IR 05000335/2011002

IR 05000335-11-002, 05000389-11-002, 05000335-11-501, 05000389-11-501; 01/01/2011 - 03/31/2011; St. Lucie Nuclear Plant, Units 1 & 2; Radiological Hazard Assessment and Exposure Controls; Other Activities

ML111220053
Person / Time
Site:	Saint Lucie
Issue date:	04/29/2011
From:	Rich D NRC/RGN-II/DRP/RPB3
To:	Nazar M Florida Power & Light Co
References
IR-11-002, IR-11-501
Download: ML111220053 (54)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ril 29, 2011

SUBJECT:

ST. LUCIE NUCLEAR PLANT - NRC INTEGRATED INSPECTION REPORT 05000335/2011002, 05000389/2011002 AND EMERGENCY PREPAREDNESS REPORT 05000335/2011501, 05000389/2011501

Dear Mr. Nazar:

On March 31, 2011, the US Nuclear Regulatory Commission (NRC) completed an inspection at your St. Lucie Plant. The enclosed inspection report documents the inspection results, which were discussed on March 31, 2011, with Mr. Anderson and other members of your staff.

The inspection examined activities conducted under your license as they related 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.

This report documents one NRC identified finding and one self-revealing finding, both of very low safety significance (Green). These findings were determined to involve violations of NRC requirements. However, because of the very low safety significance and because they were entered into your corrective action program, the NRC is treating the findings as a non-cited violations (NCV) consistent with the NRC Enforcement Policy. If you contest these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the St. Lucie facility. In addition, if you disagree with the characterization of any finding 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 Regional Administrator, Region II, and the NRC Resident Inspector at St. Lucie. The information you provide will be considered in accordance with Inspection Manual Chapter 0305.

FPL 2 In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the 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/

Daniel W. Rich, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket Nos. 50-335, 50-389 License Nos. DPR-67, NPF-16

Enclosure:

Inspection Report 05000335/2011002, 05000389/2011002 w/Attachment: Supplemental Information

REGION II==

Docket Nos: 50-335, 50-389 License Nos: DPR-67, NPF-16 Report Nos: 05000335/2011002, 05000389/2011002 and 05000335/2011501, 05000389/2011501 Licensee: Florida Power & Light Company (FP&L)

Facility: St. Lucie Nuclear Plant, Units 1 & 2 Location: 6351 South Ocean Drive Jensen Beach, FL 34957 Dates: January 1 to March 31, 2011 Inspectors: T. Hoeg, Senior Resident Inspector S. Sanchez, Resident Inspector S. Ninh, Senior Project Engineer S. Mendez-Gonzalez, Fuel Facility Inspector B. Collins, Reactor Inspector (1R08)

J. Rivera-Ortiz, Senior Reactor Inspector (1R08)

W. Loo, Senior Health Physicist (2RS1, 2RS2, 2RS4, 2RS5, 4OA1, 4OA5)

G. Kuzo, Senior Health Physicist (2RS3)

R. Kellner, Health Physicist (2RS1, 2RS2, 2RS4, 2RS5, 4OA1, 4OA5)

J. Beavers, Senior Emergency Preparedness Inspector (1EP2, 1EP3, 1EP4, 1EP5, 4OA1)

M. Speck, Emergency Preparedness Inspector (1EP2, 1EP3, 1EP4, 1EP5, 4OA1)

R. Patterson, Reactor Inspector (4OA5.3)

Approved by: D. Rich, Chief Reactor Projects Branch 3 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000335/2011-002, 05000389/2011-002 and IR 05000335/2011-501, 05000389/2011-501 01/01/2011 - 03/31/2011; St. Lucie Nuclear Plant, Units 1 & 2; Radiological Hazard Assessment and Exposure Controls; Other Activities.

The report covered a three month period of inspection by resident inspectors and region based inspectors. Two Green NCVs were identified. The significance of most findings is identified by their color (Green, White, Yellow, Red) using IMC 0609, Significance Determination Process (SDP) and the cross-cutting aspect was determined using IMC 310, Components Within The Cross-Cutting Areas. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, and Revision 4, dated December 2006.

Cornerstone: Occupational Radiation Safety (RS)

Green.

A self-revealing non-cited violation (NCV) of 10 CFR Part 20.1501(a) was identified for failure to perform adequate surveys to verify radiological conditions within the Unit 1 B Waste Gas Decay Tank (WGDT) room prior to allowing workers to enter the area. This resulted in workers unknowingly entering an area with general area dose rates exceeding High Radiation Area (HRA) conditions, i.e., dose rates exceeding 100 millirem per hour (mrem/hr) at 30 centimeters (cm). Because of the potential for changing radiological conditions resulting from normal operation, radiation protection staff established controls for access to all WGDT rooms through administrative postings and locked entry doors to ensure monitoring and establishment of appropriate radiological controls prior to worker entry into the areas. However, on October 4, 2010, two maintenance workers were allowed access to the 1B WGDT room without a Radiation Protection Technician (RPT) performing a survey prior to entry. One worker subsequently received a dose rate alarm on their Electronic Dosimeter (ED), maximum dose rate measurement of 77.5 mrem/hr which exceeded the ED dose rate alarm setpoint of 75 mrem/hr. Both workers exited the room and contacted the assigned RPT.

Subsequent surveys measured HRA conditions adjacent to the 1B WGDT, maximum general area dose rates of 250 mrem/hr, resulting from operations venting gas to the subject tank several hours before the workers entered the room. Room postings and access controls were upgraded immediately for the identified HRA conditions. The licensee entered the issue into their corrective action program (CAP) as condition report (CR) number AR 585076.

This finding is greater than minor because it was associated with the Occupational Radiation Safety Cornerstone attribute of Program and Process (Monitoring and RP Controls) and adversely affects the cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. The finding was evaluated using the Occupational Radiation Safety Significance Determination Process (SDP) and was determined to be of very low safety significance (Green) because it was not related to As Low As Reasonably Achievable (ALARA) Planning and the ability to assess dose was not compromised. In addition, it did not involve overexposure or substantial potential for overexposure because the maximum exposure rate within the 1B WGDT were not estimated to exceed Locked High Radiation Area (LHRA) conditions, WGDT room doors are administratively locked, keys only issued to RP personnel, and the entrances are posted Radiation Area, Contact RP Prior to Entry. The cause of this finding was directly related to the cross-cutting aspect of Conservative Assumptions in the Decision Making component of the Human Performance area because the RPT assumed that radiological conditions in the 1B WGDT room had not changed, even though additional administrative controls were in place due specifically to the identified potential for changing radiological conditions in the area when venting gas to the WGDT.

H.1(b). (Section 2RS1)

Cornerstone: Mitigating Systems

Green.

A NRC identified NCV of Technical Specification (TS) 6.8.1, which requires that written procedures be established, implemented, and maintained covering the activities in NRC Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation),

Appendix A, for the licensees failure to follow posted and published guidelines per ADM-17.25, Plant Barrier Control and 0-NOP-99.02, Watchstation General Inspection Guidelines, Rev. 13A was identified. The failure to follow posted and published guidelines per ADM-17.25, Plant Barrier Control, and 0-NOP-99.02, Watchstation General Inspection Guidelines, Rev. 13A, is a performance deficiency.

The finding was determined to be of more than minor significance because it affected the mitigating systems cornerstone attribute of equipment performance to ensure the availability and reliability of the ECCS ventilation system to perform its intended safety function during a design basis event; and closely parallels IMC 0612, Appendix E,

Example 3.j, in that there was reasonable doubt regarding the capability of the system to perform its intended function pending reanalysis (i.e. testing). Specifically, not fully securing the RAB doors via the dog latches could adversely affect the operability of the ECCS ventilation system to perform its safety functions. The inspectors evaluated the risk of this finding using IMC 0609, Significance Determination Process, Attachment 4,

Phase 1 - Initial Screening and Characterization of Findings. The inspectors determined that the finding was of very low safety significance because it did not result in an actual loss of operability to the ECCS ventilation system. The finding involved the cross-cutting area of human performance, the component of work practices and the aspect of human prevention techniques and peer checking (H.4.a), in that, the licensee failed to practice their human prevention techniques specifically, peer checking to ensure that personnel followed procedures and postings which required the RAB doors to be completely dogged closed. (Section 4OA5)

Licensee Identified Violations

None.

REPORT DETAILS

Summary of Plant Status

Unit 1 operated at full Rated Thermal Power (RTP) during this entire inspection period. Unit 2 was shut down for a scheduled refueling outage on January 2, 2011, and remained shut down during this entire inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity (Reactor-R)

1R01 Adverse Weather Protection

.1 Seasonal Winter Weather Conditions

a. Inspection Scope

During the week of February 7 the inspectors reviewed the status of licensee actions in accordance with ADM-04.03, Cold Weather Preparations for winter weather conditions. The inspectors verified conditions were met for entering the subject procedure and that equipment status was verified as directed by the procedure. The inspectors performed a walkdown of the safety-related equipment and areas noted below that are exposed to the outside weather conditions to identify any potential adverse conditions. Condition reports (CRs) were checked to assure that the licensee was identifying and resolving weather related issues.

• Unit 1 Emergency Diesel Generator (EDG) Rooms

• Unit 2 EDG Rooms

• Unit 1 Refueling Water Tank (RWT) Area

• Unit 2 RWT Area

• 1C Auxiliary Feedwater (AFW) Pump Area

• Unit 1 Main Feedwater Pump Areas

• Unit 2 Main Feedwater Pump Areas

b. Findings

No findings were identified.

.2 Impending Adverse Weather Conditions

a. Inspection Scope

On February 14 the inspectors reviewed licensee preparations for an overnight weather forecast of freezing temperatures. The inspectors verified conditions were established for the onset of the freezing temperatures including the placement of temporary heaters around equipment affected by low temperatures. The inspectors reviewed compensatory measures put in place or expected to be put in place during the expected freezing temperatures while considering equipment controls, area accessibility, and system indications. The inspectors performed a walkdown of the following areas:

• Unit 1 EDG Rooms

• Unit 1 RWT Area

• Unit 2 EDG Rooms

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Partial Equipment Walkdowns

a. Inspection Scope

The inspectors conducted four partial alignment verifications of the safety-related systems listed below. These inspections included reviews using plant lineup procedures, operating procedures, and piping and instrumentation drawings, which were compared with observed equipment configurations to verify that the critical portions of the systems were correctly aligned to support operability. The inspectors also verified that the licensee had identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers by entering them into the corrective action program (CAP).

• 2A Spent Fuel Pool Cooling (SFPC) System While 2B SFPC System Out of Service (OOS)

• 2A EDG While 2B EDG OOS

• 1B Emergency Core Cooling Systems (ECCS) While 1A ECCS OOS

• 1B EDG While 1A EDG OOS

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Fire Area Walkdowns

a. Inspection Scope

The inspectors toured the following five plant areas during this inspection period to evaluate conditions related to control of transient combustibles and ignition sources, the material condition and operational status of fire protection systems including fire barriers used to prevent fire damage or fire propagation. The inspectors reviewed these activities against provisions in the licensees procedure AP-1800022, Fire Protection Plan, and 10 CFR Part 50, Appendix R. The licensees fire impairment lists, updated on an as-needed basis, were routinely reviewed. In addition, the inspectors reviewed the Condition Report (CR) database to verify that fire protection problems were being identified and appropriately resolved. The following areas were inspected:

• Unit 2 Spent Fuel Pool Pump and Heat Exchanger Areas

• Unit 2 Component Cooling Water (CCW) Building

• Unit 2 Intake Cooling Water (ICW) Building

• Unit 2 Fuel Handling Building 62 Foot Elevation

• Unit 1 CCW Pump and Heat Exchanger Area

b. Findings

No findings were identified.

1R08 Inservice Inspection Activities

From January 10 - 28, 2011, the inspectors conducted a review of the implementation of the licensees Inservice Inspection (ISI) Program for monitoring degradation of the reactor coolant system, steam generator tubes, emergency feedwater systems, risk-significant piping and components and containment systems.

The inspections described in Sections 1R08.1, 1R08.2, 1R08.3, 1R08.4 and 1R08.5 below constituted one inservice inspection sample as defined in Inspection Procedure 71111.08-05.

.1 Piping Systems ISI

a. Inspection Scope

The inspectors evaluated the following non-destructive examinations mandated by the ASME Code Section XI to verify compliance with the ASME Code Section XI and Section V requirements and, if any indications and defects were detected, to evaluate if they were dispositioned in accordance with the ASME Code or an NRC-approved alternative requirement.

• Ultrasonic Testing (UT) of HPSI Header B to SDC Loop 2B Pipe-to-Valve weld (SI-180-FW-2), ASME Class 2, High Pressure Safety Injection system, 3 diameter -

Direct Observation

• Liquid Penetrant Testing (PT) of HPSI Header B to SDC Loop 2B Pipe-to-Elbow weld (SI-181-1-SW-1), ASME Class 2, High Pressure Safety Injection system, 3 diameter

- Direct Observation

• Visual Examination (VT) of HSPI Header B to SDC Loop 2B Box Restraint (SI-2415-138), ASME Class 2, High Pressure Safety Injection system, 3 diameter - Direct Observation During non-destructive surface and volumetric examinations performed since the previous refueling outage, the licensee did not identify any recordable indications that were accepted for continued service. Therefore, no NRC review was completed for this inspection procedure attribute.

The inspectors reviewed documentation for the following pressure boundary welds completed for risk-significant systems during the outage to evaluate if the licensee applied the pre-service non-destructive examinations and acceptance criteria required by the construction Code. In addition, the inspectors reviewed the welding procedure specifications, welder qualifications, welding material certifications and supporting weld procedure qualification records to evaluate if the weld procedures were qualified in accordance with the requirements of Construction Code and the ASME Code Section IX.

• Work Order 38001164, Replace Pressurizer Heaters and Sleeves by Welding

• Work Order 39019244, Replace MV-07-4 by Welding

• Work Order 33008835, Repair HCV-3615, LPSI Feed Containment Loop 2A2

b. Findings

No findings were identified.

.2 Reactor Pressure Vessel Upper Head Penetration Inspection Activities

a. Inspection Scope

The inspectors reviewed records of the visual examination conducted on the Unit 2 reactor vessel head at to evaluate if the activities were conducted in accordance with the requirements of ASME Code Case N-729-1 and 10 CFR 50.55a(g)(6)(ii)(D).

Specifically, the inspectors reviewed the following documentation and/or observed the following activities:

• Evaluated if the required visual examination scope/coverage was achieved and limitations (if applicable) were recorded in accordance with the licensee procedures.

