Text

NRC Integrated Inspection Report 05000413/2016003 and 05000414/2016003 and Exercise of Enforcement Discretion
	ML16307A004
Person / Time
Site:	Catawba
Issue date:	11/02/2016
From:	Joel Munday; Division Reactor Projects II
To:	Simril T; Duke Energy Corp
References
	EA-16-229 IR 2016003
	Download: ML16307A004 (41)
	v • d • e

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

245 PEACHTREE CENTER AVENUE NE, SUITE 1200

ATLANTA, GEORGIA 30303-1257

November 2, 2016

EA-16-229

Mr. Tom Simril

Site Vice President

Duke Energy Corporation

Catawba Nuclear Station

4800 Concord Road

York, SC 29745-9635

SUBJECT: CATAWBA NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT

05000413/2016003 AND 05000414/2016003 AND EXERCISE OF

ENFORCEMENT DISCRETION

Dear Mr. Simril:

On September 30, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an

inspection at your Catawba Nuclear Station Units 1 and 2. On October 24, 2016, the NRC

inspectors discussed the results of this inspection with you and other members of your staff.

The results of this inspection are documented in the enclosed report.

The NRC inspectors did not identify any finding or violation of more than minor significance.

The enclosed report also documents non-compliances for which the NRC is exercising

enforcement discretion in accordance with Section 9.1 of the NRC Enforcement Policy,

Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48). The non-

compliances are associated with your implementation of the requirements and standards of your

technical specifications, as well as Title 10 of the Code of Federal Regulations 50, Appendix R,

Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979. The

inspectors have screened the violation and determined that it warrants enforcement discretion

per the Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire

Protection Issues, and Section 11.05.b of IMC 0305.

T. Simril

2

This letter, its enclosure, and your response (if any) will be made available for public

inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC

Public Document Room in accordance with 10 CFR 2.390, Public Inspections,

Exemptions, Requests for Withholding.

Sincerely,

/RA/

Joel T. Munday, Director

Division of Reactor Projects

Docket Nos.: 50-413, 50-414

License Nos.: NPF-35, NPF-52

Enclosure:

IR 05000413/2016003 and 05000414/2016003

w/Attachment: Supplemental Information

cc w/encl: Distribution via ListServ

DISTRIBUTION:

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ML16307A004

SUNSI Review Complete

By: Frank Ehrhardt

ADAMS

Yes No

Publicly Available

Non-Publicly Available

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Keyword: SUNSI

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OFFICE

RII: DRP

RII: DRS

NAME

JAustin

CScott

JWorosilo

MToth

RWilliams

RKellner

CDykes

SIGNATURE

JDA via email

CBS via email

JGW1 via

email

MMT2 via

email

REW1 via

email

RXK3 via

email

CMDB4 via

email

DATE

10/25/2016

10/26/2016

10/25/2016

OFFICE

RII: DRS

RII:EICS

RII:DRP

NAME

JPanfel

JMontgomery

MKowal

FEhrhardt

JMunday

SIGNATURE

JRP1 via email

JMM9 via email

MXK7

FJE

JTM

DATE

11/01/2016

10/26/2016

10/31/2016

11/01/2016

T. Simril

3

Letter to Tom Simril from Joel T. Munday dated November 2, 2016

SUBJECT: CATAWBA NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT

05000413/2016003 AND 05000414/2016003 AND EXERCISE OF

ENFORCEMENT DISCRETION

DISTRIBUTION:

M. Kowal, RII

OE Mail

RIDSNRRDIRS

PUBLIC

RidsNrrPMCatawba Resource

Enclosure

U.S. NUCLEAR REGULATORY COMMISSION

REGION II

Docket Nos.:

50-413, 50-414

License Nos.:

NPF-35, NPF-52

Report No.:

05000413/2016003 and 05000414/2016003

Licensee:

Duke Energy Carolinas, LLC

Facility:

Catawba Nuclear Station, Units 1 and 2

Location:

York, SC 29745

Dates:

July 1, 2016 through September 30, 2016

Inspectors:

J. Austin, Senior Resident Inspector

C. Scott, Resident Inspector

M. Toth, Project Engineer

J. Montgomery, Senior Reactor Inspector (Section 4OA3)

R. Williams, Senior Reactor Inspector (Sections 1R07, 1R08)

R. Kellner, Senior Health Physicist (Sections 2RS1, 2RS3)

C. Dykes, Health Physicist (Sections 2RS2, 2RS4)

J. Panfel, Health Physicist (Sections 2RS5, 4OA1)

Approved by:

Frank Ehrhardt, Chief

Reactor Projects Branch 1

Division of Reactor Projects

SUMMARY

IR 05000413/2016003 and 05000414/2016003, July 1, 2016 through September 30, 2016;

Catawba Nuclear Station, Units 1 and 2; Integrated Inspection Report

The report covered a three-month period of inspection by the resident inspectors and regional

inspectors. No findings were identified during this inspection period. The significance of

inspection findings are indicated by their color (i.e., greater than Green, or Green, White,

Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance

Determination Process, (SDP) dated April 29, 2015. The cross-cutting aspects are determined

using IMC 0310, Aspects within the Cross-Cutting Areas dated December 4, 2014. All

violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement

Policy dated August 1, 2016. The NRCs program for overseeing the safe operation of

commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,

Revision 6.

REPORT DETAILS

Summary of Plant Status

Unit 1: Operated at or near 100 percent rated thermal power for the entire inspection period.

Unit 2: Operated at or near 100 percent rated thermal power through September 9. On

September 10, the unit commenced refueling outage 2EOC21 and remained in the

outage throughout the report period.

1.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection (71111.01)

a.

Inspection Scope

.1

Impending Adverse Weather Conditions

The inspectors reviewed the licensees preparations to protect risk-significant systems

from tropical storm Hermine expected September 2-3, 2016. The inspectors evaluated

the licensees implementation of adverse weather preparation procedures and

compensatory measures, including operator staffing, before the onset of the adverse

weather conditions. The inspectors reviewed the licensees plans to address the

consequences that may result from the tropical storm. The inspectors verified that

operator actions specified in the licensees adverse weather procedure maintained

readiness of essential systems. The inspectors verified that required surveillances were

current, or were scheduled and completed, if practical, before the onset of anticipated

adverse weather conditions. The inspectors also verified that the licensee implemented

periodic equipment walkdowns or other measures to ensure that the condition of plant

equipment met operability requirements. Documents reviewed are listed in the

Attachment.

b.

Findings

No findings were identified.

1R04 Equipment Alignment (71111.04)

a.

Inspection Scope

.1

Partial Walkdown

The inspectors verified that critical portions of the selected systems were correctly

aligned by performing partial walkdowns. The inspectors selected systems for

assessment because they were a redundant or backup system or train, were important

for mitigating risk for the current plant conditions, had been recently realigned, or were a

single-train system. The inspectors determined the correct system lineup by reviewing

plant procedures and drawings. Documents reviewed are listed in the Attachment.

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The inspectors selected the following three systems or trains to inspect:

2A diesel generator (DG) with the 2B DG out of service (OOS) for planned

maintenance

2B motor driven auxiliary feedwater (CA) pump with the 2A CA pump OOS for

service water to auxiliary feedwater flow measurement

1B containment spray (NS) pump with the 1A NS pump OOS for maintenance

b.

Findings

No findings were identified.

1R05 Fire Protection (71111.05AQ)

a.

Inspection Scope

.1

Quarterly Inspection

The inspectors evaluated the adequacy of selected fire plans by comparing the fire plans

to the defined hazards and defense-in-depth features specified in the fire protection

program. In evaluating the fire plans, the inspectors assessed the following items:

control of transient combustibles and ignition sources

fire detection systems

fire suppression systems

manual firefighting equipment and capability

passive fire protection features

compensatory measures and fire watches

issues related to fire protection contained in the licensees corrective action program

The inspectors toured the following five fire areas to assess material condition and

operational status of fire protection equipment. Documents reviewed are listed in the

Attachment.

Auxiliary building 594' Level, fire area 22

2A DG room, fire area 27

Unit 1, Essential Switchgear Room level 577, fire area 15

Unit 1, Essential Switchgear Room level 560, fire area 8

Unit 1, Turbine Building 594 level, fire zone N

b.

Findings

No findings were identified.

5

1R06 Flood Protection Measures (71111.06)

a.

Inspection Scope

.1

Internal Flooding

The inspectors reviewed related flood analysis documents and walked down the area

listed below containing risk-significant structures, systems, and components susceptible

to flooding. The inspectors verified that plant design features and plant procedures for

flood mitigation were consistent with design requirements and internal flooding analysis

assumptions. The inspectors also assessed the condition of flood protection barriers

and drain systems. In addition, the inspectors verified the licensee was identifying and

properly addressing issues using the corrective action program. Documents reviewed

are listed in the Attachment.

Unit 1, turbine building

b.

Findings

No findings were identified.

1R07 Heat Sink Performance (71111.07T)

a.

Inspection Scope

Triennial Review of Heat Sink Performance

The inspectors reviewed operability determinations, completed surveillances, vendor

manual information, associated calculations, performance test results, and cooler

inspection results associated with the service water pump upper bearing oil cooler

(SWUBOC) and the auxiliary feedwater pump motor coolers (AFWPMC). These coolers

were chosen based on their risk significance in the licensees probabilistic safety

analysis, their important safety-related mitigating system support functions and their

relatively low margin.

For the SWUBOC, the inspectors determined whether testing, inspection, maintenance,

and monitoring of biotic fouling and macrofouling programs were adequate to ensure

proper heat transfer. This was accomplished by determining whether the test method

used was consistent with accepted industry practices, or equivalent; the test conditions

were consistent with the selected methodology; the test acceptance criteria were

consistent with the design basis values; and reviewing results of heat exchanger

performance testing. The inspectors also determined whether the test results

appropriately considered differences between testing conditions and design conditions,

whether the frequency of testing based on trending of test results was sufficient to detect

degradation prior to loss of heat removal capabilities below design basis values, and

whether test results considered test instrument inaccuracies and differences.

