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{{#Wiki_filter:UNITED STATES
{{#Wiki_filter:UNITED STATES  
                          NUCLEAR REGULATORY COMMISSION
NUCLEAR REGULATORY COMMISSION  
                                            REGION I
REGION I  
                            2100 RENAISSANCE BOULEVARD, SUITE 100
2100 RENAISSANCE BOULEVARD, SUITE 100  
                                  KING OF PRUSSIA, PA 19406-2713
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
May 9, 2018  
4300 Winfield Road
Warrenville, IL 60555
SUBJECT:         CALVERT CLIFFS NUCLEAR POWER PLANT - INTEGRATED INSPECTION
Mr. Bryan C. Hanson  
                REPORT 05000317/2018001 AND 05000318/2018001
Senior Vice President, Exelon Generation Company, LLC  
Dear Mr. Hanson:
President and Chief Nuclear Officer, Exelon Nuclear  
On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
4300 Winfield Road  
at Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2. On April 25, 2018, NRC
Warrenville, IL 60555  
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
SUBJECT:  
report.
CALVERT CLIFFS NUCLEAR POWER PLANT - INTEGRATED INSPECTION  
NRC inspectors documented one finding of very low safety significance (Green) in this report.
REPORT 05000317/2018001 AND 05000318/2018001
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.
Dear Mr. Hanson:  
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
On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection  
Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with
at Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2. On April 25, 2018, NRC  
copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the
inspectors discussed the results of this inspection with Mr. Mark Flaherty, Site Vice President,  
NRC Resident Inspector at CCNPP. In addition, if you disagree with the cross-cutting aspect in
and other members of your staff. The results of this inspection are documented in the enclosed  
this report, you should provide a response within 30 days of the date of this inspection report,
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
NRC inspectors documented one finding of very low safety significance (Green) in this report.
Administrator, Region I, and the NRC Resident Inspector at CCNPP.
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
B. Hanson  
This letter, its enclosure, and your response (if any) will be made available for public inspection
2  
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
This letter, its enclosure, and your response (if any) will be made available for public inspection  
Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
and copying at http://www.nrc.gov/reading-rm/adams.html and the Nuclear Regulatory  
                                              Sincerely,
Commission Public Document Room in accordance with Title 10 of the Code of Federal  
                                              /RA/
Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.  
                                              Michelle Catts, Acting Chief
                                              Reactor Projects Branch 1
Sincerely,  
                                              Division of Reactor Projects
Docket Nos. 50-317 and 50-318
License Nos. DPR-53 and DPR-69
Enclosure:
Inspection Report 05000317/2018001 and
  05000318/2018001
  w/Attachment: Supplementary Information
cc w/encl: Distribution via ListServ
/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
  05000318/2018001  
  w/Attachment: Supplementary Information  
cc w/encl: Distribution via ListServ  




  ML18130A878
  ML18130A878
                                              Non-Sensitive                             Publicly Available
      SUNSI Review
SUNSI Review
                                              Sensitive                                  Non-Publicly Available
   
  OFFICE         RI/DRP               RI/DRP               RI/ORA               RI/DNMS                 RI/DRP
Non-Sensitive  
  NAME           RClagg/AR per telecon ARosebrook           BBickett/NCV only     RPowell                 MCatts
Sensitive
  DATE           4/26/18               5/7/18               5/8/18               5/7/18                   5/9/18
                                         
Publicly Available  
                                                1
Non-Publicly Available  
                          U.S. NUCLEAR REGULATORY COMMISSION
                                            REGION I
OFFICE  
Docket Numbers:        50-317 and 50-318
RI/DRP  
License Numbers:      DPR-53 and DPR-69
RI/DRP  
Report Numbers:        05000317/2018001 and 05000318/2018001
RI/ORA  
Enterprise Identifier: I-2018-001-0044
RI/DNMS  
Licensee:              Exelon Generation Company, LLC
RI/DRP  
Facility:              Calvert Cliffs Nuclear Power Plant, Units 1 and 2
NAME  
Location:              Lusby, MD
RClagg/AR per telecon  
Inspection Dates:      January 1, 2018 to March 31, 2018
ARosebrook  
Inspectors:            R. Clagg, Senior Resident Inspector
BBickett/NCV only  
                      C. Roettgen, Resident Inspector
RPowell  
                      H. Anagnostopoulos, Senior Health Physicist
MCatts  
                      E. Burket, Reactor Inspector
DATE  
                      A. Rosebrook, Senior Project Engineer
4/26/18  
Observer:              A. Chereskin, Chemical Engineer
5/7/18  
Approved by:          Michelle Catts, Acting Chief
5/8/18  
                      Reactor Projects Branch 1
5/7/18  
                      Division of Reactor Projects
5/9/18  


                                                  2
1
                                            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
U.S. NUCLEAR REGULATORY COMMISSION
Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for
overseeing the safe operation of commercial nuclear power reactors. Refer to
REGION I
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.
Docket Numbers:
                                  List of Findings and Violations
50-317 and 50-318
  Failure to Conduct Adequate Radiation Surveys and Evaluate Potential Radiological Hazards
  Cornerstone          Significance                            Cross-Cutting      Report
                                                                Aspect              Section
License Numbers:
Occupational          Green Non-Cited Violation                H.11 - Human        71124.01
DPR-53 and DPR-69 
  Radiation Safety      05000317/2018001-01                      Performance -
                      Closed                                  Challenge the
                                                                Unknown
Report Numbers:
  A self-revealed Green non-cited violation (NCV) of Title 10 Code of Federal Regulations
05000317/2018001 and 05000318/2018001
  (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
Enterprise Identifier: I-2018-001-0044
  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
Licensee:
  accessible dose-rates of up to 2,000 millirem per hour (mrem/hr) in the pump bay.
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
   
   
   
   
   