• Evaluated if the licensees criteria for visual examination quality and instructions for resolving interference and masking issues were adequate.

The licensee did not perform any welded repairs to vessel head penetrations since the beginning of the preceding outage for Unit 2. Therefore, no NRC review was completed for this inspection procedure attribute.

b. Findings

No findings were identified.

.3 Boric Acid Corrosion Control (BACC)

a. Inspection Scope

The inspectors performed an independent walkdown of portions of the containment building, which recently received a licensee boric acid walkdown and evaluated if the licensees BACC visual examinations emphasized locations where boric acid leaks could cause degradation of safety-significant components.

The licensee did not perform any evaluations of reactor coolant system components with boric acid deposits and no corrective actions for any degraded reactor coolant system components were required. Therefore, no NRC review was completed for this inspection procedure attribute.

The inspectors reviewed the following corrective actions related to evidence of boric acid leakage to evaluate if the corrective actions completed were consistent with the requirements of the ASME Code Section XI and 10 CFR Part 50, Appendix B, Criterion XVI.

• CR 2009-11082 - Active Boric Acid Leak V2326, Safety Relief 2C Charging Pump

• CR 2009-12716 - Potential Active Boric Acid Leak on ICI #4

b. Findings

No findings were identified.

.4 Steam Generator (SG) Tube Inspection Activities

a. Inspection Scope

The inspectors reviewed the Unit 2 eddy current (EC) examination activities in SGs 2A and 2B and evaluated them against the licensees Technical Specifications, NRC commitments, ASME Section XI, and Nuclear Energy Institute (NEI) 97-06, Steam Generator Program Guidelines. The inspectors reviewed the scope of the EC examinations to verify it included the applicable potential areas of tube degradation. The inspectors also verified that appropriate inspection scope expansion criteria were planned based on inspection results. Additionally, the inspectors reviewed EC examination status reports to ensure that all tubes with relevant indications were appropriately screened for in-situ pressure testing. Based on the EC examination results, no new degradation mechanisms were identified, no EC scope expansion was required, and none of the SG tubes examined met the criteria for in-situ pressure testing.

The inspectors reviewed the last Condition Monitoring and Operational Assessment report to assess the licensees prediction capability for maximum tube degradation. The inspectors review also included the licensees repair criteria and repair process to ensure they were consistent with plant Technical Specifications and industry guidelines.

The inspectors also reviewed the primary to secondary leakage (e.g., SG tube leakage)history for the last operating cycle. The inspectors noted that primary to secondary leakage was below the detection threshold during the previous operating cycle.

Additionally, the inspectors reviewed documentation to ensure that data analysts, EC probes, and equipment configurations were qualified to detect the existing and potential SG tube degradation mechanisms. The inspectors review included a sample of site-specific Examination Technique Specification Sheets (ETSSs) to ensure that their qualification was consistent with Appendix H or I of the Electric Power Research Institute Pressurized Water Reactor Steam Generator Examination Guidelines, Revision 7. The inspectors also directly observed a sample of EC data acquisition in SG 2A Cold Leg Channel Head (Bobbin Probe) and SG 2B Cold Leg Channel Head (Bobbin Probe).

Furthermore, the inspectors reviewed EC data with a qualified data analyst for the following tubes: SG 2A (tubes R69C108, R103C86, R127C84, and R94C85) and SG 2B (tube R121C126). Finally, the inspectors reviewed the licensees corrective actions for indications (either from EC or secondary side visual inspections) of potential loose parts on the SG secondary side.

b. Findings

No findings were identified.

.5 Identification and Resolution of Problems

a. Inspection Scope

The inspectors performed a review of ISI-related problems entered into the licensees corrective action program and conducted interviews with licensee staff to determine if;

• the licensee had established an appropriate threshold for identifying ISI-related problems;

• the licensee had performed a root cause (if applicable) and taken appropriate corrective actions; and

• the licensee had evaluated operating experience and industry generic issues related to ISI and pressure boundary integrity.

The inspectors performed these reviews to evaluate compliance with 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requirements. The corrective action documents reviewed by the inspectors are listed in the Attachment to this report.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Training Program

Resident Inspector Quarterly Review

a. Inspection Scope

On February 17, 2011, the inspectors observed and assessed licensed operator actions during a simulated loss of component cooling water to the reactor coolant pumps and subsequent reactor trip training exercise. The inspectors also reviewed simulator physical fidelity and specifically evaluated the following attributes related to the operating crews performance:

• Clarity and formality of communication

• Ability to take timely action to safely control the unit

• Prioritization, interpretation, and verification of alarms

• Correct use and implementation of off-normal and emergency operation procedures; and emergency plan implementing procedures

• Control board operation and manipulation, including high-risk operator actions

• Oversight and direction provided by supervision, including ability to identify and implement appropriate technical specification actions, regulatory reporting requirements, and emergency plan classification and notification

• Crew overall performance and interactions

• Effectiveness of the post-evaluation critique.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed system performance data and associated CRs for the two systems listed below to verify that the licensees maintenance efforts met the requirements of 10 CFR 50.65 (Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants) and licensee Administrative Procedure ADM-17-08, Implementation of 10 CFR 50.65, Maintenance Rule. The inspectors efforts focused on maintenance rule scoping, characterization of maintenance problems and failed components, risk significance, determination of a(1) and a(2) classification, corrective actions, and the appropriateness of established performance goals and monitoring criteria. The inspectors also interviewed responsible engineers and observed some of the corrective maintenance activities. The inspectors also attended applicable expert panel meetings and reviewed associated system health reports. The inspectors verified that equipment problems were being identified and entered into the licensees CAP.

• Unit 1 High Pressure Safety Injection System

• Unit 2 Emergency Diesel Generators

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors completed in-office reviews, plant walkdowns, and control room inspections of the licensees risk assessment of six emergent or planned maintenance activities. The inspectors verified the licensees risk assessment and risk management activities using the requirements of 10 CFR 50.65(a)(4); the recommendations of Nuclear Management and Resource Council 93-01, Industry Guidelines for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 3; and licensee procedure ADM-17.16, Implementation of the Configuration Risk Management Program.

The inspectors also reviewed the effectiveness of the licensees contingency actions to mitigate increased risk resulting from the out of service equipment. The inspectors interviewed responsible Senior Reactor Operators on-shift, verified actual system configurations, and specifically evaluated results from the online risk monitor (OLRM) for the combinations of out of service (OOS) risk significant systems, structures, and components (SSCs) listed below:

• 1A and 1B Containment Instrument Air Compressors (IACs),1D IAC, 1A ICW Pumps, and 2B EDG OOS

• Unit 1 Control Room Air Conditioner HVA 3B and 1B Start-up Transformer OOS

• 1A and 1B Containment IACs, 1A Charging Pump, Unit 1 Reactor Auxiliary Building Main Supply Fan HVS 4B, and 2A EDG OOS

• 1A and 1B Containment IACs, 1A Low Pressure Safety Injection (LPSI) and High Pressure Safety Injection (HPSI) Pumps, and 2A EDG OOS

• Unit 2 Safe Shutdown Assessment Risk Following Core Reload With Scheduled Switchyard Work and Containment Building Open

• 1A and 1B Containment IACs, 1A Containment Spray Pump, 1A LPSI Pump, 1A HPSI Pump, and 1B Boric Acid Make-up Pump OOS

b. Findings

No findings were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following six interim dispositions and operability determinations to ensure that operability was properly supported and the affected SSCs remained available to perform its safety function with no increase in risk. The inspectors reviewed the applicable UFSAR, and associated supporting documents and procedures, and interviewed plant personnel to assess the adequacy of the interim disposition.

• Action Request (AR) 1611382, Unit 1 Feedwater Regulating Valve FCV-9011A Position Indication Sluggish

• AR 01601708, 1C Intake Cooling Water Piping Through-Wall Leak

• AR 01620081, Control Room Ventilation Placed in Recirculation Mode by Human Error

• AR 01619887, 1C Intake Cooling Water Pump Head Low

• AR 01628947, 1A Auxiliary Feedwater Pump Motor Oil Low Level

• AR 01629027, 1A2 Emergency Diesel Generator Immersion Heater Failed

b. Findings

No findings were identified.

1R18 Plant Modifications

a. Inspection Scope

The inspectors reviewed the documentation for a permanent modification to the Unit 2 Reactor Coolant Pumps (RCP) Seal Lines. The plant change modification (PCM) was performed in accordance with PCM 09-106 to correct known vibration-induced problems associated with RCP seal line piping. The inspectors reviewed the 10 CFR 50.59 screening and evaluation, fire protection review, environmental review, and license renewal review, to verify that the modification had not affected system operability/availability. The inspectors reviewed associated plant drawings and UFSAR documents impacted by this modification and discussed the changes with licensee personnel to verify that the installation was consistent with the modification documents.

The inspectors walked down the modification to determine if it was installed in the field as described in the subject PCM. Additionally, the inspectors verified that problems associated with modifications were being identified and entered into the CAP.

b. Findings

No findings were identified.

1R19 Post Maintenance Testing

a. Inspection Scope

For the six Post Maintenance Tests (PMTs) listed below, the inspectors reviewed the test procedures and either witnessed the testing and/or reviewed test records to determine whether the scope of testing adequately verified that the work performed was correctly completed and demonstrated that the affected equipment was functional and operable. The inspectors verified that the requirements of licensee procedure ADM-78.01, Post Maintenance Testing, were incorporated into test requirements. The inspectors reviewed the following work orders (WO) and/or work requests (WR):

• WO 40012588, 1A Charging Pump Accumulator Maintenance

• WO 40053821, 1-HVE-9A Damper Maintenance

• WO 40057413, 1C Intake Cooling Water Pump Maintenance

• WO 40020852, 1-HVS-4B Fan Maintenance

• WO 40076908, 2B EDG Fan Bearings Lubrication

• WO 40073161, 2C AFW Pump Trip and Throttle Valve Maintenance

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities

Unit 2 Refueling Outage SL2-19

a. Inspection Scope

Outage Planning, Control and Risk Assessment During daily outage planning activities by the licensee, the inspectors reviewed the risk reduction methodology employed by the licensee during various refueling outage (RFO)

SL2-19 meetings including Outage Control Center OCC morning meetings, Operations Daily Team Meetings, and Schedule Performance Update Meetings. The inspectors examined the licensee implementation of shutdown safety assessments during SL2-19 in accordance with Administrative Procedure 0-AP-010526, Outage Risk Assessment and Control, to verify whether a defense in depth concept was in place to ensure safe operations and avoid unnecessary risk. In addition, the inspectors regularly monitored outage planning and control activities in the Outage Control Center (OCC), and interviewed responsible OCC management, during the outage to ensure system, structure, and component configurations and work scope were consistent with TS requirements, site procedures, and outage risk controls.

Monitoring of Shutdown Activities The inspectors observed portions of the reactor plant cool down of Unit 2 beginning on January 3, 2011. The inspectors also reviewed operating logs and plant parameters to determine that reactor plant shutdown activities were conducted in accordance with Technical Specifications and applicable operating procedures, such as: 2-GOP-123, Turbine Shutdown - Full Load to Zero Load; 2-GOP-203, Reactor Shutdown; 2-GOP-305, Reactor Plant Cooldown - Hot Standby To Cold Shutdown; and 2-NOP-03.05, Shutdown Cooling. The inspectors performed walk downs of important systems and components used for decay heat removal from the reactor core and the spent fuel pool during the shutdown period including the intake cooling water system, component cooling water system, and spent fuel pool cooling system.

Outage Activities The inspectors examined outage activities to verify that they were conducted in accordance with TS, licensee procedures, and the licensees outage risk control plan.

Some of the more significant inspection activities accomplished by the inspectors were as follows:

• Walked down selected safety-related equipment clearance orders

• Verified operability of RCS pressure, level, flow, and temperature instruments during various modes of operation

• Verified electrical systems availability and alignment

• Verified shutdown cooling system and spent fuel pool cooling system operation

• Evaluated implementation of reactivity controls

• Reviewed control of containment penetrations

• Examined foreign material exclusion (FME) controls put in place inside containment (e.g., around the refueling cavity, near sensitive equipment and RCS breaches) and around the spent fuel pool (SFP)

• Verified workers fatigue was properly managed Refueling Activities and Containment Closure The inspectors witnessed selected fuel handling operations being performed according to TS and applicable operating procedures from the main control room, refueling cavity inside containment, and the SFP. The inspectors also examined licensee activities to control and track the position of each fuel assembly. The inspectors evaluated the licensees ability to close the containment equipment, personnel, and emergency hatches in a timely manner per procedure 2-MMP-68.02, Containment Closure.

Correction Action Program The inspectors reviewed CRs generated during SL2-19 to evaluate the licensees threshold for initiating CRs. The inspectors reviewed CRs to verify priorities, mode holds, and significance levels were assigned as required. Resolution and implementation of corrective actions of several CRs were also reviewed for completeness. The inspectors routinely reviewed the results of Quality Assurance (QA)daily surveillances of outage activities.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors either reviewed or witnessed the following six surveillance tests to verify that the tests met the TS, the UFSAR, the licensees procedural requirements, and demonstrated the systems were capable of performing their intended safety functions and their operational readiness. In addition, the inspectors evaluated the effect of the testing activities on the plant to ensure that conditions were adequately addressed by the licensee staff and that after completion of the testing activities, equipment was returned to the positions/status required for the system to perform its safety function.

The tests reviewed included one in-service test (IST) surveillance. The inspectors verified that surveillance issues were documented in the CAP.

• 2-OSP-03.01A, 2A HPSI Full Flow Test

• 1-OSP-01.03, Reactor Coolant System (RCS) Inventory Balance

• 1-OSP-21.01C, 1C ICW Pump Code Run

• 2-OSP-59.01B, 2B EDG Monthly Surveillance Test

• 1-OP-0010125A, MV-071A/2A Surveillance Stroke Test (IST)

• 2-OSP-68.02, Local Leak Rate Test of Penetration 7 - Primary Water (CIV)

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP2 Alert and Notification System Testing

a. Inspection Scope

The inspector evaluated the adequacy of licensees methods for testing the Alert and Notification System (ANS) in accordance with Nuclear Regulatory Commission (NRC)

Inspection Procedure 71114, Attachment 02, Alert and Notification System Evaluation.

The applicable planning standard, 10 CFR Part 50.47(b)(5), and its related requirements, 10 CFR Part 50, Appendix E, Section IV.D, were used as reference criteria. The criteria contained in NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, was also used as a reference.

