Text

IR 05000454-13-004 & 05000455-13-004; 07/01/2013 - 09/30/2013; Byron Station, Units 1 and 2
	ML13318B061
Person / Time
Site:	Byron
Issue date:	11/14/2013
From:	Eric Duncan; Region 3 Branch 3
To:	Pacilio M; Exelon Generation Co, Exelon Nuclear
References
	IR-13-004
	Download: ML13318B061 (56)
	v • d • e

UNITED STATES ber 14, 2013

SUBJECT:

BYRON STATION, UNITS 1 AND 2, NRC INTEGRATED INSPECTION REPORT 05000454/2013004; 05000455/2013004

Dear Mr. Pacilio:

On September 30, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Byron Station, Units 1 and 2. The enclosed report documents the results of this inspection, which were discussed on October 8, 2013, with Mr. R. Kearney and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, no findings of significance were identified. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and 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 System (PARS)

component of NRC's Agencywide Documents Access and Management System (ADAMS),

accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Eric R. Duncan, Chief Branch 3 Division of Reactor Projects Docket Nos. 50-454; 50-455 License Nos. NPF-37; NPF-66

Enclosure:

Inspection Report 05000454/2013004; 05000455/2013004 w/Attachment: Supplemental Information

REGION III==

Docket Nos: 50-454; 50-455 License Nos: NPF-37; NPF-66 Report No: 05000454/2013004; 05000455/2013004 Licensee: Exelon Generation Company, LLC Facility: Byron Station, Units 1 and 2 Location: Byron, IL Dates: July 1 through September 30, 2013 Inspectors: B. Bartlett, Senior Resident Inspector J. Robbins, Resident Inspector J. Draper, Reactor Engineer J. Cassidy, Senior Health Physicist L. Carson, Senior Health Physicist - Region IV T. Go, Health Physicist J. Rivera, Health Physicist - Region II C. Thompson, Resident Inspector, Illinois Emergency Management Agency Approved by: E. Duncan, Chief Branch 3 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

Inspection Report (IR) 05000454/2013004; 05000455/2013004; 07/01/2013 - 09/30/2013;

Byron Station, Units 1 and 2.

This report covers a three-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4.

NRC-Identified

and Self-Revealed Findings None

Licensee-Identified Violations

None

REPORT DETAILS

Summary of Plant Status

Unit 1 operated at or near full power throughout the inspection period.

Unit 2 operated at or near full power throughout the inspection period.

REACTOR SAFETY

Cornerstone: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Main article: IP 71111.01

.1 Readiness for Impending Adverse Weather Condition

a. Inspection Scope

Since high temperatures were predicted coincident with work on the ultimate heat sink (UHS) cooling towers on September 10, 2013, the inspectors reviewed the licensees overall preparations and protection for the expected weather conditions. The inspectors compared the licensee staffs preparations with site procedures and determined whether the staffs planned actions were adequate. During the inspection, the inspectors focused on plant-specific design features and the licensees procedures used to respond to specified adverse weather conditions. The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant.

Additionally, the inspectors reviewed the Updated Final Safety Analysis Report (UFSAR)and performance requirements for systems selected for inspection, and verified that operator actions were appropriate as specified by plant specific procedures. The inspectors also verified that the licensee identified adverse weather issues at an appropriate threshold and dispositioned them through the corrective action program (CAP) in accordance with station corrective action procedures. Documents reviewed are listed in the Attachment.

This inspection constituted one readiness for impending adverse weather condition sample as defined in Inspection Procedure (IP) 71111.01-05.

b. Findings

No findings were identified.

1R04 Equipment Alignment

Main article: IP 71111.04

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk-significant systems:

Unit 2 Train B Diesel Generator (DG) Following the Emergent Failure of the Unit 2 Train A DG;

Unit 1 Train B Residual Heat Removal During Planned Work on Train A of Residual Heat Removal; and

Unit 0 Train B Control Room Ventilation During Planned Work on Train A of Control Room Ventilation.

The inspectors selected these systems based on their risk significance relative to the Reactor Safety Cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could impact the function of the system and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, the UFSAR, Technical Specification (TS) requirements, outstanding work orders (WOs), issue reports (IRs), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment.

These activities constituted three partial system walkdown samples as defined in IP 71111.04-05.

b. Findings

No findings were identified.

.2 Semi-Annual Complete System Walkdown

a. Inspection Scope

On September 16, 2013, the inspectors performed a complete system alignment inspection of the Unit 2 Train B auxiliary feedwater system while the Unit 2 Train A auxiliary feedwater system was out of service for planned maintenance to verify the functional capability of the system. This system was selected because it was considered both safety significant and risk significant in the licensees probabilistic risk assessment.

The inspectors walked down the system to review mechanical and electrical equipment lineups; electrical power availability; system pressure and temperature indications; component labeling; component lubrication; component and equipment cooling; hangers and supports; operability of support systems; and to ensure that ancillary equipment or debris did not interfere with equipment operation. A review of a sample of past and outstanding WOs was performed to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the CAP database to ensure that system equipment alignment problems were being identified and appropriately resolved. Documents reviewed are listed in the Attachment.

These activities constituted one complete system walkdown sample as defined in IP 71111.04-05.

b. Findings

No findings were identified.

1R05 Fire Protection

Main article: IP 71111.05

.1 Routine Resident Inspector Tours

Main article: IP 71111.05Q

a. Inspection Scope

The inspectors conducted fire protection walkdowns which were focused on the availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:

Fire Zone 11.6-0, Auxiliary Building, Elevation 426, General Area;

Fire Zone 11.2-0, Auxiliary Building, Elevation 346, Unit 2 General Area;

Fire Zone 5.1-1, Division 12 4 kilovolt (kV) Switchgear Room;

Fire Zone 5.1-2, Division 22 4kV Switchgear Room;

Fire Zone 5.2-1, Division 11 4kV Switchgear Room; and

Fire Zone 5.2-2, Division 21 4kV Switchgear Room.

The inspectors reviewed these areas and determined whether the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and implemented adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems, or features in accordance with the licensees fire plan. The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plants ability to respond to a security event. Using the documents listed in the Attachment, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensees CAP.

These activities constituted six quarterly fire protection inspection samples as defined in IP 71111.05-05.

b. Findings

No findings were identified.

.2 Annual Fire Protection Drill Observation

Main article: IP 71111.05A

a. Inspection Scope

On August 13, 2013, the inspectors observed a fire brigade activation for a fire in the maintenance shop tool storage area. This drill included participation of offsite fire teams.

Based on this observation, the inspectors evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that the licensee staff identified deficiencies, openly discussed them in a self-critical manner at the drill debrief, and took appropriate corrective actions. Specific attributes evaluated were:

proper wearing of turnout gear and self-contained breathing apparatus;

proper use and layout of fire hoses;

employment of appropriate firefighting techniques;

sufficient firefighting equipment brought to the scene;

effectiveness of fire brigade leader communications, command, and control;

search for victims and propagation of the fire into other plant areas;

smoke removal operations;

utilization of pre-planned strategies;

adherence to the pre-planned drill scenario; and

drill objectives.

Documents reviewed are listed in the Attachment to this report.

These activities constituted one annual fire protection inspection sample as defined in IP 71111.05-05.

b. Findings

No findings were identified.

1R06 Flooding

Main article: IP 71111.06

.1 Internal Flooding

a. Inspection Scope

The inspectors reviewed selected risk important plant design features and licensee procedures intended to protect the plant and its safety-related equipment from internal flooding events. The inspectors reviewed flood analyses and design documents, including the UFSAR, engineering calculations, and abnormal operating procedures to identify licensee commitments. In addition, the inspectors reviewed licensee drawings to identify areas and equipment that may be affected by internal flooding caused by the failure or misalignment of nearby sources of water, such as the fire suppression or the circulating water systems. The inspectors also reviewed the licensees corrective action documents with respect to past flood-related items identified in the CAP to verify the adequacy of the corrective actions. The inspectors performed a walkdown of the following plant area to assess the adequacy of watertight doors and verify drains and sumps were clear of debris and were operable, and that the licensee complied with its commitments:

Units 1 and 2 Train A Essential Service Water Pump Room.

Documents reviewed are listed in the Attachment.

This inspection constituted one internal flooding sample as defined in IP 71111.06-05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

Main article: IP 71111.11

.1 Quarterly Review of Licensed Operator Requalification

Main article: IP 71111.11Q

a. Inspection Scope

On July 30, 2013, the inspectors observed a crew of licensed operators in the plants simulator during licensed operator requalification training to verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:

licensed operator performance;

crews clarity and formality of communications;

ability to take timely actions in the conservative direction;

prioritization, interpretation, and verification of annunciator alarms;

correct use and implementation of abnormal and emergency procedures;

control board manipulations;

oversight and direction from supervisors; and

ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications.