For the AFWPMC, the inspectors reviewed the methods and results of heat exchanger

performance inspections. The inspectors determined whether the methods used to

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inspect and clean heat exchangers were consistent with as-found conditions identified

and expected degradation trends and industry standards; the licensees inspection and

cleaning activities had established acceptance criteria consistent with industry

standards; and the as-found results were recorded, evaluated, and appropriately

dispositioned so that the as-left condition was acceptable.

In addition, the inspectors determined whether the condition and operation of the

SWPUBOC and the AFWPMC were consistent with design assumptions in heat transfer

calculations, and as described in the final safety analysis report. This included

determining whether the number of plugged tubes was within pre-established limits

based on capacity and heat transfer assumptions. The inspectors determined whether

the licensee evaluated the potential for water hammer and established adequate

controls and operational limits to prevent heat exchanger degradation due to excessive

flow induced vibration during operation. In addition, visual inspection records were

reviewed to determine the structural integrity of the heat exchanger. For the AFWPMC,

the inspectors determined whether the licensees chemical treatment programs for

corrosion control were consistent with industry norms, and implemented accordingly.

The inspectors determined whether the performance of the safety-related ultimate heat

sink, identified as the standby nuclear service water pond (SNSWP), and its

subcomponents such as piping, intake screens, pumps, valves, etc., was appropriately

evaluated by tests or other equivalent methods, to ensure availability and accessibility to

the in-plant cooling water systems. The inspectors determined whether the licensees

inspection of the SNSWP was thorough and of sufficient depth to identify degradation of

the shoreline protection or loss of structural integrity. This included determination

whether vegetation present along the slopes was trimmed, maintained, and was not

adversely impacted the embankment. In addition, the inspectors determined whether

the licensee ensured sufficient reservoir capacity by trending and removing debris, or

sediment buildup, in the SNSWP.

The inspectors reviewed the licensees operation of the service water system and

SNSWP. This included a review of licensees procedures for a loss of the service water

system or SNSWP; a verification that instrumentation, which is relied upon for decision

making, was available and functional; and a review of design changes made to the

service water system and the SNSWP. In addition, the inspectors determined whether

macrofouling was adequately monitored, trended, and controlled by the licensee to

prevent clogging. The inspectors determined whether the licensees biocide treatments

for biotic control were adequately conducted and whether the results were adequately

monitored, trended, and evaluated. The inspectors also reviewed whether the licensee

maintained adequate pH, calcium hardness, etc.

The inspectors reviewed the licensees performance testing of service water system and

SNSWP results. This included a review of the licensees performance test results for

key components and service water flow balance test results. In addition, the inspectors

compared the flow balance results to system configuration and flow assumptions during

design basis accident conditions. The inspectors also determined whether the licensee

ensured adequate isolation during design basis events, consistency between testing

methodologies and design basis leakage rate assumptions, and proper performance of

risk significant non-safety related functions.

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The inspectors performed a system walkdown of the service water systems to determine

whether the licensees assessment on structural integrity was adequate. In addition, the

inspectors reviewed available licensee testing and inspections results, the licensee's

disposition of any active through wall pipe leaks, and the history of through wall pipe

leakage to identify any adverse trends since the last NRC inspection. For buried or

inaccessible piping, the inspectors reviewed the licensee's pipe testing, inspection, or

monitoring program to determine whether structural integrity was ensured and that any

leakage or degradation was appropriately identified and dispositioned by the licensee.

The inspectors performed a system walkdown of the service water intake structure to

determine whether the licensees assessment of structural integrity and component

functionality was adequate and that the licensee ensured proper functioning of traveling

screens and strainers, and structural integrity of component mounts. In addition, the

inspectors determined whether service water pump bay silt accumulation was monitored,

trended, and maintained at an acceptable level by the licensee, and that water level

instruments were functional and routinely monitored. The inspectors also determined

whether the licensees ability to ensure functionality during adverse weather conditions

was adequate.

In addition, the inspectors reviewed condition reports related to heat exchanger, cooler

and heat sink performance issues to determine whether the licensee had an appropriate

threshold for identifying issues and to evaluate the effectiveness of the corrective

actions. The documents that were reviewed are included in the Attachment.

These inspection activities constituted three heat sink inspection samples as defined in

IP 71111.07-05.

b.

Findings

No findings were identified.

1R08 In-service Inspection Activities (71111.08)

a.

Inspection Scope

Non-Destructive Examination Activities and Welding Activities

From September 19 through September 29, 2016, the inspectors conducted an onsite

review of the implementation of the licensees in-service inspection (ISI) program for

monitoring degradation of the reactor coolant system boundary, risk-significant piping

and component boundaries, and containment boundaries in Unit 2.

The inspectors either directly observed or reviewed the following non-destructive

examinations (NDEs) mandated by the American Society of Mechanical Engineers

(ASME) Boiler and Pressure Vessel Code (Code of Record: 1998 Edition with 2000

Addenda) to evaluate compliance with the ASME Code,Section XI and Section V

requirements and, if any indications or defects were detected, to evaluate if they were

dispositioned in accordance with the ASME Code or an NRC-approved alternative

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requirement. The inspectors also reviewed the qualifications of the NDE technicians

performing the examinations to determine whether they were current and in compliance

with the ASME Code requirements.

Ultrasonic Examination (UT) of weld 2NI106-14, Pipe to tee weld, ASME Class 2

(observed)

Liquid Penetrant Examination (PT) of weld 2492NW158-10, Pipe to valve weld,

ASME Class 2 (reviewed)

PT of weld 2SM-005, Access hole plug weld, ASME Class 2 (observed)

Magnetic Particle Examination (MT) of weld C2.C5.51.0002, Pipe to elbow weld,

ASME Class 2 (reviewed)

MT of weld C2.C5.51.0001, Elbow to pipe weld, ASME Class 2 (reviewed)

Visual Examination (VT) of 2RPV-BMI-NOZZLES, ASME Class 1 (reviewed)

VT of 2RPV-HEAD-SURFACE-MULTIPLE, ASME Class 1 (reviewed)

The inspectors either directly observed or reviewed the following welding activities,

qualification records, and associated documents in order to evaluate compliance with

procedures and the ASME Code,Section XI and Section IX requirements. Specifically,

the inspectors reviewed the work order, repair and replacement plan, weld data sheets,

welding procedures, procedure qualification records, welder performance qualification

records, and NDE reports.

Weld 2492NW158-10, Pipe to valve weld, ASME Class 2 (reviewed)

Weld 2SM-005, Access hole plug weld, ASME Class 2 (observed)

During non-destructive surface and volumetric examinations performed since the

previous refueling outage, the licensee did not identify any relevant indications that were

analytically evaluated and accepted for continued service; therefore, no NRC review was

completed for this inspection procedure attribute.

PWR Vessel Upper Head Penetration Inspection Activities

The inspectors verified that for the Unit 2 vessel head, a bare metal visual (BMV)

examination and a volumetric examination were not required during this outage, in

accordance with the requirements of ASME Code Case N-729-1 and 10 CFR

50.55a(g)(6)(ii)(D). The inspectors reviewed the calculation of effective degradation

years, the previous examination history, and reviewed the results of the VT-2

examination performed under the vessel head insulation to verify that the examinations

were performed in accordance with the requirements of ASME Code,Section XI, Article

IWA-2212 requirements and the frequency was consistent with the Code Case.

The licensee did not identify any relevant indications that were accepted for continued

service. Additionally, the licensee did not perform any welding repairs to the vessel

head penetrations since the beginning of the last Unit 2 refueling outage; therefore, no

NRC review was completed for these inspection procedure attributes.

9

Boric Acid Corrosion Control Inspection Activities

The inspectors reviewed the licensees boric acid corrosion control (BACC) program

activities to determine if the activities were implemented in accordance with the

commitments made in response to NRC Generic Letter 88-05, Boric Acid Corrosion of

Carbon Steel Reactor Pressure Boundary Components in PWR Plants, and applicable

industry guidance documents. Specifically, the inspectors performed an onsite records

review of procedures and the results of the licensees containment walkdown inspections

performed during the current refueling outage. The inspectors also interviewed the

BACC program owner, conducted an independent walkdown of containment to evaluate

compliance with licensees BACC program requirements, and verified that degraded or

non-conforming conditions, such as boric acid leaks, were properly identified and

corrected in accordance with the licensees BACC and corrective action programs.

The inspectors reviewed the following engineering evaluations, completed for evidence

of boric acid leakage, to determine if the licensee properly applied applicable corrosion

rates to the affected components; and properly assessed the effects of corrosion

induced wastage on structural or pressure boundary integrity in accordance with the

licensee procedures.

AR 01898992, Excessive / Active boron accumulation from 2-NI-VA-327 pipe

AR 01931170, 0-WL-FE-9780 Active / Excessive boron leak from flange

AR 01940775, 1-NM-PG-6100 Active / Excessive boron from threaded fitting

AR 01950202, 2-KF-FS-5150 Active boron leak from fitting 30-40 dpm

The inspectors reviewed the following condition reports and associated corrective

actions related to evidence of boric acid leakage to evaluate if the corrective actions

completed were consistent with the requirements of the ASME Code and

10 CFR Part 50, Appendix B, Criterion XVI.

AR 02060953, 2B NC Pump main flange leak

AR 02020057, 1-NS-VA-1B Excessive/active boron, leak increase

AR 02047391, 1-FW-VA-45 Active Boron Leak

Steam Generator Tube Inspection Activities

The inspectors reviewed the eddy current (EC) examination activities performed in Unit 2

steam generators A, B, C, and D during this current refueling outage to verify

compliance with the licensees Technical Specifications, ASME BPVC Section XI, and

Nuclear Energy Institute 97-06, Steam Generator Program Guidelines.

The inspectors reviewed the scope of the EC examinations, and the implementation of

scope expansion criteria, to verify these were consistent with the Electric Power

Research Institute (EPRI) Pressurized Water Reactor Steam Generator Examination

Guidelines, Revision 7. The inspectors reviewed documentation for a sample of EC data

analysts, probes, and testers to verify that personnel and equipment were qualified to

detect the applicable degradation mechanisms in accordance with the EPRI Examination

Guidelines. This review included a sample of site-specific Examination Technique

10

Specification Sheets (ETSSs) to verify that their qualification and site-specific

implementation were consistent with Appendix H or I of the EPRI Examination

Guidelines. The inspectors also reviewed a sample of EC data for steam generator

tubes (B-R29C38, B-R25C42, B-R29C43, B-R32C33, C-R44C87, and D-R28C69), with

a qualified data analyst, to confirm that data analysis and equipment configuration were

performed in accordance with the applicable ETSSs and site-specific analysis

guidelines. The inspectors verified that recordable indications were detected and sized

in accordance with vendor procedures.

