ML18130A878
| ML18130A878 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 05/09/2018 |
| From: | Michelle Catts Reactor Projects Branch 1 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2018001 | |
| Download: ML18130A878 (18) | |
See also: IR 05000317/2018001
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
2100 RENAISSANCE BOULEVARD, SUITE 100
KING OF PRUSSIA, PA 19406-2713
May 9, 2018
Mr. Bryan C. Hanson
Senior Vice President, Exelon Generation Company, LLC
President and Chief Nuclear Officer, Exelon Nuclear
4300 Winfield Road
Warrenville, IL 60555
SUBJECT: CALVERT CLIFFS NUCLEAR POWER PLANT - INTEGRATED INSPECTION
REPORT 05000317/2018001 AND 05000318/2018001
Dear Mr. Hanson:
On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
at Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2. On April 25, 2018, NRC
inspectors discussed the results of this inspection with Mr. Mark Flaherty, Site Vice President,
and other members of your staff. The results of this inspection are documented in the enclosed
report.
NRC inspectors documented one finding of very low safety significance (Green) in this report.
This finding involved a violation of NRC requirements. The NRC is treating this violation as a
non-cited violation (NCV) consistent with Section 2.3.2.a of the NRC Enforcement Policy.
If you contest the violation or significance of this NCV, you should provide a response within
30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear
Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with
copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the
NRC Resident Inspector at CCNPP. In addition, if you disagree with the cross-cutting aspect 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 U.S. Nuclear Regulatory Commission,
ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional
Administrator, Region I, and the NRC Resident Inspector at CCNPP.
B. Hanson 2
This letter, its enclosure, and your response (if any) will be made available for public inspection
and copying at http://www.nrc.gov/reading-rm/adams.html and the Nuclear Regulatory
Commission Public Document Room in accordance with Title 10 of the Code of Federal
Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Michelle Catts, Acting Chief
Reactor Projects Branch 1
Division of Reactor Projects
Docket Nos. 50-317 and 50-318
License Nos. DPR-53 and DPR-69
Enclosure:
Inspection Report 05000317/2018001 and
w/Attachment: Supplementary Information
cc w/encl: Distribution via ListServ
Non-Sensitive Publicly Available
SUNSI Review
Sensitive Non-Publicly Available
OFFICE RI/DRP RI/DRP RI/ORA RI/DNMS RI/DRP
NAME RClagg/AR per telecon ARosebrook BBickett/NCV only RPowell MCatts
DATE 4/26/18 5/7/18 5/8/18 5/7/18 5/9/18
1
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket Numbers: 50-317 and 50-318
License Numbers: DPR-53 and DPR-69
Report Numbers: 05000317/2018001 and 05000318/2018001
Enterprise Identifier: I-2018-001-0044
Licensee: Exelon Generation Company, LLC
Facility: Calvert Cliffs Nuclear Power Plant, Units 1 and 2
Location: Lusby, MD
Inspection Dates: January 1, 2018 to March 31, 2018
Inspectors: R. Clagg, Senior Resident Inspector
C. Roettgen, Resident Inspector
H. Anagnostopoulos, Senior Health Physicist
E. Burket, Reactor Inspector
A. Rosebrook, Senior Project Engineer
Observer: A. Chereskin, Chemical Engineer
Approved by: Michelle Catts, Acting Chief
Reactor Projects Branch 1
Division of Reactor Projects
2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring Exelon Generation
Companys, LLC (Exelon) performance at Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1
and 2 by conducting the baseline inspections described in this report in accordance with the
Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for
overseeing the safe operation of commercial nuclear power reactors. Refer to
https://www.nrc.gov/reactors/operating/over-sight.html for more information. NRC identified and
self-revealed findings, violations, and additional items are summarized in the table below.
List of Findings and Violations
Failure to Conduct Adequate Radiation Surveys and Evaluate Potential Radiological Hazards
Cornerstone Significance Cross-Cutting Report
Aspect Section
Occupational Green Non-Cited Violation H.11 - Human 71124.01
Radiation Safety 05000317/2018001-01 Performance -
Closed Challenge the
Unknown
A self-revealed Green non-cited violation (NCV) of Title 10 Code of Federal Regulations
(10 CFR) 20.1501, Surveys and Monitoring: General, was identified when Exelon failed to
perform adequate surveys of the 11 reactor coolant pump bay area following the aggregation
of 25 high dose-rate in-core detectors in one area of the flooded refueling cavity, which is
adjacent to the pump bay. Surveys were not performed as required after radiological
conditions changed and radiological hazard mitigation measures, such as locking and
controlling access in accordance with Exelon procedures, were not implemented, resulting in
accessible dose-rates of up to 2,000 millirem per hour (mrem/hr) in the pump bay.
