IR 05000454/2020004
| ML21027A195 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 01/27/2021 |
| From: | Hironori Peterson Region 3 Branch 3 |
| To: | Rhoades D Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2020004 | |
| Download: ML21027A195 (25) | |
Text
January 27, 2021
SUBJECT:
BYRON STATION - INTEGRATED INSPECTION REPORT 05000454/2020004 AND 05000455/2020004
Dear Mr. Rhoades:
On December 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Byron Station. On January 13, 2021, the NRC inspectors discussed the results of this inspection with Mr. M. Kanavos, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
No findings or violations of more than minor significance were identified during this inspection.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Hironori Peterson, Chief Branch 3 Division of Reactor Projects
Docket Nos. 05000454 and 05000455 License Nos. NPF-37 and NPF-66
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000454 and 05000455
License Numbers:
Report Numbers:
05000454/2020004 and 05000455/2020004
Enterprise Identifier: I-2020-004-0025
Licensee:
Exelon Generation Company, LLC
Facility:
Byron Station
Location:
Byron, IL
Inspection Dates:
October 1, 2020 to December 31, 2020
Inspectors:
D. Betancourt-Roldan, Senior Resident Inspector
J. Bozga, Senior Reactor Inspector
J. Cassidy, Senior Health Physicist
M. Garza, Emergency Preparedness Inspector
G. Hansen, Sr. Emergency Preparedness Inspector
C. Hunt, Senior Resident Inspector
D. Kimble, Senior Resident Inspector
J. Park, Reactor Inspector
P. Smagacz, Resident Inspector
C. Thompson, Illinois Emergency Management Agency
Approved By:
Hironori Peterson, Chief
Branch 3
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Byron Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
PLANT STATUS
Unit 1 began the inspection period operating at full power. With the exception of minor reductions in power to support scheduled testing activities or load changes requested by the transmission dispatcher, the unit remained at or near full power for the entire inspection period.
Unit 2 began the inspection period operating at 75 percent power and was in coast down for a scheduled refueling outage. On October 5, 2020, the unit began a refueling outage. The unit went critical again on October 19, 2020. The unit was returned to full power on October 20, 2020. With the exception of minor reductions in power to support scheduled testing activities, and load changes requested by the transmission dispatcher the unit remained at or near full power for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the Coronavirus Disease 2019 (COVID-19),resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week; conducted plant status activities as described in IMC 2515, Appendix D, Plant Status; observed risk-significant activities; and completed on-site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on-site. The inspections documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Low temperature over pressure system on October 6, 2020
- (2) Fuel pool cooling and cleanup system while defueling on October 8, 2020
- (3) Residual heat removal (RH) system while refueling on October 12, 2020 (4)1A Auxiliary Feedwater (AF) train with 2B AF pump out of service for scheduled maintenance on November 12, 2020
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the 1B diesel generator (DG) on November 22, 2020.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Fire Zone (FZ) 12.1-0, fuel handling building, 401' elevation on October 8, 2020
- (2) FZ 11.2A-2, 2A RH room on October 12, 2020
- (3) FZ 9.2-2, 2A DG and day tank room on October 15, 2020
71111.08P - Inservice Inspection Activities (PWR) PWR Inservice Inspection Activities Sample (IP Section 03.01)
- (1) The inspectors verified the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary were appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing documentation for the following activities from October 5, 2020 to October 16, 2020:
03.01.a - Nondestructive Examination and Welding Activities.
- Ultrasonic (UT) and visual (VT) examinations of component 2RC14AD-2 using procedures PDI-UT-2 and ER-AA-335-015-2013
- UT and VT examinations of component 2RC37A-3 using procedures PDI-UT-2 and ER-AA-335-015-2013
- Report No. B2R21-MT-001, Component ID 2RC-01-BA/SGN-02, with relevant indications identified during prior outage accepted for continued service
- Pressure boundary welds 1 and 2 fabricated during elbow replacement on 2SXE5A-3" under Work Order 04826853-01
- Pressure boundary welds 1 and 3 fabricated during repair of 2SXL1AA-4" under Work Order 04899280-01
03.01.b - Pressurized-Water Reactor Vessel Upper Head Penetration Examination Activities.
- Liquid penetrant (PT) surface examination of reactor upper head penetrations No. 6 and 68 using procedure ER-AA-335-002
- Bare metal visual (VT) examination of reactor upper head penetrations No. 1, 24, 45, 60 and 76 using procedure ER-AP-335-001
03.01.c - Pressurized-Water Reactor Boric Acid Corrosion Control Activities.
- Boric Acid Leakage Evaluation of Component ID 2RH8703B, IR 04238047
- Boric Acid Leakage Evaluation of Component ID 2CV8444, IR 04280514
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
- (1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam administered from September 17, 2020 to December 4, 2020.
71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)
- (1) Biennial Requalification Written Examinations
The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered on November 20, 2020.