                                                  3
2
                                        REPORT DETAILS
PLANT STATUS
Unit 1 began the inspection period at rated thermal power and operated at or near full power
SUMMARY
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
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring Exelon Generation
refueling outage. Operators commenced a reactor startup on March 16, 2018, and returned the
Companys, LLC (Exelon) performance at Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1
unit to 100 percent power on March 18, 2018. On March 31, 2018, operators reduced power to
and 2 by conducting the baseline inspections described in this report in accordance with the
50 percent to repair a main turbine control valve.
Reactor Oversight Process.  The Reactor Oversight Process is the NRCs program for
Unit 2 operated at or near rated thermal power for the entire inspection period.
overseeing the safe operation of commercial nuclear power reactors.  Refer to
INSPECTION SCOPES
https://www.nrc.gov/reactors/operating/over-sight.html for more information.  NRC identified and
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
self-revealed findings, violations, and additional items are summarized in the table below. 
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
List of Findings and Violations
Failure to Conduct Adequate Radiation Surveys and Evaluate Potential Radiological Hazards
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Occupational
Radiation Safety
Green Non-Cited Violation
05000317/2018001-01
Closed
H.11 -  Human
Performance -
Challenge the
Unknown
71124.01
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-
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
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
complete when the IP requirements most appropriate to the inspection activity were met  
consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection
consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection  
Program - Operations Phase. The inspectors performed plant status activities described in
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
IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem  
Identification and Resolution. The inspectors reviewed selected procedures and records,
Identification and Resolution. The inspectors reviewed selected procedures and records,  
observed activities, and interviewed personnel to assess Exelons performance and compliance
observed activities, and interviewed personnel to assess Exelons performance and compliance  
with Commission rules and regulations, license conditions, site procedures, and standards.
with Commission rules and regulations, license conditions, site procedures, and standards.  
REACTOR SAFETY
REACTOR SAFETY
71111.01 - Adverse Weather Protection
      Impending Severe Weather (2 samples)
71111.01 - Adverse Weather Protection
      The inspectors evaluated readiness for impending adverse weather conditions for:
      (1) Forecasted high winds, March 1, 2018
Impending Severe Weather (2 samples)  
      (2) Forecasted winter storm and high winds, March 21, 2018
71111.04 - Equipment Alignment
The inspectors evaluated readiness for impending adverse weather conditions for:  
      Partial Walkdown (4 samples)
      The inspectors evaluated system configurations during partial walkdowns of the following
(1) Forecasted high winds, March 1, 2018  
      systems/trains:
(2) Forecasted winter storm and high winds, March 21, 2018  
      (1) 11 train onsite power distribution while the 14A 480V bus was out of service,
          February 23, 2018
71111.04 - Equipment Alignment
      (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
Partial Walkdown (4 samples)  
      (3) Unit 1 containment fire protection (temporary) during overhaul of O-FP-141A, Fire
          Protection Supply Inboard Containment Isolation, March 7, 2018
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  
    (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
(4) Unit 2 A train auxiliary feedwater while B auxiliary feedwater train was out of service  
    Quarterly Inspection (6 samples)
for valve maintenance, March 7, 2018  
    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
71111.05Q - Fire Protection Quarterly  
        Areas 19, 19A, and 34 on January 12, 2018
    (2) Unit 1, Cable Spreading Room and 1C Chase, Battery Rooms, and Hallway Outside of
Quarterly Inspection (6 samples)  
        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
The inspectors evaluated fire protection implementation in the following selected areas:  
        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
(1) Unit 1, 27 foot Switchgear Room, Purge Air Room, and 45 foot Switchgear Room, Fire  
    (5) Unit 1, Turbine Building, Fire Area TB on February 21, 2018
Areas 19, 19A, and 34 on January 12, 2018  
    (6) Unit 2, Turbine Building, Fire Area TB on February 22, 2018
(2) Unit 1, Cable Spreading Room and 1C Chase, Battery Rooms, and Hallway Outside of  
71111.06 - Flood Protection Measures
Cable Spreading Room, Fire Areas 16, 16A, and 16B on January 29, 2018  
    Internal Flooding (1 sample)
(3) Unit 2, Cable Spreading Room and 2C Chase, Battery Rooms, and Hallway Outside of  
    The inspectors evaluated internal flooding mitigation protections in the Unit 1 service water
Cable Spreading Room, Fire Areas 17, 17A, and 17B on January 29, 2018  
    pump room during the week of February 26, 2018.
(4) Unit 1, Containment Building, Fire Area CNMT on February 20, 2018  
71111.08 - Inservice Inspection Activities (1 sample)
(5) Unit 1, Turbine Building, Fire Area TB on February 21, 2018  
    The inspectors evaluated Exelons non-destructive examination and welding activities at
(6) Unit 2, Turbine Building, Fire Area TB on February 22, 2018  
    CCNPP, Unit 1 by reviewing the following activities and programs from February 26 to
    March 8, 2018:
71111.06 - Flood Protection Measures
    (1) Volumetric Examinations
        a) Manual Ultrasonic Testing of Pipe to Elbow Weld, 16-FW-1218-10
Internal Flooding (1 sample)  
        b) Manual Ultrasonic Testing of Containment Liner, Plate 148
    (2) Surface Examination
The inspectors evaluated internal flooding mitigation protections in the Unit 1 service water  
        a) Magnetic Particle Testing of Integral Attachment, 34-MS-1204-H-8
pump room during the week of February 26, 2018.  
    (3) Visual Examinations
        a) Bare Metal Visual Examination of the Reactor Vessel Upper Head and Nozzle
71111.08 - Inservice Inspection Activities (1 sample)  
            Partial Penetration Welds
        b) General Visual Examination of the Containment Liner