3
REPORT DETAILS
PLANT STATUS
Unit 1 began the inspection period at rated thermal power and operated at or near full power
until February 12, 2018, when the unit entered end-of-cycle coastdown operations. On
February 18, 2018, operators commenced a shutdown, from 76 percent power, for a planned
refueling outage. Operators commenced a reactor startup on March 16, 2018, and returned the
unit to 100 percent power on March 18, 2018. On March 31, 2018, operators reduced power to
50 percent to repair a main turbine control valve.
Unit 2 operated at or near rated thermal power for the entire inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
their attached revision histories are located on the public website at http://www.nrc.gov/reading-
rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared
complete when the IP requirements most appropriate to the inspection activity were met
consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection
Program - Operations Phase. The inspectors performed plant status activities described in
IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem
Identification and Resolution. The inspectors reviewed selected procedures and records,
observed activities, and interviewed personnel to assess Exelons performance and compliance
with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Impending Severe Weather (2 samples)
The inspectors evaluated readiness for impending adverse weather conditions for:
(1) Forecasted high winds, March 1, 2018
(2) Forecasted winter storm and high winds, March 21, 2018
71111.04 - Equipment Alignment
Partial Walkdown (4 samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1) 11 train onsite power distribution while the 14A 480V bus was out of service,
February 23, 2018
(2) 2B emergency diesel generator, 1A emergency diesel generator, 0C diesel generator
while offsite power transformer P-13000-1 was out of service, February 27, 2018
(3) Unit 1 containment fire protection (temporary) during overhaul of O-FP-141A, Fire
Protection Supply Inboard Containment Isolation, March 7, 2018
4
(4) Unit 2 A train auxiliary feedwater while B auxiliary feedwater train was out of service
for valve maintenance, March 7, 2018
71111.05Q - Fire Protection Quarterly
Quarterly Inspection (6 samples)
The inspectors evaluated fire protection implementation in the following selected areas:
(1) Unit 1, 27 foot Switchgear Room, Purge Air Room, and 45 foot Switchgear Room, Fire
Areas 19, 19A, and 34 on January 12, 2018
(2) Unit 1, Cable Spreading Room and 1C Chase, Battery Rooms, and Hallway Outside of
Cable Spreading Room, Fire Areas 16, 16A, and 16B on January 29, 2018
(3) Unit 2, Cable Spreading Room and 2C Chase, Battery Rooms, and Hallway Outside of
Cable Spreading Room, Fire Areas 17, 17A, and 17B on January 29, 2018
(4) Unit 1, Containment Building, Fire Area CNMT on February 20, 2018
(5) Unit 1, Turbine Building, Fire Area TB on February 21, 2018
(6) Unit 2, Turbine Building, Fire Area TB on February 22, 2018
71111.06 - Flood Protection Measures
Internal Flooding (1 sample)
The inspectors evaluated internal flooding mitigation protections in the Unit 1 service water
pump room during the week of February 26, 2018.
71111.08 - Inservice Inspection Activities (1 sample)
The inspectors evaluated Exelons non-destructive examination and welding activities at
CCNPP, Unit 1 by reviewing the following activities and programs from February 26 to
March 8, 2018:
(1) Volumetric Examinations
a) Manual Ultrasonic Testing of Pipe to Elbow Weld, 16-FW-1218-10
b) Manual Ultrasonic Testing of Containment Liner, Plate 148
(2) Surface Examination
a) Magnetic Particle Testing of Integral Attachment, 34-MS-1204-H-8
(3) Visual Examinations
a) Bare Metal Visual Examination of the Reactor Vessel Upper Head and Nozzle
Partial Penetration Welds
b) General Visual Examination of the Containment Liner
(5) The inspectors evaluated Exelons boric acid corrosion control program performance.