Annual Requalification Operating Tests
The inspectors evaluated the adequacy of the facility licensees annual requalification operating test.
Administration of an Annual Requalification Operating Test
The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.
Requalification Examination Security
The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.
Remedial Training and Re-examinations
The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.
Operator License Conditions
The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.
Control Room Simulator
The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.
Problem Identification and Resolution
The inspectors evaluated the licensees ability to identify and resolve problems associated with licensed operator performance.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the Control Room during refueling outage U2R22 from October 4 through October 7, 2020, including:
- Shutdown evolutions
- Emergency core cooling system full flow testing
- Reactor head lift
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator annual requalification training on November 3, 2020.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
(1)2B AF pump on November 2, 2020
- (2) Unit 2 diesel fuel oil transfer system on December 16, 2020
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Unit 2 yellow shutdown safety window with pressurizer level < 5 percent and short time to boil on October 6, 2020 (2)2PS9356B is not operable as documented in Action Request (AR) 04377380 on October 18, 2020
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (8 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
(1)1B turbine driven feedwater stop valve test as documented in AR 04372705 on October 1, 2020
- (2) Nuclear instrument N32 spiking as documented in AR 04374650 on October 6, 2020 (3)2B reactor coolant pump (RCP) oil leaks as documented in AR 04374472 on October 8, 2020
- (4) Valve 2SI8807B, will not open as documented in AR 04375187 on October 8, 2020.
- (5) Fuel moves suspended due to TRM 3.9a decay time requirements as documented in AR 04375665 on October 10, 2020 (6)2SX02K heat exchanger failed GL 89-13 acceptance criteria as documented in AR 04375807 on October 13, 2020 (7)2DG01KB-X2 lower jacket water cooler leaking 2B DG as documented in AR 04376393 on October 14, 2020
- (8) Through wall leak branch leg of tee with lines 1SX311B-6 and 1SXA3A-6 as documented in AR 04392079 on December 30, 2020
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (8 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
- (1) Valve 2SI8807B will not open as set forth in Work Order (WO) 05085974 on October 13, 2020
- (2) TS/Repair 2RH606 valve positioner as set forth in WO 05086643 on October 13, 2020
- (3) Valve 2RH610 not functioning in auto as set forth in WO 05084875 on October 13, 2020 (4)2BOSR 5.5.8.CV.5-2A, Group A Inservice Testing (IST) requirements for 2B charging pump 2CV01PB, revision 12, following maintenance on October 14, 2020 (5)2B AF pump as set forth in WO 4649471 following maintenance on October 15, 2020 (6)2B RCP following repair on October 14, 2020
- (7) SPP-20-016, Ovation U2 N-Outage MAT, Revision 0 on October 15, 2020
- (8) Low power physics testing as set forth in WO 04915374 on October 19, 2020
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated refueling outage U2R22 activities from October 5 through October 24, 2020.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) Main steam safety valve operability test as set forth in WO 04911628 on October 2, 2020
- (2) Local leak-rate test (LLRT) for P-47; 2RF026, 2RF027, and 2RF055 as set forth in WO 0491196 on October 13, 2020
71114.02 - Alert and Notification System Testing
Inspection Review (IP Section 02.01-02.04) (1 Sample)
- (1) The inspectors evaluated the following maintenance and testing of the alert and notification system:
- Annual siren inspection and maintenance records for the period from September 2018 to September 2020.
- Monthly alert notification system (siren) tests for the period from September 2018 to September 2020.
71114.03 - Emergency Response Organization Staffing and Augmentation System
Inspection Review (IP Section 02.01-02.02) (1 Sample)
- (1) The inspectors evaluated the readiness of the Emergency Preparedness Organization.
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
- (1) The inspectors completed an evaluation of submitted emergency action level and emergency plan changes on December 2, 2020. This evaluation does not constitute NRC approval.
71114.05 - Maintenance of Emergency Preparedness
Inspection Review (IP Section 02.01 - 02.11) (1 Sample)
- (1) The inspectors evaluated the maintenance of the emergency preparedness program.
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Instructions to Workers (IP Section 03.02) (1 Partial)
(1)
(Partial)
The inspectors evaluated radiological protection-related instructions to plant workers.
However, the completion of the sample requires direct inspector observations which could not be performed due to COVID-19 restrictions.
71124.04 - Occupational Dose Assessment
Source Term Characterization (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.
External Dosimetry (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to external dosimetry that is used to assign occupational dose.
Internal Dosimetry (IP Section 03.03) (1 Sample)
The inspectors evaluated the following internal dose assessments for actual internal exposures:
- (1) Dose assessment for an individual potentially exposed to airborne radioactivity during temporary ventilation system malfunction in the Unit 1 containment on March 14, 2020.