The inspectors evaluated Exelons non-destructive examination and welding activities at  
    (5) The inspectors evaluated Exelons boric acid corrosion control program performance.
CCNPP, Unit 1 by reviewing the following activities and programs from February 26 to  
    (6) In accordance with the CCNPP Steam Generator Program, Exelon did not perform
March 8, 2018:  
        steam generator tube inspections during this refueling outage.
71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance
(1) Volumetric Examinations  
    Operator Requalification (1 sample)
a) Manual Ultrasonic Testing of Pipe to Elbow Weld, 16-FW-1218-10  
    The inspectors observed and evaluated licensed operators during a positive moderator
b) Manual Ultrasonic Testing of Containment Liner, Plate 148  
    temperature coefficient startup/shutdown training on January 16, 2018.
(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
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
Operator Performance (2 samples)  
    (2) Unit 1 heatup and reactor startup, March 16, 2018
71111.12 - Maintenance Effectiveness
The inspectors observed and evaluated main control room performance during:  
    Routine Maintenance Effectiveness (1 sample)
    The inspectors evaluated the effectiveness of routine maintenance activities associated
(1) Unit 1 reactor shutdown and cooldown, February 18, 2018  
    with the 22 steam generator feed pump speed control trouble alarm on February 6, 2018.
(2) Unit 1 heatup and reactor startup, March 16, 2018  
    Quality Control (1 sample)
    The inspectors evaluated maintenance and quality control activities associated with the
71111.12 - Maintenance Effectiveness  
    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
Routine Maintenance Effectiveness (1 sample)  
    2PCV4550, air supply to 2SV4550.
71111.13 - Maintenance Risk Assessments and Emergent Work Control (4 samples)
The inspectors evaluated the effectiveness of routine maintenance activities associated  
    The inspectors evaluated the risk assessments for the following planned and emergent
with the 22 steam generator feed pump speed control trouble alarm on February 6, 2018.
    work activities:
    (1) Unit 2 maintenance risk assessment during offsite power transformer P-13000-1 out of
Quality Control (1 sample)  
        service for maintenance, February 27, 2018
    (2) Units 1 and 2 updated maintenance risk assessment during forecasted high winds,
The inspectors evaluated maintenance and quality control activities associated with the  
        March 2, 2018
control of quality parts during work orders C91504027, Replace Unit 2 to Unit 1 Auxiliary  
    (3) Unit 2, maintenance risk assessment for auxiliary feedwater train B out of service for
Feedwater System cross connect Solenoid valve, 2SV4550, and C91932471, Replace  
        valve maintenance, March 6, 2018
2PCV4550, air supply to 2SV4550.  
    (4) Unit 1, updated maintenance risk assessment during reduced inventory in the reactor
        pressure vessel, March 10, 2018
71111.13 - Maintenance Risk Assessments and Emergent Work Control (4 samples)  
71111.15 - Operability Determination and Functionality Assessments (5 samples)
    The inspectors evaluated the following operability determinations and functionality
The inspectors evaluated the risk assessments for the following planned and emergent  
    assessments:
work activities:  
    (1) Underground piping leakage north of turbine building (AR04087759) on
        January 5, 2018
(1) Unit 2 maintenance risk assessment during offsite power transformer P-13000-1 out of  
    (2) 12 service water pump inboard bearing leaks oil (AR04095258) on January 19, 2018
service for maintenance, February 27, 2018  
    (3) Unit 1 turbine building service water isolation valve 1CV1638 sticks as it strokes
(2) Units 1 and 2 updated maintenance risk assessment during forecasted high winds,  
        (AR04114002) on March 12, 2018
March 2, 2018  
    (4) Historical foreign material identified during refueling water tank inspection
(3) Unit 2, maintenance risk assessment for auxiliary feedwater train B out of service for  
        (AR04107455) on February 23, 2018
valve maintenance, March 6, 2018  
    (5) 0C diesel generator cracked fitting on pneumatic prelube manifold (AR04119229) on
(4) Unit 1, updated maintenance risk assessment during reduced inventory in the reactor  
        March 26, 2018
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
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
71111.18 - Plant Modifications (2 samples)  
        pump motor oil level indication system.
    (2) ECP-18-00016, Unit 1, Reactor Internal Inspections found one of eight Core Shroud
The inspectors evaluated the following temporary or permanent modifications:  
        Tie-rods Dis-engaged form the threaded connections at each end. Temporary
        modification accepting condition as is.
(1) Engineering Change Package (ECP)--17-000416, Unit 1,Replace reactor coolant  
71111.19 - Post-Maintenance Testing (5 samples)
pump motor oil level indication system.  
    The inspectors evaluated post-maintenance testing for the following maintenance/repair
(2) ECP-18-00016, Unit 1, Reactor Internal Inspections found one of eight Core Shroud  
    activities:
Tie-rods Dis-engaged form the threaded connections at each end. Temporary  
    (1) Work Order (WO) C93596764, adjust packing on B train Unit 2 service water strainer
modification accepting condition as is.
        flushing valves, on February 13, 2018
    (2) WO C91833187, inspect and overhaul SI-414, 12 high-pressure safety injection
71111.19 - Post-Maintenance Testing (5 samples)  
        discharge check valve, on March 6, 2018
    (3) WO C92789902, replace solenoid valve on service water turbine building header 12
The inspectors evaluated post-maintenance testing for the following maintenance/repair  
        isolation valve, on March 11, 2018
activities:  
    (4) WO C93063804, replace 1SI-451-12, low-pressure safety injection pump mini flow
        check valve, on March 14, 2018
(1) Work Order (WO) C93596764, adjust packing on B train Unit 2 service water strainer  
    (5) WO C92583375, replace upper flange on 1MOV636OP, 12A safety injection tank high
flushing valves, on February 13, 2018  
        pressure loop, and repack valve, on March 23, 2018
(2) WO C91833187, inspect and overhaul SI-414, 12 high-pressure safety injection  
71111.20 - Refueling and Other Outage Activities (1 sample)
discharge check valve, on March 6, 2018  
    The inspectors evaluated Unit 1 refueling outage activities from February 19 to
(3) WO C92789902, replace solenoid valve on service water turbine building header 12  
    March 16, 2018.