(6) In accordance with the CCNPP Steam Generator Program, Exelon did not perform
steam generator tube inspections during this refueling outage.
71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance
Operator Requalification (1 sample)
The inspectors observed and evaluated licensed operators during a positive moderator
temperature coefficient startup/shutdown training on January 16, 2018.
5
Operator Performance (2 samples)
The inspectors observed and evaluated main control room performance during:
(1) Unit 1 reactor shutdown and cooldown, February 18, 2018
(2) Unit 1 heatup and reactor startup, March 16, 2018
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness (1 sample)
The inspectors evaluated the effectiveness of routine maintenance activities associated
with the 22 steam generator feed pump speed control trouble alarm on February 6, 2018.
Quality Control (1 sample)
The inspectors evaluated maintenance and quality control activities associated with the
control of quality parts during work orders C91504027, Replace Unit 2 to Unit 1 Auxiliary
Feedwater System cross connect Solenoid valve, 2SV4550, and C91932471, Replace
2PCV4550, air supply to 2SV4550.
71111.13 - Maintenance Risk Assessments and Emergent Work Control (4 samples)
The inspectors evaluated the risk assessments for the following planned and emergent
work activities:
(1) Unit 2 maintenance risk assessment during offsite power transformer P-13000-1 out of
service for maintenance, February 27, 2018
(2) Units 1 and 2 updated maintenance risk assessment during forecasted high winds,
March 2, 2018
(3) Unit 2, maintenance risk assessment for auxiliary feedwater train B out of service for
valve maintenance, March 6, 2018
(4) Unit 1, updated maintenance risk assessment during reduced inventory in the reactor
pressure vessel, March 10, 2018
71111.15 - Operability Determination and Functionality Assessments (5 samples)
The inspectors evaluated the following operability determinations and functionality
assessments:
(1) Underground piping leakage north of turbine building (AR04087759) on
January 5, 2018
(2) 12 service water pump inboard bearing leaks oil (AR04095258) on January 19, 2018
(3) Unit 1 turbine building service water isolation valve 1CV1638 sticks as it strokes
(AR04114002) on March 12, 2018
(4) Historical foreign material identified during refueling water tank inspection
(AR04107455) on February 23, 2018
(5) 0C diesel generator cracked fitting on pneumatic prelube manifold (AR04119229) on
March 26, 2018
6
71111.18 - Plant Modifications (2 samples)
The inspectors evaluated the following temporary or permanent modifications:
(1) Engineering Change Package (ECP)--17-000416, Unit 1,Replace reactor coolant
pump motor oil level indication system.
(2) ECP-18-00016, Unit 1, Reactor Internal Inspections found one of eight Core Shroud
Tie-rods Dis-engaged form the threaded connections at each end. Temporary
modification accepting condition as is.
71111.19 - Post-Maintenance Testing (5 samples)
The inspectors evaluated post-maintenance testing for the following maintenance/repair
activities:
(1) Work Order (WO) C93596764, adjust packing on B train Unit 2 service water strainer
flushing valves, on February 13, 2018
(2) WO C91833187, inspect and overhaul SI-414, 12 high-pressure safety injection
discharge check valve, on March 6, 2018
(3) WO C92789902, replace solenoid valve on service water turbine building header 12
isolation valve, on March 11, 2018
(4) WO C93063804, replace 1SI-451-12, low-pressure safety injection pump mini flow
check valve, on March 14, 2018
(5) WO C92583375, replace upper flange on 1MOV636OP, 12A safety injection tank high
pressure loop, and repack valve, on March 23, 2018
71111.20 - Refueling and Other Outage Activities (1 sample)
The inspectors evaluated Unit 1 refueling outage activities from February 19 to
March 16, 2018.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Routine (5 samples)
(1) STP-O-5A21-2, 21 Auxiliary Feedwater Pump Quarterly Surveillance Test, Revision 6,
January 24, 2018
(2) STP-O-8A-2, Test of 2A Diesel and 4kV Bus 21 Undervoltage, Revision 31,
February 2, 2018
(3) PSTP-10, Conduct of Coastdown, Revision 2, February 13, 2018
(4) PE-1-036-3-O-R, Over Speed Testing of the 12 Auxiliary Feedwater Pump, Revision 3,
March 11, 2018
(5) STP-O-004B-1, B Train Integrated Engineered Safety Features Test Revision 32,
March 12, 2018
In-service (1 sample)
(1) STP-O-073H-1, Auxiliary Feedwater Pump Large Flow Test, Revision 11, February 15,
2018
7
Containment Isolation Valve (3 samples)
(1) STP-M-003A-O, Online Main and Offline Steam Safety Valve Testing, Revision 008,
February 14, 2018
(2) STP-O108D9-1, Containment Penetration 9 Local Leak Rate Tests, Revision 0,
February 23, 2018
(3) STP-O-108D44-1, Containment Penetration 44 Local Leak Rate Tests, Revision 1,
February 27, 2018
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (1 Sample)
The inspectors evaluated radiological hazards assessments and controls.
