IR 05000261/2001005

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IR 05000261/2001-005, H.B. Robinson Steam Electric Plant, Baseline Integrated Inspection on 09/30-12/29/2001. No Violations Noted
ML020170273
Person / Time
Site: Robinson Duke Energy icon.png
Issue date: 01/17/2002
From: Brian Bonser
Division Reactor Projects II
To: Moyer J
Carolina Power & Light Co
References
IR-01-005
Download: ML020170273 (25)


Text

ary 17, 2002

SUBJECT:

H.B. ROBINSON STEAM ELECTRIC PLANT- NRC INTEGRATED INSPECTION REPORT 50-261/01-05

Dear Mr. Moyer:

On December 29, 2001, the Nuclear Regulatory Commission (NRC) completed an inspection at your Robinson facility. The enclosed report documents the inspection findings which were discussed on January 7, 2002, with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations, and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

No findings of significance were identified.

Immediately following the terrorist attacks on the World trade Center and the Pentagon, the NRC issued an advisory recommending that nuclear power plant licensees go to the highest level of security, and all promptly did so. With continued uncertainty about the possibility of additional terrorist activities, the Nations nuclear power plants remain at the highest level of security and the NRC continues to monitor the situation. This advisory was followed by additional advisories, and although the specific actions are not releasable to the public, they generally include increased patrols, augmented security forces and capabilities, additional security posts, heightened coordination with law enforcement and military authorities, and more limited access of personnel and vehicles to the sites. The NRC has conducted various audits of Carolina Power and Lights response to these advisories and Robinsons ability to respond to terrorist attacks with the capabilities of the current design basis threat. From these audits, the NRC has concluded that the Robinson security program is adequate at this time.

CP&L 2 In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Brian R. Bonser, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket No.: 50-261 License No.: NPF-23

Enclosure:

(See page 3)

CP&L 3 Enclosure: Inspection Report 50-261/01-05 w/Attachment

REGION II==

Docket Nos: 50-261 License No: DPR-23 Report No: 50-261/01-05 Licensee: Carolina Power & Light (CP&L)

Facility: H. B. Robinson Steam Electric Plant, Unit 2 Location: 3581 West Entrance Road Hartsville, SC 29550 Dates: September 30, 2001 - December 29, 2001 Inspectors: B. Desai, Senior Resident Inspector A. Hutto, Resident Inspector F. Wright, Senior Health Physicist (2OS1, 2OS3, 4OA1)

J. Kreh, Emergency Preparedness Inspector (1EP1, 1EP4, 4OA1)

Approved by: B. Bonser, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS IR 05000261-01-05, on 09/30 - 12/29/2001, Carolina Power & Light Company, H. B. Robinson Steam Electric Plant, Unit 2. Baseline integrated resident inspection report.

The inspection was conducted by resident inspectors, a senior health physicist, and an emergency preparedness inspector. No findings of significance were identified during this inspection. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described at its Reactor Oversight Process website.

A. Inspector Identified Findings None B. Licensee Identified Violations None

Report Details Summary of Plant Status The unit operated at or near full power from the beginning of the report period until October 26, when power was reduced briefly to 60 percent for main turbine electro-hydraulic test switch troubleshooting. The unit remained at full power until December 7, when power was reduced to 55 percent to support main condenser tube repair. The unit was returned to 100 percent power on December 8. The unit was operated at or near 100 percent power for the remainder of the report period.

1. REACTOR SAFETY Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity 1R01 Adverse Weather Protection a. Inspection Scope The inspectors conducted a plant walkdown with primary focus on the condition of the temporary enclosures and other measures taken by the licensee to protect equipment from cold weather. The inspectors checked the condition of thermal insulation protecting sensing lines for main steam and turbine first stage impulse pressure transmitters and for the main steam power operated relief valve controllers. The inspectors looked for any gaps or damage to the insulation that could result in freezing of the lines during extreme cold weather conditions. The inspectors also reviewed completed maintenance work requests to verify that freeze protection circuit checks had been performed in accordance with the licensees procedures.

b. Findings No findings of significance were identified.