isolation valve, on March 11, 2018  
71111.22 - Surveillance Testing
(4) WO C93063804, replace 1SI-451-12, low-pressure safety injection pump mini flow  
    The inspectors evaluated the following surveillance tests:
check valve, on March 14, 2018  
    Routine (5 samples)
(5) WO C92583375, replace upper flange on 1MOV636OP, 12A safety injection tank high  
    (1) STP-O-5A21-2, 21 Auxiliary Feedwater Pump Quarterly Surveillance Test, Revision 6,
pressure loop, and repack valve, on March 23, 2018  
        January 24, 2018
    (2) STP-O-8A-2, Test of 2A Diesel and 4kV Bus 21 Undervoltage, Revision 31,
71111.20 - Refueling and Other Outage Activities (1 sample)  
        February 2, 2018
    (3) PSTP-10, Conduct of Coastdown, Revision 2, February 13, 2018
The inspectors evaluated Unit 1 refueling outage activities from February 19 to  
    (4) PE-1-036-3-O-R, Over Speed Testing of the 12 Auxiliary Feedwater Pump, Revision 3,
March 16, 2018.  
        March 11, 2018
    (5) STP-O-004B-1, B Train Integrated Engineered Safety Features Test Revision 32,
71111.22 - Surveillance Testing
        March 12, 2018
    In-service (1 sample)
The inspectors evaluated the following surveillance tests:  
    (1) STP-O-073H-1, Auxiliary Feedwater Pump Large Flow Test, Revision 11, February 15,
        2018
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
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,
Containment Isolation Valve (3 samples)  
        February 23, 2018
    (3) STP-O-108D44-1, Containment Penetration 44 Local Leak Rate Tests, Revision 1,
(1) STP-M-003A-O, Online Main and Offline Steam Safety Valve Testing, Revision 008,  
        February 27, 2018
February 14, 2018  
RADIATION SAFETY
(2) STP-O108D9-1, Containment Penetration 9 Local Leak Rate Tests, Revision 0,  
71124.01 - Radiological Hazard Assessment and Exposure Controls
February 23, 2018  
    Radiological Hazard Assessment (1 Sample)
(3) STP-O-108D44-1, Containment Penetration 44 Local Leak Rate Tests, Revision 1,  
    The inspectors evaluated radiological hazards assessments and controls.
February 27, 2018  
    Instructions to Workers (1 Sample)
    The inspectors evaluated worker instructions.
RADIATION SAFETY  
    Contamination and Radioactive Material Control (1 Sample)
    The inspectors evaluated contamination and radioactive material controls.
71124.01 - Radiological Hazard Assessment and Exposure Controls  
    Radiological Hazards Control and Work Coverage (1 Sample)
    The inspectors evaluated radiological hazards control and work coverage.
Radiological Hazard Assessment (1 Sample)  
    High Radiation Area and Very High Radiation Area Controls (1 Sample)
    The inspectors evaluated risk-significant high radiation area and very high radiation area
The inspectors evaluated radiological hazards assessments and controls.  
    controls.
    Radiation Worker Performance and Radiation Protection Technician Proficiency
Instructions to Workers (1 Sample)  
    (1 Sample)
    The inspectors evaluated radiation worker performance and radiation protection technician
The inspectors evaluated worker instructions.  
    proficiency.
71124.02 - Occupational As Low As Reasonably Achievable Planning and Controls
Contamination and Radioactive Material Control (1 Sample)  
    Radiological Work Planning (1 sample)
    The inspectors selected the following radiological work activities based on exposure
The inspectors evaluated contamination and radioactive material controls.  
    significance for review:
    (1) As Low As Reasonably Achievable (ALARA) Plan 17RFO-0019, Dissimilar Metal Weld
Radiological Hazards Control and Work Coverage (1 Sample)  
        Inspections
    (2) ALARA Plan 17RFO-0010, Scaffold Activities
The inspectors evaluated radiological hazards control and work coverage.  
    (3) ALARA Plan 17RFO-0013, NSRX Reactor Disassembly/Reassembly
    (4) ALARA Plan 17RFO-0011, Outage Insulation
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
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.
For each of these activities, the inspectors reviewed: ALARA work activity evaluations,  
    Verification of Dose Estimates and Exposure Tracking Systems (1 sample)
exposure estimates, exposure reduction requirements, results achieved (dose rate  
    The inspectors reviewed the current annual collective dose estimate; basis methodology;
reductions, actual dose), person-hour estimates and results achieved and post-job reviews  
    and measures to track, trend, and reduce occupational doses for ongoing work activities.
that were conducted to identify lessons learned.  
    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
Verification of Dose Estimates and Exposure Tracking Systems (1 sample)  
    excessive exposure.
    Implementation of As Low As Reasonably Achievable and Radiological Work Controls
The inspectors reviewed the current annual collective dose estimate; basis methodology;  
    (1 Sample)
and measures to track, trend, and reduce occupational doses for ongoing work activities.
    The inspectors reviewed ALARA practices and radiological work controls by reviewing the
The inspectors evaluated the adjustment of exposure estimates, or re-planning of work.
    following activities:
The inspectors reviewed post-job as low as reasonably achievable evaluations of  
    (1) ALARA Plan 18RFO-0005
excessive exposure.  
    (2) ALARA Plan 18RFO-0006
    (3) ALARA Plan 18RFO-0007
Implementation of As Low As Reasonably Achievable and Radiological Work Controls  
    (4) ALARA Plan 18RFO-0018
(1 Sample)  
    (5) ALARA Plan 18RFO-0021
    Radiation Worker Performance (1 Sample)
The inspectors reviewed ALARA practices and radiological work controls by reviewing the  
    The inspectors evaluated radiation worker and radiation protection technician
following activities:  
    performance.
OTHER ACTIVITIES - BASELINE
(1) ALARA Plan 18RFO-0005  
71151 - Performance Indicator Verification
(2) ALARA Plan 18RFO-0006  
    The inspectors verified Exelon performance indicators submittals listed below for the
(3) ALARA Plan 18RFO-0007  
    period January 1, 2017, through December 31, 2017. (4 samples)
(4) ALARA Plan 18RFO-0018  
    (1) Units 1 and 2 Reactor Coolant System Specific Activity
(5) ALARA Plan 18RFO-0021  
    (2) Units 1 and 2 Reactor Coolant System Leak Rate
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
9  
INSPECTION RESULTS
  Failure to Conduct Adequate Radiation Surveys and Evaluate Potential Radiological Hazards
Cornerstone           Significance                               Cross-Cutting     Report
INSPECTION RESULTS  
                                                                  Aspect            Section
   