Instructions to Workers (1 Sample)
The inspectors evaluated worker instructions.
Contamination and Radioactive Material Control (1 Sample)
The inspectors evaluated contamination and radioactive material controls.
Radiological Hazards Control and Work Coverage (1 Sample)
The inspectors evaluated radiological hazards control and work coverage.
High Radiation Area and Very High Radiation Area Controls (1 Sample)
The inspectors evaluated risk-significant high radiation area and very high radiation area
controls.
Radiation Worker Performance and Radiation Protection Technician Proficiency
(1 Sample)
The inspectors evaluated radiation worker performance and radiation protection technician
proficiency.
71124.02 - Occupational As Low As Reasonably Achievable Planning and Controls
Radiological Work Planning (1 sample)
The inspectors selected the following radiological work activities based on exposure
significance for review:
(1) As Low As Reasonably Achievable (ALARA) Plan 17RFO-0019, Dissimilar Metal Weld
Inspections
(2) ALARA Plan 17RFO-0010, Scaffold Activities
(3) ALARA Plan 17RFO-0013, NSRX Reactor Disassembly/Reassembly
(4) ALARA Plan 17RFO-0011, Outage Insulation
8
For each of these activities, the inspectors reviewed: ALARA work activity evaluations,
exposure estimates, exposure reduction requirements, results achieved (dose rate
reductions, actual dose), person-hour estimates and results achieved and post-job reviews
that were conducted to identify lessons learned.
Verification of Dose Estimates and Exposure Tracking Systems (1 sample)
The inspectors reviewed the current annual collective dose estimate; basis methodology;
and measures to track, trend, and reduce occupational doses for ongoing work activities.
The inspectors evaluated the adjustment of exposure estimates, or re-planning of work.
The inspectors reviewed post-job as low as reasonably achievable evaluations of
excessive exposure.
Implementation of As Low As Reasonably Achievable and Radiological Work Controls
(1 Sample)
The inspectors reviewed ALARA practices and radiological work controls by reviewing the
following activities:
(1) ALARA Plan 18RFO-0005
(2) ALARA Plan 18RFO-0006
(3) ALARA Plan 18RFO-0007
(4) ALARA Plan 18RFO-0018
(5) ALARA Plan 18RFO-0021
Radiation Worker Performance (1 Sample)
The inspectors evaluated radiation worker and radiation protection technician
performance.
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified Exelon performance indicators submittals listed below for the
period January 1, 2017, through December 31, 2017. (4 samples)
(1) Units 1 and 2 Reactor Coolant System Specific Activity
(2) Units 1 and 2 Reactor Coolant System Leak Rate
9
INSPECTION RESULTS
Failure to Conduct Adequate Radiation Surveys and Evaluate Potential Radiological Hazards
Cornerstone Significance Cross-Cutting Report
Aspect Section
Occupational Green H.11 - Human 71124.01
Radiation Safety NCV 05000317/2018001-01 Performance -
Closed Challenge the
Unknown
A self-revealed Green non-cited violation (NCV) of Title 10 Code of Federal Regulations
(10 CFR) 20.1501, Surveys and Monitoring: General, was identified when Exelon failed to
perform adequate surveys of the 11 reactor coolant pump bay area following the aggregation
of 25 high dose-rate in-core detectors in one area of the flooded refueling cavity, which is
adjacent to the pump bay. Surveys were not performed to evaluate the resulting dose rates
after the licensee changed the storage location of the detectors and radiological hazard
mitigation measures, such as locking and controlling access in accordance with Exelon
procedures, were not implemented, resulting in accessible dose-rates of up to 2,000 millirem
per hour (mrem/hr) in the pump bay.