Special Dosimetric Situations (IP Section 03.04) (1 Sample)
The inspectors evaluated the following special dosimetric situations:
- (1) Effective Dose Equivalent for External Exposures related to Control Rod Drive Mechanism (CRDM) Inspections on Radiation Work Permit (RWP) BY-1-20-0067 (Task 1).
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
EP01: Drill/Exercise Performance (IP Section 02.12)===
- (1) January 1, 2019 - June 30, 2020
EP02: ERO Drill Participation (IP Section 02.13) (1 Sample)
- (1) January 1, 2019 - June 30, 2020
EP03: Alert & Notification System Reliability (IP Section 02.14) (1 Sample)
- (1) January 1, 2019 - June 30, 2020
BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)
- (1) Unit 1 (October 1, 2019 - September 30, 2020)
- (2) Unit 2 (October 1, 2019 - September 30, 2020)
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) April 2019 - September 2020
71152 - Problem Identification and Resolution
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in GL 89-13 heat exchanger (HX) failures that might be indicative of a more significant safety issue on November 10, 2020.
Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) RCCA R785 has a bent rodlet as documented in IR 04375784 on October 16,
INSPECTION RESULTS
Observation: Rod Cluster Control Assembly R785 has a bent rodlet 71152 On October 10, 2020, during insert shuffles in support of the Unit 2 refueling outage, while attempting to insert a Rod Cluster Control Assembly (RCCA) into the host assembly the crew observed a rodlet bending and immediately stopped the evolution. The licensee inspected the affected RCCA and made the decision to remove it from service. The licensee performed inspections of the RCCA tool visually and functionally, as well as the associated fuel assemblies, and did not identify any additional issues. After inspections were completed, the licensee resumed transferring the other 24 RCCAs without incident, including a replacement for the damaged RCCA.
In conjunction with the fuel vendor, the licensee chose a suitable RCCA for replacement after evaluating the available RCCAs in the spent fuel pool. The evaluation included mechanical integrity testing, to include a visual inspection and a drag test. The fuel vendor also performed an engineering evaluation to support the lifetime extension of the chosen RCCA for one additional refueling cycle. The evaluation included an evaluation of swelling, mechanical wear, risk of potential manufacturing issues, and corrosion. The vendor concluded that the chosen RCCA was an acceptable replacement for use provided it not be used in a shutdown bank, the RCCA be parked at 231 steps or at 225 steps for the upcoming cycle, and that the exposure for the RCCA does not exceed 16 effective full power years.
On November 22, 2020, while performing training with a dummy fuel assembly and dummy RCCA, the licensee observed a similar bending of a rodlet while lowering the RCCA into the assembly. The licensee removed the RCCA tool from service pending an investigation of the tool by the vendor.
The inspectors reviewed the corrective action program (CAP) causal evaluation performed by the licensee for the initial occurrence of the rodlet bending during insert shuffles. The inspectors determined that the actions taken by the licensee were commensurate with the safety significance of the issue and in accordance with site procedures. The inspectors reviewed the engineering evaluation on the replacement RCCA chosen from the spent fuel pool and concluded that there is reasonable assurance that the replacement RCCA will perform as required for the upcoming cycle. At the time of this report, the investigation of the RCCA tool by the vendor is scheduled to be complete in February of 2021 and is being tracked in the licensee's CAP.
The inspectors did not identify any findings or violations during this inspection sample.
Observation: Generic Letter 89-13 Heat Exchanger Inspection Failures 71152 Inspectors performed a semi-annual trend review of as-found heat exchanger inspections performed by the licensee between May 1, 2020, and December 15, 2020. Inspections were performed in accordance with licensee procedure BVP 800-30, Essential Service Water Fouling Monitoring Program, which is the licensee's Generic Letter (GL) 89-13 program basis document and identifies the procedures and methodology used to control and monitor fouling of the safety related service water system piping, components, and heat exchangers at Byron in accordance with the licensees official response to NRC. Over this time period, the licensee performed seven as-found heat exchanger inspections. Of the seven inspections, five inspections failed to meet the acceptance criteria for tube blockage and were entered in the CAP as listed below:
- AR 04343226 2SX01AB HX Failed GL 89-13 Acceptance Criteria on May 14, 2020;
- AR 04349085 2SX01AA HX Failed GL 89-13 Acceptance Criteria on June 09, 2020;
- AR 04370066 1SI01SB HX Failed GL 89-13 Acceptance Criteria on September 17, 2020;
- AR 04375807 2SX02K HX Failed GL 89-13 Acceptance Criteria on October 10, 2020; and
- AR 04387841 2SX01AA As found Heat Exchanger Inspection on December 03, 2020.
The inspectors reviewed the past operability evaluation performed by the licensee for each as-found heat exchanger inspection failure. The inspectors determined that in each case, the licensee provided reasonable assurance that the safety related components supported by each heat exchanger would have been able to perform their safety functions as required during a design basis accident.
