ML21124A037
| ML21124A037 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 05/04/2021 |
| From: | Matt Young Division of Operating Reactors |
| To: | Rhoades D Exelon Generation Co, Exelon Nuclear |
| Young M | |
| References | |
| IR 2021001 | |
| Download: ML21124A037 (15) | |
See also: IR 05000317/2021001
Text
May 4, 2021
Mr. David P. Rhoades
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, UNITS 1 AND 2 -
INTEGRATED INSPECTION REPORT 05000317/2021001 AND
Dear Mr. Rhoades:
On March 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
at Calvert Cliffs Nuclear Power Plant, Units 1 and 2. On April 9, 2021, the NRC inspectors
discussed the results of this inspection with Mr. Thomas Haaf, Site Vice President and other
members of your staff. The results of this inspection are documented in the enclosed report.
No NRC-identified or self-revealing findings were identified during this inspection.
A licensee-identified violation which was determined to be Severity Level IV is documented in
this report. We are treating this violation as a non-cited violation (NCV) consistent with Section
2.3.2 of the Enforcement Policy. The NRC will not conduct a follow-up inspection for this
violation because it does not involve any of the initiating criteria in Inspection Procedure 92702,
Follow-up on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory
Action Letters, and Orders."
If you contest the violation or the significance or severity of the violation documented in this
inspection report, 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
Calvert Cliffs Nuclear Power Plant, Units 1 and 2.
D. Rhoades
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 at the NRC Public Document
Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public
Inspections, Exemptions, Requests for Withholding.
Sincerely,
X /RA/
Signed by: Matthew R. Young
Matt R. Young, Chief
Reactor Projects Branch 5
Division of Operating Reactor Safety
Docket Nos. 05000317 and 05000318
License Nos. DPR-53 and DPR-69
Enclosure:
As stated
cc w/ encl: Distribution via LISTSERV
x
SUNSI Review
x
Non-Sensitive
Sensitive
x
Publicly Available
Non-Publicly Available
OFFICE RI/DORS
RI/DORS
RI/DORS
NAME
DBeacon
LCline
MYoung
DATE
5/4/21
5/4/21
5/4/21
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Numbers:
05000317 and 05000318
License Numbers:
Report Numbers:
05000317/2021001 and 05000318/2021001
Enterprise Identifier: I-2021-001-0101
Licensee:
Exelon Generation Company, LLC
Facility:
Calvert Cliffs Nuclear Power Plant, Units 1 and 2
Location:
Lusby, MD
Inspection Dates:
January 1, 2021 to March 31, 2021
Inspectors:
H. Anagnostopoulos, Senior Health Physicist
D. Beacon, Resident Inspector
R. Clagg, Senior Resident Inspector
L. Cline, Senior Project Engineer
N. Floyd, Senior Reactor Inspector
S. Obadina, Resident Inspector
Approved By:
Matt R. Young, Chief
Reactor Projects Branch 5
Division of Operating Reactor Safety
2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting an integrated inspection at Calvert Cliffs Nuclear Power Plant,
Units 1 and 2, 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/oversight.html for more information. A
licensee-identified non-cited violation is documented in report section: 71152.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
3
PLANT STATUS
Unit 1 operated at or near rated thermal power for the entire inspection period.
Unit 2 began the inspection period at rated thermal power and was operated at or near full
power until February 28 when the unit was shut down for a planned refueling outage. Following
refueling, Unit 2 was restarted and began power ascension on March 20. On March 21 during
power ascension, the unit was tripped from 38 percent power due to a steam generator
feedwater regulating valve mechanical failure. Following completion of valve repairs, Unit 2 was
restarted on March 23 and operated at or near full power through the end of the 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 licensee performance and compliance
with Commission rules and regulations, license conditions, site procedures, and standards.