Description:
In-core detectors are used in the reactor in order to monitor reactor power. These detectors
are exposed to a high neutron flux and become highly radioactive during normal operations.
During the Calvert Cliffs Unit 1 refueling outage, 25 in-core detectors were removed from the
reactor vessel and hung in a common location in the flooded refueling cavity for temporary
storage prior to cutting and disposal. During this work, a change to the process was made in
that the cold ends of the detector assemblies were positioned above the surface of the water
in the refueling cavity (instead of the typical ten feet below the water surface) during storage.
This resulted in a change in the relative position of the highly activated hot ends. The
collection of these 25 sources in one location, and the change in the position of the hot ends
within the flooded cavity, created an intense source of radioactivity which affected the
radiological conditions in the space adjacent to that portion of the refueling cavity.
The 11 reactor coolant pump enclosure (i.e, pump bay) is normally controlled as a high
radiation area during refueling outages because doses of greater than 100 mrem in one hour
are expected in accessible areas of the room. When the 25 in-core detectors were
aggregated in the refueling cavity for temporary storage between February 23 and 24, 2018,
radiation surveys were not re-performed in all areas where radiological conditions may have
changed. Some of the in-core detectors were placed at a location approximately ten feet
higher within the refueling cavity than usual due to larger number of detectors being replaced.
As a result, an accessible radiation field of up to 2,000 mrem/hr in the 11 pump bay was not
identified and controlled in accordance with Exelon procedures. This radiation field was
nearly 100 times the value that workers were being briefed to using the existing radiological
survey maps. On February 24, 2018, a worker in the 11 pump bay experienced an
unexpected electronic personal dosimeter alarm due to the high dose rate. The worker
immediately left the area and informed the radiation protection staff. The area was re-
surveyed at this time and the 2,000 mrem/hr field was discovered. The workers actual dose
received was far below the 10 CFR 20 dose limits.
The workers electronic personal dosimeter alarm set-points were 30 mrem dose and 400
mrem/hr dose rate. Exelon radiation workers are required to check their electronic personal
dosimeter for accumulated dose every 15 minutes. Electronic personal dosimeters for work in
this area are monitored remotely by radiation protection personnel, which increases the
likelihood that this unexpected condition would be detected prior to the worker being
overexposed. As a result, there was no substantial potential for over exposure. A single
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instance of failure to survey an area is also not considered to be a compromised ability to
assess dose.
Radiological verification surveys of the 11 pump bay to check for unexpected radiation levels
following the placement of 25 highly radioactive in-core detectors (in one location in the
adjacent portion of the refueling cavity) were reasonable under the circumstances, and were
needed to demonstrate compliance with 10 CFR 20.1601 Control of Access to High
Radiation Areas, and Exelon procedure RP-AA-460, Controls for High and Locked High
Radiation Areas. As a result of the failure to perform the surveys, one person was exposed
to unexpected high dose rates, since radiological conditions in assessable areas of the pump
bay had changed significantly.
The statements of consideration associated with the issuance of 10 CFR 20.1501 (as
provided in the Federal Register Notice 56 FR 23398) indicate that The principal role of the
[radiation] survey is preventative. Adequate survey procedures provide measurable
protection for the health and safety of the worker and the public because they provide the
information necessary for the establishment of adequate protective measures. The
usefulness of this early warning system may be seriously reduced if licensees are not held
responsible for failure to conduct any survey or for failure to conduct an adequate survey
[even] when violations of other Part 20 requirements have not occurred
Corrective Actions
Exelon conducted new radiation surveys, upgraded radiological controls in the 11 pump bay
(including controlling the area as a locked high radiation area), restricted access to the area,
and conducted a prompt investigation. The in-core detectors were lowered such that the
cold ends were again at their usual position of ten feet below the water surface, which
resulted in dose rates in the 11 pump bay returning to normal levels. The detectors were then
cut and put into disposal containers as planned. Exelon entered the issue into their
corrective action program. The inspectors reviewed the licensees investigation and
associated corrective actions and determined that they were reasonable and appropriate.
Corrective Action References: Exelon placed the issue in their corrective action program as
AR04108011, AR04107884, and AR04108041.