Occupational           Green                                      H.11 - Human      71124.01
Failure to Conduct Adequate Radiation Surveys and Evaluate Potential Radiological Hazards  
Radiation Safety       NCV 05000317/2018001-01                   Performance -
Cornerstone  
                        Closed                                    Challenge the
Significance  
                                                                  Unknown
Cross-Cutting  
A self-revealed Green non-cited violation (NCV) of Title 10 Code of Federal Regulations
Aspect
(10 CFR) 20.1501, Surveys and Monitoring: General, was identified when Exelon failed to
Report  
perform adequate surveys of the 11 reactor coolant pump bay area following the aggregation
Section  
of 25 high dose-rate in-core detectors in one area of the flooded refueling cavity, which is
Occupational  
adjacent to the pump bay. Surveys were not performed to evaluate the resulting dose rates
Radiation Safety  
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
Green
procedures, were not implemented, resulting in accessible dose-rates of up to 2,000 millirem
NCV 05000317/2018001-01  
per hour (mrem/hr) in the pump bay.
Closed
Description:
H.11 -  Human
In-core detectors are used in the reactor in order to monitor reactor power. These detectors
Performance -  
are exposed to a high neutron flux and become highly radioactive during normal operations.
Challenge the  
During the Calvert Cliffs Unit 1 refueling outage, 25 in-core detectors were removed from the
Unknown  
reactor vessel and hung in a common location in the flooded refueling cavity for temporary
71124.01
storage prior to cutting and disposal. During this work, a change to the process was made in
A self-revealed Green non-cited violation (NCV) of Title 10 Code of Federal Regulations  
that the cold ends of the detector assemblies were positioned above the surface of the water
(10 CFR) 20.1501, Surveys and Monitoring: General, was identified when Exelon failed to  
in the refueling cavity (instead of the typical ten feet below the water surface) during storage.
perform adequate surveys of the 11 reactor coolant pump bay area following the aggregation  
This resulted in a change in the relative position of the highly activated hot ends. The
of 25 high dose-rate in-core detectors in one area of the flooded refueling cavity, which is  
collection of these 25 sources in one location, and the change in the position of the hot ends
adjacent to the pump bay. Surveys were not performed to evaluate the resulting dose rates  
within the flooded cavity, created an intense source of radioactivity which affected the
after the licensee changed the storage location of the detectors and radiological hazard  
radiological conditions in the space adjacent to that portion of the refueling cavity.
mitigation measures, such as locking and controlling access in accordance with Exelon  
  The 11 reactor coolant pump enclosure (i.e, pump bay) is normally controlled as a high
procedures, were not implemented, resulting in accessible dose-rates of up to 2,000 millirem  
radiation area during refueling outages because doses of greater than 100 mrem in one hour
per hour (mrem/hr) in the pump bay.  
are expected in accessible areas of the room. When the 25 in-core detectors were
Description:  
aggregated in the refueling cavity for temporary storage between February 23 and 24, 2018,
In-core detectors are used in the reactor in order to monitor reactor power. These detectors  
radiation surveys were not re-performed in all areas where radiological conditions may have
are exposed to a high neutron flux and become highly radioactive during normal operations.
changed. Some of the in-core detectors were placed at a location approximately ten feet
During the Calvert Cliffs Unit 1 refueling outage, 25 in-core detectors were removed from the  
higher within the refueling cavity than usual due to larger number of detectors being replaced.
reactor vessel and hung in a common location in the flooded refueling cavity for temporary  
As a result, an accessible radiation field of up to 2,000 mrem/hr in the 11 pump bay was not
storage prior to cutting and disposal. During this work, a change to the process was made in  
identified and controlled in accordance with Exelon procedures. This radiation field was
that the cold ends of the detector assemblies were positioned above the surface of the water  
nearly 100 times the value that workers were being briefed to using the existing radiological
in the refueling cavity (instead of the typical ten feet below the water surface) during storage.  
survey maps. On February 24, 2018, a worker in the 11 pump bay experienced an
This resulted in a change in the relative position of the highly activated hot ends. The  
unexpected electronic personal dosimeter alarm due to the high dose rate. The worker
collection of these 25 sources in one location, and the change in the position of the hot ends  
immediately left the area and informed the radiation protection staff. The area was re-
within the flooded cavity, created an intense source of radioactivity which affected the  
surveyed at this time and the 2,000 mrem/hr field was discovered. The workers actual dose
radiological conditions in the space adjacent to that portion of the refueling cavity.  
received was far below the 10 CFR 20 dose limits.
   