The inspectors selected a sample of degradation mechanisms from the Unit 2

Degradation Assessment report (i.e. anti-vibration bar wear and stress corrosion

cracking) and verified that their respective in-situ pressure testing criteria were

determined in accordance with the EPRI Steam Generator Integrity Assessment

Guidelines, Revision 3. Additionally, the inspectors reviewed EC indication reports to

determine whether tubes with relevant indications were appropriately screened for in-situ

pressure testing. The inspectors also compared the latest EC examination results with

the last Condition Monitoring and Operational Assessment report for Unit 2 to assess the

licensees prediction capability for maximum tube degradation and number of tubes with

indications. The inspectors verified that the licensees evaluation was conservative and

that current examination results were bound by the Operational Assessment projections.

The inspectors assessed the latest EC examination results to verify that new

degradation mechanisms, if any, were identified and evaluated before plant startup. The

review of EC examination results included the disposition of potential loose part

indications on the steam generator secondary side to verify that corrective actions for

evaluating and retrieving loose parts were consistent with the EPRI Guidelines. The

inspectors also reviewed a sample of primary-to-secondary leakage data for Unit 2 to

confirm that operational leakage in each steam generator remained below the detection

or action level threshold during the previous operating cycle.

The inspectors review included the implementation of tube repair criteria and repair

methods to verify they were consistent with plant Technical Specifications and industry

guidelines. The inspectors verified that the licensee had selected the appropriate tubes

for plugging based on the required plugging criteria. The inspectors reviewed the tube

plugging procedure and directly observed tube plugging activities for tubes A-R36C37

and B-R23C104, to determine if the licensee installed the tube plugs in accordance with

the applicable procedures.

Furthermore, the inspectors interviewed licensee staff and reviewed a sample of

inspection results for the visual inspection conducted in the primary side bowl of Steam

Generator D, to verify that potential areas of degradation based on site-specific

operating experience were inspected, and appropriate corrective actions were taken to

address degradation indications.

Identification and Resolution of Problems

The inspectors reviewed a sample of ISI-related issues entered into the corrective action

program to determine if the licensee had appropriately described the scope of the

11

problem and had initiated corrective actions. The review also included the licensees

consideration and assessment of operating experience events applicable to the plant.

The inspectors performed this review to ensure compliance with 10 CFR Part 50,

Appendix B, Criterion XVI, Corrective Action, requirements.

b.

Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

(71111.11)

a.

Inspection Scope

.1

Resident Inspector Quarterly Review of Licensed Operator Requalification

On August 11, 2016, the inspectors observed an evaluated simulator scenario

administered to an operating crew as part of the annual requalification operating test

required by 10 CFR 55.59, Requalification. The crew responded to an instrument

malfunction, followed by an automatic trip without a scram, loss of A 4 kV vital bus and a

safety injection signal.

The inspectors assessed the following:

licensed operator performance

the ability of the licensee to administer the scenario and evaluate the operators

the quality of the post-scenario critique

simulator performance

.2

Resident Inspector Quarterly Review of Licensed Operator Performance in the Actual

Plant/Main Control Room

The inspectors observed licensed operator performance in the main control room on July

26, 2016 while responding to an increase in letdown pressure caused by an equipment

issue.

The inspectors assessed the following:

use of plant procedures

control board manipulations

communications between crew members

use and interpretation of instruments, indications, and alarms

use of human error prevention techniques

documentation of activities

management and supervision

Documents reviewed are listed in the Attachment.

12

b.

Findings

No findings were identified.

1R12 Maintenance Effectiveness (71111.12)

a.

Inspection Scope

The inspectors assessed the licensees treatment of the three issues listed below to

verify the licensee appropriately addressed equipment problems within the scope of the

maintenance rule (10 CFR 50.65, Requirements for Monitoring the Effectiveness of

Maintenance at Nuclear Power Plants). The inspectors reviewed procedures and

records to evaluate the licensees identification, assessment, and characterization of the

problems as well as their corrective actions for returning the equipment to a satisfactory

condition. Documents reviewed are listed in the Attachment.

CR 2054316: 02054316-05: QCE 02054316 - Aux. switch: medium voltage

CR 2033128, Unit 0, A controlled area chilled water chiller trip, Maintenance rule

functional failure oil pump

CR 2052366, Extended equalize charge required for battery SDSB1 safe shutdown

facility (SSF)

In addition, the inspectors performed a review of the licensees Quality Assurance

Program to ensure licensee was in compliance with their program requirements.

b.

Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)

a.

Inspection Scope

The inspectors reviewed the four maintenance activities listed below to verify that the

licensee assessed and managed plant risk as required by 10 CFR 50.65(a)(4) and

licensee procedures. The inspectors assessed the adequacy of the licensees risk

assessments and implementation of risk management actions. The inspectors also

verified that the licensee was identifying and resolving problems with assessing and

managing maintenance-related risk using the corrective action program. Additionally, for

maintenance resulting from unforeseen situations, the inspectors assessed the

effectiveness of the licensees planning and control of emergent work activities.

Documents reviewed are listed in the Attachment.

Protected equipment plan for SSF DG control panel electrical maintenance

Yellow risk condition for 2A DG preventive maintenance

Yellow risk condition for maintenance on 1A2 component cooling water pump

Yellow risk condition while inspecting 1A DG connecting rod inspection

13

b.

Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments (71111.15)

a.

Inspection Scope

.1

Operability and Functionality Review

The inspectors selected the six operability determinations or functionality evaluations

listed below for review based on the risk-significance of the associated components and

systems. The inspectors reviewed the technical adequacy of the determinations to

ensure that technical specification operability was properly justified and the components

or systems remained capable of performing their design functions. To verify whether

components or systems were operable, the inspectors compared the operability and

design criteria in the appropriate sections of the technical specification and updated final

safety analysis report to the licensees evaluations. Where compensatory measures

were required to maintain operability, the inspectors determined whether the measures

in place would function as intended and were properly controlled. Additionally, the

inspectors reviewed a sample of corrective action documents to verify the licensee was

identifying and correcting any deficiencies associated with operability evaluations.

Documents reviewed are listed in the Attachment.

CR 2039992, 2SV-19 stroke time longer than usual (for A Train solenoid)

CR 2049828, Unit 1 and Unit 2 EPL and EPQ minimum voltage calculations need

revision

CR 2053485, centrifugal charging pump 1B thrust bearing oil sight glass leak

CR 2059121, 1B DG starting air compressor not maintaining pressure

CR 2056751, auxiliary feedwater (CA) flow transmitters do not meet loss of coolant

accident (LOCA) accuracy requirements

CR 2060673, 2A auxiliary feedwater pump will not stop

b.

Findings

No findings were identified.

1R18 Plant Modifications (71111.18)

a.

Inspection Scope

The inspectors verified that the plant modification listed below did not affect the safety

functions of important safety systems. The inspectors confirmed the modifications did

not degrade the design bases, licensing bases, and performance capability of risk

significant structures, systems and components. The inspectors also verified

modifications performed during plant configurations involving increased risk did not place

the plant in an unsafe condition. Additionally, the inspectors evaluated whether system

operability and availability, configuration control, post-installation test activities, and

14

changes to documents, such as drawings, procedures, and operator training materials,

complied with licensee standards and NRC requirements. In addition, the inspectors

reviewed a sample of related corrective action documents to verify the licensee was

identifying and correcting any deficiencies associated with modifications. Documents

reviewed are listed in the Attachment.

Engineering change (EC) 110357, Motor Lubricant Replacement for SR pumps

b.

Findings

No findings were identified.

1R19 Post-Maintenance Testing (71111.19)

a.

Inspection Scope

The inspectors either observed post-maintenance testing or reviewed the test results for

the maintenance activities listed below to verify the work performed was completed

correctly and the test activities were adequate to verify system operability and functional

capability.

post maintenance test of the E instrument air compressor following the breaker trip

on August 23, 2016

in-service valve test following repair of 1NW-110B, NW supply to 1KC424B on July

27, 2016

operability performance test of the 1B containment spray (NS) pump following

preplanned maintenance on August 2, 2016

operability performance test of the 1A train of auxiliary building ventilation following

preventive maintenance on August 8, 2016

operability performance test of the 1A train of auxiliary building ventilation following

replacement of the exhaust fan breaker on August 23, 2016

The inspectors evaluated these activities for the following:

acceptance criteria were clear and demonstrated operational readiness

effects of testing on the plant were adequately addressed

test instrumentation was appropriate

tests were performed in accordance with approved procedures

equipment was returned to its operational status following testing

test documentation was properly evaluated

Additionally, the inspectors reviewed a sample of corrective action documents to verify

the licensee was identifying and correcting any deficiencies associated with

post-maintenance testing. Documents reviewed are listed in the Attachment.

b.

Findings

No findings were identified.

15

1R20 Refueling and Other Outage Activities (71111.20)

a.

Inspection Scope

For the Unit 2 refueling outage from September 9, 2016 through the remainder of the

inspection period, the inspectors evaluated the following outage activities:

outage planning

shutdown, cooldown and refueling

reactor coolant system instrumentation and electrical power configuration

reactivity and inventory control

decay heat removal and spent fuel pool cooling system operation

containment closure

The inspectors verified that the licensee:

considered risk in developing the outage schedule

controlled plant configuration per administrative risk reduction methodologies

developed work schedules to manage fatigue

developed mitigation strategies for loss of key safety functions

adhered to operating license and technical specification requirements

The inspectors verified that safety-related and risk-significant structures, systems, and

components not accessible during power operations were maintained in an operable

condition. The inspectors also reviewed a sample of related corrective action

documents to verify the licensee was identifying and correcting any deficiencies

associated with outage activities. Documents reviewed are listed in the Attachment.

b.