The inspector reviewed various documents that are listed in the Attachment to this report. This inspection activity satisfied one inspection sample for the ANS on a biennial basis.

b. Findings

No findings were identified.

1EP3 Emergency Preparedness Organization Staffing and Augmentation System

a. Inspection Scope

The inspector reviewed the licensees Emergency Response Organization (ERO)augmentation staffing requirements and process for notifying the ERO to ensure the readiness of key staff for responding to an event and timely facility activation. The qualification records of key position ERO personnel were reviewed to ensure all ERO qualifications were current. A sample of problems identified from augmentation drills or system tests performed since the last inspection were reviewed to assess the effectiveness of corrective actions.

The inspection was conducted in accordance with NRC Inspection Procedure 71114, 03, Emergency Response Organization Staffing and Augmentation System. The applicable planning standard, 10 CFR 50.47(b)(2), and its related requirements, 10 CFR 50, Appendix E, were used as reference criteria.

The inspector reviewed various documents that are listed in the Attachment to this report. This inspection activity satisfied one inspection sample for the ERO staffing and augmentation system on a biennial basis.

b. Findings

No findings were identified.

1EP4 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

Since the last NRC inspection of this program area, revision 55 of the Radiological Emergency Response Plan was implemented based on the licensees determination, in accordance with 10 CFR 50.54(q), that the changes resulted in no decrease in the effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. The inspector conducted a sampling review of the Plan changes and implementing procedure changes made between February 2010, and February 2011, to evaluate for potential decreases in effectiveness of the Plan. However, this review was not documented in a Safety Evaluation Report and does not constitute formal NRC approval of the changes.

Therefore, these changes remain subject to future NRC inspection in their entirety.

The inspection was conducted in accordance with NRC Inspection Procedure 71114, 04, Emergency Action Level and Emergency Plan Changes. The applicable planning standard, 10 CFR 50.47(b)(4), and its related requirements, 10 CFR 50, Appendix E, were used as reference criteria.

The inspector reviewed various documents that are listed in the Attachment to this report. This inspection activity satisfied one inspection sample for the emergency action level and emergency plan changes on an annual basis.

b. Findings

No findings were identified.

1EP5 Correction of Emergency Preparedness Weaknesses

a. Inspection Scope

The inspector reviewed the corrective actions identified through the Emergency Preparedness (EP) program to determine the significance of the issues and to determine if repeat problems were occurring. The facilitys self-assessments and audits were reviewed to assess the licensees ability to be self-critical, thus avoiding complacency and degradation of their emergency preparedness program. In addition, the inspector reviewed licensee self-assessments and audits to assess the completeness and effectiveness of all emergency preparedness related corrective actions.

The inspection was conducted in accordance with NRC Inspection Procedure 71114, 05, Correction of Emergency Preparedness Weaknesses. The applicable planning standard, 10 CFR 50.47(b)(14), and its related requirements, 10 CFR 50, Appendix E, were used as reference criteria.

The inspector reviewed various documents that are listed in the Attachment to this report. This inspection activity satisfied one inspection sample for the correction of emergency preparedness weaknesses on a biennial basis.

b. Findings

No findings were identified.

RADIATION SAFETY

(RS)

Cornerstones: Occupational Radiation Safety (OS)

2RS1 Radiological Hazard Assessment and Exposure Controls

a. Inspection Scope

Hazard Assessment and Instructions to workers During facility tours, the inspectors directly observed labeling of radioactive material and postings for radiation areas, high radiation areas (HRAs), and Very High Radiation Areas (VHRAs) in the radiologically controlled area (RCA) of the Unit 2 (U2) containment, Unit 1 (U1) and U2 auxiliary buildings, Independent Spent Fuel Storage Installation (ISFSI) and radioactive waste (radwaste) processing and storage locations. The inspectors directly observed conduct of licensee radiation surveys for selected RCA areas. The inspectors reviewed survey records for several plant areas including surveys for alpha emitters, hot particles, airborne radioactivity, gamma surveys within areas of high dose rate gradients, and pre-job surveys for upcoming tasks. The inspectors also discussed changes to plant operations that could contribute to changing radiological conditions since the last inspection. For selected outage jobs, the inspectors attended pre-job briefings and reviewed radiation work permit (RWP) details to assess communication of radiological control requirements and current radiological conditions to workers.

Hazard Control and Work Practices The inspectors evaluated access barrier effectiveness for selected U1 and U2 Locked High Radiation Area (LHRA) and VHRA locations. Changes to procedural guidance for LHRA and VHRA controls were discussed with health physics (HP) supervisors. Controls and their implementation for storage of irradiated material within the spent fuel pool (SFP) were reviewed and discussed. Established radiological controls (including airborne controls) were evaluated for selected U2 Refueling Outage 19 (SL2-19) tasks including steam generator (S/G)nozzle dams and manways installation and removal, thimble replacement dive operations, Alloy 600 project work, and radiography. Areas where dose rates could change significantly as a result of plant shutdown and refueling operations were also reviewed and discussed.

Occupational workers adherence to selected RWPs and HP technician (HPT)proficiency in providing job coverage were evaluated through direct observations and interviews with licensee staff. Electronic dosimeter (ED) alarm set points and worker stay times were evaluated against area radiation survey results for selected SL2-19 work activities. ED alarm logs were reviewed and worker response to dose and dose rate alarms during selected work activities was evaluated. HPT coverage and actions at the Unit 1 containment access point were reviewed and discussed in detail.

Control of Radioactive Material The inspectors observed surveys of material and personnel being released from the RCA using small article monitor, personnel contamination monitor, and portal monitor instruments. The inspectors discussed equipment sensitivity, alarm setpoints, and release program guidance with licensee staff.

In addition, the inspector reviewed controls for hand surveying large tools and equipment for release from the RCA and the PA. The inspectors compared recent 10 Code of Federal Regulations (CFR) Part 61 results for the Dry Active Waste (DAW) radioactive waste stream with radionuclides used in calibration sources to evaluate the appropriateness and accuracy of release survey instrumentation. The inspectors also reviewed records of leak tests on selected sealed sources and discussed nationally tracked source transactions with licensee staff.

Problem Identification and Resolution Condition Reports (CR) associated with radiological hazard assessment and control were reviewed and assessed. The inspectors evaluated the licensees ability to identify and resolve the issues in accordance with procedure PI-SL-204, Condition Identification and Screening Process, Revision (Rev.) 4. The inspectors also evaluated the scope of the licensees internal audit program and reviewed recent assessment results.

Radiation protection (RP) activities were evaluated against the requirements of Updated Final Safety Analysis Report (UFSAR) Section 12; Technical Specifications (TS)

Sections 6.11, Radiation Protection Program and 6.12, High Radiation Area; 10 CFR Parts 19 and 20; and approved licensee procedures. Licensee programs for monitoring materials and personnel released from the RCA were evaluated against 10 CFR Part 20 and IE Circular 81-07, Control of Radioactively Contaminated Material. Documents reviewed are listed in Section 2RS1 of the Attachment.

The inspectors completed all specified line-items detailed in Inspection Procedure (IP)71124.01 (sample size of 1).

b. Findings

Introduction:

A Green, self-revealing, non-cited violation (NCV) of 10 CFR Part 20.1501(a) was identified for failure to perform adequate surveys in a Waste Gas Decay Tank (WGDT) room prior to allowing workers to enter the area. This resulted in an uncontrolled HRA, with dose rates greater than 100 millirem per hour (mrem/hr), at 30 centimeters (cm), in the 1B WGDT.

Description:

Two Fix-It-Now (FIN) maintenance workers (MM1 and MM2) performed minor maintenance on a valve in the 1B WGDT room on Friday October 1, 2010, with radiological job coverage and access to the area provided by a Radiation Protection Technician (RPT1). No radiation exposure was received while performing the valve repair activity on October 1, 2010. At approximately 3:00 AM on Monday October 4, 2010, the U1 Control Room Operator informed the shift RPT that operations would be venting the Volume Control Tank (VCT) to the WGDT. The shift RPT performed surveys in the hallway outside the WGDT and verified there was no increase in noble gas activity, and that dose rates were less than 2 mrem/hr at the locked WGDT gates.

During the morning of October 4, 2010, MM1, MM2, and RPT1 discussed post maintenance testing required on the valve that had been repaired in the 1B WGDT room on October 1, 2010. The RPT and FIN maintenance workers were unaware of the VCT venting operation that had occurred earlier on the morning on October 4, 2010, and the potential change in radiological conditions in the 1B WGDT room. RPT1 provided the administratively controlled key to the WGDT rooms to the FIN maintenance workers.

MM1 and MM2 signed in on RWP 10-0013 with ED alarm setpoints at 9 mrem dose and 75 mrem/hr dose rate, entered the RCA, and proceeded to the 1B WGDT room. Upon entering the gate, and turning the corner of the shield wall into the 1B WGDT room, MM1 received an ED dose rate alarm. MM1 and MM2 immediately exited the area and contacted RPT1 who instructed them to exit the RCA. Review of the ED history log confirmed that MM1 received a single dose rate alarm of 77.5 mrem/hr. MM2 did not receive an ED alarm because he did not enter the unshielded area of the room. RPT1 performed surveys of the area and found general area dose rates 250 mrem/hr. RPT1 posted the affected areas as a High Radiation Area (HRA) at the WGDT room gate, and requested an independent verification of the posting change as required by procedure.

Analysis:

The inspectors determined that the failure to identify a significant source of radiation, either through visual inspection or through surveys taken prior to or during entry into the 1B WGDT room, was a performance deficiency. This finding is greater than minor because it was associated with the Occupational Radiation Safety Cornerstone attribute of Program and Process (Monitoring and RP Controls) and adversely affects the cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Failure to identify significant sources of radiation could lead to unintended occupational exposures. The finding was evaluated using the Occupational Radiation Safety Significance Determination Process (SDP) and was determined to be of very low safety significance (Green) because it was not related to As Low As Reasonably Achievable (ALARA) Planning and the ability to assess dose was not compromised. In addition, it did not involve overexposure or substantial potential for overexposure because the WGDT room gates are administratively controlled by locking the doors, issuing keys only to RP personnel, and posting the entrance as Radiation Area, Contact RP Prior to Entry. The compensatory action put in place by the licensee was to post and control the entrance gates to all WGDT rooms as a High Radiation Area - Specific RWP Required. The cause of this finding was directly related to the cross-cutting aspect of Conservative Assumptions in the Decision Making component of the Human Performance area because the RPT assumed that radiological conditions in the 1B WGDT room had not changed, even though additional administrative controls were in place due specifically because of the identified potential for changing radiological conditions in the area when venting gas to the WGDT. H.1(b).

Enforcement:

10 CFR Part 20.1501(a) states, in part, Each licensee shall make or cause to be made, surveys that -

(2) Are reasonable under the circumstances to evaluate - (iii) The potential radiological hazards. Contrary to this on October 4, 2010, the licensee failed to perform reasonable surveys to adequately identify potential radiological hazards associated with work in the 1B WGDT room. This resulted in an uncontrolled HRA and a worker ED alarm in the vicinity of the 1B WGDT. Because this violation was of very low significance and was entered into the licensees corrective action program (AR 585076), this violation is being treated as an NCV, consistent with the NRC Enforcement Policy: NCV 05000335/389, 20110002-01, Failure to perform adequate surveys to identify potential radiological hazards during valve repair in the 1B WGDT room.

2RS2 As Low As Reasonably Achievable (ALARA)

a. Inspection Scope

ALARA Program Status The inspectors reviewed and discussed plant exposure history and current trends including the sites three-year rolling average (TYRA) collective exposure history for calendar year (CY) 2007 through CY 2009. Current and proposed activities to manage site collective exposure and trends regarding collective exposure were evaluated through review of previous TYRA collective exposure data and review of the licensees 5-year ALARA program implementing plan. Current ALARA program guidance and recent changes, as applicable, regarding estimating and tracking exposure were discussed and evaluated.

Radiological Work Planning The inspectors reviewed planned work activities and their collective exposure estimates for SL2-19. Work activities, exposure estimates and mitigation activities were reviewed for the following high collective exposure tasks:

reactor head disassembly and re-assembly; U2 containment scaffold installation and removal; thimble dive operations, Alloy 600 project, and S/G nozzle dams and manways installation and removal, and radiography. For the selected tasks, the inspectors reviewed dose mitigation actions and established dose goals. During the inspection, use of remote technologies including teledosimetry and remote visual monitoring were verified as specified in RWP or procedural guidance. Current collective dose data for selected tasks were compared with established estimates and, where applicable, changes to established estimates were discussed with responsible licensee ALARA planning representatives. The inspectors reviewed previous post-job reviews conducted for the SL2-19 and verified that the items were entered into the licensees corrective action program for evaluation.

Verification of Dose Estimates and Exposure Tracking Systems The inspectors reviewed select ALARA work packages and discussed assumptions with responsible planning personal regarding the bases for the current estimates. The licensees on-line RWP cumulative dose data bases used to track and trend current personal and cumulative exposure data and/or to trigger additional ALARA planning activities in accordance with current procedures were reviewed and discussed. Selected work-in-progress reviews for thimble and reactor coolant pump motor replacement project activities and adjustments to cumulative exposure estimate data were evaluated against work scope changes or unanticipated elevated dose rates.

Source Term Reduction and Control The inspectors reviewed historical dose rate trends for shutdown chemistry, cleanup, and resultant chemistry and radiation protection trend-point data against the current SL2-19 data. Licensee actions to mitigate noble gas and iodine exposures resulting from fuel leaks were discussed in detail.

Problem Identification and Resolution The inspectors reviewed and discussed selected CRs associated with ALARA program implementation. The reviewed items included CRs, self-assessments, and quality assurance audit documents. The inspectors evaluated the licensees ability to identify, characterize, prioritize, and resolve the identified issues in accordance with licensee procedure PI-SL-204, Condition Identification and Screening Process, Rev. 4.

The licensees ALARA program activities and results were evaluated against the requirements of UFSAR Section 12; TS Section 6.8.1, Procedures and Programs, 6.11, Radiation Protection Program and 6.12, High Radiation Area; 10 CFR Parts 19 and 20; and approved licensee procedures. Records reviewed are listed in Sections 2RS1 and 2RS2 of the report Attachment.

Radiation worker performance was reviewed as part of observations conducted for IP 71124.01 and is documented in section 2RS1. The inspectors completed all specified line-items detailed in IP 71124.02 (sample size of 1).

b. Findings

No findings were identified.