1R04 Equipment Alignment a. Inspection Scope The inspectors reviewed plant documents including plan-of-the-week, system descriptions (SD), Updated Final Safety Analysis Report (UFSAR), Technical Specifications (TS), and piping and instrument diagrams (P&IDs) to determine correct system lineup. The inspectors performed three partial system walkdowns to verify proper equipment alignment and to identify any discrepancies that could impact the safety function of the system or could contribute to an initiation of a plant transient. The inspectors also completed one complete system walkdown which in addition to the above, included a review of open work orders and engineering service requests (ESRs)

associated with the system that may have affected the ability of the system to perform its function.

Partial system walkdowns:

  • Engine Driven Fire Pump (EDFP) and Fuel Oil Supply with Motor Driven Fire Pump OOS Complete system walkdown:
  • High Head Safety Injection (SI)

b. Findings No findings of significance were identified.

1R05 Fire Protection a. Inspection Scope Within the areas identified below, the inspectors observed the following to determine whether any conditions adversely affected fire protection defense-in-depth features:

  • any welding or cutting being performed in the area;
  • the physical condition of the fire detection devices;
  • the physical condition of the automatic suppression system (where used);
  • the availability and general condition of portable fire extinguishers;
  • the physical condition of manual suppression systems, including fire hoses;
  • the material condition of electrical raceway fire barrier systems;
  • the material condition of the fire doors;
  • the condition of ventilation fire dampers;
  • the physical condition of seals in accessible electrical and piping penetrations;
  • the adequacy of compensatory measures, where degraded features were identified.

The inspected areas included the following:

  • Waste Gas Compressor Room
  • EDG A & B Rooms
  • Cable Spread Room
  • Control Room
  • SI Pump Room
  • Auxiliary Building Hallway
  • Condensate StorageTank/Dedicated Shutdown (CST/DS) Diesel Fuel Oil (FO)

Tank Area The inspectors also observed a fire drill conducted on October 13 to assess readiness of the licensees capability to fight fires. The inspectors evaluated the following attributes:

  • protective clothing/self contained breathing apparatus properly worn
  • adequacy of fire hoses
  • controlled access to the fire area by the fire brigade members
  • adequacy of fire fighting equipment
  • clarity and effectiveness of the fire brigade leader
  • adequate communications
  • effectiveness of smoke removal gear
  • licensee critique of the fire scenario b. Findings No findings of significance were identified.

1R06 Flood Protection Measures a. Inspection Scope The inspectors reviewed ESR 01-00102, SW Line 6-CW-89 Leak Repair, Revision 0, that installed a clamp to stop a leak from the SW return line 6-CW-89 from the Emergency Diesel Generator heat exchangers. The inspectors reviewed the flooding evaluation as well as walked down the portion of the SW system, located in the auxiliary building hallway, with the system engineer to determine current status of the leak following the implementation of the ESR.

b. Findings No findings of significance were identified.

1R07 Heat Sink Performance a. Inspection Scope The inspectors witnessed the cleaning and inspection of the A CCW heat exchanger (SW side) to verify that no deficiencies existed which could impair heat exchanger performance. The inspectors observed the as found condition of the heat exchanger and checked for the presence of debris and sludge and evidence of corrosion or microbiological growth that could result in fouling. The inspectors also observed the condition of the internal coating applied to the water boxes for any degradation.

Additionally, the inspectors assessed the results of the CCW heat exchanger inspection to determine whether current inspection and cleaning frequencies were adequate to detect degradation prior to loss of the design basis heat removal function.

b. Findings No findings of significance were identified.

1R11 Licensed Operator Requalification a. Inspection Scope The inspectors observed licensed operator requalification training activities which included simulator scenarios involving a loss of coolant accident. The inspectors assessed licensed operator performance during the scenarios to verify that the crew correctly diagnosed abnormal conditions and that the appropriate emergency operating procedures (EOP) and abnormal operating procedures (AOP) were used. The inspectors observed the effectiveness of command and control demonstrated by the crew. The inspectors reviewed the emergency classification performed by the participating operators.

b. Findings No findings of significance were identified.

