Calvert Cliffs 1
1Q/2012 Plant Inspection Findings

Significance: Dec 31, 2011
Identified By: Self-Revealing
Item Type: FIN Finding
Turbine Building Siding Failure Below Design Specification
Green: A self-revealing finding of very low safety significance was identified because
Constellation did not ensure the turbine building (TB) siding was installed in accordance with
design requirements of ES-005, Civil and Structural Design Criteria. This resulted in wind
induced TB siding failures significantly below design wind speeds. Consequently, Unit 1
experienced an automatic trip from 100 percent power due to a phase-to-phase short circuit
on the main transformer when the main transformer high voltage lines were struck by
dislodged TB siding caused by high winds associated with Hurricane lrene. The inspectors
determined that Constellation missed multiple opportunities to identify the TB siding
installation deficiencies following several high wind events and through the use of operating
experience (OE). lmmediate corrective actions included entering this issue into their CAP
and restricting personnel travel in outside areas with sustained wind speed greater than
40 mph until the TB corner siding on all corners has been verified to be properly installed.
Other corrective actions include testing and inspection of the main transformer, repairs to
the 'B' and 'C' phase high line drops to the main transformer, temporary repairs to the TB
siding, and development of new installation requirements which meet the design
requiiements of the TB siding corners. In addition, Constellation's planned corrective
actions include inspecting all building siding inside the protective area to identify other
possible deficiencies.

The finding is more than minor because it is associated with the protection against external
factors attiibute (wind and grid stability) of the Initiating Events cornerstone and adversely
affected the cornerstone objective to limit the likelihood of those events that upset plant
stability and challenge critical safety functions during power operations. Specifically, the
finding resulted in a reactor trip of Unit 1. The inspectors determined that the finding is of
very low safety significance because the finding did not contribute to both the likelihood of a
reactor trip and the likelihood that mitigation equipment or functions would not be available.
This finding has a cross-cutting aspect in the area of problem identification and resolution,
OE, because Constellation did not use OE information and internally generated lessons
learned, to support plant safety and implement changes to station processes, procedures,
equipment, and training programs. Specifically, Constellation did not implement and
institutionalize OE associated with siding failures through changes to station processes,
procedures, and equipment, and training programs (P.2.b per IMC 0310). (Section 4OA3)
Inspection Report# : 2011005 (pdf)

Significance: Dec 31, 2011
Identified By: Self-Revealing
Item Type: NCV NonCited Violation
Did Not Adequately Prescribe and Implement Procedures Associated with Protected Equipment
Green: A self-revealing NCV of 10 CFR Part 50, Appendix B, Criterion V, "lnstructions,
Procedures, and Drawings," was identified, because Constellation did not prescribe and
accomplish procedures appropriate to the circumstances associated with protected safety
related equipment. As a result, on October 3,2011, Constellation allowed work on a
protected emergency diesel generator (EDG). The work activity inadvertently resulted in the
protected EDG becoming inoperable. This led to required Technical Specification (TS)
shutdowns of Unit 1 and Unit 2 because the other required EDG was already out of service
(OOS) for planned maintenance. Prior to the shutdown being completed, the protected
EDG was restored to an operable status and the shutdowns were aborted. lmmediate
corrective actions included entering this issue into their corrective action program (CAP),
issuing a site wide communication stating the expectations regarding work on protected
safety equipment, and revising the Operations Administrative Policy (OAP) associated with
protected equipment.

The finding is more than minor because it is associated with the configuration control
attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to
ensure the availability, reliability, and capability of systems that respond to initiating events
to prevent undesirable consequences. Specifically, the work activity impacted the
availability and capability of the 1A EDG. The inspectors determined the finding is of very
low safety significance because the performance deficiency was not a design or qualification
deficiency, did not involve an actual loss of safety function for greater than its individual TS
allowed outage time, and did not screen as potentially risk significant due to a seismic,
flooding, or severe weather initiating event. This finding has a cross-cutting aspect in the
area of human performance, decision making, because the Constellation did not adequately
make a risk significant decision using a systematic process when faced with uncertain or
unexpected plant conditions, to ensure safety is maintained. Specifically, Constellation
personnel did not follow the integrated work management process for emergent work which
uttimately led to the downpower of both units (H.1.a per IMC 0310). (Section 1R04)
Inspection Report# : 2011005 (pdf)

Significance: Dec 31, 2011
Identified By: NRC
Item Type: NCV NonCited Violation
Annual Operating Tests Are Not Comprehensive
Green: The inspectors identified an NCV of 10 CFR Part 55.59(aX2Xii) for Constellation's
failure to adrninister annual operating tests to licensed operators to accomplish a
comprehensive sample of items specified by 10 CFR Part 55.45(a)(7)&(8). Specifically, for
the past five years, Constellation's annual operating tests have not evaluated licensed
operators on important tasks that would be performed inside the auxiliary building.
Constellation entered this issue into their CAP to evaluate corrective actions.

