IR 05000454/2017008

NRC Temporary Instruction 2515/191, Mitigation Strategies, Spent Fuel Pool Instrumentation and Emergency Preparedness Inspection Report 05000454/2017008; 05000455/2017008

ML17263B152
Person / Time
Site:	Byron
Issue date:	09/20/2017
From:	Ann Marie Stone NRC/RGN-III/DRP/TSS
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
References
IR 2017008
Download: ML17263B152 (17)

Text

mber 20, 2017

SUBJECT:

BYRON STATION, UNITS 1 AND 2NRC TEMPORARY INSTRUCTION 2515/191, MITIGATION STRATEGIES, SPENT FUEL POOL INSTRUMENTATION AND EMERGENCY PREPAREDNESS INSPECTION REPORT 05000454/2017008; 05000455/2017008

Dear Mr. Hanson:

On September 1, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed a Temporary Instruction 2515/191, Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans inspection at your Byron Station, Units 1 and 2. On September 1, 2017, the NRC inspectors discussed the results of this inspection with Mr. P. Boyle and other members of your staff. The results of this inspection are documented in the enclosed report.

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

The NRC inspectors did not identify any findings or violations during this inspection. This letter, its enclosure, and your response (if any) will be made available for public inspections and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Ann Marie Stone, Team Leader Technical Support Staff Division of Reactor Projects Docket Nos. 50-454; 50-455 License Nos. NPF-37; NPF-66 Enclosure:

IR 05000454/2017008; 05000455/2017008 cc: Distribution via LISTSERV

SUMMARY

Inspection Report 05000454/2017008; 05000455/2017008; 08/28/2017 - 09/01/2017;

Byron Station, Units 1 and 2; Temporary Instruction 2515/191 Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans.

This inspection was performed by three U.S. Nuclear Regulatory Commission (NRC) regional inspectors and one resident inspector. No findings of significance or violations of NRC requirements were identified during this inspection. The significance of inspection findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process, dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310, Aspects Within the Cross-Cutting Areas, dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated November 1, 2016.

The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision

NRC-Identified and Self-Revealing Findings

None.

REPORT DETAILS

4OA5 Other Activities (TI 2515/191)

The objective of Temporary Instruction (TI) 2515/191, Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, is to verify the licensee has adequately implemented the mitigation strategies as described in the licensees Final Integrated Plan [for] Mitigation Strategies for a Beyond-Design-Basis External Event (ADAMS Accession No. ML16197A390), and the NRCs safety evaluation (ADAMS Accession No. ML16334A504) and to verify the licensee installed reliable water-level measurement instrumentation in their spent fuel pool. The purpose of this TI was also to verify the licensee had implemented Emergency Preparedness (EP) enhancements as described in their site-specific submittals and NRC safety assessments, including multi-unit dose assessment capability and enhancements to ensure staffing is sufficient and communications can be maintained during such an event.

The inspection also verifies plans for complying with NRC Orders EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (ADAMS Accession No. ML12054A736) and EA-12-051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation (ADAMS Accession No. ML12054A679) are in place and are being implemented by the licensee. Additionally, the inspection verified implementation of staffing and communications information provided in response to the March 12, 2012, request for information letter and multiunit dose assessment information provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013, (ADAMS Accession No. ML12339A262).

The inspectors discussed the plans and strategies with plant staff, reviewed documentation, and where appropriate, performed plant walk downs to verify the strategies could be implemented as stated in the licensees submittals and the NRC staff prepared safety evaluation. For most strategies, this included verification that the strategy was feasible, procedures and/or guidance had been developed, training had been provided to plant staff, and required equipment had been identified and staged.

Specific details of the teams inspection activities are described in the following sections.

This inspection closes TI 2515/191 for the Byron Station, Units 1 and 2.

.1 Mitigation Strategies for Beyond-Design Basis External Events

a. Inspection Scope

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

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

b. Assessment Based on samples selected for review, the inspectors verified the licensee satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittals and the associated safety evaluation and determined the licensee is in compliance with NRC Order EA-12-049. The inspectors verified the licensee satisfactorily:

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

• integrated their FSGs into their existing plant procedures such that entry into and departure from the FSGs were clear when using existing plant procedures;

• protected FLEX equipment from site-specific hazards;

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

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

• developed the means to ensure the necessary off-site FLEX equipment would be available from off-site locations.