Findings

No findings were identified.

1R22 Surveillance Testing (71111.22)

a.

Inspection Scope

The inspectors reviewed the four surveillance tests listed below and either observed the

test or reviewed test results to verify testing adequately demonstrated equipment

operability and met technical specification and current licensing basis. The inspectors

evaluated the test activities to assess for preconditioning of equipment, procedure

adherence, and equipment alignment following completion of the surveillance.

Additionally, the inspectors reviewed a sample of related corrective action documents to

verify the licensee was identifying and correcting any deficiencies associated with

surveillance testing. Documents reviewed are listed in the Attachment.

16

Routine Surveillance Tests

PT/1/A/4350/002B, Emergency diesel generator (EDG) 1B five hour full load run

PT/2/A/4200/009, Engineered safety features actuation periodic test

PT/1/A/4600/001, Rod control cluster assembly (RCCA) movement test

In-Service Tests (IST)

PT/1/A/4250/003C, Auxiliary feedwater motor driven pump 1A performance test

b.

Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation (71114.06)

a.

Inspection Scope

The inspectors observed the emergency preparedness drill conducted on July 28, 2016.

The inspectors observed licensee activities in the simulator and/or technical support

center to evaluate implementation of the emergency plan, including event classification,

notification, and protective action recommendations. The inspectors evaluated the

licensees performance against criteria established in the licensees procedures.

Additionally, the inspectors attended the post-exercise critique to assess the licensees

effectiveness in identifying emergency preparedness weaknesses and verified the

identified weaknesses were entered in the corrective action program. Documents

reviewed are listed in the Attachment.

b.

Findings

No findings were identified.

2.

RADIATION SAFETY (RS)

2RS1 Radiological Hazard Assessment and Exposure Controls (71124.01)

a. Inspection Scope

Hazard Assessment and Instructions to Workers: During facility tours, the inspectors

directly observed radiological postings and container labeling for areas established

within the radiologically controlled area (RCA) of the Unit 2 (U2) reactor building, U2

turbine building, Unit 1 (U1) and U2 auxiliary buildings, independent spent fuel storage

installation (ISFSI), and radioactive waste (radwaste) processing and storage locations.

The inspectors independently measured radiation dose rates or directly observed

conduct of licensee radiation surveys for selected RCA areas. The inspectors reviewed

survey records for several plant areas including surveys for airborne radioactivity,

17

gamma surveys with a range of dose rate gradients, surveys for alpha-emitters and

other hard-to-detect radionuclides, and pre-job surveys for upcoming tasks. The

inspectors also discussed changes to plant operations that could contribute to changing

radiological conditions since the last inspection. The inspectors attended pre-job

briefings and reviewed radiation work permit (RWP) details to assess communication of

radiological control requirements and current radiological conditions to workers.

Control of Radioactive Material: The inspectors observed surveys of material and

personnel being released from the RCA using small article monitor, personnel

contamination monitor, and portal monitor instruments. The inspectors discussed

equipment sensitivity, alarm setpoints, and release program guidance with licensee staff.

The inspectors also reviewed records of leak tests on selected sealed sources and

discussed nationally tracked source transactions with licensee staff.

Hazard Control: The inspectors evaluated access controls and barrier effectiveness for

selected high radiation area (HRA), locked high radiation area (LHRA), and very high

radiation area (VHRA) locations and discussed changes to procedural guidance for

LHRA and VHRA controls with radiation protection (RP) supervisors. The inspectors

reviewed implementation of controls for the storage of irradiated material within the

spent fuel pool. Established radiological controls, including airborne controls and

electronic dosimeter (ED) alarm setpoints, were evaluated for selected U2 refueling

outage (2EOC21) tasks such as steam generator inspections, tasks completed in lower

containment of U2, and tasks associated with lifting the reactor head. In addition, the

inspectors reviewed licensee controls for areas where dose rates could change

significantly as a result of plant shutdown and refueling operations. The inspectors also

reviewed the use of personnel dosimetry including extremity dosimetry and multibadging

in high dose rate gradients.

Radiation Worker Performance and RP Technician Proficiency: Occupational workers

adherence to selected RWPs and RP technician proficiency in providing job coverage

were evaluated through direct observations and interviews with licensee staff. Jobs

observed included work on the refueling floor, lifting the reactor head, and steam

generator tasks in high radiation and contaminated areas. The inspectors also

evaluated worker responses to dose and dose rate alarms during selected work

activities.

Problem Identification and Resolution: The inspectors reviewed and assessed condition

reports associated with radiological hazard assessment and control. The inspectors

evaluated the licensees ability to identify and resolve the issues in accordance with

licensee procedures. The inspectors also reviewed recent self-assessment results.

Inspection Criteria: Radiation protection activities were evaluated against the

requirements of Updated Final Safety Analysis Report (UFSAR) Section 12, Technical

Specifications (TS) Section 5.0, 10 CFR Parts 19 and 20, and approved licensee

procedures. Licensee programs for monitoring materials and personnel released from

the RCA were evaluated against 10 CFR Part 20 and IE Circular 81-07, Control of

Radioactively Contaminated Material. Documents and records reviewed are listed in

the Attachment.

18

The inspectors completed the required seven samples specified in Inspection Procedure

(IP) 71124.01.

b. Findings

No findings were identified.

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

(71124.02)

a. Inspection Scope

Work Planning and Exposure Tracking: The inspectors reviewed work activities and

their collective exposure estimates during the U2 refueling/maintenance outage

(2EOC21) and the recently completed U1 refueling/maintenance outage (1EOC22). The

inspectors reviewed ALARA planning packages for activities related to the following U2

high collective exposure tasks: primary side steam generator (S/G) work (diaphragm and

nozzle dam installation and removal, eddy current testing, and tube plugging); secondary

side S/G work (sludge lancing, foreign object search and retrieval (FOSAR), feed ring

inspection); reactor head disassembly and reassembly; temporary shielding installation;

and 2B reactor coolant pump motor removal and replacement. For the selected tasks,

the inspectors reviewed established dose goals and discussed assumptions regarding

the bases for the current estimates with responsible ALARA planners. The inspectors

evaluated the incorporation of exposure reduction initiatives and operating experience,

including historical post-job reviews, into RWP requirements. Day-to-day collective dose

data for the selected tasks were compared with established dose estimates and

evaluated against procedural criteria (work-in-progress review limits) for additional

ALARA review. Where applicable, the inspectors discussed changes to established

estimates with ALARA planners and evaluated them against work scope changes or

unanticipated elevated dose rates.

Source Term Reduction and Control: The inspectors reviewed the collective exposure

three-year rolling average from (2013 - 2015). The inspectors evaluated historical crud

burst/cleanup results and dose rate trends for reactor coolant system piping and

compared them to current 2EOC21 data. Source term reduction initiatives, including

cobalt reduction and zinc injection, were reviewed and discussed with RP staff. The

inspectors also reviewed temporary shielding packages for 2EOC21.

Radiation Worker Performance: As part of Inspection Procedure (IP) 71124.01, the

inspectors observed pre-job ALARA briefings and radiation worker performance for

various HRA jobs in the auxiliary building and containment. While observing job tasks,

the inspectors evaluated the use of remote technologies to reduce dose including

teledosimetry and remote visual monitoring.

19

Problem Identification and Resolution: The inspectors reviewed and discussed selected

corrective action program documents associated with ALARA program implementation.

The inspectors evaluated the licensees ability to identify and resolve issues. The

inspectors also reviewed recent self-assessment results.

Inspection Criteria: ALARA program activities were evaluated against the requirements

of UFSAR Section 12, TS Section 5.4, 10 CFR Part 20, and approved licensee

procedures. Documents reviewed are listed in the Attachment.

The inspectors completed the required five samples specified in IP 71124.02.

b. Findings

No findings were identified.

2RS3 In-Plant Airborne Radioactivity Control and Mitigation (71124.03)

a. Inspection Scope

Engineering Controls: The inspectors reviewed the use of temporary and permanent

engineering controls to mitigate airborne radioactivity during 2EOC21 outage tasks. The

inspectors observed the use of portable air filtration units for work in contaminated areas of

the RCA and reviewed filtration unit testing certificates. The inspectors evaluated the

effectiveness of continuous air monitors to provide indication of increasing airborne levels

and the placement of air samplers in work area breathing zones, including accounting for

alpha emitting nuclides inclusion in setpoint determination.

Respiratory Protection Equipment: The inspectors reviewed the use of respiratory

protection devices to limit the intake of radioactive material. This included review of

devices used for routine tasks and devices stored for use in emergency situations. The

inspectors reviewed ALARA evaluations for the use of respiratory protection for steam

generator work and other tasks performed during 2EOC21. Selected self-contained

breathing apparatus (SCBA) units and negative pressure respirators (NPRs) staged for

routine and emergency use in the main control room and other locations were inspected for

material condition, SCBA bottle air pressure, number of units, and number of spare masks

and availability of air bottles. The inspectors reviewed maintenance records for selected

SCBA units for the past two years and evaluated SCBA and NPR compliance with National

Institute for Occupational Safety and Health certification requirements. The inspectors also

reviewed records of air quality testing for supplied-air devices and SCBA bottles.

The inspectors discussed training for various types of respiratory protection devices with

licensee staff and interviewed radworkers and control room operators on use of the devices

including SCBA bottle change-out and use of corrective lens inserts. The inspectors

reviewed respirator qualification records (including medical qualifications) for several main

control room operators and emergency responder personnel. In addition, inspectors

evaluated qualifications for individuals responsible for testing and repairing SCBA vital

components.

20

Problem Identification and Resolution: The inspectors reviewed and discussed selected

corrective action program documents associated with airborne controls and respiratory

protection activities. The inspectors evaluated the licensees ability to identify and

resolve issues. The inspectors also reviewed recent self-assessment results.

Inspection Criteria: Radiation protection program activities associated with airborne

radioactivity monitoring and controls were evaluated against details and requirements

documented in the UFSAR Chapters 3, 12 and 15; TS Sections 3.7, 5.5.11 and 5.5.16,

10 CFR Part 20; Regulatory Guide (RG) 8.15, Acceptable Programs for Respiratory

Protection and approved licensee procedures. Documents reviewed are listed in the

Attachment.