  The workers electronic personal dosimeter alarm set-points were 30 mrem dose and 400
The 11 reactor coolant pump enclosure (i.e, pump bay) is normally controlled as a high  
mrem/hr dose rate. Exelon radiation workers are required to check their electronic personal
radiation area during refueling outages because doses of greater than 100 mrem in one hour  
dosimeter for accumulated dose every 15 minutes. Electronic personal dosimeters for work in
are expected in accessible areas of the room. When the 25 in-core detectors were  
this area are monitored remotely by radiation protection personnel, which increases the
aggregated in the refueling cavity for temporary storage between February 23 and 24, 2018,  
likelihood that this unexpected condition would be detected prior to the worker being
radiation surveys were not re-performed in all areas where radiological conditions may have  
overexposed. As a result, there was no substantial potential for over exposure. A single
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  


                                                10
10  
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
instance of failure to survey an area is also not considered to be a compromised ability to  
following the placement of 25 highly radioactive in-core detectors (in one location in the
assess dose.
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
Radiological verification surveys of the 11 pump bay to check for unexpected radiation levels  
Radiation Areas, and Exelon procedure RP-AA-460, Controls for High and Locked High
following the placement of 25 highly radioactive in-core detectors (in one location in the  
Radiation Areas. As a result of the failure to perform the surveys, one person was exposed
adjacent portion of the refueling cavity) were reasonable under the circumstances, and were  
to unexpected high dose rates, since radiological conditions in assessable areas of the pump
needed to demonstrate compliance with 10 CFR 20.1601 Control of Access to High  
bay had changed significantly.
Radiation Areas, and Exelon procedure RP-AA-460, Controls for High and Locked High  
The statements of consideration associated with the issuance of 10 CFR 20.1501 (as
Radiation Areas. As a result of the failure to perform the surveys, one person was exposed  
provided in the Federal Register Notice 56 FR 23398) indicate that The principal role of the
to unexpected high dose rates, since radiological conditions in assessable areas of the pump  
[radiation] survey is preventative. Adequate survey procedures provide measurable
bay had changed significantly.  
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
The statements of consideration associated with the issuance of 10 CFR 20.1501 (as  
usefulness of this early warning system may be seriously reduced if licensees are not held
provided in the Federal Register Notice 56 FR 23398) indicate that The principal role of the  
responsible for failure to conduct any survey or for failure to conduct an adequate survey
[radiation] survey is preventative. Adequate survey procedures provide measurable  
[even] when violations of other Part 20 requirements have not occurred
protection for the health and safety of the worker and the public because they provide the  
Corrective Actions
information necessary for the establishment of adequate protective measures. The  
Exelon conducted new radiation surveys, upgraded radiological controls in the 11 pump bay
usefulness of this early warning system may be seriously reduced if licensees are not held  
(including controlling the area as a locked high radiation area), restricted access to the area,
responsible for failure to conduct any survey or for failure to conduct an adequate survey  
and conducted a prompt investigation. The in-core detectors were lowered such that the
[even] when violations of other Part 20 requirements have not occurred  
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
Corrective Actions
cut and put into disposal containers as planned. Exelon entered the issue into their
Exelon conducted new radiation surveys, upgraded radiological controls in the 11 pump bay  
corrective action program. The inspectors reviewed the licensees investigation and
(including controlling the area as a locked high radiation area), restricted access to the area,  
associated corrective actions and determined that they were reasonable and appropriate.
and conducted a prompt investigation. The in-core detectors were lowered such that the  
Corrective Action References: Exelon placed the issue in their corrective action program as
cold ends were again at their usual position of ten feet below the water surface, which  
AR04108011, AR04107884, and AR04108041.
resulted in dose rates in the 11 pump bay returning to normal levels. The detectors were then  
Performance Assessment:
cut and put into disposal containers as planned.   Exelon entered the issue into their  
Performance Deficiency: The performance deficiency is the failure to perform radiological
corrective action program. The inspectors reviewed the licensees investigation and  
surveys in the 11 pump bay to evaluate the impact of a change in the storage location of
associated corrective actions and determined that they were reasonable and appropriate.
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
Corrective Action References: Exelon placed the issue in their corrective action program as  
cavity than usual, surveys were not performed in the adjacent space, which was controlled as
AR04108011, AR04107884, and AR04108041.  
a High Radiation Area to which where personnel had access, to verify radiological conditions
Performance Assessment:
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,
Performance Deficiency: The performance deficiency is the failure to perform radiological  
Exelon was aware of the very high dose rates from the in-core instrumentation and
surveys in the 11 pump bay to evaluate the impact of a change in the storage location of  
reasonably should have evaluated the impact on adjacent locations in containment.
highly radioactive sources within the adjacent refueling cavity. Specifically following the  
Containment access restrictions are routinely employed when moving fuel and therefore
placement of in-core detectors at a location approximately ten feet higher within the refueling  
Exelon had an opportunity to realize that highly radioactive sources such as the in-core
cavity than usual, surveys were not performed in the adjacent space, which was controlled as  
instrumentation may have required similar precautions. As a result of the failure to perform
a High Radiation Area to which where personnel had access, to verify radiological conditions  
the surveys, appropriate radiological controls were not established in accordance with Exelon
had not changed. 10 CFR 20.1501 is the standard not met. This performance deficiency was  
procedure RP-AA-460 section 3.4 and one person was exposed to unexpected high dose
within Exelons ability to foresee and correct, and should have been prevented.   Specifically,  
rates.
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
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,
Title 10 CFR 20.1501 requires that each licensee make or cause to be made surveys that  
concentrations or quantities of residual radioactivity, and the potential hazards of the radiation
may be necessary for the licensee to comply with the regulations in Part 20 and that are  
levels and residual radioactivity detected.
reasonable under the circumstances to evaluate the magnitude and extent of radiation levels,  
Screening: This finding is more than minor because it is associated with the Program &
concentrations or quantities of residual radioactivity, and the potential hazards of the radiation  
Process attribute of the Occupational Radiation Safety cornerstone and affects the
levels and residual radioactivity detected.  
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
Screening: This finding is more than minor because it is associated with the Program &  
operation. Specifically, radiation levels in an adjacent and accessible area were not verified
Process attribute of the Occupational Radiation Safety cornerstone and affects the  
following a change in radiological conditions in that area. Thus a process radiation safety
cornerstone objective to ensure the adequate protection of the worker health and safety from  
barrier was defeated. The deficiency is similar to Example 6F in IMC 0612 Appendix E,