The inspectors verified non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program (CAP) as appropriate.

c. Findings

No findings were identified.

.2 Spent Fuel Pool Instrumentation

a. Inspection Scope

The inspectors examined the licensees newly installed spent fuel pool instrumentation.

Specifically, the inspectors verified the sensors were installed as described in the plant specific submittals and the associated safety evaluation and that the cabling for the power supplies and the indications for each channel are physically and electrically separated. Additionally, environmental conditions and accessibility of the instruments were evaluated. Documents reviewed are listed in the attachment.

b. Assessment Based on samples selected for review, the inspectors determined the licensee satisfactorily installed and established control of the spent fuel pool (SFP)instrumentation as described in the plant specific submittals and the associated safety evaluation and determined the licensee is in compliance with NRC Order EA-12-051.

The inspectors verified the licensee satisfactorily:

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

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

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

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

The inspectors verified non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's CAP.

c. Findings

No findings were identified.

.3 Staffing and Communication Request for Information

a. Inspection Scope

Through discussions with plant staff, review of documentation and plant walk downs, the inspectors verified the licensee has implemented required changes to staffing, communications equipment and facilities to support a multi-unit extended loss of AC power (ELAP) scenario as described in the licensees staffing assessment and the NRC safety assessment. The inspectors also verified the licensee has implemented multi-unit dose assessment (including releases from spent fuel pools) capability using the licensees site-specific dose assessment software and approach as described in the licensees multi-unit dose assessment submittal. Documents reviewed are listed in the attachment.

b. Assessment The inspectors reviewed information provided in the licensees multi-unit dose submittal and in response to the NRCs March 12, 2012, request for information letter and verified that the licensee satisfactorily implemented enhancements pertaining to Near-Term Task Force Recommendation 9.3 response to a large scale natural emergency event that results in an ELAP to all site units and impedes access to the site. The inspectors verified the following:

• the licensee satisfactorily implemented required staffing changes to support a multi-unit ELAP scenario;

• EP communications equipment and facilities are sufficient for dealing with a multi-unit ELAP scenario; and

• the licensee implemented multi-unit dose assessment capabilities (including releases from spent fuel pools) using the licensees site-specific dose assessment software and approach.

The inspectors verified non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's CAP.

c. Findings

No findings were identified.

4OA6 Management Meeting

.1 Exit Meeting Summary

On September 1, 2017, the inspectors presented the inspection results to Mr. P. Boyle and other members of the licensees staff. The licensee acknowledged the issues presented. The inspectors confirmed none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

B. Hanson, Senior Vice President

P. Boyle, Plant Manager

C. Catencamp, Security Manager

J. Lynde, Manager Operations Support

H. Welt, Operations Director

G. Gugle, Deputy Maintenance Director

C. Cote, Shift Operations Supervisor

M. Roberts, Radiation Protection Manager (acting)

C. Keller, Engineering Director

L. Zurawski, Principle Regulatory Engineer

R. Bolin, Operations SRO

S. Pierson, Operations EOP/SAMG/FSG Lead

J. Printz, Contractor-Procedure Writer

K. Zlevor, Senior Engineer-Design

J. Smith, Engineer-Programs

S. Thunberg, Operations CAP Coordinator

P. Henderson, Sr Operations Procedure Writer

D. Gutierrez, Sr Operations Procedure Writer

T. Edwards, Fire Marshal

K. Pope, Operations Admin

R. Lloyd, EP Manager

R. Kartheiser, EP

D. Wallheimer, Communications Manager

S. Harvey, Chemistry/Radwaste/Environmental Manager

R. Lawlor, Training Manager-Operations

Z. Cox, NRC Coordinator

U.S. Nuclear Regulatory Commission

A. Stone, Team Leader, Technical Support Staff, Division of Reactor Projects

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None.

Closed

None.

Discussed

None.