Starting March 20, 2020, in response to the National Emergency declared by the President of
the United States on the public health risks of the coronavirus (COVID-19), resident and
regional inspectors were directed to begin telework and to remotely access licensee information
using available technology. During this time the resident inspectors performed periodic site visits
each week, increasing the amount of time on site as local COVID-19 conditions permitted. As
part of their onsite activities, resident inspectors conducted plant status activities as described in
IMC 2515, Appendix D; observed risk significant activities; and completed on site portions of
IPS. In addition, resident and regional baseline inspections were evaluated to determine if all or
portion of the objectives and requirements stated in the IP could be performed remotely. If the
inspections could be performed remotely, they were conducted per the applicable IP. In some
cases, portion of an IP were completed remotely and on site. The inspections documented
below met the objections and requirements for completion of the IP.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1)
Unit 1, 13 auxiliary feedwater pump during 12 auxiliary feedwater pump out of service
for quarterly surveillance testing, January 22, 2021
(2)
Unit 2, 2B emergency diesel generator while 21 saltwater header is out of service for
maintenance, January 26, 2021
4
(3)
Unit 2, 22 saltwater header while the 21 saltwater header is out of service for
maintenance, March 9, 2021
(4)
Unit 2, spent fuel pool cooling during fuel shuffle, March 11, 2021
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a
walkdown and performing a review to verify program compliance, equipment functionality,
material condition, and operational readiness of the following fire areas:
(1)
Unit 1, cable spreading room and battery rooms, fire areas 16, 16A, and 16B,
January 8, 2021
(2)
Unit 2, cable spreading room and battery rooms, fire areas 17, 17A, and 17B,
January 15, 2021
(3)
Unit 2, turbine building, fire area TB, March 6, 2021
(4)
Unit 2, containment, fire area CNMT, March 10, 2021
(5)
Unit 1, turbine building, fire area TB, March 16, 2021
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
(1)
The inspectors evaluated the onsite fire brigade training and performance during an
unannounced drill on March 1, 2021.
71111.08P - Inservice Inspection Activities (PWR)
PWR Inservice Inspection Activities Sample (IP Section 03.01) (1 Sample)
(1)
The inspectors verified that the reactor coolant system boundary, steam generator
tubes, reactor vessel internals, risk-significant piping system boundaries, and
containment boundary are appropriately monitored for degradation and that repairs
and replacements were appropriately fabricated, examined and accepted by
reviewing the following activities from March 1 to March 23, 2021:
03.01.a - Nondestructive Examination and Welding Activities
Manual ultrasonic testing of the pressurizer surge line nozzle, 4-404 (NDE
Report ISI-UT-016).
Manual ultrasonic testing of the pressurizer pipe to safe end weld, 4-PS-2003-
7 (NDE Report ISI-UT-008).
Manual ultrasonic testing of the safety injection pipe to valve weld, 12-SI-
2012-7 (NDE Report ISI-UT-015).
Liquid penetrant testing of the 21 reactor coolant pump support lug, 21A-2
(NDE Report ISI-PT-003).
Visual examinations of the core shroud tie-rods #1 through #8 (NDE Report
ISI-VT-144).
Visual examinations of the containment accessible surfaces, including the
liner, leak chase channels, and moisture barrier (WO C93732456).
Welding activities associated with the repair of the pressurizer heater sleeve
penetration G-1 under engineering change ECP-21-000102
5
(WO C91977390). This repair was in response to leakage identified during
the visual examination of the pressurizer heater sleeves in accordance with
American Society of Mechanical Engineers Code Case N-722-1 (NDE Report
ISI-VT-051).
03.01.b - Pressurized-Water Reactor Vessel Upper Head Penetration Examination
Activities
Follow-up review of head penetrations 72 and 73 subjected to bare metal
visual examinations as required in response to previous examination results
(NDE Report ISI-VT-134).
03.01.c - Pressurized-Water Reactor Boric Acid Corrosion Control Activities
Boric acid evaluation for 2CV517 on the core spray system (IR 04405537).
Boric acid evaluation for the reactor vessel head flange (IR 04406312).
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)
(1 Sample)
(1)
The inspectors observed and evaluated licensed operator performance in the Control
Room during the shutdown of Unit 2 for the refueling outage on March 1, 2021.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
(1)
The inspectors observed operator simulator training involving the loss of a low
pressure safety injection pump, loss of offsite power, and leak on a shutdown cooling
heat exchanger on February 2, 2021.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
The inspectors evaluated the effectiveness of maintenance to ensure the following
structures, systems, and components (SSCs) remain capable of performing their intended
function:
(1)
Unit 2, AR04399180, 2CV110Q letdown control valve failure to shut, March 22, 2021
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to
ensure the following SSC remains capable of performing its intended function:
(1)
Unit 2, WO C93721752, 21 saltwater header out of service due to replacement of