The crews performance in these areas was compared to pre-established operator action expectations, procedural compliance, and successful critical task completion requirements. Documents reviewed are listed in the Attachment.

This inspection constituted one quarterly licensed operator requalification program simulator sample as defined in IP 71111.11

b. Findings

No findings were identified.

.2 Quarterly Observation of Heightened Activity or Risk

Main article: IP 71111.11Q

a. Inspection Scope

On September 4, the inspectors observed operations staff performing control board manipulations during required TS surveillance testing. This was an activity that required heightened awareness or was related to increased risk. The inspectors evaluated the following areas:

licensed operator performance;

crews clarity and formality of communications;

ability to take timely actions in the conservative direction;

prioritization, interpretation, and verification of annunciator alarms;

correct use and implementation of procedures;

control board manipulations;

oversight and direction from supervisors; and

ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications.

The performance in these areas was compared to pre-established operator action expectations, procedural compliance, and successful critical task completion requirements. Documents reviewed are listed in the Attachment.

This inspection constituted one quarterly licensed operator heightened activity/risk sample as defined in IP 71111.11.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

Main article: IP 71111.12

.1 Routine Quarterly Evaluations

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following risk-significant system:

Auxiliary Building Ventilation (VA)

The inspectors reviewed events including those in which ineffective equipment maintenance had resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:

implementing appropriate work practices;

identifying and addressing common cause failures;

scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule;

characterizing system reliability issues for performance;

charging unavailability for performance;

trending key parameters for condition monitoring;

ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and

verifying appropriate performance criteria for structures, systems, or components (SSCs)/functions classified as (a)(2), or appropriate and adequate goals and corrective actions for systems classified as (a)(1).

The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment.

This inspection constituted one quarterly maintenance effectiveness sample as defined in IP 71111.12-05.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

Main article: IP 71111.13

.1 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the licensee's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that appropriate risk assessments were performed prior to removing equipment for work:

Unit 2 Risk Following the Emergent Failure of the Unit 2 Train A DG;

Unit 2 Risk During Emergent Repair of the Unit 2 Train B DG;

Plant Risk During Emergent Repair of Transmission Equipment Associated with Line 0627; and

Plant Risk with Switchyard Bus 7 Out of Service while Direct Current Bus 111 Charger was Out of Service.

These activities were selected based on their potential risk significance relative to the Reactor Safety cornerstones. As applicable for each activity, the inspectors verified that risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate and complete. When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met. Documents reviewed are listed in the Attachment.

These maintenance risk assessments and emergent work control activities constituted four samples as defined in IP 71111.13-05.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

Main article: IP 71111.15

.1 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following issues:

Unit 2 Train A Diesel Generator Injection Pump Hold Down Bolt Failure;

Operation of Unit 2 with 1 of 54 Reactor Vessel Closure Bolts Removed from Service;

Operability Evaluation 13-005, GDC [General Design Criteria] 5 Concern with Sharing of Essential Service Water Cooling Tower; and

Operability Evaluation 12-005, HELB [High Energy Line Break] Load Not Considered in Structural Calculation.

The inspectors selected these potential operability issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS and UFSAR to the licensees evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors reviewed a sample of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Documents reviewed are listed in the

.

This operability inspection constituted four samples as defined in IP 71111.15-05.

b. Findings

No findings were identified.

1R18 Plant Modifications

Main article: IP 71111.18

.1 Plant Modifications

a. Inspection Scope

The inspectors reviewed the following modifications:

Essential Service Water Cooling Tower (SXCT) Capacity Reduction; and

Essential Service Water Cooling Tower Tornado Missile Protection.

The inspectors reviewed the configuration changes and associated 10 CFR 50.59 safety evaluation screening against the design basis, the UFSAR, and the TS, as applicable, to verify that the modification did not affect the operability or availability of the affected systems. The inspectors, as applicable, observed ongoing and completed work activities to ensure that the modifications were installed as directed and consistent with design control documents; the modifications operated as expected; post-modification testing adequately demonstrated continued system operability, availability, and reliability; and that operation of the modifications did not impact the operability of any interfacing systems. As applicable, the inspectors verified that relevant procedure, design, and licensing documents were properly updated. Lastly, the inspectors discussed the plant modifications with operations, engineering, and training personnel to ensure that the individuals were aware of how operation with the plant modifications in place could impact overall plant performance. Documents reviewed are listed in the Attachment.

This inspection constituted two permanent plant modification samples as defined in IP 71111.18-05.

b. Findings

(1) (Open) Unresolved Item (URI)05000454/2013004-01; 05000455/2013004-01: 10 CFR 50.59 Evaluation Affecting Tornado Analysis

Introduction:

During inspection activities associated with the review of tornado protection of the UHS, the inspectors identified an Unresolved Item associated with the implementation of Engineering Change (EC) 385829, Tornado Missile Design Basis for the Essential Service Water Cooling Towers, that potentially departed from an approved method of evaluation described in the FSAR (as updated).

Description:

In response to 2007 NCV 05000454/2007004-003; 05000455/2007004-003, Discrepancies with Tornado Analysis, the licensee completed EC 385829, Tornado Missile Design Basis for the Essential Service Water Cooling Towers, dated February 9, 2012. This analysis reviewed the design standards and design requirements for tornado protection of structures, systems, or components (SSCs).

The licensee concluded that deficiencies identified in the violation could be addressed analytically; therefore, no physical changes to the system would be required. The licensee adopted an approach that required two of the eight UHS fans to be available for use following a tornado.

The inspectors questioned this change as it differed from the description found in the original safety evaluation. Specifically, Section 9.2.5, Ultimate Heat Sink, of Safety Evaluation Report Related to the Operation of Byron Station, Units 1 and 2, dated February 1982, contained the following information regarding tornado protection of the UHS:

The UHS function is not affected by tornado missiles as discussed further in Section 3.5.2 of this SER [Safety Evaluation Report]. Thus, the requirements of GDC 2 and the guidelines of Regulatory Guides 1.27, Position C.2, regarding UHS protection against natural phenomena, and 1.29 are met.

Also, Section 3.5.2, Structures, Systems, and Components to be Protected from Externally Generated Missiles, of Safety Evaluation Report Related to the Operation of Byron Station, Units 1 and 2, dated February 1982, stated, in part:

Each unit has one essential service water cooling tower composed of four cells which serves as the ultimate heat sink. The towers are concrete structures designed to withstand tornado-missile impact. However, exposed piping on the towers, and the cooling tower fans and fan motor drives located on top of the towers are not protected from tornado-generated missiles. The applicant has committed (Tramm letter dated January 2, 1982) to provide protection for all piping external to the missile-proof cooling tower walls. The applicant has also provided the results of an analysis (Tramm letter dated January 2, 1982) which shows that in the event of a failure of all the essential service water cooling tower fans, the essential service water system temperature can be maintained within acceptable limits for proper operation of safety-related equipment served in both units with the towers functioning strictly in a natural draft cooling mode and makeup available from the tornado-missile protected onsite wells. The staff concurs that the applicant has satisfactorily demonstrated the availability of the essential service water system and ultimate heat sink in the event of postulated tornado missiles. Thus, the design of the essential service water cooling towers meets the guidelines of Regulatory Guide 1.27, "Ultimate Heat Sink for Nuclear Power Plants," with respect to missile protection.

The inspectors also identified information in UFSAR Section 3.5.4.1 that indicated that the UHS was expected to be able to meet its design requirements without operating fans. The following first appeared in a January 2, 1982, licensee response to questions by NRC staff regarding UHS performance. These words, or similar words, continued to appear through Revision 13 of the UFSAR.

An analysis of cooling tower capacity without fans has been made. Using the most conservative design conditions, it is predicted if the plant is shut down under non-LOCA conditions with loss of offsite power, the temperature of the service water supplied to the plant will not exceed 110°F. Although this exceeds the normal maximum temperature of 100°F, no adverse impact on safety equipment will result.

In December 2012, the UFSAR was updated to Revision 14. The following language in Revision 14 was selected to be in alignment with the methodology outlined in EC 385829.