1R12 Maintenance Rule Implementation a. Inspection Scope The inspectors assessed the effectiveness of the licensees maintenance efforts by evaluating several conditions that occurred during the inspection period. The inspection determined the risk significance of the condition, licensee implementation of the maintenance rule (10 CFR 50.65) with respect to characterization of failures, the appropriateness of the associated a(1) or a(2) classification as well as the associated performance criteria, and the utilization of the corrective action program. The specific conditions evaluated by the inspectors included:

  • 4160 V 50 DH 350E Type Breaker Number 52/20 failure to open (Functional Failure)
  • Charging Pump C Failure to Start
  • EDG B Overload (Functional Failure)
  • Control Rod Drive System Review following indication drift issues
  • AFW OOS time review to determine appropriate logging in maintenance rule log book
  • Radiation Monitor, R-14 Sample Pump Failure b. Findings No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Evaluation a. Inspection Scope

The inspectors reviewed the licensees risk assessments for the following plant configurations. The inspectors reviewed the licensees implementation of 10 CFR 50.65 (a)(4) requirements during scheduled and emergent maintenance activities. The licensee evaluated plant risk in accordance with Operations Management Manual OMM-048, Work Coordination and Safety Assessment, Revision 11, during the scheduling of planned and emergent work items. The inspectors reviewed the effectiveness of licensee actions to plan and control scheduled work to minimize overall plant risk while the emergent work items were being addressed. The inspectors reviewed the applicable plant risk profiles, work week schedules, and maintenance work requests associated with the following out of service equipment:

  • Battery Charger A, and Instrument Air Compressor D OOS with ongoing switchyard work
  • Auxiliary Transformer fan bank OOS/EDG test postponement
  • B Charging Pump packing leak and C Charging Pump surveillance
  • Pressurizer Protection Channel Calibrations during B CCW Pump maintenance b. Findings No findings of significance were identified.

1R14 Personnel Performance During Non-Routine Plant Evolutions and Events a. Inspection Scope The inspectors observed operator performance and reviewed operator logs, plant computer data, and control room annunciator panels during a reactor power reduction to 60 percent to support main turbine electro-hydraulic test button troubleshooting. The inspectors observed the operators procedure usage, command and control techniques, and adherence to TS reactor coolant sampling requirements.

The inspectors also reviewed licensee follow-up of an event involving high tritium concentration in the west settling pond, located within the site boundary. The source of the tritium was leakage from a chemical and volume control system (CVCS) letdown demineralizer isolation valve. The inspectors walked down a portion of the CVCS, reviewed the licensee action plan to initially identify the leak, licensee actions to repair the leak, and results from the periodic monitoring of the west settling pond following the replacement of the leaking valve.

b. Findings No findings of significance were identified.

1R15 Operability Evaluations a. Inspection Scope The inspectors selected operability evaluation Action Requests (ARs) affecting the risk significant mitigating systems listed below to assess as appropriate: (1) the technical adequacy of the evaluations; (2) whether continued component or system operability was warranted; and (3) whether compensatory measures were in place, would work as intended and were appropriately controlled:

  • AR 52641, Dedicated Shutdown Diesel Generator Start Failure Alarm
  • AR 52929, Service Water Booster Pump Oil Seal Leak b. Findings No findings of significance were identified.

1R16 Operator Work-Arounds a. Inspection Scope The inspectors performed a cumulative review of existing operator work-arounds to determine any change from the previous inspection period. The review also considered the effect of the work-arounds on the operators ability to implement AOPs or EOPs.

Additionally, the inspectors periodically reviewed ARs and held discussions with operators to determine if any conditions existed that should have been identified by the licensee as operator work-arounds.

b. Findings No findings of significance were identified.

1R17 Permanent Plant Modifications a. Inspection Scope The inspectors performed a review of the following permanent plant modifications to verify that the design bases, licensing bases, and performance capability of the affected risk significant structures, systems and components (SSCs) had not been degraded as a result of the modifications. The inspectors also, where applicable, verified that the modification performed during risk-significant configurations did not place the plant in an unsafe condition.

