IR 05000317/2017007

Temporary Instruction 2515/191, Inspection Report 05000317/2017007 and 05000318/2017007

ML17151A232
Person / Time
Site:	Calvert Cliffs
Issue date:	05/30/2017
From:	Marc Ferdas Division Reactor Projects I
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
References
IR 2017007
Download: ML17151A232 (12)

Text

May 30, 2017

SUBJECT:

CALVERT CLIFFS NUCLEAR POWER PLANT - TEMPORARY INSTRUCTION 2515/191 INSPECTION REPORT 05000317/2017007 AND 05000318/2017007

Dear Mr. Hanson:

On April 20, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2. On April 20, 2017, the 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.

The inspection examined activities conducted under your licenses as they relate to the implementation of mitigation strategies and spent fuel pool instrumentation orders (EA-12-049 and EA-12-051) and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, your compliance with the Commissions rules and regulations, and with the conditions of your operating licenses. Within these areas, the inspection involved examination of selected procedures and records, observation of activities, and interviews with plant personnel.

The NRC inspectors did not identify any finding or violation of more than minor significance. 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Marc S. Ferdas, Chief Technical Support and Assessment Branch Division of Reactor Projects Docket Nos. 50-317 and 50-318 License Nos. DPR-53 and DPR-69

Enclosure:

Inspection Report 05000317/2017007 and 05000318/2017007 w/Attachment: Supplementary Information

REGION I==

Docket Nos. 50-317 and 50-318 License Nos. DPR-53 and DPR-69 Report Nos. 05000317/2017007 and 05000318/2017007 Licensee: Exelon Generation Company, LLC (Exelon)

Facility: Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Location: Lusby, MD Dates: April 17-20, 2017 Inspectors: C. Cahill, PE, Senior Reactor Analyst, Division of Reactor Safety (DRS)

S. Anderson, Reactor Engineer, DRS C. Roettgen, Resident Inspector (Calvert Cliffs)

Approved by: Marc S. Ferdas, Chief Technical Support and Assessment Branch Division of Reactor Projects Enclosure

SUMMARY

Inspection Report 05000317/2017007 and 05000318/2017007; 04/17/2017 - 04/20/2017;

Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2; Temporary Instruction (TI)2515/191, Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans.

The inspection covered a one week inspection by one senior reactor analyst, a reactor engineer, and the resident inspector. No findings were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 6.

REPORT DETAILS

4OA5 Other Activities

TI 2515/191 - Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans The objective of TI 2515/191, Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, is to verify:

(1) that licensees have adequately implemented the mitigation strategies as described in the licensees Final Integrated Plan (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16131A638) and the NRCs plant safety evaluation (ADAMS Accession No. ML16258A446);

(2) that the licensees installed reliable water-level measurement instrumentation in their spent fuel pools (SFPs); and

(3) that licensees have implemented emergency preparedness enhancements as described in their site-specific submittals and NRC safety assessments, including multi-unit dose assessment capability, enhancements to ensure that staffing is sufficient, and that communications can be maintained during beyond-design-basis external events.

The team verified that plans for complying with NRC Orders EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design Basis External Events, (ADAMS Accession No. ML12054A735) and EA-12-051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation, (ADAMS Accession No. ML12056A044) were in place and were being implemented by Exelon. The team also verified that Exelon had implemented staffing and communications plans provided in response to the March 12, 2012, request for information letter and multi-unit dose assessment information provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013 (ADAMS Accession No.

ML12339A262).

The team discussed the plans and strategies with Exelon personnel, reviewed documentation, completed a tabletop exercise involving a beyond design basis event leading to an extended loss of offsite power and, where appropriate, performed plant walk downs to verify that the strategies could be implemented as stated in Exelons submittals and the NRC staff prepared safety evaluation. For most strategies, this included verification that the strategy was feasible, procedures and/or guidance had been developed, training had been provided to plant staff, and required equipment had been identified and staged. Specific details of the teams inspection activities are described in the following sections. Documents reviewed for each section of this report are listed in the Attachment.

1. Mitigation Strategies for Beyond-Design Basis External Events

a. Inspection Scope

The team examined Exelons established guidelines and implementing procedures for the beyond-design-basis mitigation strategies. The team assessed how the Exelon staff coordinated and documented the interface/transition between existing off-normal and emergency operating procedures with the newly developed mitigation strategies. The team selected a number of mitigation strategies and conducted plant walk downs with licensed operators and responsible plant staff to assess: the adequacy and completeness of the procedures; familiarity of operators with the procedure objectives and specific guidance; staging and compatibility of equipment; and the practicality of the operator actions prescribed by the procedures, consistent with the postulated scenarios.