This finding is more than minor because if left uncorrected, it would have the potential to
lead to a more significant safety concern. This finding is associated with human
performance attribute of the mitigating systems cornerstone and affected the cornerstone
objective to ensure the availability, reliability, and capability of systems that respond to
iniiiating events to prevent undesirable consequences. Specifically, Constellation's annual
operating tests have not evaluated licensed operators on mitigation tasks that would be
performed inside the auxiliary building. The finding is of very low safety significance
according to IMC 0609, "SDP," Appendix l, "Licensed Operator Requalification SDP,"
because the issue was related to operating test quality. The inspectors determined that this
finding had a cross-cutting aspect in the area of human performance, decision making,
because Constellation did not use conservative assumptions in decision making that
resulted in the development and administration of annual operating tests over the past five
years that were not comprehensive (H.1.b per IMC 0310). (Section 1R11 )
Inspection Report# : 2011005 (pdf)

Significance: Dec 31, 2011
Identified By: NRC
Item Type: NCV NonCited Violation
Inadequate Inspection of Floor Drains Led to Clogging and EDG Failure During Hurricane
Green: The inspectors identified an NCV of TS 5.4.1, "Procedures," because Constellation
did not adequately implement the procedural requirements to conduct floor drain
inspections. Specifically, operators did not ensure that floor drains were free to drain and
clear of debris in the 80 foot elevation of the 1A EDG building. This contributed to the
inoperability of the 1A EDG due to clogged floor drains during Hurricane lrene on August 28,
2011. Additional causes included the failure of a combustion intake penetration boot seal to
remain leak tight and the installation of drain filters without an engineering evaluation.
lmmediate corrective actions included entering this issue into their CAP, removing all the
drain filters from the 1A EDG building, and installation of a curb around the combustion
intake penetration. Planned corrective actions include replacing combustion intake
penetration boot seal.

The finding is more than minor because it is associated with the human performance
attribute of the Mitigating System cornerstone and affected the cornerstone's objective to
ensure the availability, reliability, and capability of systems that respond to initiating events
to prevent undesirable consequences (i.e., core damage). Specifically, the performance
deiiciency resulted in the 1A EDG becoming inoperable. A phase 3 SDP was required
because the finding was potentially risk significant due to a seismic, flooding, or severe
weather initiating event. A Region I Senior Reactor Analyst (SRA) conducted a Phase 3
assessment and concluded that the finding was of very low safety significance. The finding
has a cross-cutting aspect in the area of human performance, work practices, because
Constellation did not ensure that personnel work practices support human performance by
defining and effectively communicating expectations regarding procedural compliance and
personnel following procedures related to floor drain inspections (H.4.b per IMC 0310).
(Section 4OA3)
Inspection Report# : 2011005 (pdf)

Significance: Sep 30, 2011
Identified By: NRC
Item Type: NCV NonCited Violation
Inadequate Corrective Actions Associated with Submerged Saltwater Pump Motor Cables
Green: The inspectors identified an NCV of 10 CFR Part 50, Appendix B, Criterion XVI,
“Corrective Actions,” because Constellation did not promptly identify and correct a condition
adverse to quality associated with submerged saltwater (SW) pump motor safety-related
medium voltage cables. As a result, safety-related cables were subjected to a submerged
or continuously wetted environment for extended periods. Immediate corrective action
included entering this issue into their corrective action program (CAP), conducting an
operability determination (OD), and placing these cables into Constellation’s Medium
Voltage Cable Program.
The finding is more than minor because it is associated with the equipment performance
attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to
ensure the availability, reliability, and capability of systems that respond to initiating events
to prevent undesirable consequences. Specifically, this condition could lead to cable
degradation, increased likelihood of cable failure, and subsequent risk associated with the
failure of safety-related equipment. The inspectors determined the finding is of very low
safety significance because the finding is a design or qualification deficiency confirmed not
to result in a loss of operability. The finding has a cross-cutting aspect in the area of
problem identification and resolution, operating experience (OE), because Constellation did
not fully implement and institutionalized OE to change station processes and procedures
associated with submerged cables (P.2.b per IMC 0310).
Inspection Report# : 2011004 (pdf)

Significance: Sep 30, 2011
Identified By: NRC
Item Type: NCV NonCited Violation
Inadequate Compensatory Actions for Out of Service High Range Effluent Radiation Monitors
Green. The inspectors identified an NCV of 10 CFR Part 50.54, “Conditions of Licenses,”
paragraph (q), because Constellation did not maintain the Emergency Plan to adequately
meet the standards in 50.47(b). Specifically, Constellation periodically removed the high
range effluent monitors from service without addressing the impact on the site’s ability to
make a timely assessment of radiological releases as discussed in the Emergency Plan.
This could result in an unnecessary delay in dose projection for certain radiological events.
Immediate corrective actions included entering this issue into the CAP, updating the
evaluation to address any potential delays, and protecting equipment required for dose
projection.