  • ESR 01-00237, DS-UPS K3 Relay Replacement, Revision 0
  • ESR 01-00204, Replacement Power Supply for FQ-958A, Revision 0

b. Findings No findings of significance were identified.

1R19 Post-Maintenance Testing a. Inspection Scope The inspectors witnessed the following post maintenance tests (PMT) and/or reviewed the test data to determine if the tests were adequate for the scope of maintenance, and if the acceptance criteria and test results demonstrated the operational readiness of the SSCs in accordance with plant TS. The activities were selected based on a risk assessment associated with the scheduled or emergent activity.

+ OST-201-1 MDAFW System Component Test-Train A, Revision 16, following routine calibration of Train A discharge pressure switches and flow control valve.

+ OST-352-2 Containment Spray Component Test-Train B (Quarterly),

Revision 15, following limitorque maintenance and grease inspection on valve SI-844B

+ OST-401-2 EDG B Slow Speed Start, Revision 18, following replacement of air start solenoid valve.

+ OST-101-2 CVCS Component Test Charging Pump B (Quarterly), Revision 23, following breaker maintenance for B charging pump.

+ OST-251-1 RHR Pump A and Components Test (Quarterly), Revision 14, following breaker maintenance for valve SI-861A.

+ OST-302-1 Service Water System Component Test-Train A (Quarterly),

Revision 31, following bearing seal replacement on A SW Booster Pump.

b. Findings No findings of significance were identified.

1R22 Surveillance Testing a. Inspection Scope The inspectors witnessed the following surveillance tests and/or reviewed test data to verify that the surveillance test results demonstrated that the SSCs were capable of performing their intended safety functions. Specifically, the inspectors considered the following: pre-conditioning, plant risk, appropriate acceptance criteria, adequate test equipment, procedure adherence, completeness of data, adequate test frequency, and configuration control.

+ OST-302-1 Service Water System Component Test Train A (Quarterly),

Revision 31

+ MST-003 Tavg and Delta-T Protection Channel Testing, Revision 28

+ OST-409-1 EDG A Fast Speed Start, Revision 15

+ OST-927-1 Flow Test for CC-931 and SW-924 Check Valves (Quarterly),

Revision 7

+ OST-352-1 Containment Spray Component Test-Train A (Quarterly),

Revision 17

+ OST-151-1 Safety Injection System Components Test-Pump A (Quarterly),

Revision 16 b. Findings No findings of significance were identified.

1R23 Temporary Plant Modifications a. Inspection Scope The inspectors reviewed the following temporary modifications to determine their impact on safety functions. This review included the associated 10 CFR 50.59 screening to verify the system design basis, UFSAR and TS were considered, and the configuration control for the modification to verify that any affected plant documents, such as drawings and procedures were properly controlled.

+ ESR 01-00133, Back Out Valve Body Vent Plug To Vent RC-523, Revision 0

+ ESR 01-00144, Leak Repair for SW Line 8-CW-61, Revision 0

+ ESR 01-00164, Justify Loss of Use of MS-111 for Furmanite Repair, Revision 0 b. Findings No findings of significance were identified.

Cornerstone: Emergency Preparedness 1EP1 Exercise Evaluation a. Inspection Scope The inspectors reviewed the exercise objectives and scenario to determine whether they were designed to test major elements of the licensees emergency plan. The inspectors observed and evaluated the licensees performance in the exercise, conducted on October 9, 2001 from 7:00 a.m. to 12:30 p.m., as well as selected proceedings related to the licensees conduct of the exercise. Licensee activities inspected during the exercise included those occurring in the Control Room Simulator, Technical Support Center, Operational Support Center, and Emergency Operations Facility. The NRCs assessment focused on the risk-significant activities of event classification, notification of governmental authorities, onsite protective actions, offsite protective action recommendations, and accident mitigation. The inspectors also evaluated command and control, the transfer of emergency responsibilities between facilities,

communications, and adherence to emergency plan implementing procedures. The performance of the emergency response organization was evaluated against applicable licensee procedures and regulatory requirements. The inspectors attended the post-exercise critique to evaluate the licensee's self-assessment process, as well as the presentation of critique results to plant management.

b. Findings No findings of significance were identified.