The inspectors completed the required four samples specified in IP 71124.03.

b. Findings

No Findings

2RS4 Occupational Dose Assessment (71124.04)

a. Inspection Scope

Source Term Characterization: The inspectors reviewed the plant radiation

characterization (including gamma, beta, alpha, and neutron) being monitored verified

the use of scaling factors to account for hard-to-detect radionuclides in internal dose

assessments.

External Dosimetry: The inspectors reviewed national voluntary accreditation program

(NVLAP) certification data of the licensees thermoluminescent dosimeter (TLD)

processor for the years 2014 through 2017. The inspectors observed and evaluated

onsite storage of TLDs. Comparisons between ED and TLD results, including correction

factors, were reviewed and discussed. The inspectors also evaluated licensee

procedures for unusual dosimetry occurrences. Electronic dosimeter alarm logs were

reviewed as part of Inspection Procedure 71124.01.

Internal Dosimetry: The inspectors reviewed and discussed the in-vivo bioassay

program with the licensee. Inspectors reviewed procedures that addressed methods for

determining internal or external contamination, releasing contaminated individuals, and

the assignment of dose. The inspectors evaluated the licensees program for in-vivo and

in-vitro monitoring including passive whole body monitoring and bioassay results for

diving activities. The inspectors also reviewed contamination logs and evaluated events

with the potential for internal dose.

21

Special Dosimetry Situations: The inspectors reviewed records for declared pregnant

workers (DPWs) from June 2014 through June 2016 and discussed guidance for

monitoring and instructing DPWs. Inspectors reviewed the licensees program for

monitoring external dose in areas of expected dose rate gradients, including the use of

multi-badging and extremity dosimetry. The inspectors evaluated the licensees neutron

dosimetry program including instrumentation used to perform neutron surveys. In

addition, the inspectors reviewed the licensees program for evaluation of shallow dose

equivalent (SDE). The inspectors also reviewed contamination logs and evaluated

events with the potential for SDE.

Problem Identification and Resolution: The inspectors reviewed and discussed selected

corrective action program documents associated with occupational dose assessment

including self-assessments. The inspectors evaluated the licensees ability to identify

and resolve issues.

Inspection Criteria: The licensees occupational dose assessment activities were

evaluated against the requirements of UFSAR Section 12; TS Section 5.4; 10 CFR Parts

19 and 20; and approved licensee procedures. Documents reviewed are listed in the

Attachment.

The inspectors completed the required five samples specified in IP 71124.04.

b. Findings

No findings were identified.

2RS5 Radiation Monitoring Instrumentation (71124.05)

a. Inspection Scope

The inspectors reviewed the licensees radiation monitoring instrumentation programs to

verify the accuracy and operability of radiation monitoring instruments used to monitor

areas, materials, and workers to ensure a radiologically safe work environment during

normal operations and under postulated accident conditions.

Walkdowns and Observations: During tours of the site areas, the inspectors observed

installed radiation detection equipment including the following instrument types: area

radiation monitors (ARMs), continuous air monitors (CAMs), personnel contamination

monitors (PCMs), small article monitors (SAMs), and portal monitors (PMs). The

inspectors observed the calibration status, physical location, material condition and

compared technical specifications for this equipment with UFSAR requirements. In

addition, the inspectors observed the calibration status and functional checks of selected

in-service portable instruments and discussed the bases for established frequencies and

source ranges with RP staff personnel. The inspectors reviewed periodic source check

records for compliance with plant procedures and manufacturers recommendation for

selected instruments and observed the material condition of sources used.

22

Calibration and Testing Program: The inspectors reviewed calibration data for selected

ARMs, PCMs, PMs, SAMs, and laboratory instruments as well as the last calibration and

methodology for the whole body counter. The inspectors reviewed calibration data,

methodology used and the source certification for the containment high range monitor

area steam line monitors, control room area monitor, and refueling bridge monitors. The

current output values for the portable instrument calibrator and the instrument

certifications used to develop them were reviewed by the inspectors. The inspectors

reviewed the licensees process for investigating instruments that are removed from

service for calibration or response check failures and discussed specific instrument

failures with plant staff. In addition, the inspectors reviewed 10 CFR 61 data to

determine if sources used in the maintenance of the licensees radiation detection

instrumentation were representative of radiation hazards in the plant and scaled

appropriately for hard to detect nuclides.

Problem Identification and Resolution: The inspectors reviewed and discussed selected

corrective action program documents associated with radiological instrumentation

including licensee sponsored assessments. The inspectors evaluated the licensees

ability to identify and resolve issues.

Inspection Criteria: Operability and reliability of selected radiation detection instruments

were reviewed against details documented in the following: 10 CFR Part 20; NUREG-

0737, Clarification of TMI Action Plan Requirements; UFSAR Chapters 11 and 12, TS Sections 3.3 and 5.4, and applicable licensee procedures. Documents reviewed are

listed in the Attachment.

The inspectors completed the required three samples specified in IP 71124.05.

b. Findings

No findings were identified.

4.

OTHER ACTIVITIES

4OA1 Performance Indicator Verification (71151)

a.

Inspection Scope

The inspectors reviewed a sample of the performance indicator (PI) data, submitted by

the licensee, for the Unit 1 and Unit 2 PIs listed below. The inspectors reviewed plant

records compiled between July 2015 and June 2016 to verify the accuracy and

completeness of the data reported for the station. The inspectors verified that the PI

data complied with guidance contained in Nuclear Energy Institute 99-02, Regulatory

Assessment Performance Indicator Guideline, and licensee procedures. The inspectors

verified the accuracy of reported data that were used to calculate the value of each PI.

In addition, the inspectors reviewed a sample of related corrective action documents to

verify the licensee was identifying and correcting any deficiencies associated with PI

data. Documents reviewed are listed in the Attachment.

23

Cornerstone: Initiating Events

unplanned power changes per 7000 critical hours

Cornerstone: Mitigating Systems

residual heat removal system

Cornerstone: Occupational Radiation Safety

occupational exposure control effectiveness

The inspectors reviewed the occupational exposure control effectiveness PI results for

the occupational radiation safety cornerstone from January 2015 through August 2016.

For the assessment period, the inspectors reviewed electronic dosimeter alarm logs and

condition reports related to controls for exposure significant areas. Documents reviewed

are listed in the attachment.

Cornerstone: Public Radiation Safety

radiological control effluent release occurrences

The inspectors reviewed the radiological control effluent release occurrences PI results

for the public radiation safety cornerstone from January 2015 through August 2016. For

the assessment period, the inspectors reviewed cumulative and projected doses to the

public contained in liquid and gaseous release permits and condition reports related to

radiological effluent technical specifications/ODCM issues. The inspectors also

reviewed licensee procedural guidance for collecting and documenting PI data.

Documents reviewed are listed in the attachment.

b.

Findings

No findings were identified.

4OA2 Problem Identification and Resolution (71152)

.1

Routine Review

The inspectors screened items entered into the licensees corrective action program to

identify repetitive equipment failures or specific human performance issues for follow-up.

The inspectors reviewed problem identification program reports, attended screening

meetings, or accessed the licensees computerized corrective action database.

24

.2

Annual Followup of Selected Issues

a.

Inspection Scope

The inspectors conducted a detailed review of the following two nuclear condition reports

(NCRs):

CR 2058838, Multiple failed barriers during maintenance task

CR 2055501, Extended equalize required for safe shutdown facility battery SDSB2

The inspectors evaluated the following attributes of the licensees actions:

complete and accurate identification of the problem in a timely manner

evaluation and disposition of operability and reportability issues

consideration of extent of condition, generic implications, common cause, and

previous occurrences

classification and prioritization of the problem

identification of root and contributing causes of the problem

identification of any additional condition reports

completion of corrective actions in a timely manner

Documents reviewed are listed in the Attachment.

b.

Findings and Observations

No findings were identified.

4OA3 Event Followup

(Closed) Licensee Event Report (LER) 05000413/2014-002-00, 01: Unanalyzed

Condition Due to Deviations from Fire Protection Current Licensing Basis Identified

During NFPA 805 Transition

a.

Inspection Scope

On June 2, 2014, the licensee submitted an LER documenting the discovery of a

condition of non-compliance with the sites fire protection program (FPP). These

conditions could prevent operators from achieving and maintaining safe shutdown (SSD)

of the plant, in the case of a postulated fire.

The inspectors performed a detailed review of the information related to this LER.

Inspectors reviewed documents, and discussed the issues with licensee personnel to

gain an understanding of the issues. The inspectors assessed the licensees

compensatory measures and corrective actions to determine if they were adequate.

LERs 05000413/2014-002-00, 01 are closed.

25

b.

Findings

Introduction: The licensee identified a non-compliance with Operating License Condition

2.C.(5), for Units 1 and 2, for the failure to protect one of the redundant trains of

equipment needed to achieve post-fire SSD from fire damage. Specifically, the licensee

failed to use one of the means described in Branch Technical Position (BTP) Chemical

Engineering Branch (CMEB) 9.5-1, Item C.5.b.2 to ensure that one of the redundant

trains of equipment necessary to achieve and maintain hot shutdown conditions was

protected from fire damage.

Description: On June 2, 2014, the licensee submitted LER 413/2014-002-00 with

Revision 01 submitted on December 1, 2014, which documented discovery of cable

routing issues and postulated fire-induced circuit failures that could prevent operation or

cause maloperation of equipment required to achieve SSD in the event of a fire. This

condition was identified during the licensees transition to National Fire Protection

Association Standard 805 (NFPA 805).

During the transition to NFPA 805, the licensee identified multiple instances of cables for

equipment required to achieve SSD not meeting the separation requirements of the

current licensing basis. The licensee determined that this condition existed for 22 fire

areas (FAs) across both units. The licensee characterized these issues as variance(s)

from deterministic requirements (VFDRs). The conditions identified in the LER are

related to VFDRs that met the following criteria: 1) VFDRs that required a plant

modification to meet the fire risk criteria of NFPA 805, or 2) VFDRs where a potential

concern existed with respect to NRC Information Notice (IN) 92-18, Potential for Loss of

Remote Shutdown Capability During a Control Room Fire, dated February 28, 1992.