Performance Assessment:
Performance Deficiency: The performance deficiency is the failure to perform radiological
surveys in the 11 pump bay to evaluate the impact of a change in the storage location of
highly radioactive sources within the adjacent refueling cavity. Specifically following the
placement of in-core detectors at a location approximately ten feet higher within the refueling
cavity than usual, surveys were not performed in the adjacent space, which was controlled as
a High Radiation Area to which where personnel had access, to verify radiological conditions
had not changed. 10 CFR 20.1501 is the standard not met. This performance deficiency was
within Exelons ability to foresee and correct, and should have been prevented. Specifically,
Exelon was aware of the very high dose rates from the in-core instrumentation and
reasonably should have evaluated the impact on adjacent locations in containment.
Containment access restrictions are routinely employed when moving fuel and therefore
Exelon had an opportunity to realize that highly radioactive sources such as the in-core
instrumentation may have required similar precautions. As a result of the failure to perform
the surveys, appropriate radiological controls were not established in accordance with Exelon
procedure RP-AA-460 section 3.4 and one person was exposed to unexpected high dose
rates.
11
Title 10 CFR 20.1501 requires that each licensee make or cause to be made surveys that
may be necessary for the licensee to comply with the regulations in Part 20 and that are
reasonable under the circumstances to evaluate the magnitude and extent of radiation levels,
concentrations or quantities of residual radioactivity, and the potential hazards of the radiation
levels and residual radioactivity detected.
Screening: This finding is more than minor because it is associated with the Program &
Process attribute of the Occupational Radiation Safety cornerstone and affects the
cornerstone objective to ensure the adequate protection of the worker health and safety from
exposure to radiation from radioactive material during routine civilian nuclear reactor
operation. Specifically, radiation levels in an adjacent and accessible area were not verified
following a change in radiological conditions in that area. Thus a process radiation safety
barrier was defeated. The deficiency is similar to Example 6F in IMC 0612 Appendix E,
Examples of Minor Issues.
Significance: Using IMC 0609.04, Initial Characterization of Findings, issued October 7,
2016, and IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination
Process, issued August 19, 2008, the inspection finding was not related to ALARA practices
(Step 1), did not result in an overexposure (Step 5), did not represent a substantial potential
for overexposure (Step 11), and did not compromise Exelons ability to assess dose (Step
14). As a result, this finding was determined to be of very low safety significance (Green).
Cross Cutting Aspect: This finding has a cross-cutting aspect in the area of Human
Performance, Challenge the Unknown, in that Exelon did not ensure that individuals stop
when faced with uncertain conditions and ensure risks are evaluated and managed before
proceeding. Specifically, no one questioned whether the placement of the in-core detectors
at a higher level within the reactor cavity could adversely affect radiological conditions in
adjacent areas. (H.11)
Enforcement:
Violation: 10 CFR 20.1501 requires that each licensee make or cause to be made surveys
that may be necessary for the licensee to comply with the regulations in Part 20 and that are
reasonable under the circumstances to evaluate the magnitude and extent of radiation levels,
concentrations or quantities of residual radioactivity, and the potential hazards of the radiation
levels and residual radioactivity detected.
Title 10 CFR 20.1003 defines a survey as an evaluation of the radiological conditions and
potential hazards incident to the production, use, transfer, release, disposal, or presence of
radioactive material or other sources of radiation. When appropriate, such an evaluation
includes a physical survey of the location of radioactive material and measurements or
calculations of levels of radiation, or concentrations or quantities of radioactive material
present.
Title 10 CFR 20.1601, Control of access to high radiation area, requires licensees to provide
specific access controls for areas in which radiation levels from radiation sources external to
the body could result in an individual receiving a dose equivalent in excess of 0.1 rem in
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source or 30 centimeters from any surface that the
radiation penetrates. These access controls include locking entryways to such areas or
providing positve control over each individual entry when access to the areas is required.
Title 10 CRF 20.1601(c) allows a licensee to request approval of alternate means for
controlling access to high radiation areas.
12
The NRC had previously approved alternate means for controlling access to high radiation
areas for Calvert Cliffs. These alternate means had been provided in the Calvert Cliffs
Nuclear Power Plant, Unit Nos. 1 and 2 Technical Specifications, Section 6.12, High
Radiation Area.