During their review, inspectors reviewed GL 89-13 inspections from previous years on the heat exchangers listed above to determine if an adverse trend existed. Inspectors noted that the 2A essential service water pump lube oil cooler (2SX01AA) has failed six out of its last seven GL 89-13 heat exchanger inspections since 2016. The 2B essential service water pump lube oil cooler (2SX01AB) has failed two out of three GL 89-13 heat exchanger inspections since 2016. The acceptance criteria for tube blockage on the 2SX01AA and 2SX01AB heat exchangers, as determined by Byron calculation BYR03-115 (EC 628987), is no greater than four total blocked tubes.
ER-AA-340-1001, "GL 89-13 Program Implementation Instructional Guide," states, in part, that the licensee should evaluate past heat exchanger cleaning and inspection frequency against as found conditions to determine if the frequency is adequate. Additionally, the licensee should document the justification for the chosen frequency of cleaning and inspecting to ensure that the heat removal requirements for the system are satisfied. Based on the inspectors review of previous GL 89-13 inspections, the licensees practice is to reduce the inspection frequency by one half upon a failure to meet the acceptance criteria for tube blockage (e.g., from two years to one year). The current inspection frequency for 2SX01AA is every six months while the inspection frequency for 2SX01AB is every year.
The inspectors reviewed the most recent licensee evaluation of the inspection frequencies for both heat exchangers after their respective inspection failures. In both cases, the licensee determined that the heat exchanger inspection frequencies would remain unchanged. The licensee highlighted previous engineering calculations concerning the heat removal capability of the coolers and noted that reducing the frequency further would increase unavailability on a mitigating system perform index (MSPI) related train in order to perform the inspections.
Inspectors noted that one particular GL 89-13 inspection failure captured under AR 02735109 on October 31, 2016, documented a failed inspection for the 2SX01AA heat exchanger in which five tubes were fully blocked and seven tube were partially blocked on the inlet/outlet tube side, and seven tubes were found fully blocked and four tubes were partially blocked on the reversing end of the heat exchanger. The licensee performed an evaluation of the condition under Engineering Change (EC) 617320 and determined that lube oil temperatures would have remained acceptable under design basis conditions even with the reported tube blockage.
Following the condition evaluated in AR 02735109, programmatically driven evaluations performed by the licensee for subsequent inspection failures have continuously highlighted EC 617320 as justification for why exceeding the tube plugging limit in BYR03-115 would not have challenged the safety function of the essential service water (SX) pump. Additionally, the licensee has also repeatedly highlighted an evaluation performed at the Braidwood Station of a similar condition deemed acceptable under EC 619171. The Byron and Braidwood Station essential service water pumps are a similar design.
On February 12, 2019, the licensee completed a GL 89-13 program self-assessment. An action from that assessment was generated in the CAP under AR 04136180-11 for the site to determine if the essential service water pump lube oil coolers could be removed from the GL 89-13 program based on previous EC evaluations. The licensee stated that preliminary information received from the vendor verified that the oil coolers heat exchanging properties are not required for SX pump bearing health and that eliminating the oil coolers would be acceptable for normal and accident operation. The due date for this action item, however, has been pushed to March 25, 2022, awaiting the final decision on the permanent shutdown of Byron Station.
Specifically concerning the 2SX01AA and 2SX01AB heat exchangers, the inspectors determined that by waiting to evaluate whether the heat exchangers can be removed from the GL 89-13 program until March 25, 2022, combined with not taking any additional programmatic actions for GL 89-13 inspection failures, the licensee appears to be creating a de facto alternate set of acceptance criteria by which the heat exchangers are being evaluated against after an inspection failure occurs. In doing this, the licensee has set up a rear looking program in which there is a presumption that any failure to meet the acceptance criteria given in BYR03-115 will be acceptable because EC 617320 will justify past operation of the heat exchanger, given a certain amount of tube blockage, and therefore the safety related function of the components supported by each heat exchanger will have been preserved. As such, by entering each inspection failure into the CAP and generating actions to perform programmatic evaluations the licensee is meeting the requirements of BVP 800-30; however, without taking action to either change the acceptance criteria, change the inspection frequency, or justify the exclusion of the heat exchangers from the program, the likely outcome is that the whole scenario will repeat itself upon the next inspection failure. This practice has the potential to put an undue strain on site resources and can reduce the sites focus on other safety significant work.
The inspectors did not identify any findings or violations during this sample.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On January 13, 2021, the inspectors presented the integrated inspection results to Mr. M. Kanavos, Site Vice President, and other members of the licensee staff.
- On October 2, 2020, the inspectors presented the emergency preparedness baseline inspection results to Mr. M. Kanavos, Site Vice President, and other members of the licensee staff.
- On October 16, 2020, the inspectors presented the Inservice Inspection results to Mr. Harris Welt, Plant Manager, and other members of the licensee staff.
- On October 26, 2020, the inspectors presented the radiation protection inspection results to Mr. J. Reed, Radiation Protection Manager, and other members of the licensee staff.
