot self'assessments hadbeen completed by Calvert Cliffs personnel once every three years, and not a violationof NRC requirements. Constellation entered this issue into the corrective action program(cR 2011-0113e8).FindinqsNo findings were identified.Assessqent of Safetv Conscious Work EnvironmentInspection ScopeDuring interviews with station personnel, the inspectors assessed the safety consciouswork environment (SCWE) at Calvert Cliffs. Specifically, the inspectors interviewedpersonnel to determine whether they were hesitant to raise safety concerns to theirmanagement and/or the NRC. The inspectors also interviewed the station EmployeeConcerns Program (ECP) coordinator to determine what actions are implemented toensure employees are aware of the program and its availability with regards to raisingsafety concerns. The inspectors reviewed the Employee Concerns Program files toensure that Constellation entered issues into the corrective action program whenappropriate. The inspectors performed a follow-up of ECP items identified during thelast Problem ldentification and Resolution inspection in November 2009 to determine ifConstellation adequately addressed the issues. Finally, the inspectors reviewed theresults of the Nuclear Safety Culture Assessments conducted in 2009 and 2011 to gaininsights into the SCWE at Calvert CliffsAssessmentDuring interviews, Calvert Cliffs staff expressed a willingness to use the corrective actionprogram to identify plant issues and deficiencies and stated that they were willing toraise safety issues. The inspectors noted that no one interviewed stated that theypersonally experienced or were aware of a situation in which an individual had beenretaliated against for raising a safety issue. All persons interviewed demonstrated an.4a.b.Enclosure 40A611adequate knowledge of the corrective action program and the Employee ConcernsProgram. Based on these limited interviews, the inspectors concluded that there was noevidence of an unacceptable safety conscious work environment and no significantchallenges to the free flow of information.FindinqsNo findings were identified.Meetinos. Includins ExitOn November 18, 2011, the inspectors presented the inspection results to Mr. ChrisCostanzo, Plant Manager, and other members of the Calvert Cliffs staff, The inspectorsverified that no proprietary information was retained by the inspectors or documented inthis report.ATTACHMENT: SU PPLEMENTARY INFORMATIONEnclosure A-1

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

P. Amos, Performance lmprovement Unit Director

D. Bartnik, Security Director

J. Beasley, Engineering Supervisor

K. Bodine, Engineering Programs Supervisor

C. Costanzo, Plant Manager

J. Etzweiler, Principal Engineer

J. Gaffey, Design Engineer

R. Gines, System Engineer

R. Jones, Boric Acid Corrosion Control Program Manager

C. Jackson, System Engineer

M. Jones, System Engineer

S. Kirkpatrick, l&C Supervisor

G. Knull, Work Management

J. Klecha, Work Management

S. Kowaluk, Engineering Programs

D. Lauver, Licensing Director

M. Major, Engineering Programs

C. Neyman, Senior Engineering Analysl

J. Phifer, Senior Quality Analyst, ECP

S. Sanders. GS-Asset ManagerJ. Schoolcraft, Performance lmprovement

A. Simpson, Licensing Supervisor

W. Tippett, Senior Program Analyst

P. Tolliver, l&C Supervisor

K. Umphrey, Shift Operations Manager

T. Unkle, Licensing Engineering Analyst

L. Williams, System Engineer

J. Wilson, System Engineering SupervisorNone

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Attachment

A-2

LIST OF DOCUMENTS REVIEWED

Sqction 4OA2: Problem ldentification and ResolutionAudits and Self-AssessmentsCCNPP BACCP Self-assessment (54-2009-000068)Report of Audit, Maintenance Rule Program (MAl-11-01-C)1 25 VDC System Self-assessment (SA-201

1-000224)Electrical Maintenance Technician Training (SAA-201 1 -0001 28)CCNPP - Fleet Type ll - Safety Culture Assessment (2010-112)Comparative Report of Self-assessments of the Employee Concerns Program (ECP)Quality and Performance Assessment, Fleet Employee Concerns Program (October 2011)Security Training Academic Program Self-assessment (August 26, 201 1)Corrective Action Program (201 0-1 03)Control of Condition Report Backlogs (2010-006)Corrective Action Program Closure Quality (2010-049)Site Use of OE (2010-012)Top Ten.Oldest Cat 1 CRs (2010-096)Line Self-assessments (201 0-098)Attachment