An analysis of the UHS cooling capability for a tornado missile event has been made. The analysis was performed using service water cooling tower performance curves generated using the method described in UFSAR Section 9.2.5.3.1.1.2 and the time dependent two cooling tower model described in UFSAR Section 9.2.5.3.1.1.3. The following inputs and assumptions were used in the analysis: a. A single tornado generated missile is assumed to disable two essential service water cooling tower (SXCT) fans. Concurrent with the missile impact, a LOOP [Loss of Offsite Power] and an electrical failure is assumed to occur that results in the loss of power to two additional SXCT fans. Additionally up to two SXCT fans are assumed to be initially out of service The inspectors determined that the method of analysis used in the original safety analysis only relied on equipment that was protected from a tornado to evaluate the designs capability to mitigate the consequences of a tornado. As the fans, fan motors, and fan drives were not protected, they were not relied upon. As stated in the original SER, the design complied with the GDCs, due to the designs ability to maintain service water temperatures within design limits while operating strictly in a natural draft cooling mode.

The inspectors questioned whether the licensees revised approach which credited equipment that was not protected from a tornado to mitigate the consequences of a tornado constituted a change in a method of evaluation as described in the UFSAR and associated safety analyses. The licensee entered this issue into their CAP as IR 1546621, Inadequate 50.59 for EC 385829 (SXCT Tornado Missiles).

The inspectors have engaged the Office of Nuclear Reactor Regulation (NRR) for clarification regarding the licensees current licensing basis. This issue is an Unresolved Item (URI 05000454/2013004-001; 05000455/2013004-001) pending a response from NRR and the completion of additional reviews.

(2) (Open) URI 05000454/2013004-02; 05000455/2013004-02: Ultimate Heat Sink Limiting Design Basis Event

Introduction:

During inspection activities associated with the review of tornado protection of the UHS, the inspectors identified an Unresolved Item concerning the heat removal requirements of the SXCT. Specifically, the inspectors questioned whether the licensees analysis for a design basis accident on one unit coincident with a shutdown of the non-accident unit was adequate.

Description:

The inspectors reviewed the UFSAR and supporting analyses to understand the heat load impact on the UHS during a design basis accident on one unit coincident with the safe shutdown of the non-accident unit.

The inspectors determined that the licensee assumed that a design basis accident and safe shutdown of the non-accident unit would begin simultaneously. This sequence had the net effect of separating the maximum heat loads for each unit by a span of hours. In particular, the accident unit maximum heat load would be generated almost immediately following the onset of the accident, while the maximum heat load from the non-accident unit would be delayed by some amount of time during the transition from full power operation to a cold shutdown condition.

The UHS is shared between units; that is, either unit can transfer heat to the UHS and cause its temperature to rise. Therefore, this separation in time of the maximum heat loads experienced by the accident and non-accident units reduced the overall peak heat load. The inspectors reviewed the list of Condition I events, Normal Operation and Operational Occurrences, described in Chapter 15 of the UFSAR to determine whether any of those events listed were capable of generating concurrent heat loads. The inspectors selected Hot Shutdown (subcritical with residual heat removal system in operation) from the list under item a, Steady State and Shutdown Operations. The inspectors postulated a case where the non-accident unit had just entered Hot Shutdown when an accident occurred on the other unit.

The inspectors discussed this postulated scenario with licensee personnel. A preliminary review by the licensee staff concluded that this case may not be bounded by the current analysis. The licensee also concluded that although this case may not have been previously considered, it was also not required to be considered as part of their current licensing basis. The inspectors questioned this position as technical specifications (TSs) included limiting conditions for operation (LCOs) for the UHS that were derived from a design basis event.

The licensee entered this issue into their CAP as IR 1524228, NRC Question on the Licensing/Design Bases for the UHS. The inspectors have engaged NRR for clarification regarding the licensees current licensing basis. This issue is an Unresolved Item (URI 05000454/2013004-002; 05000455/2013004-002) pending a response from NRR and the completion of additional reviews.

(3) (Open) URI 05000454/2013004-03; 05000455/2013004-03: Ultimate Heat Sink Design Changes

Introduction:

During inspection activities associated with the review of tornado protection of the UHS, the inspectors identified an Unresolved Item concerning the redundant design of the SXCTs. Specifically, the inspectors were interested in changes to the description of the UHS and how, over time, the descriptions changed, particularly as associated with an apparent change from a redundant SXCT design to a non-redundant design, without any associated physical SXCT modifications.

Description:

Original design documents identified that the UHS was designed with sufficient capacity to permit it to perform its safety-related function following a passive failure of one of two SXCTs. In particular, the remaining SXCT was able to provide sufficient cooling to mitigate an accident on one unit coincident with the safe shutdown of the non-accident unit. During a design basis reconstitution of the UHS, the description of the UHS was revised and references to this design redundancy were eliminated. In particular, the final UHS design basis reconstitution report did not mention any intent or need to alter this characteristic of the UHS. Similarly, the safety evaluation associated with the license amendment for the UHS design basis reconstitution did not identify that a change occurred. The licensee entered this issue into their CAP as IR 1551720, NRC Questions Information Provided in 1992. At the end of the inspection period the inspectors were still evaluating whether the change in the description of the SXCTs was reflective of a corresponding change in UHS performance. If the performance of the UHS changed, the inspectors planned to evaluate whether such a change had been appropriately reviewed and approved. This issue is an Unresolved Item (URI 05000454/2013004-003; 05000455/2013004-003) pending the completion of that review.

1R19 Post-Maintenance Testing

Main article: IP 71111.19

.1 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the following post-maintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:

Unit 2 Train A Diesel Generator Following Injector 5R Bolt Replacement;

Unit 2 Train B Diesel Generator Following Bolt Replacement on the 9L Fuel Injector Pedestal;

Unit 2 Process Instrument and Control Power Supply Replacement Cabinet 8 Card 423 (#C8-423);

Unit 1 Train B Component Cooling Pump Following Seal Replacement;

Unit Common Essential Service Water Cooling Tower Riser Valve 0SX163F Following Actuator Replacement; and

Unit 2 Boric Acid Transfer Pump.

These activities were selected based upon the SSCs ability to impact risk. The inspectors evaluated these activities for the following (as applicable): the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as written in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing (temporary modifications or jumpers required for test performance were properly removed after test completion); and test documentation was properly evaluated. The inspectors evaluated the activities against TSs, the UFSAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with post-maintenance tests to determine whether the licensee was identifying problems and entering them into the CAP at the appropriate threshold and that the problems were being corrected commensurate with their importance to safety. Documents reviewed are listed in the Attachment.

This inspection constituted six post-maintenance testing sample as defined in IP 71111.19-05.

b. Findings

No findings were identified.

1R22 Surveillance Testing

Main article: IP 71111.22

.1 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the test results for the following activities to determine whether risk-significant systems and equipment were capable of performing their intended safety function and to verify testing was conducted in accordance with applicable procedural and TS requirements:

0B Essential Service Water Make-up Pump (Routine);

1B Diesel Generator Monthly Surveillance (Routine);

Unit 1 Train B Auxiliary Feedwater Valve Stroke Line Test and Position Indicator Test for Valves 1AF13E-H (In-Service Testing); and

Unit 1 Pressurizer Heater Resistance and Megger Readings WO 01498047 (Routine).

The inspectors observed in-plant activities and reviewed procedures and associated records to determine the following:

did preconditioning occur;

were the effects of the testing adequately addressed by control room personnel or engineers prior to the commencement of the testing;

were acceptance criteria clearly stated and consistent with the system design basis to demonstrate operational readiness;

was plant equipment calibration correct, accurate, and properly documented;

were as-left setpoints within required ranges; and calibration frequency in accordance with TSs, the UFSAR, plant procedures, and applicable commitments;

was measuring and test equipment calibration current;

was the test equipment used within the required range and accuracy;

were applicable prerequisites described in the test procedures satisfied;

did test frequencies meet TS requirements and demonstrate operability and reliability;

were tests performed in accordance with the test procedures and other applicable procedures;

were jumpers and lifted leads controlled and restored where used;

were test data and results accurate, complete, within limits, and valid;

was test equipment removed following testing;

where applicable for IST activities, was testing performed in accordance with the applicable version of Section XI, the American Society of Engineers (ASME)

Code, and reference values consistent with the system design basis;

was the unavailability of the test equipment appropriately considered in the performance indicator data;

where applicable, were test results not meeting acceptance criteria addressed with an adequate operability evaluation, or was the system or component declared inoperable;

where applicable for safety-related instrument control surveillance tests, was the reference setting data accurately incorporated into the test procedure;

was equipment returned to a position or status required to support the performance of its safety function following testing;

were all problems identified during the testing appropriately documented and dispositioned in the licensees CAP;

where applicable, were annunciators and other alarms demonstrated to be functional and annunciator and alarm setpoints consistent with design documents; and

where applicable, were alarm response procedure entry points and actions consistent with the plant design and licensing documents.