- On December 2, 2020, the inspectors presented the emergency action level and emergency plan changes inspection results to Mr. D. Moore, Senior Manager - Emergency Preparedness, and other members of the licensee staff.
- On December 8, 2020, the inspectors presented the biennial licensed operator requalification program inspection results to Mr. K. McGuire, Operations Director, and other members of the licensee staff.
- On December 10, 2020, the inspectors presented the radiation protection inspection results to Mr. J. Reed, Radiation Protection Manager, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
BOP AF-E2A
Auxiliary Feedwater Train A Electrical Lineup
BOP AF-M2
Auxiliary Feedwater System Valve Lineup
BOP AF-M2A
Auxiliary Feedwater System Train A Valve Lineup
Fuel Pool Cooling - Electrical Lineup
Fuel Pool Cooling and Cleanup System Valve Lineup
Fire Plans
FZ 1.2A-2
Aux Building 346'0" ELE. 2A RHR Pump Room
FZ 12.1-0
Fuel Handling Building 401'-0" Elevation
FZ 9.2-2
Aux Building 401'0" Elevation 2A Diesel Generator & Day
Tank Room
Corrective Action
Documents
238047
Boric Acid Leakage Evaluation for Component ID
2RH8703B
04/19/2020
238994
Indications Observed During ISI Exam of 2RC-01-BA/SGN-
04/12/2019
280514
Boric Acid Leakage Evaluation for Component ID 2CV8444
10/14/2019
04362874
B2R22 ISI Scope Deferred Due to Ongoing COVID-19
08/13/2020
Corrective Action
Documents
Resulting from
Inspection
04374742
Incorrect NDE Report # Entered in B2R21 WO# 04826853-
WDR
10/06/2020
Miscellaneous
1-53B
Procedure Qualification Record (PQR)
01/29/1986
2-53A
Procedure Qualification Record (PQR)
2/12/1986
WPS 1-1-GTSM-
ASME Welding Procedure Specification Record
WPS 1-8-GTSM
ASME Welding Procedure Specification Record
NDE Reports
2019-034
03/20/2019
2019-035
03/20/2019
2019-036
03/20/2019
2019-037
03/21/2019
2019-039
03/21/2019
2019-MT-012
04/13/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2019-MT-013
04/13/2019
20-UT-047
10/07/2020
20-VT-010
10/07/2020
10/08/2020
10/08/2020
10/07/2020
Reactor Vessel Head Bare Metal Visual Examination Record 10/11/2020
10/07/2020
Procedures
Guidance for Performing Thermal Fatigue Examinations
When Utilizing Generic Procedure PDI-UT-2
Liquid Penetrant (PT) Examination
ER-AA-335-015-
2013
VT-2 Visual Examination in Accordance with ASME 2013
Edition
Ultrasonic Examination of Austenitic Piping Welds
Bare Metal Visual Examination for Nickel Alloy Materials
PDI-UT-2
Generic Procedure for the Ultrasonic Examination of
Austenitic Pipe Welds
H
PDI-UT-2 Table 1
PDI-UT-2 Table 2
03/04/2020
Work Orders
04826853-01
MM Repair Leak by Replacing Elbow
04/13/2019
04899280-01
MM - Potential Inactive Leak on 2SXL1AA-4" Line
04/04/2019
Corrective Action
Documents
4.0 Critique FOR 2FW-541A Failure
10/30/2018
4.0 Critique for U-1 Main Condenser Vacuum Degrading -
Prompt Investigation and Site Communication Actions Will
be Performed Under IR 4209128
01/09/2019
4.0 Critique - 2C MSIV Standby Actuation Train Leak
08/21/2019
4.0 Critique - EH Return Filter Response
2/12/2020
Trend in HU Fundamental Usage in Operations (CAPE)
06/12/2020
Corrective Action
Documents
Resulting from
Inspection
Simulator Set-up Procedure TQ-BY-201-0113 Was Not
Followed, Challenging LORT Exam Security During the
Annual Exam
11/16/2020
Simulator Work Request (SWR) Written to Investigate
Status Lights on 1PM04J. When the Valves were Closed the
11/18/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Light Needed Tapping to Light and Show That Valves Were
Closed.