The team verified that a preventive maintenance program had been established for the Diverse and Flexible Coping Strategies (FLEX) portable equipment and that periodic equipment inventories were in place and being conducted. Additionally, the team examined the introductory and planned periodic/refresher training provided to the Operations and CCNP staff most likely to be tasked with implementation of the FLEX mitigation strategies. The team also reviewed the introductory and planned periodic training provided to the Emergency Response Organization personnel.

b. Assessment Based on samples selected for review, the inspectors verified that Exelon satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittals and the associated safety evaluation (ADAMS Accession No.

ML16258A446) and determined that Exelon was in compliance with NRC Order EA-12-049.

The team verified that Exelon satisfactorily:

• Developed and issued FLEX Support Guidelines (FSGs) to implement the FLEX strategies for postulated external events;

• Integrated their FSGs into their existing emergency operating procedures and off-normal procedures such that entry into and departure from the FSGs are clear when using existing plant procedures;

• Protected FLEX equipment from site-specific hazards;

• Developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability;

• Trained their staff to assure personnel proficiency in the mitigation of beyond-design-basis events; and

• Developed procedures to ensure that the necessary off-site FLEX equipment will be available from off-site locations.

The team verified that inspector observations identified during the inspection were entered into Exelons corrective action program, where appropriate.

c. Findings

No findings were identified.

2. Spent Fuel Pool Instrumentation

a. Inspection Scope

The team examined Exelons newly installed SFP instrumentation. Specifically, the team verified the sensors were installed as described in the plant specific submittals and the associated safety evaluation, and that the cabling for the power supplies and the indications for each channel are physically and electrically separated. In addition, the team verified that Exelon had evaluated environmental conditions and accessibility of the instrumentation.

The team verified that Exelon had approved procedures for maintenance, testing, calibration, and use of the primary and backup SFP instrumentation channels. The team also verified that the procedures followed the industry guidance contained in Nuclear Energy Institute 12-02, Industry Guidance for Compliance with NRC Order EA-12-051, To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, and that these procedures were part of an existing Exelon process to be maintained.

b. Assessment Based on samples selected for review, the team determined that Exelon satisfactorily installed and established appropriate operating and maintenance controls for the SFP instrumentation as described in the plant specific submittals and the associated safety evaluation. The team determined that Exelon was in compliance with NRC Order EA-12-051.

The team verified that Exelon satisfactorily:

• Installed the SFP instrumentation sensors, cabling, and power supplies to provide physical and electrical separation as described in the plant specific submittals and safety evaluation;

• Installed the SFP instrumentation display in the accessible location, and environmental conditions as described in the plant specific submittals;

• Trained their staff to assure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation; and

• Developed and issued procedures for maintenance, testing, and use of the reliable SFP instrumentation.

The team verified that issues identified during the inspection were entered into Exelons corrective action program.

c. Findings

No findings were identified.

3. Staffing and Communication Request for Information

a. Inspection Scope

Through discussions with plant staff, review of documentation, and plant walk downs, the team verified that Exelon had implemented required changes to staffing, communications equipment, and facilities to support an extended loss of all AC power (ELAP) scenario as described in Exelons staffing assessment and the NRC safety evaluation. The team also verified that Exelon had implemented dose assessment (including releases from SFPs) capability using site-specific dose assessment software, as described in Exelons dose assessment submittal.

b. Assessment The team reviewed information provided in Exelons dose assessment submittal and in response to the NRCs March 12, 2012, request for information letter (ML12053A340),

and verified that Exelon satisfactorily implemented enhancements pertaining to Near-Term Task Force (NTTF) Recommendation 9.3, response to a large scale natural emergency event that results in an ELAP to all site units and impedes access to the site.

The team verified the following:

• Exelon satisfactorily implemented required staffing changes to support an ELAP scenario;

• Emergency preparedness communications equipment and facilities were sufficient for dealing with an ELAP scenario; and

• Exelon implemented dose assessment capabilities (including releases from SFPs)using CCNPP site-specific dose assessment software and approach.

The team verified that issues identified during the inspection were entered into Exelons corrective action program.

c. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On April 20, 2017, the team exited the inspection results with Mr. Mark Flaherty, Site Vice President, and other members of the CCNPP staff. The team verified that no proprietary information was retained by team members or documented in this report.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

M. Flaherty, Site Vice President

P. Amos, Site Emergency Planning Manager

F. Bazyk, Manager, Operations Support

J. Delgado, Senior Engineer

M. Fick, Principal Regulatory Engineer

B. Ficke, Senior Site Emergency Planning Specialist

D. Geneva, Ops Shift Manager

K. Greene, Principal Regulatory Engineer

R. Gretz, Lead Operations Instructor

J. Huber, Supervisor Facilities

J. Lyter, Exelon Corporate FLEX Transition Ops/BWR Lead

R. Pace, Consultant

S. Pierson, Exelon Corporate FLEX Transition Ops/PWR Lead

M. Robinson, Senior Emergency Preparedness Specialist

A. Thorne, Programs Engineer

J. Wood, Principal Plant Operator

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened and Closed:

None

Discussed:

None