exposure to radiation from radioactive material during routine civilian nuclear reactor  
Examples of Minor Issues.
operation. Specifically, radiation levels in an adjacent and accessible area were not verified  
Significance: Using IMC 0609.04, Initial Characterization of Findings, issued October 7,
following a change in radiological conditions in that area. Thus a process radiation safety  
2016, and IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination
barrier was defeated. The deficiency is similar to Example 6F in IMC 0612 Appendix E,  
Process, issued August 19, 2008, the inspection finding was not related to ALARA practices
Examples of Minor Issues.  
(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
Significance: Using IMC 0609.04, Initial Characterization of Findings, issued October 7,  
14). As a result, this finding was determined to be of very low safety significance (Green).
2016, and IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination  
Cross Cutting Aspect: This finding has a cross-cutting aspect in the area of Human
Process, issued August 19, 2008, the inspection finding was not related to ALARA practices  
Performance, Challenge the Unknown, in that Exelon did not ensure that individuals stop
(Step 1), did not result in an overexposure (Step 5), did not represent a substantial potential  
when faced with uncertain conditions and ensure risks are evaluated and managed before
for overexposure (Step 11), and did not compromise Exelons ability to assess dose (Step  
proceeding. Specifically, no one questioned whether the placement of the in-core detectors
14). As a result, this finding was determined to be of very low safety significance (Green).  
at a higher level within the reactor cavity could adversely affect radiological conditions in
adjacent areas. (H.11)
Cross Cutting Aspect: This finding has a cross-cutting aspect in the area of Human  
Enforcement:
Performance, Challenge the Unknown, in that Exelon did not ensure that individuals stop  
Violation: 10 CFR 20.1501 requires that each licensee make or cause to be made surveys
when faced with uncertain conditions and ensure risks are evaluated and managed before  
that may be necessary for the licensee to comply with the regulations in Part 20 and that are
proceeding. Specifically, no one questioned whether the placement of the in-core detectors  
reasonable under the circumstances to evaluate the magnitude and extent of radiation levels,
at a higher level within the reactor cavity could adversely affect radiological conditions in  
concentrations or quantities of residual radioactivity, and the potential hazards of the radiation
adjacent areas. (H.11)  
levels and residual radioactivity detected.
Title 10 CFR 20.1003 defines a survey as an evaluation of the radiological conditions and
Enforcement:
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
Violation: 10 CFR 20.1501 requires that each licensee make or cause to be made surveys  
includes a physical survey of the location of radioactive material and measurements or
that may be necessary for the licensee to comply with the regulations in Part 20 and that are  
calculations of levels of radiation, or concentrations or quantities of radioactive material
reasonable under the circumstances to evaluate the magnitude and extent of radiation levels,  
present.
concentrations or quantities of residual radioactivity, and the potential hazards of the radiation  
Title 10 CFR 20.1601, Control of access to high radiation area, requires licensees to provide
levels and residual radioactivity detected.  
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
Title 10 CFR 20.1003 defines a survey as an evaluation of the radiological conditions and  
1 hour at 30 centimeters from the radiation source or 30 centimeters from any surface that the
potential hazards incident to the production, use, transfer, release, disposal, or presence of  
radiation penetrates. These access controls include locking entryways to such areas or
radioactive material or other sources of radiation. When appropriate, such an evaluation  
providing positve control over each individual entry when access to the areas is required.
includes a physical survey of the location of radioactive material and measurements or  
Title 10 CRF 20.1601(c) allows a licensee to request approval of alternate means for
calculations of levels of radiation, or concentrations or quantities of radioactive material  
controlling access to high radiation areas.
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 hour 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
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
The NRC had previously approved alternate means for controlling access to high radiation  
Radiation Area.
areas for Calvert Cliffs. These alternate means had been provided in the Calvert Cliffs  
In an August 26, 1996, letter issuing Amendment No. 216 to Facility Operating License No.
Nuclear Power Plant, Unit Nos. 1 and 2 Technical Specifications, Section 6.12, High  
OPR-53 and Amendment No.193 to Facility Operating License No.DPR-69 for the Calvert
Radiation Area.  
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
In an August 26, 1996, letter issuing Amendment No. 216 to Facility Operating License No.  
the licensee must comply with this regulation [10CFR 20.1601] and, specifically with
OPR-53 and Amendment No.193 to Facility Operating License No.DPR-69 for the Calvert  
20.1601(c) regarding Commission approval of alternative methods, the relocation of TS 6.12
Cliffs Nuclear Power Plant, Unit Nos. 1 and 2, respectively, the NRC approved the licensees  
to plant procedures is acceptable.
request to relocate the TS 6.12 controls to site procedures. As noted in the NRC letter, since  
Exelon Procedure RP-AA-460, Controls for High and Locked High Radiation Areas,
the licensee must comply with this regulation [10CFR 20.1601] and, specifically with  
Revision 31 is the plant procedure implementing these alternate methods of compliance with
20.1601(c) regarding Commission approval of alternative methods, the relocation of TS 6.12  
10 CFR 20.1601.
to plant procedures is acceptable.  
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,
Exelon Procedure RP-AA-460, Controls for High and Locked High Radiation Areas,  
POST AND CONTROL area as a Locked High Radiation Area when:
Revision 31 is the plant procedure implementing these alternate methods of compliance with  
1. Dose rates accessible to an individual(s) are 800 mrem/hr at 30 cm or greater,
10 CFR 20.1601.  
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.
RP-AA-460 Section 3.4, Locked High Radiation Area Controls (greater than OR equal to  
Contrary to the above, on February 23 - 24, 2018, Exelon did not make or cause to be made
1000 mrem/hr at 30 cm; < 500 Rad/hr at 1 meter) states,  
surveys that were necessary for the licensee to comply with the regulations in Part 20 and
POST AND CONTROL area as a Locked High Radiation Area when:  
were reasonable under the circumstances to evaluate the magnitude and extent of radiation
1. Dose rates accessible to an individual(s) are 800 mrem/hr at 30 cm or greater,  
levels and, as a result, did not identify the presence of dose rates exceeding 1000 mrem/hr
unless waived by the RPM using Attachment 1, OR  
within an area being controlled as a High Radiation Area. Specifically, the licensee had been
2. Dose rate(s) accessible to an individual(s) equal OR exceed 1000 mrem/hr at 30 cm.  
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
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-
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
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
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
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
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
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
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
as a Locked High Radiation Area in accordance with Exelon procedure RP-AA-460 section  
3.4 until a workers electronic personal dosimeter alarmed.
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 Actions:  
Enforcement Policy. (NCV 05000317/2018001-01: Failure to Conduct Adequate
This violation is being treated as a NCV, consistent with Section 2.3.2 of the NRC  
Radiation Surveys and Evaluate Potential Radiological Hazards)
Enforcement Policy. (NCV 05000317/2018001-01: Failure to Conduct Adequate  
Radiation Surveys and Evaluate Potential Radiological Hazards)  