2CV5150, 21 A/B service water heat exchanger saltwater inlet, February 24, 2021
6
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the
following planned and emergent work activities to ensure configuration changes and
appropriate work controls were addressed:
(1)
Unit 2, elevated risk condition due to preventive maintenance on the 21A service
water heat exchanger, January 13, 2021
(2)
Unit 2, elevated risk condition due to 22 emergency core cooling system pump room
air cooler maintenance, January 21, 2021
(3)
Unit 2, elevated risk condition due to 21 saltwater header out of service for
maintenance, January 27, 2021
(4)
Unit 2, Yellow risk condition due to having four containment air coolers out of service,
March 5, 2021
(5)
Unit 2, Yellow risk condition due to lowered inventory for reactor pressure vessel
head installation, March 14, 2021
(6)
Unit 2, Yellow risk condition due to reduced inventory for reactor coolant system
vacuum fill, March 18, 2021
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the
following operability determinations and functionality assessments:
(1)
Unit 1, AR04393743, 1MOV6200OP, fire protection containment isolation valve,
degraded grease, Grade 3, January 12, 2021
(2)
Unit 2, AR04395519, Unit 2 containment outage door penetration 13 leaking
excessively, January 13, 2021
(3)
Units 1 and 2, AR04396365, 0-FP-110, 12 diesel fire pump discharge valve packing
leak, January 21, 2021
(4)
Unit 2, AR04396969, Unit 2 cable spreading room supply damper not functioning
properly, January 21, 2021
(5)
Unit 2, AR04395583, technical evaluation to remove high energy line break barrier
plug for draining of the 21 charging and volume control system letdown filter to
support basket inspection, February 16, 2021
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)
(2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
(1)
ECP-17-000734, air operated valve/containment isolation valve vulnerability
reduction, March 24, 2021
(2)
ECP-21-000102, Unit 2 pressurizer heater sleeve penetration G-1 plug repair,
March 22, 2021
7
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system
operability and functionality:
(1)
Unit 2, WO C93721752, 21 saltwater header out of service due to replacement of
CV5150, 21 A/B service water heat exchanger inlet valve, January 28, 2021
(2)
Unit 2, WO C93720690, preventative maintenance on 2MOV269OP, safety injection
to charging header motor operated valve, January 29, 2021
(3)
Unit 2, WO C93705327, 23 auxiliary feedwater pump bearing replacement, March 24,
2021
(4)
Unit 2, WO C92676514, 21 high pressure safety injection pump bearing replacement,
March 31, 2021
(5)
Unit 2, WO C93092012, 21 low pressure safety injection pump discharge check valve
maintenance, March 31, 2021
(6)
Unit 2, WO C93704701, 21 auxiliary feedwater governor valve and throttle/stop valve
maintenance, March 31, 2021
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
(1)
The inspectors evaluated refueling outage 2R24 activities from February 28, 2021 to
March 26, 2021.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01) (5 Samples)
(1)
Unit 2, I-131-2, "Leak Rate Testing of Containment Outage Door (COD) Seals and
Penetrations," Revision 003, January 12, 2021
(2)
Unit 2, STP-M-698-2, "Functional Test of Halon System for Cable Spreading Room,"
Revision 003, January 21, 2021
(3)
Unit 2, STP-O-8B-2, "Test of 2B Diesel Generator and 4kV Bus 24 Undervoltage,"
Revision 03404, January 21, 2021
(4)
STP-O-8A-1, "Test of 1A Diesel Generator and 11 4kV Bus Undervoltage," Revision
33, February 24, 2021
(5)
Unit 1, STP-O-8B-1, "Test of 1B Diesel Generator and 14 4kV Bus Undervoltage,"
Revision 35, March 31, 2021
Inservice Testing (IP Section 03.01) (2 Samples)
(1)
Unit 1, STP-O-5A12-1, "12 Auxiliary Feedwater Pump Quarterly Surveillance Test,"
Revision 8, January 22, 2021
(2)
Unit 2, STP-O-5A23-2, "23 Auxiliary Feedwater Pump Quarterly Surveillance
Test," Revision 0, February 17, 2021
8
Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)
(1)
Unit 2, STP-O-108D38-2, "Containment Penetration 38 Local Leak Rate Tests,"
Revision 0, March 15, 2021
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
(1)
The inspectors evaluated how the licensee identifies the magnitude and extent of
radiation levels and the concentrations and quantities of radioactive materials and
how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
The inspectors evaluated instructions to workers including radiation work permits used to
access high radiation areas.
(1)
The inspectors reviewed the following:
Radiation Work Packages
CC-2-21-00401
CC-2-21-00613
CC-2-21-00503
Electronic Alarming Dosimeter Alarms
No alarms occurred during the period of this inspection]
Labeling of Containers
Boxes in the storage yard adjacent to the Unit 2 butler building
Resin drums in the Unit 2 69' truck bay
Storage box for a tri-nuke filtration system in the solid waste processing area
Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)
The inspectors evaluated licensee processes for monitoring and controlling contamination
and radioactive material.
(1)
The inspectors verified the following sealed sources are accounted for and are intact:
03C24
(2)
The inspectors verified the following sealed sources are accounted for and are intact:
CZ2578
Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)
The inspectors evaluated in-plant radiological conditions during facility walkdowns and
observation of radiological work activities.