Miscellaneous
20 JPM Wk 1
20 Byron Annual Operating Test Week 1 Job
Performance Measures (N001a, N019, N089a, N136, N144,
S033t)
06/12/2020 -
06/22/2020
20 JPM Wk 5
20 Byron Annual Operating Test Week 5 Job
Performance Measures (N042, N046, N088, N128a, N147a,
S035t)
06/15/2020 -
06/23/2020
20 Op-Test
Outline
20 Byron Annual Operating Test Outline
11/09/2020
20 Scn Wk 1
20 Byron Annual Operating Test Week 1 Scenarios
(BY-59R3, BY-70R3)
09/09/2020
20 Scn Wk 5
20 Byron Annual Operating Test Week 5 Scenarios
(BY-44R7, BY-73R9)
06/09/2020
JPM N147a
LORT Annual Exam JPM Performed 11/17/2020 in the
Simulator
6/22/2020
Reviewed 6 Medical Records (3 RO and 3 SRO) to Assess
Compliance with 10CFR55.53 and Medical Fitness
2/2019
ATTACHMENT 1
Several Active License Tracking Logs (Record of 8 / 12 Hour
Shifts Worked During Quarter) to Assess the Licensees
Program for Ensuring that Licensed Operators Meet the
Conditions of their Licenses
TQ-AA-224-F100
Reviewed 15 Individual "Remedial Training Notification and
Action on Failure" Forms for LORT Remediations Performed
from 2018 to 2020
- 8
TQ-AA-306-J002
Test Report Documenting the Simulator's Testing
Completed Since the Previous Report on 11/5/2018
Documenting Conformance to the Requirements of ANSI 3.5
2009Property "ANSI code" (as page type) with input value "ANSI 3.5</br></br>2009" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. and Regulatory Guide 1.149 Revision 4
Vision ID 337340
20 Week 5 Biennial SRO Written Exam
11/11/2020
Vision ID 342306
20 Week 5 Biennial RO Written Exam
11/06/2020
Procedures
TQ-AA-150-J202
LORT Annual Exam Development Job Aid
005
Conduct of Simulator Training and Evaluation
010
Examination Security and Administration
017
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
TQ-BY-201-0113,
1,
PRE - Simulator
Examination
Security Checklist
The Examination Security Checklist That Was Not
Performed Properly, Resulting in the Exam Security
Challenge Documented by AR 4384222 and Subsequent
Reviews
11/12/2020
71111.11Q Miscellaneous
Operations Scenarios
11/03/2020
Procedures
Maintenance Rule Implementation Per NEI 18-19
Corrective Action
Documents
04375187
2SI8807B Will Not Open
10/08/2020
04377380
2PS9356B is Not Operable
10/17/2020
Engineering
Changes
Documentation of the Basis for Maximum Allowed Leakage
Rate in Procedures 1/2BVSR 6.1.1-26
Miscellaneous
Penetration/Valve:
P-70, 2PS9356B
Containment Boundary Repair Deferral Form
10/17/2020
Calculations
Generic Jacket Water Leakage Evaluation for Emergency
Diesel Generators
06/02/2000
Design Attribute Review CC-AA-102-F-01
Corrective Action
Documents
04372705
1B TDFW Pump Stop Valve Test Failure
09/28/2020
04373650
N32 Spiking
11/05/2020
04374472
2B RCP Oil Leaks
10/05/2020
04375187
2SI8807B Will Not Open
10/08/2020
04375665
TRM 3.9A, Decay Time Requirements and Fuel Moves
10/09/2020
04375807
2SX02K HX Failed GL 89-13 Acceptance Criteria
10/10/2020
04376393
2DG01KB-X2 LWR JKT Water Cooler Leaking 2B DG
10/13/2020
04392079
Through Wall Leak Branch Leg of Tee with Lines 1SX211B-
6" & 1SXA3A=6"
2/25/2020
Engineering
Changes
633450
Operability Evaluation 20-002
Past Operability Evaluation for 2B AF Pump Right Angle
Gear Lube Oil Cooler - 2SX02K
Procedures
GL 89-13 Program Implementation Instructional Guide
Corrective Action
Documents
04374416
2RH610 Not Functioning in Auto
10/05/2020
04375187
2SI8807B Will Not Open
10/08/2020
04375247
2RH606 is Not Full Open
10/08/2020
04375488
2RH606 Valve Control Issue
10/09/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
04375187
2SI8807B Will Not Open
10/08/2020
NF-BY-510
Low Power Physics Testing
SFP-20-016
Ovation U2 N-Outage MAT
Work Orders
04915374
Low Power Physics Testing
10/19/2020
04942198
EWP MM: 2CV01PB Repair Inboard Bearing Housing Oil
Leak
10/09/2020
05084875
EWP IM Troubleshoot 2FIS-0610
10/10/2020
05085974
2SI8807B Will Not Open
10/09/2020
4649471
Replace 2B AF Pump Outboard Seal and PMT
10/14/2020
4948255
Unexpected Alarm: 2B RCP Upper Oil Reservoir
10/09/2020
Engineering
Evaluations
BY-MODE-030
TS 3.0.4.B Evaluation - Mode Change with Technical
Specifications Equipment Out of Service
Procedures