                                                13
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
EXIT MEETINGS AND DEBRIEFS  
  Section 71124.02 to Mr. Mark Flaherty, Site Vice President, and other members of the
  Exelon staff.
The inspectors verified no proprietary information was retained or documented in this report.  
* 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 January 11, 2018, the inspectors presented the inspection results of activities related to  
* On March 8, 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  
  Section 71111.08 inspection results to Mr. Mark Flaherty, Site Vice President, and other
Exelon staff.  
  members of the Exelon staff.
*  
* On April 25, 2018, the inspectors presented the quarterly resident inspector inspection
On March 2, 2018, the inspectors presented the inspection results of activities related to  
  results to Mr. Mark Flaherty, Site Vice President, and other members of the Exelon staff.
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
14  
DOCUMENTS REVIEWED
Section 71111.18 - Plant Modifications
Calculation:
DOCUMENTS REVIEWED  
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
Section 71111.18 - Plant Modifications  
Miscellaneous
ECP-17-000416, Unit 1,Replace reactor coolant pump motor oil level indication system.
Calculation:  
ECP-18-00016, Unit 1, Reactor Internal Inspections found one of eight Core Shroud Tie-rods
CN-SDA-18-12, Calvert Cliffs Unit 1 Core Shroud Tie Rod Evaluation for Continued Operation  
      Dis-engaged form the threaded connections at each end.
of One Cycle with One Missing Core Shroud Tie Rod, Revision 0  
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
Miscellaneous  
Section 71124.01 - Radiological Hazard Assessment and Exposure Controls
ECP-17-000416, Unit 1,Replace reactor coolant pump motor oil level indication system.  
Procedures
ECP-18-00016, Unit 1, Reactor Internal Inspections found one of eight Core Shroud Tie-rods  
NISP-RP-005, Access Controls for High Radiation Areas, Revision 0
Dis-engaged form the threaded connections at each end.  
RP-AA-300-1006, Radiological Controls for System Operations with Radiological Impact in
FS1-0036628, Evaluation of Calvert Cliffs Bypass Flow, Revision 1  
    Normally Accessible Areas, Revision 0
LTR-RC-18-13, Calvert Cliffs Unit 1 Cycle 24 Dropped Tie Rod Use-as-is 10 CFR 50.59 Input  
RP-AA-460, Controls for High and Locked High Radiation Areas, Revision 31
RV-68, In-Core Instrumentation Removal, Revision 02300
Section 71124.01 - Radiological Hazard Assessment and Exposure Controls  
Miscellaneous
ALARA Plan 18RFO-0015, RT 10842007, Remove ICIS IAW RV-68 Procedure, dated
Procedures  
    12/8/2017
NISP-RP-005, Access Controls for High Radiation Areas, Revision 0  
ALARA Waiver Form, 18RFO-0015, dated 2/26/2018
RP-AA-300-1006, Radiological Controls for System Operations with Radiological Impact in  
AR04107884
Normally Accessible Areas, Revision 0  
AR04108011
RP-AA-460, Controls for High and Locked High Radiation Areas, Revision 31  
AR04108041 and its related HURB report
RV-68, In-Core Instrumentation Removal, Revision 02300  
Drawing C-261, Containment Interior Section and CL Reactor Vessel, Sheet 5
Radiation Work Permit CC-1-18-00615, Revision 00
Miscellaneous  
Radiological survey 2018-003297
ALARA Plan 18RFO-0015, RT 10842007, Remove ICIS IAW RV-68 Procedure, dated  
Radiological survey 2018-002455
12/8/2017  
Radiological survey 2018-003277
ALARA Waiver Form, 18RFO-0015, dated 2/26/2018  
Radiological survey 2018-003400
AR04107884  
Radiological survey 2018-003269
AR04108011  
Radiological survey 2018-00
AR04108041 and its related HURB report  
WO C93489748
Drawing C-261, Containment Interior Section and CL Reactor Vessel, Sheet 5  
Section 71124.02 - Occupational ALARA Planning and Controls
Radiation Work Permit CC-1-18-00615, Revision 00  
Procedures
Radiological survey 2018-003297  
RP-AA-1008, Unescorted Access to and Conduct in Radiologically Controlled Areas, Revision 6
Radiological survey 2018-002455  
RP-AA-400, As Low As Reasonably Achievable Program, Revision 14
Radiological survey 2018-003277  
RP-AA-401, Operational As Low As Reasonably Achievable Planning and Controls, Revision 22
Radiological survey 2018-003400  
RP-AA-403, Administration of the Radiation Work Permit Program, Revision 9
Radiological survey 2018-003269  
RP-AA-441, TEDE As Low As Reasonably Achievable Evaluation, Revision 8
Radiological survey 2018-00  
Action Request
WO C93489748  
AR03973742 AR03980352 AR04027589 AR04040215 AR04042311 AR04064701
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
15  
Documents
ALARA Plan 17RFO-0010, Scaffold Activities
ALARA Plan 17RFO-0011, Outage Insulation
Documents  
ALARA Plan 17RFO-0013, NSRX Reactor Disassembly/Reassembly
ALARA Plan 17RFO-0010, Scaffold Activities  
ALARA Plan 17RFO-0019, Dissimilar Metal Weld Inspections
ALARA Plan 17RFO-0011, Outage Insulation  
ALARA Plan 18Q-0009
ALARA Plan 17RFO-0013, NSRX Reactor Disassembly/Reassembly  
ALARA Post-Job Review, 17RFO-0010
ALARA Plan 17RFO-0019, Dissimilar Metal Weld Inspections  
ALARA Post-Job Review, 17RFO-0011
ALARA Plan 18Q-0009  
ALARA Post-Job Review, 17RFO-0013
ALARA Post-Job Review, 17RFO-0010  
ALARA Post-Job Review, 17RFO-0019
ALARA Post-Job Review, 17RFO-0011  
ALARA Post-Job Review, 17RFO-0042
ALARA Post-Job Review, 17RFO-0013  
ALARA Work-In-Progress Review, 17RFO-0006, REM Discretion, 50%, Other
ALARA Post-Job Review, 17RFO-0019  
ALARA Work-In-Progress Review, 17RFO-0010, REM Discretion, 50%, 80%
ALARA Post-Job Review, 17RFO-0042  
ALARA Work-In-Progress Review, 17RFO-0011, 50%, 80%
ALARA Work-In-Progress Review, 17RFO-0006, REM Discretion, 50%, Other  
ALARA Work-In-Progress Review, 17RFO-0019, 50%
ALARA Work-In-Progress Review, 17RFO-0010, REM Discretion, 50%, 80%  
Dose Excellence Plan, Calvert Cliffs Nuclear Power Plant, 2017-2021, Revision 0
ALARA Work-In-Progress Review, 17RFO-0011, 50%, 80%  
List, 17RFO radiation exposure, actual vs estimate.
ALARA Work-In-Progress Review, 17RFO-0019, 50%  
List, On-line work activities > 1 REM
Dose Excellence Plan, Calvert Cliffs Nuclear Power Plant, 2017-2021, Revision 0  
Radiation Protection Outage Report, CC2R22
List, 17RFO radiation exposure, actual vs estimate.  
Radiation work permit CC-0-18-00312, Revision 1
List, On-line work activities > 1 REM  
Radiation work permit CC-2-17-00502, Revision 0
Radiation Protection Outage Report, CC2R22  
Radiation work permit CC-2-17-00503, Revision 0
Radiation work permit CC-0-18-00312, Revision 1  
Radiation work permit CC-2-17-00505, Revision 0
Radiation work permit CC-2-17-00502, Revision 0  
Radiation work permit CC-2-17-00613, Revision 0
Radiation work permit CC-2-17-00503, Revision 0  
Radiological survey, containment post-shutdown, Unit1, dated 2/15/2016
Radiation work permit CC-2-17-00505, Revision 0  
Radiological survey, containment post-shutdown, Unit2, dated 2/13/2017
Radiation work permit CC-2-17-00613, Revision 0  
Radiological survey, EPRI standard radiation monitoring program, Unit 1, dated 3/14/2010
Radiological survey, containment post-shutdown, Unit1, dated 2/15/2016  
Radiological survey, EPRI standard radiation monitoring program, Unit 1, dated 3/4/2016
Radiological survey, containment post-shutdown, Unit2, dated 2/13/2017  
Station ALARA Committee Agenda and Package, dated 1/10/18
Radiological survey, EPRI standard radiation monitoring program, Unit 1, dated 3/14/2010  
Station ALARA Committee Meeting Minutes from 1/13/2017
Radiological survey, EPRI standard radiation monitoring program, Unit 1, dated 3/4/2016  
Station ALARA Committee Meeting Minutes from 1/6/2017
Station ALARA Committee Agenda and Package, dated 1/10/18  
Station ALARA Committee Meeting Minutes from 10/31/2017
Station ALARA Committee Meeting Minutes from 1/13/2017  
Station ALARA Committee Meeting Minutes from 3/1/2017
Station ALARA Committee Meeting Minutes from 1/6/2017  
Station ALARA Committee Meeting Minutes from 7/27/2017
Station ALARA Committee Meeting Minutes from 10/31/2017  
Station ALARA Committee Meeting Minutes from 9/26/2017
Station ALARA Committee Meeting Minutes from 3/1/2017  
Station ALARA Committee Meeting Minutes from 9/6/2017
Station ALARA Committee Meeting Minutes from 7/27/2017  
TEDE ALARA Evaluation, CC-2-17-00502
Station ALARA Committee Meeting Minutes from 9/26/2017  
TEDE ALARA Evaluation, CC-2-17-00503
Station ALARA Committee Meeting Minutes from 9/6/2017  
TEDE ALARA Evaluation, CC-2-17-00505
TEDE ALARA Evaluation, CC-2-17-00502  
TEDE ALARA Evaluation, CC-2-17-00613
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
Whole body count #14952
}}
}}

Latest revision as of 22:08, 5 January 2025

Integrated Inspection Report 05000317/2018001 and 05000318/2018001
ML18130A878
Person / Time
Site: Calvert Cliffs  Constellation icon.png
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)
v • d • e


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

05000318/2018001

w/Attachment: Supplementary Information

cc w/encl: Distribution via ListServ

ML18130A878

SUNSI Review

Non-Sensitive

Sensitive

Publicly Available

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

Aspect

Report

Section

Occupational

Radiation Safety

Green Non-Cited Violation 05000317/2018001-01

Closed

H.11 - Human

Performance -

Challenge the

Unknown

71124.01

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

Aspect

Report

Section

Occupational

Radiation Safety

Green

NCV 05000317/2018001-01

Closed

H.11 - Human

Performance -

Challenge the

Unknown

71124.01

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

10

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

10 CFR 20.1601.

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 Plan 18Q-0009

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

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