In an August 26, 1996, letter issuing Amendment No. 216 to Facility Operating License No.
OPR-53 and Amendment No.193 to Facility Operating License No.DPR-69 for the Calvert
Cliffs Nuclear Power Plant, Unit Nos. 1 and 2, respectively, the NRC approved the licensees
request to relocate the TS 6.12 controls to site procedures. As noted in the NRC letter, since
the licensee must comply with this regulation [10CFR 20.1601] and, specifically with
20.1601(c) regarding Commission approval of alternative methods, the relocation of TS 6.12
to plant procedures is acceptable.
Exelon Procedure RP-AA-460, Controls for High and Locked High Radiation Areas,
Revision 31 is the plant procedure implementing these alternate methods of compliance with
RP-AA-460 Section 3.4, Locked High Radiation Area Controls (greater than OR equal to
1000 mrem/hr at 30 cm; < 500 Rad/hr at 1 meter) states,
POST AND CONTROL area as a Locked High Radiation Area when:
1. Dose rates accessible to an individual(s) are 800 mrem/hr at 30 cm or greater,
unless waived by the RPM using Attachment 1, OR
2. Dose rate(s) accessible to an individual(s) equal OR exceed 1000 mrem/hr at 30 cm.
Contrary to the above, on February 23 - 24, 2018, Exelon did not make or cause to be made
surveys that were necessary for the licensee to comply with the regulations in Part 20 and
were reasonable under the circumstances to evaluate the magnitude and extent of radiation
levels and, as a result, did not identify the presence of dose rates exceeding 1000 mrem/hr
within an area being controlled as a High Radiation Area. Specifically, the licensee had been
applying High Radiation Area access controls for the 11 pump bay, based on initial
radiological surveys performed at the start of the outage and historical dose rates in the room
from the adjacent refueling cavity, including the impact from the temporary placement of in-
core detectors in the adjacent cavity. However, the licensee did not perform subsequent
surveys to evaluate the resulting radiation levels in the 11 pump bay after changing the
storage location of the in-core detectors to an area approximately ten feet higher within the
cavity than had been historically used. These surveys were reasonable due to the change in
location of the detectors and were necessary to demonstrate compliance with 10 CFR 20.1601(c). As a result, the licensee did not identify the presence of an area requiring control
as a Locked High Radiation Area in accordance with Exelon procedure RP-AA-460 section
3.4 until a workers electronic personal dosimeter alarmed.
Enforcement Actions:
This violation is being treated as a NCV, consistent with Section 2.3.2 of the NRC
Enforcement Policy. (NCV 05000317/2018001-01: Failure to Conduct Adequate
Radiation Surveys and Evaluate Potential Radiological Hazards)
13
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On January 11, 2018, the inspectors presented the inspection results of activities related to
Section 71124.02 to Mr. Mark Flaherty, Site Vice President, and other members of the
Exelon staff.
- On March 2, 2018, the inspectors presented the inspection results of activities related to
Sections 71124.01 and 71124.02 to Mr. Mark Flaherty, Site Vice President, and other
members of the Exelon staff.
- On March 8, 2018, the inspectors presented the inspection results of activities related to
Section 71111.08 inspection results to Mr. Mark Flaherty, Site Vice President, and other
members of the Exelon staff.
- On April 25, 2018, the inspectors presented the quarterly resident inspector inspection
results to Mr. Mark Flaherty, Site Vice President, and other members of the Exelon staff.
14
DOCUMENTS REVIEWED
Section 71111.18 - Plant Modifications
Calculation:
CN-SDA-18-12, Calvert Cliffs Unit 1 Core Shroud Tie Rod Evaluation for Continued Operation
of One Cycle with One Missing Core Shroud Tie Rod, Revision 0
Miscellaneous
ECP-17-000416, Unit 1,Replace reactor coolant pump motor oil level indication system.
ECP-18-00016, Unit 1, Reactor Internal Inspections found one of eight Core Shroud Tie-rods
Dis-engaged form the threaded connections at each end.