A-3Condition Reports (* indicates that condition report was generafed as a result of fhis inspection)IRE-o18-156tRE-024-255IRE-024-256tRE-024-257IRE-024-258IRE-025-534tRE-027-361tRE-028-266IRE-028-267tRE-029-507IRE-011-4262008-0016692009-0015972009-0016162009-0028222009-0028642009-0037202009-0049512009-00521 52009-0056402009-0061 842009-0057922009-0077262009-0078802009-0080072009-0080302009-0080632009-0083132009-0083242009-0084442009-0085012009-00861 12009-008860201 0-0000852010-0000942010-0002012010-0003242010-000551201 0-0005622010-0006052010-0008992010-00't3782010-002768201 0-0033262010-003589201 0-0039742010-0041232010-004244201 0-0043402010-0Q48452010-0049542010-0054492010-0056122010-0057022010-0052972010-0059962010-006096201 0-0065062010-0066812010-0066832010-0068252010-0070452010-0072242010-007251201 0-0076292010-0084572010-0088592010-0115712010-0116452010-0117072010-0117112010-0123702010-0127032010-012711201 0-01 29302010-0129482011-004027201

1-000044201 1 -000606201 1,0008s42011-001107201 1-001 1912011-001233201 1 -001 2362011-001754201

1-0020932011-0Q25022011-0032152011-003271201

1-0033582011-0034222011-004203201

1-0052002011-A05294201

1-006592201 1 -006605201 1 -0069322011-007794201

1-0088372011-0084442011-A094722009-0084282009-0085452009-0022892009-008722201 0-0001 962010-0002942010-0003482010-000871201 0-001 1 582010-001

173201 0-001 5832010-0017452010-0021232010-0021252010-0021752010-002600201 0-0031 68201 0-0037802010-0040212010-004673201 0-0051 872010-005858201 0-006763201 0-0068972010-009394201 0-0095632010-0100702010-010443201 0-01 05342010-012055201

1-000378201 1 -0021 502011-0022982011-0023312011-0025602011-0026072011-003122201

1-0036782011-008192201

1-008230201

1-0088202011-009214201

1-009302201

1-009303201

1-0100702011-0106442009-00831 72010-0029222A11.0088722009-009300201 0-01

0348201 0-0095452010-011777201

1-003960201

1-0070162011-0092322011-008734201

1-0092582A10-0044272010-0063312009-0083092009-0079332010-012954201 0-00881 62010-0101972009-0081222009-0081 232009-0081252009-0081262009-0081272009,0081282009,008129201 0-0066012010-0066032010-0066042010-006605201 0-0066072010-0066092010-0009432010-0049742010-0107322011-010224201A-412647201

1-0083592010-0122322009-000854201 0-0058282Q11-010714.201 1 -01 0689.201 1-01 1 375*2011-011402*2011-01 1 385.2011-01 1409.2011-010801*201

1-010851.2011-010820"2011-011397*2011-011411*2011-01 1 398*Ooeratino Exoerience and NRC Generic CommunicationsoE-2009-002799oE-2009-002822oE-2009-003343oE-2010-000348oE-2010-001144lN 2009-21, Incomplete MedicalTesting for Licensed OperatorslN 2010-03, Failures of Motor-Operated Valves Due to Degraded Stem LubricantAttachment