2RS3 In-Plant Airborne Radioactivity Control and Mitigation

a. Inspection Scope

Plant Airborne Radioactivity Controls and Mitigation The inspectors reviewed the plants UFSAR and current SL2-19 tasks to identify potential airborne radiation areas, and associated ventilation systems and monitoring instrumentation. Selected licensee documents including TS, UFSAR, design basis documents, and procedures associated with plant airborne radioactivity controls and monitoring, and with respiratory protection program implementation were reviewed and discussed with cognizant licensee representatives.

Engineering Controls Licensee engineering controls to control and mitigate airborne radioactivity were reviewed and discussed. The inspectors evaluated engineering controls use for radiation protection purposes, including operation of the U2 Reactor Containment Building (RCB) purge and installation of temporary HEPA systems for selected tasks and operations with the potential for generating airborne activity conditions during the current SL2-19 outage. The evaluation included procedural guidance, operability testing, and established configurations. In addition, plant guidance and its implementation for monitoring beta-gamma and alpha-emitting radionuclides for airborne conditions were reviewed and discussed with licensee representatives.

Use of Respiratory Protection Devices Program guidance for issuance and use of respiratory protection devices were reviewed and discussed with responsible licensee representatives. The inspectors reviewed TEDE-ALARA evaluations conducted for the select SL2-19 tasks including pressurizer and deck plate maintenance activities.

Selected whole-body count routine and investigative (WBC) analysis results for occupational workers were reviewed and discussed. Use of respiratory protective equipment was evaluated for the workers involved in SL2-19 pressurizer, deck plate, and steam generator maintenance activities. The inspectors toured selected onsite compressors available to supply breathing air for current outage activities and verified Grade D air certification for all staged compressors. Training, fit testing, and medical qualifications for selected RP, maintenance, instrument and control (I&C), and operations (OP) staff involved respiratory protection activities for current SL2-19 activities were reviewed and verified. .

Self-Contained Breathing Apparatus (SCBA) for Emergency Use The inspectors verified current status, operability and availability of select SCBA equipment maintained within the firehouse, operations support center, U1 and U2 control rooms, and reactor auxiliary building. Maintenance activities for selected respiratory protective equipment, e.g.,

compressed gas cylinders, regulators, valves, and hose couplings, by certified vendor technicians was verified for selected SCBA units. Training, fit testing, and medical qualifications for selected RP, maintenance, I&C, and Ops staff assigned Emergency Response Organization (ERO) duties were reviewed and verified. For selected Unit 1 and U2 control room operators, the inspectors discussed and verified annual hands-on SCBA training activities including donning, doffing and functionally checking SCBA equipment and availability of corrective lens.

Problem Identification and Resolution The inspectors reviewed selected Corrective Action Program (CAP) documents within the area of radiological airborne controls and respiratory protection activities. The inspectors evaluated the licensees ability to identify and resolve the issues in accordance with Performance Improvement Procedure - PI-SL-204, Condition Identification and Screening Process, Rev. 4. The inspectors also evaluated the scope of the licensees internal audit program and reviewed recent assessment results. Licensee CAP documents reviewed are listed in Section 2RS3 of the report Attachment.

Radiation protection program activities associated with airborne radioactivity monitoring and controls were evaluated against details and requirements documented in the UFSAR Sections 11 and 12; TS Sections 3.6.1.7, Containment Ventilation System, 6.8.1 Procedures and Programs, 6.11, Radiation Protection Program, and 6.8.4 (k), Ventilation Filter Test Program; 10 CFR Part 20; and approved licensee procedures. Records reviewed are listed in Sections 2RS1, 2RS2, and 2RS3.

The inspectors completed all specified line-items detailed in IP 71124.03 (sample size of 1).

b. Findings

No findings were identified.

2RS4 Occupational Dose Assessment

a. Inspection Scope

The inspectors evaluated current RP program activities and results associated with internal and external radiation exposure monitoring of occupational workers. The review included program guidance, equipment and changes, as applicable; quality assurance activities, results, and responses to identified issues; and individual dose results for occupational workers.

External Dosimetry The inspectors reviewed and discussed RP program guidance for monitoring external and internal radiation exposures of occupational workers. The inspectors verified National Voluntary Laboratory Accreditation Program (NVLAP)certification data and discussed program guidance for storage, processing and results for active and passive personnel dosimeters currently in use. Comparisons between direct reading dosimeter (DRD) and thermoluminescent dosimeter (TLD) data were reviewed and discussed.

Internal Dosimetry Program guidance, instrument detection capabilities, and select results for the internally deposited radionuclides were reviewed in detail. The inspectors reviewed routine termination and follow-up in vivo (WBC) analyses, as well as, in vitro bioassays conducted for tritium monitoring for divers in CYs 2009 and 2010. In addition, guidance for collection and conduct of special bioassay sampling were discussed in detail.

Special Dosimetric Situations The inspectors reviewed monitoring conducted and results for special dosimetric situations. The methodology and results of monitoring occupational workers within non-uniform external dose fields were evaluated. In addition, the adequacy of dosimetry program guidance and its implementation were reviewed for shallow dose assessments and calculations for discrete radioactive particle skin contamination events. Neutron monitoring conducted in support of ISFSI loading and transport operations during 2010 was reviewed and discussed. Since there have been no declarations of pregnancy by workers during the last 3 years, the inspectors were unable to review monitoring conducted for declared pregnant workers. However, inspectors reviewed licensee procedures for monitoring declared pregnant workers. In addition, proficiency of RP staff involved in conducting skin dose assessments, neutron monitoring, and WBC equipment operations were evaluated through direct interviews, onsite observations, and review and discussions of completed records and supporting data.

CAP Review The inspectors reviewed and discussed selected CAP documents associated with occupational dose assessment. The reviewed items included Condition Report (CR), self-assessment, and quality assurance audit documents. The inspectors evaluated the licensees ability to identify, characterize, prioritize, and resolve identified issues in accordance with licensee procedure Performance Improvement Procedure -

PI-SL-204, Condition Identification and Screening Process, Rev. 4.

RP program occupational dose assessment guidance and activities were evaluated against the requirements of the UFSAR Section 12; TS Section 6.8.1, Procedures and Programs, 6.11, Radiation Protection Program, and 6.12, High Radiation Area; 10 CFR Parts 19 and 20; and approved licensee procedures. Records reviewed are listed in Section 2RS4 of the Attachment.

The inspectors completed all specified line-items detailed in IP 71124.04 (sample size of

b. Findings

No findings were identified.

2RS5 Radiation Monitoring Instrumentation

a. Inspection Scope

Radiation Monitoring Instrumentation During tours of the auxiliary building, SFP areas, and RCA exit point, the inspectors observed installed radiation detection equipment including the following instrument types: area radiation monitors (ARM), continuous air monitors (CAM), liquid and gaseous effluent monitors, personnel contamination monitors (PCM), small article monitors (SAM), and portal monitors (PM). The inspectors observed the physical location of the components, noted the material condition, and compared sensitivity ranges with UFSAR requirements.

In addition to equipment walk-downs, the inspectors observed source checks and alarm setpoint testing of various portable and fixed detection instruments, including ion chambers, telepoles, PCM, SAM, and PM. For the portable instruments, the inspectors observed the use of a high-range calibrator and discussed periodic output value testing with a radiation protection technician. The inspectors reviewed the last two calibration records and evaluated alarm setpoint values for selected ARM, PCM, PM, SAM, effluent monitors, laboratory counting systems, and WBC systems. This included a sampling of instruments used for post-accident monitoring such as containment high-range ARMs, and effluent monitor high-range noble gas and iodine channels. Radioactive sources used to calibrate selected ARMs and effluent monitors were evaluated for traceability to national standards. Calibration stickers on portable survey instruments and air samplers were noted during inspection of storage areas for Aready-to-use@ equipment. The most recent 10 CFR Part 61 analysis for DAW was reviewed to determine if calibration and check sources are representative of the plant source term. The inspectors also reviewed countroom quality assurance records for alpha and gamma ray spectroscopy equipment.

Effectiveness and reliability of selected radiation detection instruments were reviewed against details documented in the following: 10 CFR Part 20; NUREG-0737, Clarification of TMI Action Plan Requirements; TS Section 3/4.3.3; UFSAR Chapters 11 and 12; and applicable licensee procedures. Documents reviewed during the inspection are listed in section 2RS5 of the report Attachment.

Problem Identification and Resolution The inspectors reviewed and discussed selected Corrective Action Program (CAP) documents associated with radiological instrumentation. The reviewed items included CRs, self-assessment, and quality assurance audit documents. The inspectors evaluated the licensees ability to identify, characterize, prioritize, and resolve identified issues in accordance with licensee procedure Performance Improvement Procedure - PI-SL-204, Condition Identification and Screening Process, Rev. 4. Documents reviewed are listed in section 2RS5 of the to this report.

The inspectors completed 1 sample as required by IP 71124.05 (sample size of 1).

b. Findings

No findings were identified.

4OA1 Performance Indicator Verification

.1 Initiating Events and Mitigating Systems Cornerstones

a. Inspection Scope

The inspectors checked licensee submittals for the performance indicators (PIs) listed below for the period January 1, 2010, thru December 31, 2010, to verify the accuracy of the PI data reported during that period. Performance indicator definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, and licensee procedures ADM-25.02, NRC Performance Indicators, and NAP-206, NRC Performance Indicators, were used to check the reporting for each data element. The inspectors checked operator logs, plant status reports, condition reports, system health reports, and PI data sheets to verify that the licensee had identified the required data, as applicable. The inspectors interviewed licensee personnel associated with performance indicator data collection, evaluation, and distribution.

• Unit 1 Unplanned Scrams per 7000 Critical Hours

• Unit 2 Unplanned Scrams per 7000 Critical Hours

• Unit 1 Unplanned Scrams With Complications

• Unit 2 Unplanned Scrams With Complications

• Unit 1 Unplanned Power Changes per 7000 Critical Hours

• Unit 2 Unplanned Power Changes per 7000 Critical Hours

b. Findings

No findings were identified.

.2 Emergency Preparedness Cornerstone

a. Inspection Scope

The inspector sampled licensee submittals relative to the Performance Indicators (PIs)listed below for the period January 1, 2010, and December 31, 2010. To verify the accuracy of the PI data reported during that period, PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, was used to confirm the reporting basis for each data element.

• Emergency Response Organization Drill/Exercise Performance (DEP)

• Emergency Response Organization Readiness (ERO)

• Alert and Notification System Reliability (ANS)

The inspection was conducted in accordance with NRC IP 71151, Performance Indicator Verification. For the specified review period, the inspector examined data reported to the NRC, procedural guidance for reporting PI information, and records used by the licensee to identify potential PI occurrences. The inspector verified the accuracy of the PI for ERO drill and exercise performance through review of a sample of drill and event records. The inspector reviewed selected training records to verify the accuracy of the PI for ERO drill participation for personnel assigned to key positions in the ERO.

The inspector verified the accuracy of the PI for alert and notification system reliability through review of a sample of the licensees records of periodic system tests. The inspector also interviewed the licensee personnel who were responsible for collecting and evaluating the PI data. Licensee procedures, records, and other documents reviewed within this inspection area are listed in the Attachment to this report.

This inspection activity satisfied one inspection sample each for the Drill/Exercise Performance, ERO Drill Participation, and Alert and Notification System as defined in IP 71151-05.

b. Findings

No findings were identified.

.3 Radiation Safety Cornerstones

a. Inspection Scope

The inspectors sampled licensee data for the PIs listed below. To verify the accuracy of the PI data reported during the period reviewed, PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Indicator Guideline, Rev. 4, were used to verify the basis for each data element.

Occupational Radiation Safety Cornerstone The inspectors reviewed the Occupational Exposure Control Effectiveness PI results for the ORS Cornerstone from July to December 2010. For the assessment period, the inspectors reviewed ED alarm logs and selected CRs related to controls for exposure significant areas. The inspectors also reviewed licensee procedural guidance for collecting and documenting PI data. Documents reviewed are listed in sections 2RS1 and 4OA1 of the report Attachment.

Public Radiation Safety (PS) Cornerstone The inspectors reviewed the Radiological Effluent Technical Specification/Offsite Dose Calculation Manual Radiological Effluent Occurrences PI results from July to December 2010. The inspectors reviewed CRs, effluent dose data, and licensee procedural guidance for classifying and reporting PI events. The inspectors also interviewed licensee personnel responsible for collecting and reporting the PI data. Reviewed documents are listed in Section 4OA1 of the Attachment.

The inspectors completed 2 of the required 2 samples for IP 71151.

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems

.1 Daily Review

a. Inspection Scope

As required by Inspection Procedure 71152, Identification and Resolution of Problems, and to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a screening of items entered daily into the licensees CAP. This review was accomplished by reviewing daily printed summaries of CRs and by reviewing the licensees electronic CR database. Additionally, reactor coolant system unidentified leakage was checked on a daily basis to verify no substantive or unexplained changes.

b. Findings

No findings were identified.

.2 Annual Sample Root Cause Evaluation Associated With the Unit 1 Manual Reactor Trip

Due to Two Dropped Control Element Assemblies (CEAs)

a. Inspection Scope

The inspectors selected AR 403655, Unit 1 Reactor Trip, specifically, Root Cause Evaluation for Unit 1 CEAs 38 and 65 Drops During Plant Startup, for a more in-depth review of the circumstances and the corrective actions that followed.

The inspectors reviewed the licensees evaluation of the event and the associated corrective actions. The inspectors interviewed plant personnel and evaluated the licensees administration of this selected condition report in accordance with their CAP as specified in licensee procedures PI-AA-204, Condition Identification and Screening Process, and PI-AA-205, Condition Evaluation and Corrective Actions.

b. Findings

No findings were identified.

.3 Operating Experience Smart Sample (OpESS) FY 2010-01, Recent Inspection

Experience for Components Installed Beyond Vendor Recommended Service Life

a. Inspection Scope

The inspectors used the guidance provided in OpESS 2010-01 in conducting a baseline inspection of the licensees Preventive Maintenance (PM) Program activities. The inspectors sampled the licensees PM program associated with reactor plant safety related control relays used in both Unit 1 and Unit 2. The inspectors reviewed licensee procedures 0010431, Preventive maintenance Program and ER-AA-204, Preventive Maintenance Program Strategy to determine if the procedures provided adequate information and instructions on maintaining equipment in accordance with vendor recommendations. The inspectors reviewed the licensee bases for PM frequencies of safety related relays and their technical information that justified the required PM frequencies compared to vendor recommendations. The inspectors reviewed the licensees corrective action program data base for past equipment failures to determine if corrective actions were in place that addressed PM frequencies to prevent recurrence based on vendor recommended service life.

b. Findings

No findings were identified.