Documents reviewed are listed in the Attachment.

This inspection constituted three routine surveillance testing samples, and one inservice testing sample as defined in IP 71111.22, Sections -02 and -05.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

Main article: IP 71114.06

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine licensee emergency drill on August 15, 2013, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the Operations Support Center (OSC) to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the licensee drill critique to compare any inspector-observed weakness with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensee staff was properly identifying weaknesses and entering them into the CAP. As part of the inspection, the inspectors reviewed the drill package and other documents listed in the Attachment.

This emergency preparedness drill inspection constituted one sample as defined in IP 71114.06-05.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstone: Occupational Radiation Safety and Public Radiation Safety

2RS1 Radiological Hazard Assessment and Exposure Controls

Main article: IP 71124.01

The inspection activities supplement those documented in NRC Inspection Report 05000454/2013003; 05000455/2013003 and constituted a partial sample as defined in IP 71124.01-05.

.1 Inspection Planning (02.01)

a. Inspection Scope

The inspectors reviewed all licensee performance indicators for the Occupational Exposure Cornerstone for follow-up. The inspectors reviewed the results of radiation protection program audits (e.g., licensees quality assurance audits or other independent audits). The inspectors reviewed any reports of operational occurrences related to occupational radiation safety since the last inspection. The inspectors reviewed the results of the audit and operational report reviews to gain insights into overall licensee performance.

b. Findings

No findings were identified.

.2 Radiological Hazard Assessment (02.02)

a. Inspection Scope

The inspectors determined whether there had been changes to plant operations since the last inspection that may have resulted in a significant new radiological hazard for onsite workers or members of the public. The inspectors evaluated whether the licensee assessed the potential impact of these changes and had implemented periodic monitoring, as appropriate, to detect and quantify the radiological hazard.

b. Findings

The inspectors identified that changes were made to the Technical Requirements Manual since the last inspection that reduced the required in-core decay time from greater than 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months to less than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . Records of this change indicated that the actual decay time was determined by heat loading parameters of the spent fuel pool.

The inspectors attempted to assess whether an accident, such as a dropped fuel bundle, within this shortened decay time might result in a significant new radiological hazard for onsite workers or members of the public. However, this assessment could not be completed within this inspection period. This issue remains under review by the NRC and is categorized as an URI (URI 05000454/2013004-04; 05000455/2013004-004 Reduced Decay Time) pending completion of that NRC review.

.3 Instructions to Workers (02.03)

a. Inspection Scope

The inspectors reviewed selected occurrences where a workers electronic personal dosimeter noticeably malfunctioned or alarmed. The inspectors evaluated whether workers responded appropriately to the off-normal condition. The inspectors assessed whether the issue was included in the CAP and whether dose evaluations were conducted, as appropriate.

The inspectors assessed the licensees means to inform workers of changes that could significantly impact their occupational dose for work activities that could suddenly and severely increase radiological conditions.

b. Findings

No findings were identified.

.4 Contamination and Radioactive Material Control (02.04)

a. Inspection Scope

The inspectors reviewed the licensees procedures and records to verify that the radiation detection instrumentation was used at its typical sensitivity level based on appropriate counting parameters. The inspectors assessed whether or not the licensee has established a de facto release limit by altering the instruments typical sensitivity through such methods as raising the energy discriminator level or locating the instrument in a high radiation background area.

The inspectors selected several sealed sources from the licensees inventory records and assessed whether the sources were accounted for and verified to be intact.

The inspectors evaluated whether any transactions, since the last inspection, involving nationally tracked sources were reported in accordance with 10 CFR 20.2207.

b. Findings

No findings were identified.

.5 Radiological Hazards Control and Work Coverage (02.05)

a. Inspection Scope

The inspectors evaluated the adequacy of radiological controls, such as required surveys, radiation protection job coverage (including audio and visual surveillance for remote job coverage), and contamination controls. The inspectors evaluated the licensees use of electronic personal dosimeters in high noise areas as high radiation area monitoring devices.

The inspectors assessed whether radiation monitoring devices were placed on the individuals body consistent with licensee procedures. The inspectors assessed whether the dosimeter was placed in the location of highest expected dose or that the licensee properly employed an NRC-approved method of determining effective dose equivalent.

The inspectors reviewed the application of dosimetry to effectively monitor exposure to personnel in high radiation work areas with significant dose rate gradients.

The inspectors reviewed the following radiation work permits for work within airborne radioactivity areas with the potential for individual worker internal exposures:

Mechanical Stress Improvement Program (MSIP) Process/External Measurements/Testing;

2SI8900 A/B/C/D Repairs/Replacements; and

Spent Filter Replacement.

For these radiation work permits, the inspectors evaluated airborne radioactive controls and monitoring, including the potential for significant airborne levels (e.g., grinding, grit blasting, system breaches, entry into tanks, cubicles, and reactor cavities). The inspectors assessed barrier (e.g., tent or glove box) integrity and temporary high efficiency particulate air ventilation system operation.

The inspectors examined the licensees physical and programmatic controls for highly activated or contaminated materials (nonfuel) stored within spent fuel and other storage pools. The inspectors assessed whether appropriate controls (i.e., administrative and physical controls) were in place to preclude inadvertent removal of these materials from the pool.

The inspectors examined the postings and physical controls for selected high radiation areas and very high radiation areas to verify conformance with the occupational radiation safety performance indicator.

b. Findings

No findings were identified.

.6 Risk-Significant High Radiation Area and Very High Radiation Area Controls (02.06)

a. Inspection Scope

The inspectors discussed with the radiation protection manager the controls and procedures for risk-significant high radiation areas and very high radiation areas. The inspectors discussed methods employed by the licensee to provide stricter control of very high radiation area access as specified in 10 CFR 20.1602, Control of Access to Very High Radiation Areas, and Regulatory Guide 8.38, Control of Access to High and Very High Radiation Areas of Nuclear Plants. The inspectors assessed whether any changes to licensee procedures substantially reduced the effectiveness and level of worker protection.

a. Inspection Scope

The inspectors evaluated whether problems associated with radiation monitoring and exposure control were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensees CAP. The inspectors assessed the appropriateness of the corrective actions for a selected sample of problems documented by the licensee that involved radiation monitoring and exposure controls.

The inspectors assessed the licensees process for applying operating experience to their plant.

b. Findings

No findings were identified.

2RS2 Occupational As-Low-As-Is-Reasonably-Achievable (ALARA) Planning and Controls

Main article: IP 71124.02

The inspection activities supplement those documented in NRC Inspection Reports 05000454/2012002; 05000455/2012002; 05000454/2012004, and 05000455/2012004 and constituted one complete sample as defined in IP 71124.02-05.

.1 Radiological Work Planning (02.02)

a. Inspection Scope

The inspectors compared the results achieved (dose rate reductions, person-rem used)with the intended dose established in the licensees ALARA planning for these work activities. The inspectors compared the person-hour estimates provided by maintenance planning and other groups to the radiation protection group with the actual work activity time requirements, and evaluated the accuracy of these time estimates.

The inspectors assessed the reasons (e.g., failure to adequately plan the activity, failure to provide sufficient work controls) for any inconsistencies between intended and actual work activity doses.

b. Findings

No findings were identified.

.2 Problem Identification and Resolution (02.06)

a. Inspection Scope

The inspectors evaluated whether problems associated with ALARA planning and controls are being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensees CAP.

b. Findings

No findings were identified.

2RS3 In-Plant Airborne Radioactivity Control and Mitigation

Main article: IP 71124.03

This inspection constituted one complete sample as defined in IP 71124.03-05.

.1 Inspection Planning (02.01)

a. Inspection Scope

The inspectors reviewed the plant FSAR to identify areas of the plant designed as potential airborne radiation areas and any associated ventilation systems or airborne monitoring instrumentation. Instrumentation reviewed included continuous air monitors (continuous air monitors and particulate-iodine-noble-gas-type instruments) used to identify changing airborne radiological conditions such that actions to prevent an overexposure may be taken. The review included an overview of the respiratory protection program and a description of the types of devices used. The inspectors reviewed FSAR, TSs, and emergency planning documents to identify the location and quantity of respiratory protection devices stored for emergency use.

The inspectors reviewed the licensees procedures for maintenance, inspection, and use of respiratory protection equipment including self-contained breathing apparatus as well as procedures for air quality maintenance.

The inspectors reviewed reported performance indicators to identify any related to unintended dose resulting from intakes of radioactive material.

b. Findings

No findings were identified.