2BGP 100-2A1
Reactor Startup
BOP PC-1T1
Unit 1/2 - Containment Closure Verification Checklist
Procedures
2BOSR 6.1.1-18
Unit 2 Primary Containment Type C Local Leakage Rate
Tests and IST Tests of Containment Floor Drains System
BVP 800-39
Byron Containment Leakage Rate Testing Program
Primary Containment Leakrate Testing Program
Work Orders
0491196
Main Steam Safety Valves Operability Tests
10/02/2020
Corrective Action
Documents
EP-Siren Failure (BY17)
08/05/2019
EP-Siren Failure (BY53)
08/12/2019
EP-Siren Failure (BY05)
08/14/2019
EP-Siren Failure (BY02)
09/17/2019
EP-Siren Failure (BY53)
11/05/2019
EP-Siren Failure (BY02)
01/06/2020
EP-Siren Failure (BY59)
05/18/2020
EP-Siren Failure (BY27)
05/26/2020
Miscellaneous
Exelon Nuclear Manager, Midwest Emergency
Preparedness Letter to Program Enhancement Manager,
Illinois Emergency Management Agency; Submission of
Byron Generating Station Public Alert and Notification
System (ANS) Design Report, Revision 3
10/01/2018
Byron Station 2018 Warning System Maintenance &
01/01/2018 -
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Operational Reports
2/31/2018
Byron Station 2019 Warning System Maintenance &
Operational Reports
01/01/2019 -
2/31/2019
Byron Station 2020 Warning System Maintenance &
Operational Reports
01/01/2020 -
2/31/2020
Byron Station Monthly Siren Availability Reports
09/01/2018 -
08/31/2020
Byron Station Siren Corrective Maintenance Reports
09/01/2018 -
08/31/2020
2019/2020 Emergency Planning for the Byron Area
(Community Information Booklet)
7/19/2019
- U.S. Department of Homeland Security, FEMA Letter;
Backup Alert and Notification System
2/10/2012
KLD-TR-986
Byron Generating Station Alert and Notification System
(ANS) Design Report
09/19/2018
Procedures
Exelon Nuclear Standardized Radiological Emergency Plan
Section E
Exelon Nuclear Radiological Emergency Plan Annex for
Byron Station, Section 4
Corrective Action
Documents
294834
Byron EP Unannounced ERO Augmentation Call in Drill
Results
10/26/2019
Annual Test of ERO Back-Up Notification System
2/18/2019
ERO Vacancy - Replacement Needed
03/04/2020
Miscellaneous
Quarterly Unannounced Off-Hours Call-In Augmentation Drill
Results
09/01/2018 -
08/31/2020
Emergency Response Organization Duty Team Roster
08/31/2020
ERO Staff Training Records Review (Sample - 10)
Procedures
Exelon Nuclear Standardized Radiological Emergency Plan,
Sections B and N
Appendix 5
ERO Staffing and Augmentation
Exelon Nuclear Radiological Emergency Plan Annex for
Byron Station, Section 2
Exelon Nuclear Radiological Emergency Plan Annex for
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Byron Station, Addendum 1, On-Shift Staffing Technical
Basis
EP-AA-112-100-
F-06
ERO Notification or Augmentation
X
TSC Activation and Operation
OSC Activation and Operation
EOF Activation and Operation
EP-AA-120-F-02
EP Staff Initial Developmental Checklist
H
ERO Training and Qualification
Corrective Action
Documents
Perform Impact Review of EAL Revisions for EOP/SAMG
03/10/2020
EP FAQ EAL Change License Amendment Implementation
Actions
03/20/2020
NOS ID: Revise Standardized Emergency Plan
03/26/2020
EPlan: CDAM 50.54(q) Potential Deficiencies
04/09/2020
Miscellaneous
Eval No. 19-29
Exelon Nuclear Standardized Radiological Emergency Plan
09/04/2019
Eval No. 19-65
Exelon Nuclear Standardized Radiological Emergency Plan
09/06/2019
Eval No. 19-79
Various Station Emergency Plan Annexes
11/08/2019
Eval No. 19-80
On-Shift Staffing Assessments
11/08/2019
Eval No. 20-25
EALs for Byron Station
06/04/2020
Corrective Action
Documents
EP Benchmark Recommendation #1
10/13/2018
EMNET Phone Issues
05/13/2019
Byron EP Dixon Alt Facility - Supplies Missing
09/27/2019
NRC Red Phone Not Working in Main Control Room
2/12/2019
MET Tower 250 Ft. Wind Speed Instrument Failure
01/10/2020
2/26/2020
NRC ENS (Red) Phone Not Working
04/27/2020
Outdated URI Software Found on Three TSC Computers
04/29/2020
EP CFAM Indicators - 3 Month Decline - March
05/05/2020
Byron NRC FTS Phones Will Not Ring in the TSC
05/11/2020
Byron 2020 HP Drill - Lessons Learned
06/12/2020
NRC (ENS) Red Phone Not Working in Main Control Room
07/30/2020