4OA3 Event Follow-up

.1 (Closed) Licensee Event Report (LER) 05000389/2010002-00, Unit 2 Manual Reactor

Trip Due to Moisture Separator Re-heater (MSR) Safety Valve Lift On April 15, 2010, the licensee performed a manual reactor trip of Unit 2 due to the 2B MSR relief valve opening unexpectedly. The licensee initially performed a rapid down power evolution followed by a reactor trip. All systems responded as designed and the trip was uncomplicated. The cause of the MSR safety valve lifting prematurely was due to a broken spring in the valves pilot actuator. The licensee determined that the failure mechanism of the spring was due to corrosion and embrittlement of the high strength alloy steel. The licensee also determined that a contributing cause was not performing periodic inspections of the pilot valve springs during periodic maintenance. The LER was reviewed by the inspectors and no findings of significance were identified and no violations of NRC requirements occurred. The corrective actions taken by the licensee included replacing all eight MSR safety valve pilot actuator springs with new springs and performing successful pressure lift set point testing. The licensee documented this event in CR 2010-9924. This LER is closed.

.2 (Closed) LER 05000335, 389/2010-003, Unanalyzed Condition Resulting From

Alignment of Non-Essential CCW Header Under Certain Accident Scenarios In August 2009 the NRC Component Design Basis Inspection (CDBI) team opened as Unresolved Item (URI) 05000335, 389/2009006-04, Inadequate Procedure for Restoration of Non-Essential CCW Flow Following a SIAS. Subsequently, on May 5, 2010, the licensee validated the plant analysis and determined that re-alignment of the non-essential CCW header following a large break loss of coolant accident (LBLOCA)for Unit 2 could result in an unanalyzed condition that significantly degraded plant safety.

Also, realignment of the non-essential CCW header following a LBLOCA, both Units 1 and 2 could result in the failure of two or more trains in different systems (e.g., high pressure safety injection and containment spray) from properly completing their safety function if a failure was to occur on the non-essential CCW header. The cause of the event was determined to be an inadequate emergency operating procedure (EOP)review. Corrective actions included revisions to EOPs to preclude alignment of the non-essential CCW header to the essential CCW header, and issuance of a standing order providing guidance to the operating crews.

The URI was closed and dispositioned as Non-Cited Violation (NCV) 05000335, 389/2010-004-003. The licensee documented this issue in their corrective action program as CR 2009-22623. The inspectors reviewed the LER and no additional findings of significance were identified. This LER is closed.

.3 (Closed) LER 05000335/2010-006, Unit 1 Manual Reactor Trip Due To Two Dropped

Control Rods This LER documented a manual reactor trip that was initiated due to the control element drive mechanism (CEDM) system not effectively maintaining two control element assemblies (CEAs) in the withdrawn and aligned position. The root cause of the dropped rods was that the rod control network snubber capacitors for CEDM # 38 and 65 failed, causing a phase to phase short circuit de-energizing the CEDM hold circuit. In addition, the licensee determined that an additional cause was that the procurement engineering program did not require a review of prints and specification documents when purchasing replacement parts, which resulted in the procurement of different style capacitors in 1997 that were susceptible to breakdown in high humidity environments.

Corrective actions included replacement of the under-rated network capacitors previously replaced with a newer designed capacitor more compatible with the expected environmental conditions in the cable spreading room area on all CEDMs normally energized upper gripper power switches and the lower gripper lift and load transfer power switches for the lead group CEDMs.

The inspectors reviewed the LER and determined that during the period of 1997 through August 12, 2010, a non-controlled and non-reviewed guideline was used for performing the rebuilding of the power switches and part required. These incorrect snubber capacitors are quality-related components and were purchased in 1997. The inspectors determined that a new procedure, 1-PMI-66.15, Unit Power Switch Refurbishment and Testing, was developed to provide instructions for refurbishing, testing, and parts information for power switches. No findings of significance were identified. The inspectors determined that neither the procurement engineering program nor procedural requirements required a review of prints and specification documents when purchasing replacement quality-related parts in 1997. Therefore, no findings of significance were identified. This LER is closed.

4OA5 Other Activities

.1 Quarterly Resident Inspector Observations of Security Personnel and Activities

a. Inspection Scope

During the inspection period the inspectors conducted observations of security force personnel activities to ensure that the activities were consistent with the licensee security procedures and regulatory requirements relating to nuclear plant security.

These observations took place during both normal and off-normal plant working hours.

These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors normal plant status reviews and inspection activities.

b. Findings

No findings were identified.

.2 (Closed) TI 2515/179 Verification of Licensee Responses to NRC Requirement for

Inventories of Materials Tracked in the National Source Tracking System (NSTS) Pursuant to Title 10, Code of Federal Regulations, Part 20.2207 (10 CFR 20.2207)

a. Scope

The inspectors performed the TI concurrent with IP 71124.01 Radiation Hazard

Analysis.

The inspectors reviewed the licensees source inventory records and identified the sources that met the criteria for reporting to the NSTS. The inspectors visually identified the sources contained in various calibration systems and verified the presence of the source by direct radiation measurement using a calibrated portable radiation detection survey instrument. The inspectors reviewed the physical condition of the irradiation device. The inspectors reviewed the licensees procedures for source receipt, maintenance, transfer, reporting and disposal. The inspectors reviewed documentation that was used to report the sources to the NSTS. Documents reviewed are listed in sections 2RS1 of the Attachment.

b. Findings

There were no findings. This completes the Region II inspection requirements.

.3 Emergency Core Cooling System (ECCS) Watertight Doors

a. Inspection Scope

After further inspection related to a 4th Quarter Division of Reactor Safety engineering inspection, the inspectors determined a violation of NRC regulations occurred and is now being documented in this report.

b. Findings

Introduction:

The inspectors identified a Green, non-cited violation of Technical Specification (TS) 6.8.1, which requires that written procedures be established, implemented, and maintained covering the activities in NRC Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), Appendix A, for the licensees failure to follow posted and published guidelines per ADM-17.25, Plant Barrier Control and 0-NOP-99.02, Watchstation General Inspection Guidelines, Rev. 13A.

Description:

During a walkdown of the Emergency Core Cooling System (ECCS) Pump rooms, the inspectors identified that only one out of the required eight dog latch assemblies on the Unit 1 High Pressure Safety Injection (HPSI) Pump room watertight doors had been fully secured. Subsequent walkdowns were conducted on both units to verify the dog latch position on the remaining Reactor Auxiliary Building (RAB) Doors.

During these additional walkdowns, the inspectors observed that over half the population of RAB doors had less than the required eight dog latches secured as required by procedures ADM-17.25, Plant Barrier Control, and 0-NOP-99.02, Watchstation General Inspection Guidelines, Rev. 13A. Guidance was also posted on the doors front as a corrective action to a similar issue identified by the NRC in 1997. As referenced in Condition Report 96-1970, the licensees policy specifically states, Subject doors shall continue to be closed with all latches secured.

The design functions of the watertight doors are to provide:

• Structural/seismic Support - to ensure that the door does not create any potential adverse interaction with adjacent safety-related equipment

• Controlled Air Leakage - to ensure that the ECCS exhaust fans can maintain a slightly negative pressure in the ECCS pump rooms

• Controlled Water Leakage - to ensure that the assumptions in the flooding analyses are valid

• Fire Protection - the walls in which the doors are located are fire area boundary walls.

Of the four design functions listed above, the function of controlling air leakage was determined by the licensee to be the most limiting function. The ECCS ventilation system performs two TS safety functions: providing cooling air for the ECCS equipment; and removal of particulate and iodine from the room during post accident conditions.

With any one of the ECCS area boundary doors open for longer than its normal entry/exit usage, operability of the ECCS ventilation system is affected. Therefore, not fully securing the RAB doors could degrade the doors design function and potentially have a negative impact on the capability of the ECCS ventilation system to perform its safety function.

Upon being questioned by the inspectors, the licensee was not able to provide the design requirement or calculation of record regarding the number of latched dogs required to maintain the doors safety function. The licensee solely relied on procedures ADM-17.25, Plant Barrier Control, and 0-NOP-99.02, Watchstation General Inspection Guidelines, Rev. 13A, which required all eight dog latches to be secured at all times.

Upon identification, the licensee performed a technical assessment (AR 590273) of the adverse condition. The licensee also developed and performed surveillance testing of both the Unit 1 and Unit 2 ECCS rooms, in which HVE-9A was run with RAB door RA-5 secured with only one dog latch to establish the design test of record to maintain operability. The results, of both the technical assessment and surveillance, confirmed that doors remained functional and the ECCS ventilation system remained operable during the time in which this adverse condition existed. As an immediate compensatory action, the licensee issued correspondence to plant personnel, as well as reinforced to the security staff, instructions for fire watch patrols to ensure that each dog latch on the RAB watertight doors are properly secured.

The team noted that the licensees testing only confirmed the functionality of a single dog on door RA-5. If any of the non-tested latches on door RA-5 were postulated to be degraded, the door would not have been capable of performing its safety function.

Analysis:

The licensees failure to follow posted and published guidelines per ADM-17.25, Plant Barrier Control, and 0-NOP-99.02, Watchstation General Inspection Guidelines, Rev. 13A, is a performance deficiency. The finding was determined to be of more than minor significance because it affected the mitigating systems cornerstone attribute of equipment performance to ensure the availability and reliability of the ECCS ventilation system to perform its intended safety function during a design basis event; and closely parallels IMC 0612, Appendix E, Example 3.j, in that there was reasonable doubt regarding the capability of the system to perform its intended function pending reanalysis (i.e. testing). Specifically, not fully securing the RAB doors via the dog latches could adversely affect the operability of the ECCS ventilation system to perform its safety functions. The inspectors evaluated the risk of this finding using IMC 0609, Significance Determination Process, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings. The inspectors determined that the finding was of very low safety significance because it did not result in an actual loss of operability to the ECCS ventilation system. The finding involved the cross-cutting area of human performance, the component of work practices and the aspect of human prevention techniques and peer checking (H.4.a), in that, the licensee failed to practice their human prevention techniques specifically, peer checking to ensure that personnel followed procedures and postings which required the RAB doors to be completely dogged closed.

Enforcement:

TS 6.8.1, states that written procedures shall be established, implemented, and maintained covering the locking and tagging activities in Appendix A of Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation),

Revision 2. Contrary to the above, the licensee failed to implement administrative procedures that provide assurance that equipment with a safety-related function was controlled as required. Specifically, the licensee failed to implement procedures ADM-17.25, Plant Barrier Control, and 0-NOP-99.02, Watchstation General Inspection Guidelines, that ensure RAB doors are controlled (i.e. latched) in locked configuration to ensure the operability of the ECCS ventilation system. Because the licensee entered the issue into their corrective action program as AR 590521 and the finding is of very low safety significance (Green), this violation is being treated as an NCV, consistent with the Section 2.3.2 of the NRC Enforcement Policy (NCV 05000335, 389/2011002-02, Failure to Follow Procedures and Guidelines to Ensure RAB Doors are Completely Dogged Closed).

4OA6 Meetings

Exit Meeting Summary

The resident inspectors presented the inspection results to Mr. Anderson and other members of licensee management on March 31, 2011. The inspectors asked the licensee whether any of the material examined during the inspection should be considered proprietary information. The licensee did not identify any proprietary information.

Exit meetings were conducted with licensee management for the ISI portion on January 14, 2011 and for the SGISI portion on January 28, 2011. The licensee did not identify any material provided to the inspector to be proprietary.

On February 11, 2011, the inspectors discussed preliminary results of the onsite radiation protection inspection with Mr. R. Anderson, Site Vice President, and other responsible staff. The inspectors noted that proprietary information was reviewed during the course of the inspection but would not be included in the documented report.

On February 18, 2011, the lead inspector for the EP inspection presented the inspection results to Mr. R. Anderson and other members of licensee management. The inspector confirmed that proprietary information was not provided or examined during the inspection.

ATTACHMENT: SUPPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Licensee personnel:

R. Anderson, Site Vice President E. Belizar, Projects Manager M. Bladek, Assistant Operations Manager E. Burgos, Acting Chemistry Manager D. Calabrese, Emergency Preparedness Manager D. Cecchett, Licensing Engineer J. Connor, Engineering Manager - Programs B. Hughes, Plant General Manager M. Haskins, Maintenance Manager S. Duston, Training Manager K. Frehafer, Licensing Engineer R. Filipek, Design Engineering Manager D. Hanley, Maintenance Programs Supervisor M. Hicks, Site Excellence Manager R. Lingle, Operations Manager D. Huey, Work Control Manager T. Horton, Assistant Operations Manger J. Kramer, Site Safety Manager R. McDaniel, Fire Protection Supervisor C. Martin, Radiation Protection Manager J. Hamm, Engineering Manager R. Boorman, System Engineer J. Danek, Corporate Health Physicist E. Katzman, Licensing Manager C. Martin, Radiation Protection (RP) Manager K. Mooring, ALARA Supervisor, RP J. Owens, Performance Improvement Department B. Robinson, Supervisor - Technical, RP M. Snyder, Site Quality Assurance Manager G. Swider, Component Engineering Manager T. Young, Security Manager S. Boggs, FPL Welding Engineer B. Moss, BACCP Manager T. Coste, Repair and Replacement Program Manager G. Boyers, SG ISI Lead R. Mothena, Functional Area Manager, Emergency Preparedness R. Sandford, Emergency Preparedness staff R. Young, Emergency Preparedness Staff J. Moody, Emergency Preparedness Staff F. Blake, Emergency Preparedness Staff NRC personnel:

D. Rich, Chief, Branch 3, Division of Reactor Projects S. Ninh, Senior Project Engineer, Division of Reactor Projects LIST OF ITEMS OPENED, CLOSED AND DISCUSSED Opened and Closed 05000335/389, 20110002-01 NCV Failure to perform adequate surveys to identify potential radiological hazards during valve repair in the 1B WGDT room (Section 2RS1)05000335/389, 2011002-02 NCV Failure to Follow Procedures and Guidelines to ensure RAB Doors are Completely Dogged Closed (Section 4OA5)