.2 Engineering Controls (02.02)

a. Inspection Scope

The inspectors reviewed the licensees use of permanent and temporary ventilation to determine whether the licensee used ventilation systems as part of its engineering controls (in lieu of respiratory protection devices) to control airborne radioactivity. The inspectors reviewed procedural guidance for use of installed plant systems, such as containment purge, spent fuel pool ventilation, and auxiliary building ventilation, and assessed whether the systems were used, to the extent practicable, during risk-significant activities (e.g., using containment purge during cavity floodup).

The inspectors selected installed ventilation systems used to mitigate the potential for airborne radioactivity, and evaluated whether the ventilation airflow capacity, flow path (including the alignment of the suction and discharges), and filter/charcoal unit efficiencies, as appropriate, were consistent with maintaining concentrations of airborne radioactivity in work areas below the concentrations of an airborne area to the extent practicable.

The inspectors selected temporary ventilation system setups (high efficiency particulate air/charcoal negative pressure units, down draft tables, tents, metal Kelly buildings, and other enclosures) used to support work in contaminated areas. The inspectors assessed whether the use of these systems was consistent with licensee procedural guidance and the ALARA concept.

The inspectors reviewed airborne monitoring protocols by selecting installed systems used to monitor and warn of changing airborne concentrations in the plant and evaluated whether the alarms and setpoints were sufficient to prompt licensee/worker action to ensure that doses were maintained within the limits of 10 CFR Part 20 and the ALARA concept.

The inspectors assessed whether the licensee had established trigger points (e.g., the Electric Power Research Institutes Alpha Monitoring Guidelines for Operating Nuclear Power Stations) for evaluating levels of airborne beta-emitting (e.g., Plutonium-241) and alpha-emitting radionuclides.

b. Findings

No findings were identified.

.3 Use of Respiratory Protection Devices (02.03)

a. Inspection Scope

For those situations where it is impractical to employ engineering controls to minimize airborne radioactivity, the inspectors assessed whether the licensee provided respiratory protective devices such that occupational doses were ALARA. The inspectors selected work activities where respiratory protection devices were used to limit the intake of radioactive materials, and assessed whether the licensee performed an evaluation concluding that further engineering controls were not practical and that the use of respirators was ALARA. The inspectors also evaluated whether the licensee had established means (such as routine bioassays) to determine if the level of protection (protection factor) provided by the respiratory protection devices during use was at least as good as that assumed in the licensees work controls and dose assessment.

The inspectors assessed whether respiratory protection devices used to limit the intake of radioactive materials were certified by the National Institute for Occupational Safety and Health/Mine Safety and Health Administration or had been approved by the NRC in accordance with 10 CFR 20.1703(b). The inspectors selected work activities where respiratory protection devices were used and determined whether the devices were used consistent with their National Institute for Occupational Safety and Health/Mine Safety and Health Administration certification or any conditions of their NRC approval.

The inspectors reviewed records of air testing for supplied-air devices and self-contained breathing apparatus bottles to assess whether the air used in these devices met or exceeded Grade D quality. The inspectors reviewed plant breathing air supply systems to determine whether they met the minimum pressure and airflow requirements for the devices in use.

The inspectors selected several individuals qualified to use respiratory protection devices, and assessed whether they had been deemed fit to use the devices by a physician.

The inspectors selected several individuals assigned to wear a respiratory protection device and observed them donning, doffing, and functionally checking the device as appropriate. Through interviews with these individuals, the inspectors evaluated whether they knew how to safely use the device and how to properly respond to any device malfunction or unusual occurrence (loss of power, loss of air, etc.).

The inspectors chose multiple respiratory protection devices staged and ready for use in the plant or stocked for issuance for use. The inspectors assessed the physical condition of the device components (mask or hood, harnesses, air lines, regulators, air bottles, etc.) and reviewed records of routine inspection for each. The inspectors selected several of the devices and reviewed records of maintenance on the vital components (e.g., pressure regulators, inhalation/exhalation valves, hose couplings).

The inspectors reviewed the respirator vital components maintenance program to ensure that the repairs of vital components were performed by the respirators manufacturer.

b. Findings

No findings were identified.

.4 Self-Contained Breathing Apparatus for Emergency Use (02.04)

a. Inspection Scope

Based on the FSAR, TSs, and emergency operating procedure requirements, the inspectors reviewed the status and surveillance records of self-contained breathing apparatuses staged in-plant for use during emergencies. The inspectors reviewed the licensees capability for refilling and transporting self-contained breathing apparatus air bottles to and from the control room and operations support center during emergency conditions.

The inspectors selected several individuals on control room shift crews and from designated departments currently assigned emergency duties (e.g., onsite search and rescue duties) to assess whether control room operators and other emergency response and radiation protection personnel (assigned in-plant search and rescue duties or as required by emergency operating procedures or the emergency plan) were trained and qualified in the use of self-contained breathing apparatuses (including personal bottle changeout). The inspectors evaluated whether personnel assigned to refill bottles were trained and qualified for that task.

The inspectors determined whether appropriate mask sizes and types were available for use (i.e., in-field mask size and type match what was used in fit-testing). The inspectors determined whether on-shift operators facial hair that would interfere with the sealing of the mask to the face and whether vision correction (e.g., glasses inserts or corrected lenses) was available as appropriate.

The inspectors reviewed the past 2 years of maintenance records for select self-contained breathing apparatus units used to support operator activities during accident conditions and designated as ready for service to assess whether any maintenance or repairs on any self-contained breathing apparatus units vital components were performed by an individual, or individuals, certified by the manufacturer of the device to perform the work. The vital components typically were the pressure-demand air regulator and the low-pressure alarm. The inspectors reviewed the onsite maintenance procedures governing vital component work to determine whether there were any inconsistencies with the self-contained breathing apparatus manufacturers recommended practices. For those self-contained breathing apparatuses designated as ready for service, the inspectors determined whether the required, periodic air cylinder hydrostatic testing was documented and up-to-date, and whether the retest air cylinder markings required by the U.S. Department of Transportation were in place.

b. Findings

No findings were identified.

.5 Problem Identification and Resolution (02.05)

a. Inspection Scope

The inspectors evaluated whether problems associated with the control and mitigation of in-plant airborne radioactivity were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensee CAP. The inspectors assessed whether the corrective actions were appropriate for a selected sample of problems involving airborne radioactivity and were appropriately documented by the licensee.

b. Findings

No findings were identified.

2RS4 Occupational Dose Assessment

Main article: IP 71124.04

This inspection constituted one complete sample as defined in IP 71124.04-05.

.1 Inspection Planning (02.01)

a. Inspection Scope

The inspectors reviewed the results of radiation protection program audits related to internal and external dosimetry (e.g., licensees quality assurance audits, self-assessments, or other independent audits) to gain insights into overall licensee performance in the area of dose assessment and focus the inspection activities consistent with the principle of smart sampling.

The inspectors reviewed the most recent National Voluntary Laboratory Accreditation Program (NVLAP) accreditation report on the vendors most recent results to determine the status of the contractors accreditation.

A review was conducted of the licensee procedures associated with dosimetry operations, including issuance/use of external dosimetry (routine, multibadging, extremity, neutron, etc.), assessment of internal dose (operation of whole body counter, assignment of dose based on derived air concentration-hours, urinalysis, etc.), and evaluation of and dose assessment for radiological incidents (distributed contamination, hot particles, loss of dosimetry, etc.).

The inspectors evaluated whether the licensee had established procedural requirements for determining when external and internal dosimetry was required.

b. Findings

No findings were identified.

.2 External Dosimetry (02.02)

a. Inspection Scope

The inspectors evaluated whether the licensees dosimetry vendor was NVLAP accredited and if the approved irradiation test categories for each type of personnel dosimeter used were consistent with the types and energies of the radiation present and the way the dosimeter is being used (e.g., to measure deep dose equivalent, shallow dose equivalent, or lens dose equivalent).

The inspectors evaluated the onsite storage of dosimeters before their issuance, during use, and before processing/reading. The inspectors also reviewed the guidance provided to radiation workers with respect to care and storage of dosimeters.

The licensee does not use non-NVLAP accredited passive dosimeters.

The inspectors assessed the use of active dosimeters (electronic personal dosimeters)to determine if the licensee used a correction factor to address the response of the electronic personal dosimeter as compared to the passive dosimeter for situations when the electronic personal dosimeter must be used to assign dose. The inspectors also assessed whether the correction factor was based on sound technical principles.

The inspectors reviewed dosimetry occurrence reports or CAP documents for adverse trends related to electronic personal dosimeters, such as interference from electromagnetic frequency, dropping or bumping, failure to hear alarms, etc. The inspectors assessed whether the licensee had identified any trends and implemented appropriate corrective actions.

b. Findings

No findings were identified.