The licensee determined that the deficiencies existed because of latent design

deficiencies in the cable routing and circuit design. This LER was applicable to Units 1

and 2. Upon discovery, the licensee entered this issue into their corrective action

program as PIP C-1401427, and implemented compensatory actions in the form of fire

watches and/or control of transient combustible material for the affected FAs.

Analysis. Failure to protect one redundant train of cables and equipment necessary to

achieve post-fire SSD from fire damage was a performance deficiency. This finding was

more than minor because it was associated with the reactor safety mitigating system

cornerstone attribute of protection against external events (i.e., fire). Specifically, failure

to protect safe shutdown cables and equipment from fire damage negatively affected the

reactor safety mitigating systems cornerstone objective of ensuring the availability,

reliability, and capability of systems that respond to initiating events to prevent

undesirable consequences. Because this issue relates to fire protection and this non-

compliance was identified as a part of the sites transition to NFPA 805, this issue is

being dispositioned in accordance with Section 9.1, Enforcement Discretion for Certain

Fire Protection Issues (10 CFR 50.48) of the NRC Enforcement Policy.

In order to verify that this non-compliance was not associated with a finding of high

safety significance (Red), inspectors reviewed qualitative and quantitative risk analyses

performed by the licensee. These risk evaluations took ignition source and target

26

information from the licensees fire probabilistic risk assessment to demonstrate that the

significance of the non-compliances were less-than-Red (i.e. CDF less than 1E-4/year).

Inspectors determined that cables associated with some of the VFDRs were not located

in the zone of influence (ZOI) of any credible ignition source. For cables that were

located in the ZOI of a credible ignition source, inspectors were able to perform a

calculation to determine the change in conditional core damage probability (CCDP),

based on the postulated fire-affected equipment not being available. Based on these

screenings, inspectors determined that the significance of this non-compliance was less-

than-Red. A bounding risk assessment performed by a regional Senior Risk Analyst

(SRA) reviewed the licensee and inspector risk evaluations and confirmed the CDF risk

increase due to this condition was less than 1E-4, and therefore less than RED.

The inspectors determined that no cross cutting aspect was applicable to this

performance deficiency because this finding was not indicative of current licensee

performance.

Enforcement. Operating License Condition 2.C.(5), for Units 1 and 2, requires that the

licensee implement and maintain in effect all provisions of the approved FPP as

described in the UFSAR, as amended, for the facility and as approved in the SER

through Supplement 5. BTP CMEB 9.5-1, which incorporated the guidance of Appendix

A to BTP ASB 9.5-1 and the technical requirements of Appendix R to 10 CFR 50,

established the regulatory and licensing requirements for the FPP at Catawba Nuclear

Station (CNS). The CNS FPP was reviewed against and approved for conformance with

BTP CMEB 9.5-1 in the SER through Supplement 5. BTP CMEB 9.5-1, Item C.5.b.1,

requires that fire protection features be provided that are capable of limiting fire damage

so that one train of systems necessary to achieve and maintain hot standby conditions

from either the control room or emergency control station(s) is free from fire damage.

BTP CMEB 9.5- 1, Item C.5.b.2 requires one redundant train to be protected from fire

damage by one of the following specified methods:

(a) separation of cables and equipment by a fire barrier having a 3-hour rating,

(b) separation of cables and equipment by a horizontal distance of more than 20 feet

with no intervening combustibles or fire hazards and with fire detectors and an

automatic fire suppression system in the fire area, or

(c) enclosure of cables and equipment in a fire barrier having a 1-hour rating and with

fire detectors and an automatic fire suppression system in the fire area.

Contrary to the above, the licensee failed to use one of the means described in BTP

CMEB 9.5-1, Item C.5.b.2 to ensure that one of the redundant trains of equipment

necessary to achieve and maintain hot shutdown conditions was protected from fire

damage. Specifically, on April 2, 2014, the licensee identified the failure to protect

equipment in accordance with the current licensing basis. The licensee determined that

fire damage could prevent operation of, or cause maloperation of, components that were

required to achieve and maintain SSD. This condition has existed since initial plant

startup for Units 1 and 2. The licensee entered this issue into the corrective action

program (PIP C-14-1427) and implemented compensatory measures in the form of fire

watches and/or control of transient combustible material for the affected FAs.

27

Because the licensee committed to adopt NFPA 805 and change their fire protection

licensing bases to comply with 10 CFR 50.48(c), the NRC is exercising enforcement and

reactor oversight process (ROP) discretion for this issue in accordance with the NRC

Enforcement Policy, Section 9.1, Enforcement Discretion for Certain Fire Protection

Issues (10 CFR 50.48) and Inspection Manual Chapter 0305. Specifically, this issue

was identified and will be addressed during the licensees transition to NFPA 805, it was

entered into the licensees corrective action program, immediate corrective action and

compensatory measures were taken, it was not likely to have been previously identified

by routine licensee efforts, it was not willful, and it was not associated with a finding of

high safety significance (Red).

4OA5 Other Activities

.1

Operation of an Independent Spent Fuel Storage Installation (60855.1)

a.

Inspection Scope

The inspectors performed a walkdown of the onsite independent spent fuel storage

installation (ISFSI). The inspectors reviewed changes made to the ISFSI programs and

procedures, including associated 10 CFR 72.48, Changes, Tests, and Experiments,

screens and evaluations to verify that changes made were consistent with the license or

certificate of compliance. The inspectors reviewed records to verify that the licensee

recorded and maintained the location of each fuel assembly placed in the ISFSI. The

inspectors also reviewed surveillance records to verify that daily surveillance

requirements were performed as required by technical specifications. Documents

reviewed are listed in the Attachment.

b.

Findings

No findings were identified.

4OA6 Meetings, Including Exit

On October 24, 2016, the resident inspectors presented the inspection results to Mr.

Tom Simril and other members of the licensees staff. The inspectors verified that no

proprietary information was retained by the inspectors or documented in this report.

ATTACHMENT: SUPPLEMENTAL INFORMATION

Attachment

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

C. Abernathy, Manager, Nuclear Site Services

S. Andrews, Sr. Engineer Regulatory Affairs,

T. Arlow, Emergency Planning Manager

C. Bigham, Director Nuclear Organizational Effectiveness

M. Carwile, Chemistry Manager

C. Cauthen, SG Inspection Program

B. Cauthen, Lead Engineer

C. Curry, Plant Manager

C. Fletcher, Regulatory Affairs Manager

N. Flippin, Work Management Manager

B. Foster, Operations Manager

T. Jenkins, Maintenance Manager

A. Keller, ISI Program Owner

L. Keller, General Manager Nuclear Engineering

T. Koleva, Boric Acid Program Owner

B. Leonard, Training Manager

T. Simril, Site Vice-President

J. Smith, Radiation Protection Manager

S. West, Director, Nuclear Plant Security

B. Weaver, PRA Engineer

C. Wilson, Sr. Engineer Regulatory Affairs

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Closed

413/2014-002-00

LER

Unanalyzed Condition Due to Deviations from Fire

Protection Current Licensing Basis Identified During

NFPA 805 Transition (Section 4OA3)

413/2014-002-01

LER

Unanalyzed Condition Due to Deviations from Fire

Protection Current Licensing Basis Identified During

NFPA 805 Transition (Section 4OA3)

LIST OF DOCUMENTS REVIEWED

Section 1R04: Equipment Alignment

OP/2/A/6350/002, D/G Valve and Breaker Checklist

OP/1/A/6200/007, Containment Spray System

OP/2/A/6250/002, Auxiliary Feedwater Valve Check List

Section 1R05Q: Fire Protection

Fire Brigade Response Strategies for Safety-Related Areas, Rev. 039

Fire Strategy Plan, Fire Area 22: 594 Aux. Building

Fire Strategy Plan N: 594 Turbine Building

Fire Strategy Plan, Fire Area 27: 2A D/G room

Fire Strategy Plan, Fire Area 15: Unit 1 Essential Switchgear Room 577

Fire Strategy Plan, Fire Area 8: Unit 1 Essential Switchgear Room 560

PT/0/A/4400/001 P, Inspection of Portable Fire Extinguishers, Rev. 086

PT/0/A/4400/001 T, Visual Inspection of Fire Hose Stations and Fire Hose Equipment Houses,

Rev. 005

WO 20078175 01, Monthly Inspection of Portable Fire Extinguishers, June 2016

WO 20012734 01, Visual Inspection of Fire Hose Stations, January 2016

AR #02048934

Section 1R06: Internal Flooding

CR 2050606, Potential failure of circulation water expansion joints

Section 1R07 Heat Sink Performance

Procedures

AD-OP-ALL-0105, Operability Determinations and Functionality Assessments, Rev. 003

MP/0/A/7150/098, Nuclear Service Water (RN) Pump, Motor Upper Bearing Oil and Motor

Coolers Chemical Cleaning, Rev. 012

OP/0/A/6400/006 M, Nuclear Service Water System Unwatering Procedure, Rev. 070

PT/0/A/4400/008 A, RN Flow Balance Train A, Rev. 063

PT/0/A/4400/008 B, RN Flow Balance Train B, Rev. 057

PT/0/A/4400/024, SNSWP Temperature Monitoring, Rev. 014

Calculations

CNC-1150.01-00-0001, SNSWP Thermal Analysis during One Unit LOCA and One Unit

Shutdown, Rev. 019

CNC-1150.04-00-0009, Area and Volume of the Stby. Nuclear Service Water Pond, Rev. 002

CNC-1223.24-00-0011, Nuclear Service Water System Test Criteria, Rev. 037

Drawings

CN-1397-4, SNSW Pond Instrumentation Pier, Rev. 008

CN-1574-01.00, Flow Diagram of Nuclear Service Water System (RN), Rev. 056

CN-1574-01.01, Flow Diagram of Nuclear Service Water System (RN), Rev. 061

CN-1574-01.02, Flow Diagram of Nuclear Service Water System (RN), Rev. 056

CN-1574-02.01, Flow Diagram of Nuclear Service Water System (RN), Rev. 058

CNSF-1574-RN.01, Summary Flow Diagram Nuclear Service Water System (RN), Rev. 006