1EP4 Emergency Action Level (EAL) and Emergency Plan Changes a. Inspection Scope The inspectors reviewed changes to the Radiological Emergency Plan (REP), as contained in Revisions 42 through 47, against the requirements of 10 CFR 50.54(q) to determine whether any of the changes decreased REP effectiveness. None of the listed revisions contained modifications to the EALs.

b. Findings No findings of significance were identified.

1EP6 Drill Evaluation a. Inspection Scope The inspectors observed and evaluated the licensees conduct of a fire/emergency drill held on December 12. The drill scenario involved a fire in the CCW pump room. The inspectors observed the scenario from the CCW pump room as well as the control room. The inspectors observed the control room performance in the declaration of the emergency classifications. The inspectors also reviewed the post drill critique that was developed by the licensee evaluators.

b. Findings No findings of significance were identified.

2. RADIATION SAFETY Cornerstone: Occupational Radiation Safety 2OS1 Access Control To Radiologically Significant Areas a. Inspection Scope Licensee radiation protection activities for occupational radiation workers were evaluated against licensee procedures, UFSAR, TS, and 10 CFR Part 20 requirements.

To evaluate the licensees control of access to radiologically-significant areas the inspectors reviewed the licensees controls of locked and very high radiation areas. The inspectors observed postings and control of access to radiological control areas, high radiation areas, locked high radiation areas and very high radiation areas during inspections of the Radiologically Controlled Areas (RCAs).

b. Findings No findings of significance were identified.

2OS3 Radiation Monitoring Instrumentation a. Inspection Scope The inspectors evaluated radiological procedures, problem evaluation reports, calibration data files, interviewed health physics technicians, health physics section supervisors and managers to evaluate compliance with the UFSAR, TS, Offsite Dose Calculation Manual, 10 CFR Part 20 requirements, and licensee procedure requirements.

The operability of the plant area radiation monitors (ARMs), used to alert the site staff of changing radiation exposures, were examined to verify that the equipment was properly maintained and functioning as described in the UFSAR. Operability of the ARMs was checked by comparing measured radiation levels at the monitor locations using portable radiation survey instruments with indicated radiation levels displayed on local and control room instrumentation.

Routine instrument operation checks, source checks, and calibration records for selected plant instruments were reviewed to verify licensee surveillance met procedural and TS requirements. Instrument set points and their basis for plant radiation measuring equipment were evaluated for adequacy.

The inspectors reviewed the operability of portable survey instrumentation used for the protection of occupational radiation workers in high radiation work areas. Calibration records were reviewed.

Recent whole body counter calibrations, daily quality control checks, check source standardization, and efficiency parameters were reviewed.

The inspectors reviewed self-contained breathing apparatus (SCBA) qualifications of control room operators, SCBA training, and the impact of SCBAs on control room operators during an emergency. The review included inspections of SCBA equipment for readiness, SCBA air quality to industry standards, respiratory training for the licensees control room operators, readiness of SCBA equipment in the control room, and the licensees capability for replenishing control room SCBA air bottles during adverse conditions.

Recently identified problems with plant instrumentation documented in the licensees corrective action program were reviewed for adverse trends on radiation monitoring system performance. The inspectors also reviewed licensee self-assessments to determine whether the licensee was identifying and resolving problems. Corrective actions for identified issues were checked to verify their adequacy and timely resolution.

The inspectors evaluated the Respiratory Protection Program and evaluated the licensees actions taken with regards to NRC Information Notices (IN) 98-20 and 99-05.

The inspectors observed the availability of corrective lenses for use in respirators of control room operators.

b. Findings No findings of significance were identified.

4. OTHER ACTIVITIES [OA]

40A1 Performance Indicator (PI) Verification a. Inspection Scope The inspectors reviewed the following PIs. To verify data for PIs under Mitigating Systems, Barrier Integrity, and Initiating Events, the inspectors reviewed control room logs, maintenance rule logs, data reported to NRC, and condition reports. PI data for the period of April through November 2001 was reviewed using the guidance in Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Performance Indicator Guideline.