A-4lN 2009-25, SmallArms Firing Range Safety lssueslN 2010-08, Welding and Non-Destructive Examination lssuesNCVs and FindinqsProceduresCNG-CA-1.01-1 000, Corrective Action Program, Revision 0501CAL-EP-MD-10-3, Emergency Preparedness Augmentation Drill Report, Revision 0CAL-EP-MD-10-4, Emergency Preparedness Augmentation Drill Report, Revision 1CAL-EP-MD-11-7, Emergency Preparedness Augmentation Drill Report, Revision 0CNG-CA'1.01-1001, Management Review Committee, Revision 00400CNG-CA-1.01-1004, Root Cause Analysis, Revision 800CNG-CA-1.01'1005, Apparent Cause Evaluation, Revision 500CNG-CA-1.01-1007, Performance lmprovement and Trending Analysis, Revision 300CNG-CA-1.01-GL002, Causal Analysis Handbook, Revision 101CNG-CA-2.O 1 -1 000, Self-Assessment and Benchmarking Process, Revision 301CNG-EP-1 .01 -1 001, Emergency Preparedness Program Responsibilities and Oversight,Revision 100CNG-MN-1.01-1004, Fluid Leak Management Program, Revision 300CNG-NS-2.01-1 000, Nuclear Safety Culture, Revision 00001CNG-CA-1.01-1010, Use of Operating Experience, Revision 00400CNG-CA-1.01-GL003, Operating Experience Screening Guidelines, Revision 00100CNG-PR.1.01-1011, Controlof Station Specific Procedure Change Process," Revision 00400ReportCornerstoneSisnificanceDescriotion2010202PhysicalProtectionGreenSafeguards Report2009005EmergencyPreparednessGreenFailure to Provide for Adequate DoseAssessment with the Containment Outage DoorOoen2009007EmergencyPreoarednessGreenlnadequate Corrective Actions for Bay WaterLevel EAL Entry Criteria201 0006MitigatingSvstemsGreenFailed to Establish Adequate Procedures forLetdown Restoration2010003MitigatingSvstemsGreenInadequate Risk Assessment Associated with the28 EDG201 0005MitigatingSvstemsGreenlnadequate Functionality Review of 0C DieselDeoraded Condition2010005OccupationalRadiation SafetyGreenFailure to lmplement Procedures to Calibrate andMaintain Ventilation and Radiation EffluentMonitorins Equipment2010006lnitiating EventsGreenFailure to Translate Design Calculation Setpointof Phase Overcurrent Relay on Feeder Breakers2010006MitigatingSystemsGreenFailure to Evaluate Degraded ConditionsAssociated with

CO-8 Relays and lmplementTimely and Effective Action to Correct theCondition Adverse to Qualitv201 0003Initiating EventsGreenInadequate Design Control Reviews of theTurbine Control System and the Nuclear SteamSupplv SvstemAttachment

A-5CNG-QL-3,01-1001, Safety Conscious Work Environment and Employee Concerns Program,Revision 0200CNG-QL-3.01, Safety Conscious Work Environment, Revision 0100CNG-TR-1.01-GL007, Training and Qualification for Personnel Performing Performancelmprovement Functions and Activities, Revision 00200EN-1-135, Control of Barriers, Revision 0202EP-1-107, Emergency Response Organization Expectations and Responsibilities, Revision 4Calvert Cliffs Nuclear Power Plant, Emergency Response Plan, Revision 42EP-1 -307, Emergency Response Organization Personnel Assignment and Qualification,Revision 5EPP-1 1-01-C, Report of Audit; Emergency Preparedness Program, Revision 0MN-3-123, Boric Acid Corrosion Control Program, Revision 201MN-l-106, Control of Equipment and Material in Safety Related Category l (SR-CATI)Structures and Trip Sensitive Areas (TSA)STP-M-171-1, Personnel Airlock Gasket Seal Test, Revision 15Work OrdersMiscellaneousMaster Calibration Data Sheet (MCDS), 2-RlT-5280 U2 Containment Particulate and GasMonitors, Revision 0000Nuclear Plant Operations Section Standing Orders, Number 09-02, Revision 3SA-2011-000348, Maintenance Rule Failure Evaluations, Revision 45A-2020-000055, Maintenance Rule (aX3) Assessment ReportSA-2008-000033, Maintenance Rule (aX3) Assessment ReportECP-10-000919, Equivalency Evaluation for Use of Dyed Diesel Fuel Oil, Rev. 0Nuclear Safety Culture Assessment, August 2011Nuclear Safety Culture Assessment, September 2009c90627594c90702781c90791825c90793896c90793915c90884034c90992600c91211657c90639910c120084454c90793896c90801334c90801345c90815388c90836393c90839610c91002366a91027078c91 179439c91682453c12006051 1c120084539Attachment

ADAMSBACCPCCNPPCFRCRCVCSDRPDRSECPEOPr&crMcMPFFMRFFNCVNRCOAOEPARSPEQPASCWEA-6

LIST OF ACRONYMS

Agency-wide Documents Access and ManagementBoric Acid Corrosion Control ProgramCalvert Cliffs Nuclear Power PlantCode of Federal RegulationsCondition ReportChemicalVolume and Control SystemDivision of Reactor ProjectsDivision of Reactor SafetyEmployee Concerns ProgramEmergency Operating ProcedureInstrumentation and Controlslnspection Manual ChapterMaintenance Preventable Functional FailureMaintenance Rule Functional FailureNon-Cited ViolationNuclear Regulatory CommissionOther ActivitiesOperating ExperiencePublicly Available Records SystemProfessional EngineerQuality and Performance AssessmentSafety Conscience Work EnvironmentSystemAttachment