.3 Internal Dosimetry (02.03)

Routine Bioassay (In Vivo)

a. Inspection Scope

The inspectors reviewed procedures used to assess the dose from internally deposited nuclides using whole body counting equipment. The inspectors evaluated whether the procedures addressed methods for differentiating between internal and external contamination, the release of contaminated individuals, the route of intake and the assignment of dose.

The inspectors reviewed the whole body count process to determine if the frequency of measurements was consistent with the biological half-life of the nuclides available for intake.

The inspectors reviewed the licensee's evaluation for use of its portal radiation monitors as a passive monitoring system to determine if instrument minimum detectable activities were adequate to determine the potential for internally deposited radionuclides sufficient to prompt additional investigation.

The inspectors selected several whole body counts and evaluated whether the counting system used had sufficient counting time/low background to ensure appropriate sensitivity for the potential radionuclides of interest. The inspectors reviewed the radionuclide library used for the count system to determine its appropriateness. The inspectors evaluated whether any anomalous count peaks/nuclides indicated in each output spectra received appropriate disposition. The inspector's reviewed the licensee's 10 CFR Part 61 data analyses to determine whether the nuclide libraries included appropriate gamma-emitting nuclides. The inspectors evaluated how the licensee accounted for hard-to-detect nuclides in the dose assessment.

b. Findings

No findings were identified.

Special Bioassay (In Vitro)

a. Inspection Scope

The inspectors reviewed and assessed the adequacy of the licensees program for in vitro monitoring (i.e., urinalysis and fecal analysis) of radionuclides (tritium, fission products, and activation products), including collection and storage of samples.

The inspectors reviewed the vendor laboratory quality assurance program and assessed whether the laboratory participated in an industry recognized cross-check program including whether out-of-tolerance results were resolved appropriately.

b. Findings

No findings were identified.

Internal Dose Assessment - Airborne Monitoring

a. Inspection Scope

The inspectors reviewed the licensee's program for airborne radioactivity assessment and dose assessment, as applicable, based on airborne monitoring and calculations of derived air concentration. The inspectors determined whether flow rates and collection times for air sampling equipment were adequate to allow lower limits of detection to be obtained. The inspectors also reviewed the adequacy of procedural guidance to assess internal dose if respiratory protection was used.

b. Findings

No findings were identified.

Internal Dose Assessment - Whole Body Count Analyses

a. Inspection Scope

The inspectors reviewed several dose assessments performed by the licensee using the results of whole body count analyses. The inspectors determined whether affected personnel were properly monitored with calibrated equipment and whether internal exposures were assessed consistent with the licensee's procedures.

b. Findings

No findings were identified.

.4 Special Dosimetric Situations (02.04)

b. Findings

No findings were identified.

.5 Problem Identification and Resolution (02.05)

a. Inspection Scope

The inspectors assessed whether problems associated with occupational dose assessment were identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensees CAP. The inspectors assessed the appropriateness of the corrective actions for a selected sample of problems documented by the licensee involving occupational dose assessment.

b. Findings

No findings were identified.

2RS6 Radioactive Gaseous and Liquid Effluent Treatment

Main article: IP 71124.06

This inspection constituted one complete sample as defined in IP 71124.06-05.

.1 Inspection Planning and Program Reviews (02.01)

Event Report and Effluent Report Reviews

a. Inspection Scope

The inspectors reviewed the radiological effluent release reports issued since the last inspection to determine if the reports were submitted as required by the Offsite Dose Calculation Manual (ODCM)/TSs. The inspectors reviewed anomalous results, unexpected trends, or abnormal releases identified by the licensee for further inspection to determine if they were evaluated, were entered in the CAP, and were adequately resolved.

The inspectors identified radioactive effluent monitor operability issues reported by the licensee as provided in effluent release reports, to review these issues during the onsite inspection, as warranted, given their relative significance and determine if the issues were entered into the CAP and adequately resolved.

b. Findings

No findings were identified.

Offsite Dose Calculation Manual and Final Safety Analysis Report Review

a. Inspection Scope

The inspectors reviewed FSAR descriptions of the radioactive effluent monitoring systems, treatment systems, and effluent flow paths so they could be evaluated during inspection walkdowns.

The inspectors reviewed changes to the ODCM made by the licensee since the last inspection using the guidance in NUREG-1301, and NUREG-0133; and Regulatory Guides 1.109, 1.21 and 4.1. When differences were identified, the inspectors reviewed the technical basis or evaluations of the change during the onsite inspection to determine whether they were technically justified and maintained effluent releases ALARA.

The inspectors reviewed licensee documentation to determine if the licensee had identified any non-radioactive systems that had become contaminated as disclosed either through an event report or the ODCM since the last inspection. This review provided an intelligent sample list for the onsite inspection of any 10 CFR 50.59 evaluations and allowed a determination of whether any newly contaminated systems had an unmonitored effluent discharge path to the environment, whether any required ODCM revisions were made to incorporate these new pathways, and whether the associated effluents were reported in accordance with Regulatory Guide 1.21.

b. Findings

No findings were identified.

Groundwater Protection Initiative Program

a. Inspection Scope

The inspectors reviewed reported groundwater monitoring results and changes to the licensees written program for identifying and controlling contaminated spills/leaks to groundwater.

b. Findings

No findings were identified.

Procedures, Special Reports, and Other Documents

a. Inspection Scope

The inspectors reviewed Licensee Event Reports, event reports and/or special reports related to the effluent program issued since the previous inspection to identify any additional focus areas for the inspection based on the scope/breadth of problems described in these reports.

The inspectors reviewed effluent program implementing procedures, particularly those associated with effluent sampling, effluent monitor setpoint determinations, and dose calculations.

The inspectors reviewed copies of licensee and third party (independent) evaluation reports of the effluent monitoring program since the last inspection to gather insights into the licensees program and aid in selecting areas for inspection review (smart sampling).

b. Findings

No findings were identified.

.2 Walkdowns and Observations (02.02)

a. Inspection Scope

The inspectors walked down selected components of the gaseous and liquid discharge systems to evaluate whether equipment configuration and flow paths aligned with the documents reviewed in 02.01 above and to assess equipment material condition.

Special attention was made to identify potential unmonitored release points (such as temporary structures butted against turbine, auxiliary or containment buildings); building alterations which could impact airborne or liquid effluent controls; and ventilation system leakage that communicated directly with the environment.

For equipment or areas associated with the systems selected for review that were not readily accessible due to radiological conditions, the inspectors reviewed the licensee's material condition surveillance records, as applicable.

The inspectors walked down filtered ventilation systems to assess for conditions such as degraded high efficiency particulate air filters/charcoal banks, improper alignment, or system installation issues that could impact the performance or the effluent monitoring capability of the effluent system.

As available, the inspectors observed selected portions of the routine processing and discharge of radioactive gaseous effluents (including sample collection and analysis) to evaluate whether appropriate treatment equipment was used and the processing activities aligned with discharge permits.

The inspectors determined if the licensee had made significant changes to their effluent release points (e.g., changes subject to a 10 CFR 50.59 review or require NRC approval of alternate discharge points).

As available, the inspectors observed selected portions of the routine processing and discharge of liquid radioactive waste (including sample collection and analysis) to determine whether appropriate effluent treatment equipment was being used and whether radioactive liquid waste was being processed and discharged in accordance with procedure requirements and aligned with discharge permits.

b. Findings

No findings were identified.

.3 Sampling and Analyses (02.03)

a. Inspection Scope

The inspectors selected effluent sampling activities, consistent with smart sampling, and assessed whether adequate controls had been implemented to ensure representative samples were obtained (e.g. provisions for sample line flushing, vessel recirculation, composite samplers, etc.).

The inspectors selected effluent discharges made with inoperable (declared out-of-service) effluent radiation monitors to assess whether controls were in place to ensure compensatory sampling was performed consistent with the radiological effluent TSs/ODCM and whether those controls were adequate to prevent the release of unmonitored liquid and gaseous effluents.

The inspectors determined whether the facility was routinely relying on the use of compensatory sampling in lieu of adequate system maintenance, based on the frequency of compensatory sampling since the last inspection.

The inspectors reviewed the results of the inter-laboratory comparison program to evaluate the quality of the radioactive effluent sample analyses and assess whether the inter-laboratory comparison program included hard-to-detect isotopes, as appropriate.

b. Findings

No findings were identified.