3

Corrective Action Documents

AR 01554606, OEDB 60799 Subject: IER L2-12-27, Reactor Scram and Loss of Off-Site Power

AR 1516631, SNSWP local level indication at the end of the outfall pier

AR 1898305, No flow discharging from long leg discharge of either A or B

PIP C-99-2777, Assessment SA-99-26(CN)(PA)

Other Documents

AD-EG-PWR-1611, Boric Acid Corrosion Control Program - Implementation, Rev. 001

AD-MN-ALL-0006, Fluid Leak Management, Rev. 000

Catawba Unit 2EOC21 Steam Generator Degradation Assessment, Rev. 001

Certificate of Compliance for UT Test Block 15-1890

Certificate of Conformity for UT Probe SN: SB1593, SB1542, RTD 03-786

Certification of Analysis for Ferromor ND 8 Yellow Lot# F-21011

Certified Test Report for Ultragel II-12125

CNS-SG-ANL-GL, Eddy Current Guidelines for Duke Energys D5 Steam Generators, Rev. 001

D5-SG-Appendix H Qual, D5 Steam Generators Site Technique Validation for Catawba Nuclear

Station Unit 2, Rev. 001

Instrument Certification for Thermometer SN: 24620999

LTR-PL-16-42, Operability Assessment for Primary Side Loose Parts from Degraded Steam

Generator Channel Head Cladding at Catawba Unit 2

Magnetic Particle Examination Report No.: MT-16-177, MT-16-178

NDE Qualification Certification for Examiners: MGW-4124, KCE-3815, MLO-2292, 624655,

625282, 246199, MGH-4124, TJW-1341

PD-EG-PWR-1611, Boric Acid Corrosion Control Program, Rev. 001

UT Calibration/Examination Report No.: UT-16-1342

Visual Examination Record for Boric Acid Detection Report No.: VT-16-1364, VT-16-1484

Weld Performance Qualification Test for welders: O2847, H5555

Welding Procedure Qualification Record No.: L-110D, L-138, L-148C

Welding Procedure Specification Technical Sheet: GTOO0808-04

Condition Reports

AR 01898992, Excessive / Active boron accumulation from 2-NI-VA-327 pipe

AR 01901090, During fit-up inspection, QC noted minimum wall thickness violation

AR 01931170, 0-WL-FE-9780 Active / Excessive boron leak from flange

AR 01940775, 1-NM-PG-6100 Active / Excessive boron from threaded fitting

AR 01950202, 2-KF-FS-5150 Active boron leak from fitting 30-40 dpm

AR 01985576, Boric Acid Corrosion Control Program - Implementation Procedure Effectiveness

AR 02020057, 1-NS-VA-1B Excessive/active boron, leak increase

AR 02047391, 1-FW-VA-45 Active Boron Leak

AR 02060612, Heavy corrosion and scaling on the lower head

AR 02060953, 2B NC Pump main flange leak

AR 02061334, Area of exam coverage limitation encountered during UT exam

AR 02062097, Potential misapplication of SR 3.0.2 and SR 3.0.3

AR 02062162, Minimum wall thickness violation under WO 20025151

AR 02062576, ISI UT Exam Coverage Limitation

AR 02062987, Steam Generator 2D primary channel head cladding

AR 02063362, Supports in U2 lower containment

5

AR 02063371, BAC walkdown in U2 containment

AR 02065690, Indentation in U2 reactor head next to outer O-ring groove

Work Orders (WO)/Work Requests (WR)

WO 02129915, 1NS-01B Dry Boron at Valve Packing

WO 02144333, 2NW-061B: Clean Valve and Internals Delete, Bonnet Seal Weld

WO 20001790, 2SM-005: Replace Gamma Plug

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

PRT-2-16-2ADGOOS-014: 2A DG OOS

PRT-0-16-SSF SG WK 28-0158

PRT-1-16-1BNSOOS, 1A NS protected due to 1B NS tagged

Section 1R15: Operability Evaluations

PT/2/A/4200/031, SV Valve Inservice Test (QU), March 30, 2016

PT/2/A/4200/031, SV Valve Inservice Test (QU), June 22, 2016

AD-OP-ALL-0105, Operability Determinations and Functionality Assessments, Rev. 003

NCR #02039992

IDO Template filled out for SV-19 Initial Operability Determination; June 23, 2016

OMP 2-29, LCO Tracking, Rev. 061

Section 2RS1: Radiological Hazard Assessment and Exposure Controls

Procedures, Guidance Documents and Manuals

AD-RP-ALL-2001, Taking, Counting, and Recording Surveys, Rev. 001

AD-RP-ALL-2009, Personnel Contamination Monitoring and Reporting, Rev. 002

AD-RP-ALL-2017, Access Controls for High, Locked High, and Very High Radiation Areas,

Rev. 002

AD-RP-ALL-3001, Control of Radioactive Material and Use of Radioactive Material Labels,

Rev. 001

RA/2/1100/004, Unit 2 Required Surveys for Plant Transients, Rev. 013

RA/0/1700/003, Issuance and Return of Radioactive Sources, Rev. 001

Records and Data

AD-RP-ALL-2011, Radiation Protection Briefings Attachment 2, Rx Head Move, 9/14/2016

AD-RP-ALL-2017, Access Controls for High, Locked High, and Very High Radiation Areas:

Attachment 1, 09/14/2016, 18:42.

AD-RP-ALL-2017, Access Controls for High, Locked High, and Very High Radiation Areas:

Attachment 1, 09/14/2016, 11:55.

AD-RP-ALL-2017 Rev 2, Attachment 9 <<LHRA or VHRA Key Log >>, 09/23/2016-09/28/2016

@ 8:30

Boundary TLD Dose Trending Report 03/01/2015 - 07/21/2016

Catawba Nuclear Site Semiannual Source Inventory and Leak Test, 06/02/2016 (in part)

Catawba Nuclear Station- Unit 2 EOC-21 Refueling Outage Hi level Schedule 09/26/2016 -

09/29/2016

Confirmation Form 2016 Annual Inventory Reconciliation [NSTS Sources], 01/13/2016

Gamma Spectrum Analyses:

12-Sep-16-220016, E/C thimble tube inspection B/Z RWP 2108, 09/12/2016

12-Sep-16-220015, E/C Thimble Tube Inspect HEPA exhaust RWP 2108, 09/12/2016

6

CN16091300020, U2 RX L/C Decon Seal Table RWP 2103, 09/13/2016

CN16091300062, U2 Rx L/C Retracting Incore Thimble Tubes RWP 2126, 09/13/2016

CN16091400017, U2 Rx UC Cavity Seal sand-box covers RWP 2405/9

CN16091400025, U2 Rx UC C/S Rtn RWP 2401/1

CN16091400007, U2 Rx UC Shallow End Stud Hole Plugs RWP 2405

CN16091400016, U2 Rx UC C/S Rtn RWP 2401

CN16092700052, U2 RX L/C PRT Platform Rtn RWP 2101, 09/27/2016

CN16092700035, U-2 L/C PRT Platform Routine, 09/27/2016

CN16092700041, U2 L/C A/D CACFU Exhaust, 09/27/2016

CN16092600046, L/C A C/L Nozdam Remov/RT Prep/Boundary, 9/26/2016

CN16092700049, U2 L/C D Platform Rtn, 9/27/2016

CN16092700026, U2 Rx L/C B/C SG Nozzle Dam Boundary RWP 2808, 9/27/2016

CNS-M-20150306-33, U2 Rx Bldg\\U-2 Upper Cont., 3/6/2015

CNS-M-20150306-34, U2 Rx Bldg\\U-2 Upper Cont., 3/6/2015

CNS-M-20160404-2, Aux Bldg\\543 Elevation room 222 A-B, 04/04/2016

Interstation Letter Subject: CNS Material Stored in Spent Fuel Pools-2015

VSDS Standard Survey Report(s):

CNS-M-20160911-18, U2 Rx Bldg\\U-2 Lower Cont., 09/11/2016

CNS-M-20160911-24, U2 Rx Bldg\\U-2 Lower Cont., 09/11/2016

CNS-M-20160913-15, U2 Rx Bldg\\U-2 Lower Cont., 09/12/2016

CNS-M-20160913-20, U2 Rx Bldg\\U-2 Lower Cont., 09/13/2016

CNS-M-20160912-52, U2 Rx Bldg\\U-2 Lower Cont., 09/12/2016

CNS-M-20160914-1, U2 Rx Bldg\\U-2 Lower Cont., 09/14/2016

CNS-M-20160914-28, U2 Rx Bldg\\U-2 Upper Cont., 09/14/2016

CNS-M-20160914-30, U2 Rx Bldg\\U-2 Upper Cont., 09/14/2016

CNS-M-20160127-7, ISFSI Yard, 01/27/2016

RA/2/1100/001, Unit 2 Outage Upper Containment Controls and Surveillance: Enclosure 5.28,

09/14/2016, 8:55-16:00.