The finding is more than minor because it is associated with the facilities and equipment
attribute of the Emergency Preparedness (EP) cornerstone and affected the cornerstone’s
objective to ensure that the licensee is capable of implementing adequate measures to
protect public health and safety in the event of a radiological emergency. Specifically, the
removal of high range effluent radiation monitors from service that provide a timely
assessment capability may result in not immediately recognizing the offsite radiological
condition that requires offsite protective actions. The inspectors determined the finding is of
very low safety significance because it did not result in a loss or degraded Risk-Significant
Planning Standard (RSPS) function. In addition, the finding is similar to examples of Green
findings in IMC 0609, Appendix B, Section 4.9, in that the equipment or systems necessary
for dose projection are not functional for longer than 24 hours from time of discovery without
adequate compensatory measures. This finding has a cross-cutting aspect in the area of
problem identification and resolution, CAP, because Constellation did not fully evaluate
problems such that the resolution address causes and extent of condition as necessary.
Specifically, Constellation did not adequately evaluate the compensatory actions following
the removal of the high range effluent monitors from service to ensure that a timely
assessment of offsite radiological conditions could be accomplished following a steam
generator tube rupture (SGTR) event (P.1.c per IMC 0310).
Inspection Report# : 2011004 (pdf)

Significance: Sep 30, 2011
Identified By: Self-Revealing
Item Type: NCV NonCited Violation
Lack of Proficiency Evaluating Seismic Recorder Data
Green. A self-revealing NCV of 10 CFR Part 50.54, “Conditions of Licenses,” paragraph (q),
was identified because Constellation did not maintain the Emergency Plan to adequately
meet the standards in 50.47(b). Specifically, Constellation did not have an adequate
emergency classification and action level scheme in place for the seismic activity initiating
condition and Constellation personnel lacked the proficiency necessary to evaluate seismic
recorder data in a timely manner during the seismic event on August 23, 2011. The
licensee entered this issue into their CAP and implemented compensatory actions, which
included training of operators.

The finding is more than minor because it is associated with the facilities and equipment
attribute of the EP cornerstone and affected the cornerstone objective of ensuring that a
licensee is capable of implementing adequate measures to protect the health and safety of
the public in the event of a radiological emergency. Specifically, incorrect seismic recorder
trigger setpoint settings and untimely evaluations of seismic recorder data could result in the
failure of Constellation to declare an Unusual Event (UE) or an Alert in a timely manner.
The inspectors determined the finding is of very low safety significance because it did not
result in a loss or degraded RSPS function. The finding is also similar to examples of Green
findings in Section 4.4 of IMC 0609, Appendix B, in that the EAL classification process
would not declare any Alert or Notification of UE that should be declared. This finding has a
cross-cutting aspect in the area of human performance, resources, because Constellation
did not ensure that the training of personnel was adequate to assure nuclear safety.
Specifically, Constellation did not ensure that personnel were proficiently trained to read and
evaluate the seismic recorder data which could delay entry into the EALs (H.2.b of IMC
0310).
Inspection Report# : 2011004 (pdf)

Although the NRC is actively overseeing the Security cornerstone, the Commission has decided that certain findings pertaining to security cornerstone will not be publicly available to ensure that potentially useful information is not provided to a possible adversary. Therefore, the cover letters to security inspection reports may be viewed.

Significance: N/A Nov 18, 2011
Identified By: NRC
Item Type: FIN Finding
Calvert Cliffs Biennial PI&R Inspection Summary
The inspectors concluded that Constellation was generally effective in identifying, evaluating, and resolving problems. Constellation personnel identified problems, entered them into the corrective action program at a low threshold, and in general, prioritized issues commensurate with their safety significance. In most cases, Constellation appropriately screened issues for operability and reportability, and performed causal analyses that appropriately considered extent of condition, generic issues, and previous occurrences. The inspectors also determined that Constellation typically implemented corrective actions to address the problems identified in the corrective action program in a timely manner.

The inspectors concluded that, in general, Constellation adequately identified, reviewed, and applied relevant industry operating experience to Calvert Cliffs operations. In addition, based on 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 and employee concerns program issues, the inspectors did not identify any indications that site personnel were unwilling to raise safety issues nor did they identify any conditions that could have had a negative impact on the site’s safety conscious work environment.

Inspection Report# : 2011010 (pdf)

Last modified : May 03, 2012