.4 Instrumentation and Equipment (02.04)

Effluent Flow Measuring Instruments

The inspectors reviewed the latest Land Use Census to assess whether changes (e.g.,

significant increases or decreases to population in the plant environs, changes in critical exposure pathways, the location of the nearest member of the public, or critical receptor, etc.) had been factored into the dose calculations.

For the releases reviewed above, the inspectors evaluated whether the calculated doses (monthly, quarterly, and annual dose) were within the 10 CFR Part 50, Appendix I and TS dose criteria.

The inspectors reviewed, as available, records of any abnormal gaseous or liquid tank discharges (e.g., discharges resulting from misaligned valves, valve leak-by, etc.) to ensure the abnormal discharge was monitored by the discharge point effluent monitor.

Discharges made with inoperable effluent radiation monitors, or unmonitored leakages were reviewed to ensure that an evaluation was made of the discharge to satisfy 10 CFR 20.1501 so as to account for the source term and projected doses to the public.

b. Findings

No findings were identified.

.6 Groundwater Protection Initiative Implementation (02.06)

a. Inspection Scope

The inspectors reviewed monitoring results of the Groundwater Protection Initiative to determine if the licensee had implemented its program as intended and to identify any anomalous results. For anomalous results or missed samples, the inspectors assessed whether the licensee had identified and addressed deficiencies through its CAP.

The inspectors reviewed identified leakage or spill events and entries made into 10 CFR 50.75

(g) records. The inspectors reviewed evaluations of leaks or spills and reviewed any remediation actions taken for effectiveness. The inspectors reviewed onsite contamination events involving contamination of ground water and assessed whether the source of the leak or spill was identified and mitigated.

For unmonitored spills, leaks, or unexpected liquid or gaseous discharges, the inspectors assessed whether an evaluation was performed to determine the type and amount of radioactive material that was discharged by:

Assessing whether sufficient radiological surveys were performed to evaluate the extent of the contamination and the radiological source term and assessing whether a survey/evaluation had been performed to include consideration of hard-to-detect radionuclides.

Determining whether the licensee completed offsite notifications, as provided in its Groundwater Protection Initiative implementing procedures.

The inspectors reviewed the evaluation of discharges from onsite surface water bodies that contained or potentially contained radioactivity, and the potential for ground water leakage from these onsite surface water bodies. The inspectors assessed whether the licensee was properly accounting for discharges from these surface water bodies as part of their effluent release reports.

The inspectors assessed whether on-site ground water sample results and a description of any significant on-site leaks/spills into ground water for each calendar year were documented in the Annual Radiological Environmental Operating Report for the radiological environmental monitoring program or the Annual Radiological Effluent Release Report for the Radiological Effluent Technical Specifications.

For significant, new effluent discharge points (such as significant or continuing leakage to ground water that continued to impact the environment if not remediated), the inspectors evaluated whether the ODCM was updated to include the new release point.

b. Findings

No findings were identified.

.7 Problem Identification and Resolution (02.07)

a. Inspection Scope

The inspectors assessed whether problems associated with the effluent monitoring and control program were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensees CAP. In addition, the inspectors evaluated the appropriateness of the corrective actions for a selected sample of problems documented by the licensee involving radiation monitoring and exposure controls.

b. Findings

No findings were identified.

2RS7 Radiological Environmental Monitoring Program

Main article: IP 71124.07

This inspection constituted one complete sample as defined in IP 71124.07-05.

.1 Inspection Planning (02.01)

a. Inspection Scope

The inspectors reviewed the annual radiological environmental operating reports and the results of any licensee assessments since the last inspection to assess whether the radiological environmental monitoring program was implemented in accordance with the TSs and ODCM. This review included reported changes to the ODCM with respect to environmental monitoring, commitments in terms of sampling locations, monitoring and measurement frequencies, land use census, inter-laboratory comparison programs, and analysis of data.

The inspectors reviewed the ODCM to identify locations of environmental monitoring stations.

The inspectors reviewed the FSAR for information regarding the environmental monitoring program and meteorological monitoring instrumentation.

The inspectors reviewed quality assurance audit results of the program to assist in choosing inspection smart samples. The inspectors also reviewed audits and technical evaluations performed on the vendor laboratory.

The inspectors reviewed the annual effluent release report and the 10 CFR Part 61, Licensing Requirements for Land Disposal of Radioactive Waste, report, to determine whether the licensee was sampling, as appropriate, for the predominant and dose-causing radionuclides likely to be released in effluents.

b. Findings

No findings were identified.

.2 Site Inspection (02.02)

a. Inspection Scope

The inspectors walked down select air sampling stations and dosimeter monitoring stations to determine whether they were located as described in the ODCM and to assess equipment material condition. Consistent with smart sampling, the air sampling stations were selected based on the locations with the highest X/Q, D/Q wind sectors, and dosimeters were selected based on the most risk-significant locations (e.g., those that had the highest potential for public dose impact).

For the air samplers selected, the inspectors reviewed the calibration and maintenance records to evaluate whether they demonstrated adequate operability of these components.

The inspectors assessed whether the licensee had initiated sampling of other appropriate media upon loss of a required sampling station.

The inspectors observed the collection and preparation of environmental samples from surface water at location BY-12 to determine if environmental sampling was representative of the release pathways as specified in the ODCM and whether sampling techniques were in accordance with procedures.

Based on direct observation and a review of records, the inspectors assessed whether the meteorological instruments were operable, calibrated, and maintained in accordance with guidance contained in the FSAR, NRC Regulatory Guide 1.23, Meteorological Monitoring Programs for Nuclear Power Plants, and licensee procedures. The inspectors assessed whether the meteorological data readout and recording instruments in the control room and, if applicable, at the tower were operable.

The inspectors evaluated whether missed and/or anomalous environmental samples were identified and reported in the annual environmental monitoring report. The inspectors selected events that involved a missed sample, inoperable sampler, lost dosimeter, or anomalous measurement to determine if the licensee had identified the cause and had implemented corrective actions. The inspectors reviewed the licensees assessment of any positive sample results (i.e., licensed radioactive material detected above the lower limits of detection) and reviewed the associated radioactive effluent release data that was the source of the released material.

The inspectors selected SSCs that involved or could reasonably involve licensed material for which there was a credible mechanism for licensed material to reach ground water, and assessed whether the licensee had implemented a sampling and monitoring program sufficient to detect leakage of these SSCs to ground water. This included a walkdown of select groundwater monitoring wells along the blowdown line and vacuum breaker locations.

The inspectors evaluated whether records, as required by 10 CFR 50.75(g), of leaks, spills, and remediation since the previous inspection were retained in a retrievable manner.

The inspectors reviewed any significant changes made by the licensee to the ODCM as the result of changes to the land census, long-term meteorological conditions (3-year average), or modifications to the sampler stations since the last inspection.

The inspectors reviewed technical justifications for any changed sampling locations to evaluate whether the licensee performed the reviews required to ensure that the changes did not affect the ability to monitor the impacts of radioactive effluent releases on the environment.

The inspectors assessed whether the appropriate detection sensitivities with respect to TSs/ODCM where used for counting samples (i.e., the samples met the TSs/ODCM required lower limits of detection). The licensee used a vendor laboratory to analyze the radiological environmental monitoring program samples, so the inspectors reviewed the results of the vendors quality control program, including the interlaboratory comparison, to assess the adequacy of the vendors program.

The inspectors reviewed the results of the licensees interlaboratory comparison program to evaluate the adequacy of environmental sample analyses performed by the licensee. The inspectors assessed whether the interlaboratory comparison test included the media/nuclide mix appropriate for the facility. The inspectors reviewed the licensees determination of any bias to the data and the overall effect on the radiological environmental monitoring program.

b. Findings

No findings were identified.

.3 Identification and Resolution of Problems (02.03)

a. Inspection Scope

The inspectors assessed whether problems associated with the radiological environmental monitoring program were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensees CAP.

Additionally, they inspectors assessed the appropriateness of the corrective actions for a selected sample of problems documented by the licensee that involved the radiological environmental monitoring program.

b. Findings

No findings were identified.

The inspectors sampled licensee submittals for the occupational radiological occurrences PI for the period from the fourth quarter 2012 through the second quarter 2013. The inspectors used PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, dated October 2009, to determine the accuracy of the PI data reported during those periods. The inspectors reviewed the licensees assessment of the PI for occupational radiation safety to determine whether indicator related data was adequately assessed and reported.

To assess the adequacy of the licensees PI data collection and analyses, the inspectors discussed with radiation protection staff, the scope and breadth of its data review and the results of those reviews. The inspectors independently reviewed electronic personal dosimetry dose rate and accumulated dose alarms and dose reports and the dose assignments for any intakes that occurred during the time period reviewed to determine if there were potentially unrecognized occurrences. The inspectors also conducted walkdowns of numerous locked high and very high radiation area entrances to determine the adequacy of the controls in place for these areas. Documents reviewed are listed in the Attachment.