9
(1)
The inspectors also reviewed the following radiological work package for areas with
airborne radioactivity:
CC-2-21-00613
(2)
The inspectors also reviewed the following radiological work package for areas with
airborne radioactivity:
CC-2-21-00503
(3)
The inspectors also reviewed the following radiological work package for areas with
airborne radioactivity:
CC-2-21-00617
High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (2 Samples)
The inspectors evaluated licensee controls of the following High Radiation Areas and Very
(1)
Unit 2 personnel airlock
(2)
Unit 1 monitored waste retention tank room
Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section
03.06) (1 Sample)
(1)
The inspectors evaluated radiation worker and radiation protection technician
performance as it pertains to radiation protection requirements.
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (5 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant
walkdowns:
(1)
REM Ball S/N 0024399
(2)
Telepole S/N 0017242
(3)
RO-20 S/N 0021939
(4)
Ludlum 9-4 S/N 0023359
(5)
3030P S/N 0018429
Calibration and Testing Program (IP Section 03.02) (11 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection
instruments:
(1)
FASTSCAN whole body counter in the dosimetry office
(2)
TriCarb 3100TR Liquid Scintillation Counter in the chemistry lab
(3)
Containment High Range Radiation Monitor (1RE5317A)
(4)
Containment High Range Radiation Monitor (2RE5317A)
(5)
Containment High Range Radiation Monitor (1RE5317B)
(6)
Containment High Range Radiation Monitor (2RE5317B)
(7)
REM Ball S/N 0024399
(8)
Telepole S/N 0017242
10
(9)
RO-20 S/N 0021939
(10)
Ludlum 9-4 S/N 0023359
(11)
3030P S/N 0018429
Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (3 Samples)
The inspectors evaluated the calibration and maintenance of the following radioactive
effluent monitoring and measurement instrumentation:
(1)
Unit 2 Wide Range Gas Monitor (2-RE-5415)
(2)
Gas & liquid waste discharge radiation monitor flow elements (0FT2192 and
0FT2199)
(3)
Waste processing exhaust filter HEPA test and flow verification
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 03.10) (2 Samples)
(1)
Unit 1, January 1, 2020 - December 31, 2020
(2)
Unit 2, January 1, 2020 - December 31, 2020
BI02: RCS Leak Rate Sample (IP Section 03.11) (2 Samples)
(1)
Unit 1, January 1, 2020 - December 31, 2020
(2)
Unit 2, January 1, 2020 - December 31, 2020
INSPECTION RESULTS
Licensee-Identified Non-Cited Violation
This violation of very low safety significance was identified by the licensee and has been
entered into the licensee corrective action program and is being treated as a non-cited
violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: The Calvert Cliffs Unit 1 and Unit 2 renewed facility operating licenses, DPR-53
and DPR-69, Appendix C, contain a license condition, implemented under License
Amendment 237, that requires, in part, that the established decommissioning trust
agreement must provide that no disbursements or payments from the trust shall be made by
the trustee until the trustee has first given the NRC 30-days prior written notice of payment.
Contrary to the above, on five occasions between 2017 and 2020, Exelon enacted
disbursements from the Calvert Cliffs Units 1 and 2 decommissioning trust funds and the
trustee had not first given the NRC 30-days prior written notice of payment.
Significance/Severity: Severity Level IV. The NRC traditional enforcement process applies to
this violation because the violation represents an impact to the regulatory process (i.e. failure
to notify the NRC of changes in licensed activities). The significance of this violation was
evaluated per the NRC enforcement policy and was determined to be Severity Level IV
because the disbursements made were legitimate decommissioning planning
11
expenses and prior written notice, as required, would not have likely caused the NRC to
reconsider its regulatory position or undertake substantial further inquiry.
Corrective Action References: AR04410080, ML21089A302
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On April 9, 2021, the inspectors presented the integrated inspection results to
Mr. Thomas Haaf, Site Vice President and other members of the licensee staff.
On January 22, 2021, the inspectors presented the radiation monitoring instrumentation
inspection results to Mr. Thomas Haaf, Site Vice President and other members of the
licensee staff.
On March 5, 2021, the inspectors presented the radiological hazard assessment and
exposure controls inspection results to Mr. Thomas Haaf, Site Vice President and other
members of the licensee staff.
On March 23, 2021, the inspectors presented the inservice inspection activities
inspection results to Mr. Thomas Haaf, Site Vice President and other members of the
licensee staff.
12
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71111.08P Corrective Action
Documents
Corrective Action
Documents
Resulting from
Inspection
Drawings
02-8126886
Calvert Cliffs Unit 2 Pressurizer Penetration G1 Plug
Implementation
Revision 0
and 2
Miscellaneous
ER-CA-330-1001
ISI program Plan Fifth Ten-Year Inspection Interval
Revision 2
Procedures
55-
WP43/43/F43AW1
Welding Procedure Specification for manual GTAW of P-
Number 43 base materials with F-Number 43 filler materials
Revision 11
and 12