For the Occupational Exposure Control Effectiveness and the Radiological Effluent Technical Specifications/Offsite Done Calculation Manual (RETS/ODCM) PI, the inspectors interviewed cognizant personnel and reviewed ARs initiated between April 1, 2001, and October 16, 2001, to support the PI verification. Selected ARs were evaluated for assignment of responsibility, licensee evaluation, adequacy of corrective actions, timely closure, and applicability for PI reporting screening criteria.

The inspectors assessed the accuracy of the PI for Emergency Response Organization (ERO) drill and exercise performance (DEP) and drill participation through review of a sample of drill records. Documentation was reviewed for an ERO drill conducted on

June 26, 2001 to verify the licensees reported data regarding successes in emergency classifications, notifications, and protective action recommendations. Through direct observation, the inspectors assessed the accuracy of the licensee's determinations with respect to the ten DEP PI opportunities during the exercise on October 9, 2001. The inspectors assessed the accuracy of the PI for the alert and notification system reliability through review of a sample of the licensees records of the biweekly silent tests, quarterly growl tests, and annual full-volume tests conducted from July 1, 2000 to June 30, 2001.

Cornerstone Performance Indicator Mitigating Systems Safety System Functional Failures Barrier Integrity Reactor Coolant System Specific Activity Initiating Events Unplanned Scrams per 7000 Critical Hours Scrams With Loss of Normal Heat Removal Unplanned Power Changes per 7000 Critical Hours Emergency Preparedness Drill/Exercise Performance ERO Drill Participation Alert and Notification System Reliability Occupational Radiation Safety Occupational Exposure Control Effectiveness Public Radiation Safety RETS/ODCM Radiological Effluent b. Findings No findings of significance were identified.

4OA6 Meetings, Including Exit Exit Meeting Summary The inspectors presented the inspection results to Mr. John Moyer and other members of licensee management on January 7, 2002. The licensee acknowledged the findings presented during the exit meeting.

The inspectors asked the licensee whether any of the material examined during the inspections should be considered proprietary. No proprietary information was identified.

PARTIAL LIST OF PERSONS CONTACTED Licensee E. Kapopoulos , Operations Manager C. Martin, Site Support Services Manager K. Jones, Operations Manager (Acting)

E. Caba, Engineering Superintendent D. Stoddard, Robinson Engineering Support Services Manager E. Rothe, Maintenance Manager T. Walt, Director of Site Operations R. Steele, Outage Management Manager T. Cleary, Plant General Manager W. Farmer, Engineering Superintendent J. Fletcher, Regulatory Affairs Manager S. Weiss, Training Manager J. Moyer, Vice President, Robinson Nuclear Plant S. Young, Superintendent Security D. Crook, Supervisor Access Authorization A.G. Cheatham, Radiation Protection Manager NRC Victor McCree, Deputy Division Director, DRP, RII Brian Bonser, Branch Chief, DRP, RII ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed None Opened and Closed None Discussed None

LIST OF DOCUMENTS REVIEWED Section 1R01 AP-008, Cold Weather Preparations, Revision 6 OP-925, Cold Weather Operation, Revision 22 WO 171220-01, Freeze Protection Panel Check Section 1R04 UFSAR Sections 1.5.2, 6.3, 7.3, 8.3.1, 9.2.1, 9.2.2, 9.5.1 TS Sections 3.5, 3.7, 3.8, 5.0 Plant Drawings G-190197, G-190199, G-190204A, 5379-376, 5379-1082, HBR2-8255 ESR 00-00176, SI-861A/B Differential Pressure, Revision 0 ESR 00-00084, Replacement of SI-857B with PCV, Revision 0 Section 1R05 UFSAR Section 9.5.1 Fire Permit 2001-33-006 Section 1R06 Drawing G-190199, Sheet 5, Generic Letter 90-05, Guidance for Performing Temporary Non-Code Repair of ASME Code Class 1,2,and 3 Piping Section 1R07 W/O 64306-06, Clean and Inspect the A CCW HX CM-201, Service Water Safety Related Heat Exchanger Data Sheet, Revision 28 Section 1R11 EPP-4, Reactor Trip Response, Revision 17 Emergency Procedure Path I Emergency Action Level Matrix Section 1R12 ADM-NGGC-0101, Maintenance Rule Program, Revision 13 PM-468, West Type 50 DH350E 3000 Amp 4160V Air Circuit Breaker Maintenance, Revision12 Drawing B-190628 Sheet 930 ITS Sections 3.1-1, 3.3-44, 3.8-1 System Description Auxiliary Feedwater System UFSAR Section 8.3 RNP Maintenance Rule Database Drawing G-190197 AR 52859, R-14 Failure - Unanticipated LCO Entry Off-Site Dose Calculation Manual (ODCM), Revision 19, Section 3.0, Gaseous Effluents Section 1R13 OMM-48, Work Condition and Risk Assessment, Revision 11 Section 1R14 GP-005, Power Operation, Revision 69 OP-105, Maneuvering the Plant When Greater Than 25% Power, Revision 19