Closed 05000389/2010002-00 LER Unit 2 Manual Reactor Trip Due to Moisture Separator Re-heater (MSR) Safety Valve Lift (Section 4OA3)05000335/389, 2010003-00 LER Unanalyzed Condition Resulting From Alignment of Non-essential CCW Header Under Certain Accident Scenarios (Section 4OA3)05000335/389, 2009006-04 URI Inadequate Procedure for Restoration of Non-essential CCW Flow Following SIAS (Section 4OA3)05000335/2010006-00 LER Unit 1 Manual Trip Due to Two Dropped Control Rods (Section 4OA3)

Discussed None LIST OF

DOCUMENTS REVIEWED

Procedures

PI-SL-204, Condition Identification and Screening Process, dated 1/4/11

ER-AA-204, Preventive Maintenance Program Strategy, dated 4/8/10

0010431, Preventive Maintenance Program, dated 2/1711

03-1275284, Field Procedure for Remote Rolled Plugging Utilizing the SAP Box, Revision 17

0-COP-06.05, Chemistry Operating Procedure - High Activity in a Steam Generator,

Revision 16A

3.3-001, Liquid Penetrant Examination Data Sheet, dated 1-12-2011

3.3-002, Liquid Penetrant Examination Data Sheet, dated 1-12-2011

51-9101356-001, St. Lucie (PSL) Unit 2 Eddy Current Data Analysis Guidelines, January

2011

54-ISI-24-31, Written Practice for Personnel Qualification in Eddy Current Examination, July

8, 2008

54-ISI-400-19, Multi-Frequency Eddy Current Examination of Tubing, Revision 19

ADM-29.03, Boric Acid Corrosion Control Program, Rev. 8

NDE 3.3, Liquid Penetrant Examination Solvent Removable Visible Dye Technique, Rev. 11

NDE 4.3, Visual Examination VT-3, Rev. 11

NDE 5.4, Ultrasonic Examination of Austenitic Piping Welds, Rev. 19

Nuclear Policy Procedure NP-910, Plant Readiness for Operations

St. Lucie Nuclear Oversight Report PSL-09-064, Fire Protection Audit

St. Lucie Daily Quality Summaries

Health Physics Procedure HPP-4, Scheduling of Health Physics Activities

Operations Department Policy OPS-119, Standing Orders/Night Orders

St. Lucie Radiation Protection Department Night Order, 2009-023

EPG-01, Emergency Preparedness Assessment and Performance Monitoring St. Lucie

Plant, Rev. 8

ADM-25.02, NRC Performance Indicators St. Lucie Plant, Rev. 23B

EPIP-01, Classification of Emergencies, Rev. 17

EPIP-08, Off-Site Notifications and Protective Action Recommendations, Rev. 24

ADM-07.04, Corrective Action Program Requirements, Revision 3

PI-AA-01, Corrective Action Program and Condition Reporting, Rev. 3

PI-SL-204, Condition Identification and Screening Process, Rev. 5

PI-SL-205, Condition Evaluation and Corrective Action, Rev. 3

ADM-17.09, Invoking 10CFR50.54(x), Rev. 4

2-EOP-03, Loss of Coolant Accident, Rev. 28

EPG-03, Review and Revision of Emergency Preparedness Documents, Rev. 3

ADM-17.25, Plan and Barrier Control, Rev 4

0-NOP-99.02, Watchstation General Inspection Guidelines, Rev. 13A

Other

Documentation of DEP opportunities: 1st, 2nd, 3rd, and 4th Quarters 2010

Drill and exercise participation records of ERO personnel, 1st, 2nd, 3rd, and 4th Quarters 2010

Siren testing data 1st, 2nd, 3rd, and 4th Quarters 2010

- 9149262 - 000, St Lucie Unit 2 EOC18 (SL2-19) ECT Inspection Plan, Revision 0

51-5001223-00, Appendix H Equivalency Cable Lengths, Revision 0

51-5002881-00, Appendix H Equivalency, MRPC Exams Probe Extensions, Cable Lengths,

and Motor Unit Length, Revision 0

51-5012000-00, Bobbin Probe Fill Factor Equivalency, Revision 0

51-5014354-00, Eddy Current Probe Extension Cable Comparison, Revision 0

51-5024836, Appendix H Equivalency, Plus Point Exam With Extensions, Revision 0

51-5031780-00, Title Appendix H Equivalency of +Point' Coils PP11A vs. PP14A

Manufactured by Zetec, Inc., Revision 0

AREVA Certificate of Conformance (304 Stainless Steel Cal Block, S/N 10863), dated 12-12-

Areva Data Analysis Training Industry Events, Dated January 10, 2011

Calibration Standard Specification Drawings for Cal Standard Z-22623, Z-22629, Z-22624,

and Z-22594

Certificate of Authenticity for Areva NP - Saint Lucie Unit 2, January 4, 2011

Certificate of Authenticity for Areva NP - Saint Lucie Unit 2, January 14, 2011

Certificate of Calibration for Eddy Current Tester Miz-80(iD), Control Numbers: VH-10374,

VH-10380, VH-10388, VH-10390, VH-10391, VH-10392, VH-10397, VH-10401, VH-10564,

and VH-10588

Certificate of Conformance for EC Probes - Shipment ID: 6194

Certification Records for 13 Qualified Data Analysts

Engineering Information Record: Document No.: 51 - 9101361 - 001, Qualified Eddy Current

Examination Techniques for St. Lucie (PSL) Unit 2, Spring 2011

Examination Technique Specification Sheet PSL 2 ETSS # 1, Bobbin: Standard ASME Code

Examination, Revision 0

Examination Technique Specification Sheet PSL 2 ETSS # 2, MRPC: TTS and Special

Interest, Revision 0

Examination Technique Specification Sheet PSL 2 ETSS # 3, Low Row U-bend MR +Point'

Exam & Special Interest, Revision 0

FPL Temperature Indicator Calibration Form (263115), dated 05/19/11

FPL Visual Examination Record VT3 Mechanical and Welded Attachments (407150), dated

1-12-2011

January 2011 PSL 2 Steam Generator Eddy Current Examination Data Analysis Guideline

Training Attendance Roster

Krautkramer Transducer Certificate of Conformity (01FKLD), dated 06/14/2006

Krautkramer Transducer Certificate of Conformity (SB0050), dated 10/24/2007

Krautkramer Transducer Certificate of Conformity (SC1023), dated 9/15/2009

Krautkramer Transducer Certification (SC0138), dated 1/11/2008

L-2006-272, Supplemental Response to Generic Letter 2006-03, dated December 19, 2006

Letter from Russell

C. Cipolla, APTECH Project Engineer, to Gary Boyers, FP&L, dated

01/26/2011.

LMT, Inc. Certification of Visual Acuity and Color Vision (Block), dated 6-11-10

LMT, Inc. Certification of Visual Acuity and Color Vision (Block), dated 5-6-2010

LMT, Inc. Certification of Visual Acuity and Color Vision (Kilpela), dated 1-5-11

LMT, Inc. Certification of Visual Acuity and Color Vision (Timm), dated 04/15/2010

LMT, Inc. Certification of Visual Acuity and Color Vision (Welch), dated 9/15/10

LMT, Inc. Personnel Certification Statement (Block), dated 10/18/2010

LMT, Inc. Personnel Certification Statement (Currao), dated 01/05/2011

LMT, Inc. Personnel Certification Statement (Kilpela), dated 08/25/2010

LMT, Inc. Personnel Certification Statement (Timm), dated 08/11/2010

LMT, Inc. Personnel Certification Statement (Welch), dated 10/18/2010

MAGNAFLUX Certificate of Compliance: Spotcheck Cleaner/Remover, dated 11/30/04

MAGNAFLUX Certificate of Compliance: Spotcheck Developer, dated 11/30/04

MAGNAFLUX Certificate of Compliance: Spotcheck Penetrant, dated 10/09/07

PSL 2 (EOC-18) - SG Eddy Current Data Analysis Training, January, 2011

PSL-ENG-SESJ-09-048, Condition Monitoring and Operational Assessment for the St. Lucie

Plant Unit 2 Steam Generators based on Eddy Current Examination End of Cycle 17, May

2009, Revision 0

PSL-ENG-SESJ-10-003, Degradation Assessment for the St. Lucie Plant Unit 2 Steam

Generators Update for End of Cycle 18 Refueling Outage, Revision 0

SG 2B Tube Plugging Reports and Data for EOC 18

Site Specific Performance Demonstration Training Records for 13 Qualified Data Analysts

WO 33008835, Repair/Rebuild HCV-3615, MOV for LPSI Feed to Containment Loop 2A2,

Rev. 0

WO 39019244, Replace MV-07-4, Containment Spray Header Isolation Valve, Rev. 0

WPS-11, Welding Procedure Specification, Rev. 11

WPS-24, Welding Procedure Specification, Rev. 5

WPS-43, Welding Procedure Specification, Rev. 11

EPIP-03, Emergency Response Organization Notification/Staff Augmentation, Rev. 16

EPIP-04, Activation and Operation of the Technical Support Center, Rev. 29

EPIP-05, Activation and Operation of the Operational Support Center, Rev. 26

EPIP-06, Activation and Operation of the Emergency Operations Facility, Rev. 2

EPIP-12, Maintaining Emergency Preparedness - Radiological Emergency Plan Training

St. Lucie Plant, Rev. 22

HP-203, Personnel Access Control During Emergencies, Rev. 22A

Federal Emergency Management Agency Approval (FEMA-43 Report)

EP-SR-102-1000, Nuclear Division Florida Alert and Notification System Guideline Nuclear

Fleet, Rev. 4

NPSS-EP-WP-001, Public Alert Notification System Testing, Maintenance, and Engineering,

Rev. 2

Transmission and Substation Siren System Availability Test Procedure No. 06.80.01, Rev. K

Transmission and Substation Siren Maintenance Procedure No. 06.80.02, Rev. G

Condition Reports

01614276 01611576 01611670 01612099 01607523

01614342 01611603 01612512 01609621 01607915

01613555 01611623 01612505 01607961 01607914

01608092 01608184 01608237 01607135 01608025

01606387 01607368 01607123 01607136 01606454

01617549 01617032 01605608 01605153 01605891

01615836 01617013 01617050 01617054 01617084

01614918 01616294 01615407 01615530 01614891

01614932 01624186 01622520 01622381 01621226

01620081 01620689 01619887 01619539 01621235

01625126 01630145 01629748 01629460 01628950

01629027 01628883 01627446 01625306

Other Corrective Action Documentation

00465313, Foreign Material Discovered in 2B Steam Generator

00465570, Steam Generator Secondary Manway Stud Tensioning

00469166, 1A2 RCP Seal Leak During Shutdown

00469166, 1A2 RCP Seal Leak during Shutdown

00471499, Accessibility of BACC Program Leak List

00472507, V3845 Vibration Restraint Corroded by Boric Acid

00472507, V3845 Vibration Restraint Corroded by Boric Acid

00476554, SL1-23 BACC Mitigation Effectiveness

00485306, Steam Generator Tubing Eddy Current Inspection

00524597, Foreign Object Identified within SG 2A Tube Bundle

00560861, NRC Information Notice 2010-007

01600495, V15349 Significant Boric Acid Corrosion

01600495, V15349 Significant Boric Acid Corrosion

01607349, Significant Accumulation of Dry Boric Acid on RCP Bolting

01607728, Loose Vanes on Drum-Type Air Outlet

01607963, Polar Crane Capacity Rating Markings Not OSHA Compliant

01608625, Fire Wrap Material Not Accounted For in Sump Debris Calculation

01612483, St Lucie Unit 2 Steam Generator AVB Transition Row Issues

2007-39350, NRC Information Notice 2007-37

2009-11082, Active Boric Acid Leak V2326, Safety Relief Valve for 2C Charging Pump,

dated 8-18-09

2009-12716, Engineering Evaluation: Potential RCS Leak from ICI #4, dated 5/29/09

2010-3252, NRC Information Notice 2010-05

2010-9068, Interim Guidance Regarding Steam Generator Management Program

Vendor CRs 2011-489, -289, -296, -435, -439, and -445

CR 01621043, Potential for Audit Program Gaps

CR 01620115, Action to Track UFSAR for Steam Line Radiation Monitors UPS Missed

CR 01621137, Update 10CFR50.54(x) Training

CR 01621160, EP Inspection Deficiencies Rollup

CR 20094172, 10CFR50.54(t) audit interface compliance

CR 20094199, 10CFR50.54(x) implementation understanding

CR 200928844, 10CFR50.54(x) implementation understanding

CR 201005052, 10CFR50.54(x) implementation understanding

CR 2010473006, Review Dose Assessment Processes

CR 2010575058, EPIPs Not Fully Maintained in Emergency Response Facilities

CR 2010575772, 50.54q Evaluation Not Done on Chemistry Procedure

CR 2010585897, Non-conservative EAL on Steam Generator Tube Rupture

CR 01620425, E-Plan Appendix Administrative Error

CR 01620950, Two Hour Dose Assessment Forecast Needs Technical Basis Document

CR 01617981, lapsed respirator and SCBA training

CR 01619788, expired training for TSC EC Assistant

CR 01619961, Learning Management System does not support automatic tracking of

respirator qualifications

Audits and Self-Assessments

PSL-09-048, 2009 Emergency Preparedness Audit, August 3 - August 18, 2009

PSL-10-029, Nuclear Oversight Report - Emergency Preparedness, July 7 - August 17, 2010

Self-Assessment Report SA 2010-210

2010 EP Self Assessment Assignment Report

2010 Emergency Preparedness Evaluated Exercise Report

2010 4th Quarter Emergency Preparedness Drill Report

2009 4th Quarter Emergency Preparedness Drill

Records and Change Packages

Emergency Plan, Rev. 55

EPIP-01, Classification of Emergencies, Rev. 16, and 17

EPIP-03, Emergency Response Organization Notification/Staff Augmentation St. Lucie Plant,

Rev. 15 and16

EPIP-07, Conduct of Evacuations/Assembly, Rev. 7, and 8

EPIP-08, Off-site Notifications and Protective Action Recommendations, Rev. 23, and 24

EPIP-10, Off-Site Radiological Monitoring, Rev. 14, and 15

EPIP-12, Maintaining Emergency Preparedness - Radiological Emergency Plan Training,

Rev. 21 and 22

0-COP-06.06, Guidelines for Collecting Post Accident Samples, Revision 7, 8, and 9