This inspection constituted one Occupational Exposure Control Effectiveness sample as defined in IP 71151-05.

b. Findings

No findings were identified.

.4 Radiological Effluent Technical Specification/Offsite Dose Calculation Manual

Radiological Effluent Occurrences

a. Inspection Scope

The inspectors sampled licensee submittals for the RETS/ODCM Radiological Effluent Occurrences PI for the period from the second quarter 2012 through the second quarter 2013. The inspectors used PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, dated October 2009, to determine the accuracy of the PI data reported during those periods.

The inspectors reviewed the licensees IR database and selected individual IRs generated since this indicator was last reviewed to identify any potential occurrences such as unmonitored, uncontrolled, or improperly calculated effluent releases that may have impacted offsite dose. The inspectors reviewed gaseous effluent summary data and the results of associated offsite dose calculations for selected dates to determine if indicator results were accurately reported. The inspectors also reviewed the licensees methods for quantifying gaseous and liquid effluents and determining effluent dose.

Documents reviewed are listed in the Attachment.

This inspection constituted one RETS/ODCM Radiological Effluent Occurrences sample as defined in IP 71151 05.

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems

Main article: IP 71152

.1 Routine Review of Items Entered into the Corrective Action Program

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify they were being entered into the licensees CAP at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. Attributes reviewed included the complete and accurate identification of the problem; that timeliness was commensurate with safety significance; that evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent-of-condition reviews, and previous occurrence reviews were proper and adequate; and that the classification, prioritization, focus, and timeliness of corrective actions were commensurate with safety and sufficient to prevent recurrence of the issue.

Minor issues entered into the licensees CAP as a result of the inspectors observations are included in the Attachment.

These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.

b. Findings

No findings were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

To facilitate the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees CAP. This review was accomplished through inspection of the stations daily IR packages.

These daily reviews were performed by procedure as part of the inspectors daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.

b. Findings

No findings were identified.

.3 Semi-Annual Trend Review

a. Inspection Scope

The inspectors performed a review of the licensees CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors review was focused on repetitive equipment issues, but also considered the results of daily inspector CAP item screening discussed in Section 4OA2.2 above, licensee trending efforts, and licensee human performance results. The inspectors review nominally considered the 6-month period of April 1, 2013, through September 27, 2013, although some examples expanded beyond those dates where the scope of the trend warranted.

The review also included issues documented outside the normal CAP in major equipment problem lists, departmental problem/challenges lists, system health reports, and Maintenance Rule assessments. The inspectors compared and contrasted their results with the results contained in the licensees CAP trending reports. Corrective actions associated with a sample of the issues identified in the licensees trending reports were reviewed for adequacy.

This review constituted one semi-annual trend inspection sample as defined in IP 71152-05.

b. Findings

No findings were identified.

.4 Selected Issue Follow-Up Inspection

a. Inspection Scope

The inspectors recognized an apparent pattern of fire header pressure reductions that were being measured as part of licensee surveillance 0BOSR 10.c.3-1, Annual Sprinkler and Deluge System Visual Inspection. Over the last 5 years of performance, the header pressure for the elevation 346 stairwell measuring point had changed from 205 psig to 110 psig to 135 psig, then back to 110 psig and finally, on November 20, 2012, the last measurement was 45 psig. On August 27, 2013, NRC license renewal team members discussed this trend with licensee personnel. On September 18, 2013, NRC personnel questioned licensee personnel regarding the trend, and IR 1560667 was generated. In addition to a question regarding the timeliness in which the IR was initiated, the inspectors also questioned the quality of the surveillance procedure steps and the failure of the test performer and the test reviewer to identify the degraded condition.

This review constituted one in-depth PI&R sample as defined in IP 71152-05.

b. Findings

After discussion with the NRC problem identification and resolution (PI&R) inspection team that was on site for the biennial PI&R inspection during the assessment period, this issue was documented in NRC Inspection Report 05000454/2013-007; 05000455/2013-007.

4OA6 Management Meetings

.1 Exit Meeting Summary

On October 8, 2013, the inspectors presented the inspection results to Mr. Russ Kearney and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

.2 Interim Exit Meeting

An interim exit was conducted for:

The inspection results for the areas of radiological hazard assessment and exposure controls; occupational ALARA planning and controls; in-plant airborne radioactivity control and mitigation; occupational dose assessment; radioactive gaseous and liquid effluent treatment; radiological environmental monitoring; and reactor coolant system specific activity, occupational exposure control effectiveness, and RETS/ODCM radiological effluent occurrences PI verification with Mr. B. Yeoman, Plant Manager, on August 23, 2013.

The inspectors confirmed that none of the potential report input discussed was considered proprietary. Proprietary material received during the inspection was returned to the licensee or destroyed.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

R. Kearney, Site Vice President

R. Lindley, Manager Site Security Operations

D. Murray, Corporate Licensing

T. Chalmers, Operations Director

J. Feimster, Engineering Manager

S. Gackstetter, Regulatory Assurance Manager

E. Hernandez, Engineering Director

J. Reed, Radiation Protection Support Manager

T. Cash, Nuclear Oversight

P. ONeill, Maintenance Program Manager

B. Barton, Radiation Protection Manager

Z. Cox, Radwaste/Environmental Supervisor

J. Golich, Environmental Chemist

R. Newton, Radiation Protection Technical Specialist

J. Reed, Radiation Protection Technical Support Manager

Nuclear Regulatory Commission

E. Duncan, Chief, Branch 3, Division of Reactor Projects

B. Bartlett, Byron Senior Resident Inspector

J. Robbins, Byron Resident Inspector

Illinois Emergency Management Agency (IEMA)

A. Settles, IEMA

C. Thompson, IEMA

Attachment

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

Opened

05000454/2013004-01; URI 10 CFR 50.59 Evaluation Affecting Tornado Analysis

05000455/2013004-01 (Section 1R18.b(1))

05000454/2013004-02; URI Ultimate Heat Sink Limiting Design Basis Event

05000455/2013004-02 (Section 1R18.b(2))

05000454/2013004-03; URI Ultimate Heat Sink Design Changes

05000455/2013004-03 (Section 1R18.b(3))

05000454/2013004-04; URI Reduced Decay Time

05000455/2013004-04 (Section 2RS1.2)

Closed

None

Discussed

None Attachment

LIST OF DOCUMENTS REVIEWED

IR 05000454/2013004

Text

SUBJECT:

Dear Mr. Pacilio:

Enclosure:

SUMMARY OF FINDINGS

NRC-Identified

Licensee-Identified Violations

REPORT DETAILS

Summary of Plant Status

REACTOR SAFETY

Cornerstone: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

.1 Readiness for Impending Adverse Weather Condition

a. Inspection Scope

b. Findings

1R04 Equipment Alignment

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

b. Findings

.2 Semi-Annual Complete System Walkdown

a. Inspection Scope

b. Findings

1R05 Fire Protection

.1 Routine Resident Inspector Tours

a. Inspection Scope

b. Findings

.2 Annual Fire Protection Drill Observation

a. Inspection Scope

b. Findings

1R06 Flooding

.1 Internal Flooding

a. Inspection Scope

b. Findings

1R11 Licensed Operator Requalification Program

.1 Quarterly Review of Licensed Operator Requalification

a. Inspection Scope

b. Findings

.2 Quarterly Observation of Heightened Activity or Risk

a. Inspection Scope

b. Findings

1R12 Maintenance Effectiveness

.1 Routine Quarterly Evaluations

a. Inspection Scope

b. Findings

1R13 Maintenance Risk Assessments and Emergent Work Control

.1 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

b. Findings

1R15 Operability Determinations and Functionality Assessments

.1 Operability Evaluations

a. Inspection Scope

b. Findings

1R18 Plant Modifications

.1 Plant Modifications

a. Inspection Scope

b. Findings

Introduction:

Description:

Introduction:

Description:

Introduction:

Description:

1R19 Post-Maintenance Testing

.1 Post-Maintenance Testing

a. Inspection Scope

b. Findings

1R22 Surveillance Testing

.1 Surveillance Testing

a. Inspection Scope

b. Findings

1EP6 Drill Evaluation

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

b. Findings

RADIATION SAFETY

Cornerstone: Occupational Radiation Safety and Public Radiation Safety

2RS1 Radiological Hazard Assessment and Exposure Controls

.1 Inspection Planning (02.01)

a. Inspection Scope