FS1-0036628, Evaluation of Calvert Cliffs Bypass Flow, Revision 1
LTR-RC-18-13, Calvert Cliffs Unit 1 Cycle 24 Dropped Tie Rod Use-as-is 10 CFR 50.59 Input
Section 71124.01 - Radiological Hazard Assessment and Exposure Controls
Procedures
NISP-RP-005, Access Controls for High Radiation Areas, Revision 0
RP-AA-300-1006, Radiological Controls for System Operations with Radiological Impact in
Normally Accessible Areas, Revision 0
RP-AA-460, Controls for High and Locked High Radiation Areas, Revision 31
RV-68, In-Core Instrumentation Removal, Revision 02300
Miscellaneous
ALARA Plan 18RFO-0015, RT 10842007, Remove ICIS IAW RV-68 Procedure, dated
12/8/2017
ALARA Waiver Form, 18RFO-0015, dated 2/26/2018
AR04107884
AR04108011
AR04108041 and its related HURB report
Drawing C-261, Containment Interior Section and CL Reactor Vessel, Sheet 5
Radiation Work Permit CC-1-18-00615, Revision 00
Radiological survey 2018-003297
Radiological survey 2018-002455
Radiological survey 2018-003277
Radiological survey 2018-003400
Radiological survey 2018-003269
Radiological survey 2018-00
WO C93489748
Section 71124.02 - Occupational ALARA Planning and Controls
Procedures
RP-AA-1008, Unescorted Access to and Conduct in Radiologically Controlled Areas, Revision 6
RP-AA-400, As Low As Reasonably Achievable Program, Revision 14
RP-AA-401, Operational As Low As Reasonably Achievable Planning and Controls, Revision 22
RP-AA-403, Administration of the Radiation Work Permit Program, Revision 9
RP-AA-441, TEDE As Low As Reasonably Achievable Evaluation, Revision 8
Action Request
AR03973742 AR03980352 AR04027589 AR04040215 AR04042311 AR04064701
15
Documents
ALARA Plan 17RFO-0010, Scaffold Activities
ALARA Plan 17RFO-0011, Outage Insulation
ALARA Plan 17RFO-0013, NSRX Reactor Disassembly/Reassembly
ALARA Plan 17RFO-0019, Dissimilar Metal Weld Inspections
ALARA Post-Job Review, 17RFO-0010
ALARA Post-Job Review, 17RFO-0011
ALARA Post-Job Review, 17RFO-0013
ALARA Post-Job Review, 17RFO-0019
ALARA Post-Job Review, 17RFO-0042
ALARA Work-In-Progress Review, 17RFO-0006, REM Discretion, 50%, Other
ALARA Work-In-Progress Review, 17RFO-0010, REM Discretion, 50%, 80%
ALARA Work-In-Progress Review, 17RFO-0011, 50%, 80%
ALARA Work-In-Progress Review, 17RFO-0019, 50%
Dose Excellence Plan, Calvert Cliffs Nuclear Power Plant, 2017-2021, Revision 0
List, 17RFO radiation exposure, actual vs estimate.
List, On-line work activities > 1 REM
Radiation Protection Outage Report, CC2R22
Radiation work permit CC-0-18-00312, Revision 1
Radiation work permit CC-2-17-00502, Revision 0
Radiation work permit CC-2-17-00503, Revision 0
Radiation work permit CC-2-17-00505, Revision 0
Radiation work permit CC-2-17-00613, Revision 0
Radiological survey, containment post-shutdown, Unit1, dated 2/15/2016
Radiological survey, containment post-shutdown, Unit2, dated 2/13/2017
Radiological survey, EPRI standard radiation monitoring program, Unit 1, dated 3/14/2010
Radiological survey, EPRI standard radiation monitoring program, Unit 1, dated 3/4/2016
Station ALARA Committee Agenda and Package, dated 1/10/18
Station ALARA Committee Meeting Minutes from 1/13/2017
Station ALARA Committee Meeting Minutes from 1/6/2017
Station ALARA Committee Meeting Minutes from 10/31/2017
Station ALARA Committee Meeting Minutes from 3/1/2017
Station ALARA Committee Meeting Minutes from 7/27/2017
Station ALARA Committee Meeting Minutes from 9/26/2017
Station ALARA Committee Meeting Minutes from 9/6/2017
TEDE ALARA Evaluation, CC-2-17-00502
TEDE ALARA Evaluation, CC-2-17-00503
TEDE ALARA Evaluation, CC-2-17-00505
TEDE ALARA Evaluation, CC-2-17-00613
Whole body count #14952