Records and Data

Current ERO Roster

ERO Training Records

03/26/09 after hours phone test

06/25/09 after hours phone test

09/24/09 after hours phone test

2/15/09 after hours phone test

03/04/10 after hours phone test

06/23/10 after hours phone test

10/17/2010 after hours phone test

10/27/2010 after hours augmentation demonstration

2009 St. Lucie Siren System Availability

2010 St. Lucie Siren System Availability

2009 Safety Planning Information Mailer

2010 Safety Planning Information Mailer

Section 2RS1: Radiological Hazard Assessment and Exposure Controls

Procedures, Guidance Documents, and Manuals

ADM-05.02, HP Controls of Spent Fuel Pool Non-SNM, Rev. 3

HP-43, Control Inventory and Leak Testing of Radioactive Sources, Rev. 18A

HP-53, Transfer of Plant Process or Tri-Nuc Filters and High Dose Rate Radioactive Waste,

Rev. 9B

HP-56, Instructions for Radiography, Rev. 10

HP-71, Decontamination of Tools, Equipment and Areas, Rev. 16E

HP-112, Multibadging, Rev. 26

HP-74, Access Control Using Alarming Dosimeters, Rev. 8

HPP-3, High Radiation Areas, Rev. 28

HPP-15, Hot Particles, Rev. 8B

HPP-20, Area Radiation and Contamination Surveys, Rev. 30

HPP-22, Air Sampling, Rev. 23

HPP-30, Personnel Monitoring, Rev. 47

HPP-41, Movement of Material and Equipment, Rev. 26

HPP-42, Identification, Survey, and Release of Material, Rev. 5

HPP-70, Personnel Contamination Monitoring, Rev. 25D

HPP-85, ISFSI Radiological Controls, Rev. 2

PI-SL-204, Condition Identification and Screening Process, Rev. 4

PI-SL-205, Condition Evaluation and Corrective Action, Rev. 3

RP-SL-103-1006, Conduct of Radiological Diving Operations, Rev. 0

RP-SR-103-1008, Remote Monitoring, Rev. 1

Records and Data Reviewed

CFR Part 50/61 Analysis Reports, Laboratory Sample Nos. Z27885, DAW 2008 090-013,

Dated 05/13/09; and Z27984, DAW Smears 090-115, Dated 08/19/09

2011 NSTS Annual Inventory Reconciliation Letter, Dated 01/28/11

Air Sample Data Sheets, Air Sample Nos. 112-005, U2 RCB 62, Initial Entry, Dated

01/02/11; 112-0450, U2 RCB 18 E

L. 2-A-2 RCP, Grinding Suction Line, Dated 01/19/11;

2-0451, U2 RCB B S/G, Detention Manway, Dated 01/19/11; 112-0470, U2 RCB 62

E

L. PZR, Cut

S.I. Line, Dated 01/20/11; 112-0475, U2 RCB 18 E

L. A S/G Bull Pen,

Install Nozzle Dams, Dated 01/20/11; 1112-0478, U2 RCB 18 E

L. B S/G Bull Pen,

Install Nozzle Dams, Dated 01/20/11; 12-0503, U2 RCB 18 A S/G, Platform Work, Dated

01/21/11; 112-0539, U2 RCB O/S PZR Tent, Remove Heaters, Dated 01/21/11; 112-

25, U2 RCB 18 E

L. I/S PZR Heater Tent, Dated 01/23/11; 112-0643, U2 RCB I/S Tent

PZR, Grind PZR for NDE Prep, Dated 01/23/11

Dive Plan, St. Lucie Unit 2, ICI Thimble Tube Replacement Project - Winter 2011

Form HP-43.5, Source Master List, Dated 01/15/11

Initial Inventory of Category 2 Nationally Tracked Sources Letter, Dated 01/23/10

Radiation Work Permit (RWP) Number No. 11-2550, Radiography, Rev. 01

RWP No. 11-3330, Thimble Mod: Diving Operations, Rev. 00

RWP No. 11-3323, UGS Thimble Mod Work, Support, Rev. 02

RWP No. 11-3402, S/G Secondary Side Activities, Rev. 01

RWP No. 11-3403, RCP Seal Lines: Remove/Replace. To include NDE/QA, Rev. 00

RWP No. 11-3404, Mechanical Seals: Remove/Replace. All Support, Rev. 00

RWP No. 11-3410, 2B2 RCP Rotating Assembly: Remove/Replace, All Support Work, Rev.

RWP No. 11-3411, 2B2 RCP Motor: Remove/Replace, All Support Work, Rev. 00

RWP No. 11-3439, S/G Primary Manways, Rev. 01

RWP No. 11-3440, Nozzle Dams: Install/Remove. All associate work, Rev. 00

RWP No. 11-3441, Eddy Current Testing and all related work, Rev. 00

Spent Fuel Pool Non-SNM Item Inventory Log Sheet, Dated 01/20/11

FPL-PSL, Radiological Surveys, Log Nos. 091-2587, A Steam Generator Platform - EL. 18

Ft., Dated 05/08/09; 091-2588, Steam Generator Channel Head (1/2 Side) - E

L. 18 Ft.,

Dated 05/08/09; 091-2589, Steam Generator Channel Head - E

L. 18 Ft.,

Dated 05/08/09; 091-2639, Steam Generator Channel Head (1/2 Side) - E

L. 18 Ft., Dated

05/09/09; 091-2640, Steam Generator Channel Head (1/2 Side) - E

L. 18 Ft., Dated

05/09/09; 091-2641, Steam Generator Platform - E

L. 18 Ft., Dated 05/09/09;

091-3240, B Steam Generator Platform - E

L. 18 Ft., Dated 05/18/09; 091-3249, A Steam

Generator Platform - E

L. 18 Ft., Dated 05/19/09

VSDS Standard Map Survey Report Survey Nos. PSL-M-20101006-6, ISFSI, Dated

10/06/10;PSL-M-20101118-9, ISFSI, Dated 11/18/10; PSL-M-20110120-13, U2 RCB/2A

Steam Generator-Cold Leg/18, Dated 01/20/11; PSL-M-20110120-16, U2 RCB/2A

SteamGenerator-Hot Leg/18, Dated 01/20/11; PSL-M-20110120-17, U2 RCB/2B Steam

Generator-Cold Leg/18, Dated 01/20/11

Corrective Action Program (CAP) Documents

Action Request Number (AR) 475966, Improper radiation worker practices

AR 477341, Outage organizational effectiveness review

AR 585076, 1B Waste Gas Decay Tank (WGDT) posted and controlled as HRA

AR 00593719, ED Rate Alarm - Security Guard, Dated 10/12/10

AR 1618528, A welder experienced a personnel contamination event while welding on the

2B1 spray line in the U2 RCB, Dated 02/09/11

Condition Report Number (CR) 2009-14731, 1B/1C WIX Leakage

St. Lucie Nuclear Oversight Report, Report Nos. PSL-10-018, Dated 06/28/10; and PSL-10-

20, Radioactive Waste Control, 06/28/10

Section 2RS2: ALARA

Procedures, Guidance Documents, and Manuals

ADM-05.04, Cobalt Reduction Program, Rev. 0E

HP-55, Portable Shielding, Rev. 20B

HPP-1, Preparing Radiation Work Permits, Rev. 33

HPP-30, Personnel Monitoring, Rev. 47

PI-SL-204, Condition Identification and Screening Process, Rev. 4

PI-SL-205, Condition Evaluation and Corrective Action, Rev. 3

RP-SL-103-2003, Crudburst Monitoring Requirements, Rev. 0A

RPAA-104, ALARA Program, Rev. 1

RPAA-104, ALARA Implementing Procedure, Rev. 1

Records and Data

ALARA Package No. 11-2550, Radiography, Rev. 00

ALARA Package No. 11-3323, ICI Thimble Replacement, Rev. 02

ALARA Review Board Meeting Agenda for 02/02/11 and 02/10/11

RWP No. 11-3323, UGS Thimble Mod Work, Support, Rev. 02

RWP No. 11-3330, Thimble Mod: Diving Operations, Rev. 00

RWP No. 11-3439, S/G Primary Manways, Rev. 01

RWP No. 11-3440, Nozzle Dams: Install/Remove. All associate work, Rev. 00

RWP No. 11-3441, Eddy Current Testing and all related work, Rev. 00

SL2-18 Refueling Outage ALARA Report, 06/03/09

SL2-18 and SL2-19 RCS Crud Burst and Cleanup Graphs, Undated

SL2-19, Radiation Protection Plan (RPP), Alloy 600 Project, Dated 12/09/10

SL2-19, RPP, Reactor Coolant Pump Motor Replacement Project, Undated

SL2-19, RPP, Steam Generator Primary Side, Rev. 1, Dated 12/12/10

SL2-19, RPP, Thimble Replacement Project, Rev. 1, Dated 01/03/11

St. Lucie Nuclear Plant 5-Year ALARA Plan 2010-2015

Temporary Shielding Placement (TSP) No.11-001, Unit -2 RCB 1A and 1B Hot Leg Loop

Drain Valves, Dated 06/07/10

TSP No.11-004, Unit-2 RCB top of PZR, Dated 06/07/10

TSP No.11-029, Unit-2 RCB under A hot leg (I-42-RC-114) V1214, Dated 06/08/10

TSP No.11-043, Unit-2 RCB inside bio-wall (shield casks for loop drains), Dated 06/09/10

Thimble Project, Thimble Task Exposure Status, SL2-19, Dated 02/01/11

Units 1 and 2 Radiological Hot Spot Logs, December 2010

VSDS Standard Map Survey Report Survey Nos. PSL-M-20110103-28, U2 RCB/RCB Lower

Level - 18/18, Dated 01/03/11; PSL-M-20110103-31, U2 RCB/RCB Lower Level -

18/18, Dated 01/03/11; PSL-M-20110104-57, U2 RCB/Top of Pressurizer/62,

Dated 01/04/11; PSL-M-20110120-5, U2 RCB/Top of Pressurizer/62, Dated 01/20/11;

PSL-M-20110109-56, Blank/Blank Map/U2 (V-1214 pipe), Dated 01/09/11;

PSL-M-20110117-52, U2 RCB/RCB Lower Level - 18/18, Dated 01/17/11;

PSL-M-20110125-61, Blank/Blank Map/U2 (V-1214 pipe), Dated 01/25/11;

Corrective Action Program (CAP) Documents

AR 560972, Scheduled work evolution to remove hot spot

St. Lucie Nuclear Oversight Report, Report No. PSL-10-018, Dated 06/28/10

Section 2RS3: In-Plant Airborne Radioactivity Control and Mitigation

Procedures, Guidance Documents, and Manuals

Emergency Plan Implementing Procedure (EPIP)-05, Activation and Operation of the

Operational Support Center, Rev. 26

EPIP-13, Maintaining Emergency Preparedness - Emergency Exercises, Drills, Tests and

Evaluations, Rev. 13

Florida Power and Light Nuclear Division, Lab Guide for: Don, Operate and Remove the

SCOTT 2.2 Self-Contained Breathing Apparatus Continuing Training, 2808100, Rev. 4

Health Physics Procedure (HP)-13F, Calibration and Operation of the Eberline Model AMS-4

Air Monitoring System, Rev. 11

HP-14F, Calibration of Portable Air Samplers, Rev. 13A

Health Physics Procedure (HPP)-22, Air Sampling, Rev. 23

HPP-23, Health Physics Activities in the Reactor Containment Building during Shutdown,

Rev. 25

HPP-37, Portable High Efficiency Particulate Air (HEPA) Filtration Ventilation Systems in the

Radiation Controlled Area, Rev. 4c

HPP-60, Respiratory Protection Manual, Rev. 7B

HPP-61, Use of Respiratory Protective Equipment, Rev. 16C

HPP-62, Inspection and Maintenance of Respiratory Protection Equipment, Rev. 15

HPP-64, Setup and Inspection of Breathing Air Purification Systems, Rev. 12

HPP-65, Cleaning and Decontamination of Respiratory Protection Equipment, Rev. 7A

HPP-66, Operation of the SCBA Fill Station, Rev. 0

HP-73, Portacount Plus Fit Test System, Rev. 15

HP-203, Personnel Access Control During Emergencies, Rev. 22A

National Institute for Occupational Safety and Health, Certified Equipment List, Schedule

13F, Approval # 0080CBRN; Respirator Details and Component Parts

Performance Improvement Procedure - St. Lucie (PI-SL)-204, Condition Identification and

Screening Process, Rev. 4

PI-SL-205, Condition Evaluation and Corrective Action, Rev. 3

Radiation Protection Fleet Procedure (RP-AA)-104-1000, Attachment 5, TEDE ALARA

Evaluation, Rev. 1

St Lucie Plant Training Department Lesson Plan: Don, Operate and remove the Scott 2.2

SCBA Initial Training, 4702100, Rev. 8

St Lucie Nuclear Plant Specialty Training Job Performance Measure: Don, Operate, and

Remove the Scott 2.2 Self-Contained Breathing Apparatus (SCBA), 4721100, Rev. 9

St Lucie Plant, Emergency Response Directory, Revs. 58 and 59

St Lucie Plant, Protection Services Department: Department Instruction (DI) S-02, Rev. 0

Grade D Breathing Air Periodic Testing, Rev. 1

Unit 2 General Operating Procedure (2-GOP-365), Refueling Sequencing Guidelines, Rev.