Corrective Action
Documents
NRC ID - Inventory Observations
09/30/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Resulting from
Inspection
Miscellaneous
EP-MW-124-
1001-F-01
Control Room/Simulator Inventory Records
10/01/2018 -
06/30/2020
EP-MW-124-
1001-F-02
CR/Simulator/TSC/OSC Equipment Test - TSC Software
and Reference Document Inventory Records
10/01/2018 -
06/30/2020
EP-MW-124-
1001-F-03
Technical Support Center Inventory Records
10/01/2018 -
06/30/2020
KLD-TR-1001
Byron Generating Station 2018 Population Update Analysis
07/05/2018
KLD-TR-1081
Byron Generating Station 2019 Population Update Analysis
09/07/2019
KLD-TR-1180
Byron Generating Station 2020 Population Update Analysis
09/05/2020
KLD-TR-637
Evacuation Time Estimates for Byron Station Plume
Exposure Pathway Emergency Planning Zone
Procedures
Exelon Nuclear Standardized Radiological Emergency Plan
Section J, Protective Response
Exelon Nuclear Radiological Emergency Plan Annex for
Byron Station, Section 3, Classification of Emergencies
EP-AA-1002; Exelon Nuclear Radiological Emergency Plan
Annex for Byron Station, Section 5.1, Emergency Response
Facilities
Addendum 3
Emergency Action Levels for Byron Station
Drills and Exercise Program
ALARA Plans
BY-2-20-00613
Rx Head Dis-Assembly / Re-Assembly
09/26/2020
BY-2-20-00623
Rx Cavity Decontamination - TASK 1 / 2
09/29/2020
Radiation Work
Permits (RWPs)
BY-2-20-00513
Aux / Containment RP Activities
Corrective Action
Documents
Containment Evacuation Required Due to Airborne
Radiation
03/14/2020
Miscellaneous
BYR-20-002
20 Bioassay Program Annual Review at Byron Nuclear
Power Station
NCS-19-002
Removing SRD/DLR Bias
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
NVLAP Lab Code
100518-0
Certificate of Accreditation to ISO/IEC 17025:2005
01/01/2020 -
2/31/2020
Project ID#
EX001-
3P61BYRON-05
Report of Analysis/Certificate of Conformance
09/23/2019
13
EID KRAME4049
Multiple Dosimetry EDE Evaluation Sheet
03/12/2020
EID Garci8849
Intake Investigation Form and Supporting Documents
03/24/2020
Alpha Area Level Assessment - Unit 1
07/05/2020
RWP BY-0-19-
00305
Planned Dose Rate Alarm Form
10/04/2019
Teledyne Brown
Engineering
Project ID#
EX001-
3P61BYRON-05
Report of Analysis/Certificate of Conformance
09/23/2019
Procedures
NISP-RP-003
Radiological Air Sampling
Dosimetry Issue, Usage, and Control
Methods for Estimating Internal Exposure from In Vivo and
In Vitro Bioassay Data
Radiation
Surveys
20-066849
B/C Steam Generator Platform
03/12/2020
Radiation Work
Permits (RWPs)
BY-1-20-00608
Rx Head and Vessel Internal ISI (Bare Metal Exam)
Self-Assessments AR 4198147
Radiation Protection Dosimetry - Exelon Stations
11/20/2019
71151
Miscellaneous
RCS Data 10/01/2019 - 09/30/2020
Monthly Data Elements for NRC Occupational Exposure
Control Effectiveness
April 2019 -
September
20
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Calculations
BYR03-115 (EC 28987)
SX Pump Oil Cooler Allowable Tube Blockage
Acceptance Criteria for As-Found Heat Exchanger Tube
Blockage
Past Operability Evaluation for 2B AF Pump Right Angle
Gear Lube Oil Cooler-2SX02K
Reportability Evaluation for 2A SX Pump Oil Cooler Silting
Review of Calculation BRW-95-218 for Application to
Identified Low Flow Condition on SX Oil Cooler
Corrective Action
Documents
04083000
2SX01AA Heat Exchanger Failed GL 89-13 Inspection
2/11/2017
230570
2SX01AB HX Failed GL 89-13 Acceptance Criteria
03/18/2019
245333
2SX01AA HX Failed GL 89-13 Acceptance Criteria
05/01/2019
04302832
2SX01AA HX Failed GL 89-13 Acceptance Criteria
2/10/2019
04349085
2SX01AA HX Failed GL 89-13 Acceptance Criteria
06/04/2020
04375785
RCCA R785 Has a Bent Rodlet
10/10/2020
04379007
Bent RCCA Rodlet
10/23/2020
Engineering
Changes
Past Operability Evaluation for the 1B SI Pump
Engineering
Evaluations
NF-CB-30-150
Review of RCCA R609 at Byron Unit 2
10/16/2020
Procedures
BVP 800-30
Essential Service Water Fouling Monitoring Program (GL 89-13 Program Basis Document)
GL 89-13 Program Implementation Instructional Guide
Service Water Heat Exchanger Inspection Guide
Self-Assessments 4136180
GL 89-13 Triennial Ultimate Heat Sink Inspection
2