TS SR 3.4.16.2 Drawing 5379-685 Action Request 52254, High Tritium Concentration in West Settling Pond Section 1R15 EGR NGGC-005, Engineering Service Requests, Revision 15 UFSAR Chapter 3.0, 7.0, 15.0 Section1R17 EGR- NGGC-005, Engineering Service Request, Revision 15 UFSAR Section 3.0,7.0,15.0 Section 1R19 PLP-033, Post Maintenance Testing (PMT) Program, Revision 23 Section IR22 ITS 3.7.7, 3.7.8 ITS SR 3.3.1-7, Table 3.3.1-1 ITS SR 3.3.2.4, Table 3.3.2-1 ITS 3.8.1, 3.8.2 WR 169147, 169158, 169157 ITS 3.4.6, ITS 3.4.7 OP-306,Component Cooling System, Revision 33 ITS 3.3.6. 5.5.8 UFSAR 6.5.2 ITS 3.5.2, 3.5.3, 5.5.8 System Description 002, Safety Injection Section 1R23 Drawings G190196, Sheet 3, G-190199, Sheet 12, System Description 34, Main Generator and Auxiliaries, System Description 1, and Reactor Coolant System, Drawing 5379-0844.

Section 1EP6 Drill Critique 01-4Q-04 TPP-219, Fire Protection Training Program, Revision 8 Section 2OS3 EPPRO-03, Training and Qualification, Revision 11 DOS-NGGC-0020, Whole Body Counter (WBC) System Calibration, Revision 6 HPP-011, Radiologically Controlled Area Surveillance Program, Revision 71 HPS-NGGC-0005, Calibration of Portable Radiation/Contamination/Air Sampling Survey Instruments, Revision 1

HPS-NGGC-0013, Personnel Contamination Monitoring, Decontamination, and Reporting, Revision 0 OP-807, Breathing Air Charging Station, Revision 9 OMM-014, Radiation Monitor Setpoints, Revision 35 OST-020, Shiftly Surveillances, Revision 11 RST-001, Radiation Monitor Source Checks, Revision 65 RST-008, Calibration of Radiation Monitor System, Monitors R-1 Through R-8, Revision 24 RST-009, Calibration of Radiation Monitoring System, Monitors R-9, R-30, R-31A, B, C and R-33, Revision 21 RST- 014, Calibration of Radiation Monitoring System, Monitor R-16, Revision 17 RST-020, Verification of Electronic Calibration Of Radiation Monitoring System Monitors R-32 A & B, Revision 15 RST-023, Routine Respirator Maintenance, Revision 16 SIC-006, Calibration of the Gamma-40 Portal Monitor, Revision 6 SIC-013, Calibration of the PNR-4, Revision 11 SIC-021, Setup, Calibration, Operation, Source-Checking of the Eberline Model PCM-1 Personnel Contamination Monitor, Revision 17 SIC-034, Calibration of Portable Air Sampling Equipment, Revision 5 SIC-037, Calibration and Operation of the APTEC PMW-3 Personnel Monitor, Revision 6 SIC-038, Calibration of the Gamma-60 Portal Monitor, Revision 0 Section 40A1 REG-NGGC-0009, NRC Performance Indicators, Revision 0