Records and Data

Contract Requisition No. 00778677, Recertify 70 SCBA Regulators and Perform 175

Cylinder Hydros, Dated 08/02/10

HPP-62.1 Form, Respiratory Equipment Maintenance/Inspection Form, SCBA Monthly/

Quarterly/Semi-Annual Inspection Data: 02/28/09, 04/12/09, 12/10/09, 01/29/10,

4/30/10, 10/29/10

Laboratory Report, Compressed Air/Gas Quality Testing Analysis Results for the following:

Compressed Air System , Unit 1 Reactor Auxiliary Building (1 RAB), 12/17/09,

03/02/10, 05/24/10, 08/25/10, 11/15/10: Compressed Air System Unit 2 Reactor

Auxiliary Building (2-RAB) , 12/11/09, 03/05/10, 05/24/10, 08/25/1011/15/10; F-5

Backup Compressor, 12/11/09 03/03/10, 05/24/10, 11/15/10; Fire House, 12/11/09,

03/05/10, 05/24/10, 08/25/10, 11/15/10; Unit 1 Reactor Containment Building (1

RCB), Electric and Diesel North 04/01/10, South, 04/01

Scott PosiChek3 Visual/Functional Test Results, Scott Air-Pak 2.2 Number 25, Dated

08/12/10

Scott PosiChek3 Visual/Functional Test Results, Scott Air-Pak 2.2 Number 34, Dated

08/13/10

TEDE ALARA Assessment for RWP 2011-3328-3, Tripod Deck Plates/Clamps, Dated

01/17/11

TEDE ALARA Assessment for RWP 2011-3432-1, PZR heater elements, Dated 01/17/11

TEDE ALARA Assessment for RWP 2011-3433-1, PZR heater cut out and replace (cut and

machine sleeves), Dated 12/28/10

Unit 2 Containment Purge Ventilation System (HVE-8A/8B) Filter Testing Surveillance Data

(OSP-25.04) Data, May 2009

CAP Documents

AR 00464328, Journeyman missed SCBA Requalification Training

AR 00464071, Respirators in the control room past due for inspection

AR 00466509, Respiratory monthly surveillance not completed as required

AR 00475944, Untimely and inadequate respirator physicals provided for contract workers

AR 00526647, I&C Journeyman will miss SCBA training

AR 00530602, Re-evaluate current training expectations for SCBA requalifications

AR 00585543, Some training SCBA masks have noticeable cracks

AR 00585649, Control room outside air radiation monitor spiked

AR 00588555, Some respirator qualifications will not be completed

St. Lucie Nuclear Oversight Report (PSL)-10-018, Radiation Protection Program,

Dated 06/28/10

Section 2RS4: Occupational Dose

Procedures, Guidance Documents, and Manuals

HP-74, Access Control Using Alarming Dosimeters, Rev. 8

HP-112, Multibadging, Rev. 26

HP-114, Calibration and Operation of the Nuclear Enterprises Personnel Contamination

Monitors, Rev. 16

HP-116, Electronic Dosimeter Program, Rev. 20

HPP-4, Scheduling of Health Physics Activities, Rev. 42

HPP-30, Personnel Monitoring, Rev. 46

HPP-31, Operation of the Whole Body Counting System, Rev. 21

HPP-39, Response Protocols for Whole Body Counting and Personnel Contamination

Monitoring, Rev. 7

HPP-72, Determination of Dose to the Skin from Skin Contamination, Rev. 5B

NPSS-HP-WP-003, External Dosimetry Measurement Quality Assurance Program, Rev. 1

RP-AA-101-2001, Sentinel Software Transactions Associated With Issuance and Control of

Personnel Monitoring Devices, Rev. 2

RP-AA-101-2004, Method for Monitoring and Assigning Effective Dose Equivalent (EDE) for

High Dose Gradient Work, Rev. 0

Records and Data

Applicable Sections of NUPIC Audit Report, Survey Number: 20459, of GEL Lab (In-vitro

analysis)

Applicable Sections of Contract Number 2260722 for analysis of bioassay sample(s) for St.

Lucie Plant

Authorization for Release of Contaminated Individuals, Health Physics Form HPP-39.2, for

CR 2009-13113

Authorization for Release of Contaminated Individuals, Health Physics Form HPP-39.2, for

CR 2010-10291

Exposure Investigation Report, Health Physics Form HPP-30.17, for CR 2010-13450

Health Physics Form HPP-30.25, RCA Exclusion Form, (for CR 2010-13550), Dated

05/21/10

NVLAP-01S, NVLAP Accreditation for Mirion Technologies (GDS), Inc., for the period 2010-

07-01 through 2011-06-30

RWP 10-1006, Rev. 1, Stud tensioners (install/remove). Detension/tension studs. Remove/

install: studs, stud hole plugs. Install/remove Guide Pins., Dated 05/17/10

Survey of Clothing and Personnel Items, Health Physics Form HPP 70.3, for CR 2009-13113

Survey of Clothing and Personnel Items, Health Physics Form HPP 70.3, for CR 2010-10291

Whole Body Count Results for CR 2010-10291, Dated 4/19/10 and 4/21/10

CAP Documents

AR 00593719, ED Rate Alarm, 10/12/10

AR 01610586, AREVA Personnel entered Containment with Wrong Dosimetry, Dated

01/20/11

AR 01611071, Inconsistencies in Unit 1 and Unit 2 UFSAR Chapter 12, Dated 01/21/11

AR 01617411, The 2010 10CFR20 Annual RP Audit Matrix Not Performed, Dated 02/07/11

AR 01617511, HPP-30 Needs Additional Tritium Bioassay Guidance, Dated 02/07/11

CR 2009-13113, Positive Whole Body Count, Dated 05/01/09

CR 2009-14048, Lost EPD, Dated 05/08/09

CR 2010-10291, Positive Whole Body Count, Dated 04/20/10

CR 2010-13450, Whole Body TLD Worn With Multi-Badge, Dated 05/20/10

CR 2010-13550, Incorrect Dosimetry Worn for an entry to the U1 reactor cavity during Rx

Head tensioning, Dated 05/21/10

St. Lucie Nuclear Oversight Report (PSL)-10-018, Radiation Protection Program,

Dated 06/28/10

St. Lucie Plant Radiation Protection Department Quick Hit Assessment, 2008 Annual RP

Programmatic Assessment, December 2-19, 2008

St. Lucie Plant Radiation Protection Department Quick Hit Assessment, 2009 Annual RP

Programmatic Assessment 10CFR20, Subpart H, Sections 20.1701 and 20.1702,

December 21-28, 2009

Section 2RS5: Radiation Monitoring Instrumentation

Procedures, Guidance Documents, and Manuals

0-COP-07.05, Process Monitor Setpoints, Rev. 8B

1-1120070, High-Range Radiation Monitor Calibration, Rev. 20

1-1220055, Calibration of Area Radiation Monitoring Systems (ARMS), Rev. 20

1-IMP-26.13, Gaseous Radwaste Process Monitor Functional and Calibration Instruction,

Rev. 11

1-PMI-26.01, Area Radiation Monitor Calibration, Rev.1

1-SMI-26.24, Control Room Outside Air Intake Radiation Monitor Functional Test, Rev. 2

2-1400069, Calibration of the PSL-2 Control Room Outside Air Intake Monitors (CROAIs)

Test, Rev. 12

2-PMI-26.62, Calibration of Non-Safety Related Area Radiation Monitors, Rev.0

C-200, Offsite Dose Calculation Manual (ODCM), Rev. 33

HP-13A, Operation of Portable Survey Instruments, Rev. 28

HP-13B, Calibration of Portable Count Rate Instruments, Rev. 18

HP-13C, Calibration of Portable Dose Rate Survey Instruments, Rev. 24

HP-14B, Recertification of Calibrated Dose Rate or Activity Radiation Sources, Rev. 4

HP-14D, Recertification of Multiple Source Gamma Calibration Ranges, Rev. 4

HP-14H, Use of the

J.L. Shepherd Model 89-400 Shielded Calibration Range, Rev. 5

HP-90, Emergency Equipment, Rev. 49

HP-105, Operation of the Victoreen model 500/530 Precision Electrometers with Victoreen

Model 550 Probes and Model 570 Condenser-R Meter, Rev. 3B

HP-116, Electronic Dosimeter Program, Rev. 20

HP-202, Environmental Monitoring During Emergencies, Rev. 37

HPP-02, Calibration and Operation of the TSA Systems Model SPM-906 Portal Monitor, Rev.

HPP-10, Multichannel Analyzers, Rev. 17

HPP-35, Operation and Calibration of the Small and Large Article Monitors, Rev. 13A

QI-12-PR/PSL-6, Radiation Protection Measuring and Test Equipment, Rev. 17

Records and Data

Alpha Spectrometer Calibration Forms, HPP-10.11, for Soloist Detectors S/Ns48-073 C4,

Dated 01/4/10; and 48-073 C5, Dated 11/24/10

Alpha Spectrum Radionuclide Identification Library files for Alpha Spec System

Areva NP Inc. Environmental Reports, 10 CFR Part 50/61 Analysis Reports, DAW 2008 090-

013, Dated 05/13/09; and DAW Smears 090-115, Dated 08/19/09

Calibration Data Packages for HPGe Gamma Vision (Form HPP-10.2) - Multiple analysis

geometries for Detector S/Ns 46-P41570A, 21551A, 11607A, and 44-TP41247B, for

the period 11/07/09 to 05/08/10

Chemistry Department List of Out of Service Effluent Radiation Monitors and Compensatory

Samples Taken for the period 10/20/09 to 10/17/10

Form HP-116.4, Annual CDM21 Calibrator Recertification Form, Dated 06/22/10

Form HP-13F-AMS-4, AMS-4 Calibration Record, for AMS-4 S/N 1625, Dated 10/13/10

FastScan 1 2010 Total Body and Lung Calibration, Dated 03/30/10

FastScan 2 2010 Total Body and Lung Calibration, Dated 03/30/10

Gamma Spectrum Radionuclide Identification Library files for Gamma Spec Systems

List of Current Alarm Setpoints for Small Article Monitor, Personnel Contamination Monitor,

Portal Monitor, and Portable Continuous Air Monitor, Dated 02/07/11

Plant Modification, PC/M 08150M, Rev 0, Attachment 1, 10CFR50.59 Applicability

Determination, PSL 1 Containment Radiation Monitors Replacement, Dated 06/29/09

Plant Modification, PC/M 08150M, Rev 0, Attachment 9, UFSAR Change Package,

Dated 06/29/09

Plant Modification, PC/M 08150M, Rev 0, PSL 1 Containment Radiation Monitors

Replacement, Dated 06/29/09 (selected pages)

Form HP-2, Instrument Calibration Data Sheet, and HPQI-12-PR/PSL-6 Attachment A,

Nonconforming Condition, for the following portable RP survey instruments that

failed As Found calibration acceptance criteria; RO-20 S/N 5148, L-177 S/N 51890,

AMS-4 S/N 1623

List of RP Portable Instruments In Service, 12/16/10 through 06/16/11, Printout Dated

2/16/10

Report of Calibration For Electrometer, Standard Imaging Model MAX-4000, S/N E053413,

Report No. EDM17584, Dated 08/27/09

Report of Calibration For Ionization Chamber, Exradin Model A3, S/N Xr053491, Report No.

ION12492, Dated 08/26/09

Report of Calibration For Ionization Chamber, Exradin Model A5, S/N XY051603, Report No.

ION12493, Dated 08/26/09

Recertification of

J.L. Shepherd Model 89-400, S/N 8167 2009 Calibration Package, Dated

07/15/09; and 2010 Calibration Package, Dated 07/13/10

Waste Stream Summary, Dry Active Waste, Dated 01/21/11

WBC Gamma Spectrum Radionuclide Identification Library files for FastScan 1 and

FastScan 2, Dated 12/10/10

Work Order (WO) 38000812, Task 1, Calibration of RIM-26-62 and RIM-26-66 Radiation

Monitors for Control Room Outside Air Intake (CROAIs), 7/22/2008

WO 38027201, Task 1, Calibrate CIS Rad Monitor RE-26-3, Dated 04/13/10

WO 38027133, Task 1, Calibrate Containment High Radiation Monitor RIS-26-58 and 59,

Dated 04/14/10

WO 39015901, Task 1, Calibration of Waste Gas Channel 42 (RE-6658), Dated 03/16/10

WO 39025251, Task 1, CROAI Monitor Monthly Functional Check, Dated 06/01/10

CAP Documents

AR 00469468, B S/G Blowdown monitor failed source check, Dated 03/08/10

AR 00472884, Annual Cross check for Multi Channel Analyzers not in agreement with

vendor supplied values, Dated 12/29/09

AR 00475705, RC-26-10 (Spent Fuel Pool Rad Monitor RM-23) Failed, Dated 03/20/10

AR 00533228, Discrepancies noted during daily RP instrument checks, Dated 04/05/10

AR 00567654, RIM-26-39, Contmt Post Accident Rad Monitor has failed, Dated 02/16/10

AR 00570893, RE-26-56, A CCW Rad monitor failed low, Dated 08/01/10

AR 00571389, 2A Containment Atmosphere Particulate Monitor OOS, Dated 08/04/10

AR 00580668, Loss of Particulate Channel on 2B Plant Vent, Dated 09/19/10

List of Condition Reports for Radiation Monitoring system code for the period 05/01/09 to

2/17/10

Section 40A1: Performance Indicator Verification

Procedures, Guidance Documents and Manuals

ADM-25.02, NRC Performance Indicators, Rev. 25

HPP-30, Personnel Monitoring, Rev. 46

NAP-206, NRC Performance Indicators, Rev. 6

NEI 99-06, Regulatory Assessment Performance Indicator Guideline, Rev. 6

Records and Data Reviewed

ADM-25.02, NRC Performance Indicators, St Lucie Plant, Appendix O, Occupational

Exposure Control Effectiveness, Rev. 25, 3rd and 4th Quarters, 2010

ADM-25.02, NRC Performance Indicators, St Lucie Plant, Appendix P, RETS/ODCM

Radiological Effluent Occurence Exposure, Rev. 25, 3rd and 4th Quarters, 2010

LIST OF ACRONYMS

ALARA As Low as is Reasonably Achievable

ANS Alert and Notification System (ANS) Testing

ARM area radiation monitor

CAM continuous air monitors

CAP Corrective Action Program

CCW Component Cooling Water

CFR Code of Federal Regulations

cm centimeters

CR Condition Reports

CRDM Control Rod Drive Mechanism

CY Calendar Year

DAW dry active waste

DEP Emergency Response Organization Drill/Exercise Performance

EAL Emergency Action Level

ECCS Emergency Core Cooling System

ED electronic dosimeter

EP Emergency Preparedness

ERO Emergency Response Organization

HP health physics

HPT health physics technician

HRA high radiation area

IP Inspection Procedure

ISFSI Independent Spent Fuel Storage Installation

IST Inservice Testing

LHRA locked high radiation area

mrem/hr millirem per hour

NAP Nuclear Administrative Procedure

NCV Non-Cited Violation

NEI Nuclear Energy Institute

NRC Nuclear Regulatory Commission

OS Occupation Radiation Safety

PCM personnel contamination monitors

PI Performance Indicator

PMs portal monitors

PS Planning Standard

radwaste radioactive waste

RCA radiologically controlled area

Rev. Revision

RP radiation protection

RS Public Radiation Safety

RWP radiation work permit

S/G steam generator

SAM small article monitor

SCBA Self-Contained Breathing Apparatus

SFP spent fuel pool

SL2-19 Unit 2 refueling outage cycle 19

TI Temporary Instruction

TS Technical Specifications

TYRA three-year rolling average

U1 Unit 1

U2 Unit 2

UFSAR Updated Final Safety Analysis Report

VHRA very high radiation area

WBC whole body count

WGDT Waste Gas Decay Tank

WO Work Order

Attachment