CAP Documents

AD-PI-ALL-0100, Corrective Action Program, Rev. 006

Action Requests (AR): 01538967, 01540206, 01540302, 01897614, 01898359, 01901055 and

02065328

Section 2RS2: ALARA

Procedures, Guidance Documents, and Manuals

AD-RP-ALL-2000, Preparation and Management of Radiation Work Permits (RWP), Rev. 001

AD-RP-ALL-2006, Radiation Protection Risk Management Process, Rev. 001

AD-RP-ALL-2019, TEDE ALARA Evaluations and DAC hour Tracking, Rev. 001

AD-RP-ALL-9000, ALARA Program, Rev. 004

AD-RP-ALL-9001, ALARA Planning, Rev. 001

AD-RP-ALL-9002, Sentinel ALARA Management, Rev. 000

AD-RP-ALL-9006, Failed Fuel Action Plan, Rev. 000

AD-RP-ALL-9007, Radiation Protection Source Term Review, Rev. 000

CSD-CP-CNS-0001, Catawba Primary Chemistry Strategic Plan, Rev. 001

Duke Fleet ALARA Manual, Various Revisions depending on Section

7

Records and Data

AD-RP-ALL-5002, Attachment 4, 10 CFR 61 Review, Catawba Nuclear Station, Annual General

Station Review, 3/1/2016

ALARA Critique, Plan # C-OL-15-10, Unit 2 Repair/Replace 2BB-012, 8/31/2015

ALARA Critique, Plan # C1EOC22-15-02, 1EOC22 Reactor Head Activities, 3/9/2016

ALARA In-Progress Review, Plan # C1EOC22-15-02, 1EOC22 Reactor Head Activities; 35%

exposure/39% work, 11/26/2015; 85% exposure/54% work, 12/3/2015; 100% exposure/70%

work, 12/9/2015

ALARA In-Progress Review, Plan # C-OL-15-10, Unit 2 Repair/Replace 2BB-012, 73%,

8/31/2015

ALARA In-Progress Review, Plan # C2EOC21-16-02, Headwork Activities, 24% exposure/36%

work, 9/15/2016

ALARA In-Progress Reviews, Plan # 2EOC21-16-04, Steam Generator Primary Side Activities:

21% exposure/14% work, 9/20/2016; 50% exposure/44% work, 9/24/2016

ALARA In-Progress Review, Plan # C2EOC21-16-08, Steam Generator Nozzle Dam Activities,

58% exposure/43% work, 9/20/2016

ALARA In-Progress Reviews, Plan # C2EOC21-16-10, 2B NC Pump Motor Removal/

Replacement: 2% exposure/1.6% work, 9/12/2016; 22.7% exposure/18% work, 9/17/2016;

39.3% exposure/48% work, 9/20/2016; 53% exposure/58% work, 9/23/2016; 75.3%

exposure/76% work, 9/23/2016

ALARA Long Range Plan 2014-2018 (2014 Update), Catawba Nuclear Station, 2/11/2014

ALARA Long Range Plan 2015-2020 (2015 Update), Catawba Nuclear Station, 8/15/2015

ALARA Long Range Plan 2016-2021 (2016 Update), Catawba Nuclear Station, 4/28/2016

ALARA Plan (AP), Plan # C-OL-15-10, Unit 2 Repair/Replace 2BB-012, 8/27/2015

AP, Plan # C1EOC22-15-02, 1EOC22 Reactor Head Activities, Rev 0, 10/29/2015

AP, Plan # C1EOC22-15-02, 1EOC22 Reactor Head Activities, Rev 1, 12/3/2015

AP, Plan # C1EOC22-15-02, 1EOC22 Reactor Head Activities, Rev 2, 12/9/2015

AP, Plan # 2EOC21-16-01, Install/Remove Temporary Shielding During 2EOC21, Rev. 000,

8/10/2016

AP, Plan # C2EOC21-16-02, Reactor Head Activities, Rev. 000, 8/9/2016

AP, Plan # C2EOC21-16-04, Steam Generator Primary Side Activities, Rev. 000, 8/9/2016

AP, Plan # C2EOC21-16-05, Steam Generator Secondary Side Activities, Rev. 000, 8/9/2016

AP, Plan # C2EOC21-16-10, 2B NC Pump Motor Removal/Replacement, Rev. 000, 8/4/2016

Catawba Nuclear Station ALARA Committee Meeting Minutes [Including 2EOC21 Challenge

Boards], January through June 2016

CNS Unit 1 EOC22 Refueling & Maintenance Outage Summary of Personnel Radiation

Exposures [Outage ALARA Report], 3/18/2016

CNS Radiation Protection Daily Status Reports/Graphs [Dose Tracking by work group and site]:

9/14/2016; 9/28/2016; and 9/29/2016

CNS Unit 2 EOC-21 Refueling Outage High Level Schedule(s): 9/12/2016-9/15/2016; 9/13-

2016-9/16/2016; 9/15/2015-9/18/2016; and 9/26/2016-9/29/2016

Micro ALARA Plan, Unit 2 Dry Cask Storage for Cask 82, 6/16/2016

Micro ALARA Plan, Unit 2 Dry Cask Storage for Cask 82, Post Job Review, 8/3/2016

Radiation Work Permits (RWP): RWP #2125, Shielding Activities (Lower Containment and

Annulus), Rev 22; RWP #2162, 2B NCP Motor Replacement, Rev 9; RWP # 2405, Reactor

Head Activities (U/C), Rev 21; RWP #2453, RX Head Inspections Includes Shroud, Hanger,

Insulation & Inspection (U/C), Rev 9; RWP #2806, S/G Remove/Install Man Ways and

Diaphragms/Bowl Pumping, Rev 30; RWP #2808, S/G Install/Remove Nozzle Covers/Dams,

8

Rev 27; RWP #2812, S/G Eddy Current Activities, Rev 43; RWP #2814, SIG Plugging

Activities, Rev. 032

RWP List Report, Catawba Nuclear Station, RWP Status, 7/12/2016

Spreadsheet, 2015 Annual ALARA Estimate (by Work Group), undated

Spreadsheet, 2016 Annual ALARA Estimate (by Work Group), undated

TEDE ALARA Evaluations: Unit 2 Reactor Cavity Deep End-Blind Flange Install (RWP 2415),

9/12/2016; Unit 2 Reactor Cavity-Head Flange Cleaning and Cavity Seals (RWP2405),

9/9/2016; Unit 2 Seal Table-Eddy Current Activities (RWP 2108), 8/25/2016; Unit 2 S/G

Bowls-Nozzle Dams (RWP 2808), 9/1/2016; Unit 2 S/G Platform-Platform Work (RWPs 2806,

2810, 2812, 2814, 2834, & 2839), 9/1/2016

Temporary Shielding Request (TSR), TSR 16-232, Pressurizer Surge Line for 2B RCP Motor

Work, 8/10/2016; TSR 16-235, PZR Curtain@593', 3/1/2016; TSR 16-235B, PZR Curtain at

2NCMR B, 8/10/2016; TSR 16-291, 2B Cold Leg Pipe, 8/8/2016; TSR 16-296, 2B Hot Leg,

8/10/2016; TSR 16-296B, 2B Hot Leg RTD, 8/10/2016

VSDS Survey # CNS-M-20150828-4, 2BB12 Job Coverage, 8/28/2015

VSDS Survey # CNS-M-20160912*6, U2 Rx Bldg\\U2 L/C Surge line Pre Shield [TSR16-232],

9/12/2016

VSDS Survey # CNS-M-20160912*6, Post Shielding for TSR16-232, 9/13/2016

VSDS Survey # CNS-M-20160911-14, Pre Shielding for TSR 16-235B, 9/11/2016

VSDS Survey # CNS-M-20160910-5, 2EOC21 Initial Entry [2B Loop], 9/10/2016

VSDS Survey # CNS-M-20160914-3, Post Shielding B Cold Leg for TSR 16-291, 9/13/2016

VSDS Survey # CNS-M-20160912-47, Pre and Post Shielding survey of 2B Hot Leg, 9/12/2016

VSDS Survey # CNS-M-20160913-13, Pre and Post Shielding survey of 2B Hot Leg, 9/13/2016

1EOC22 Crud Burst Cleanup Dose Rate Data, with Graph [including comparison to previous

outages], 9/13/16

2EOC21 Crud Burst Cleanup Dose Rate Data, with Graph [and comparison to previous

outages], 9/13/16

2015 DAW Site Composite Smear Sample for 10 CFR 61, 8/28/2015

Corrective Action Program (CAP) Documents

AD-PI-ALL-0100, Corrective Action Program, Rev. 006

Self-Assessment, Perform Annual Radiation Protection Program review (ALARA program

portion) as required by 10 CFR 20.1101(c), 10/29/2015

Self-Assessment Report G-FRPS-SA-15-22, 2015 Catawba Nuclear Station Radiation

Protection Source Term Review, 10/20/2015

Self-Assessment Report C-RPS-SA-14-18, Assessment of CNS Dose Delta PIPs, 10/29/2014

PIPs C-14-0684 (AR 01534122), C-14-10693 (AR 01897403), and C-14-10854 (AR 01897418)

Action Requests (AR): 01519038, 01535695, 01536851, 01538606, 01901022, 01901145,

01929101, 01961173, 01982820, and 02026974

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

Procedures, Guidance Documents, and Manuals

AD-RP-ALL-2019, TEDE ALARA Evaluations and DAC Hour Tracking, Rev. 001

AD-RP-ALL-6002, Inspections of Self-Contained Breathing Apparatus (SCBA) and Associated

Equipment, Rev. 000

HP/0/B/1000/006, Emergency Equipment Functional Check and Inventory, Rev. 061

PT/0/B/4600/032, Fire Brigade Equipment Inspection/Inventory, Rev. 012

PT/1/A/4450/001, Containment Purge Periodic Test, Rev. 029

9

PT/1/A/4450/001, Fuel Pool Area Filtered Exhaust Filter Train Performance Test, Rev. 026

PT/1/A/4450/009, Spent Fuel Ventilation System Train A Operability Test, Rev. 028

RA/0/1100/007, Use of Portable Ventilation Systems in Radiologically Controlled Areas,

Rev. 000

RA/0/1600/001, Respiratory Protection Equipment Receipt, Cleaning, Storage and

Documentation, Rev. 008

RA/0/1600/004, Recharging Self-Contained Breathing Apparatus, Rev. 002

Records and Data

EnRad Laboratories Central Calibration Facility Flow Test Calibration, ID 04530, 06/14/2016

EnRad Laboratories Central Calibration Facility Flow Test Calibration, ID 04186, 12/14/2015

EnRad Laboratories Central Calibration Facility Flow Test Calibration, ID 04210, 03/15/2016

EnRad Laboratories Central Calibration Facility Flow Test Calibration, ID 04160, 03/15/2016

EnRad Laboratories Central Calibration Facility Flow Test Calibration, ID 04339, 02/192016

MSA C.A.R.E Authorized Repair Center & Technician Certification, Exp. 10/30/2015

PT/2/A/4450/001, Containment Purge Filter Train Performance Test Rev 035, 02/24/2015

PT/0/A/4450/001, Control Room Area Outside Air Pressure Filter Trains Performance Test,

04/01/16

RA/0/1400/012, System Integrity Testing of Portable HEPA Units: Enclosure 5.2, Rev 1,

09/2/2016

CAP Documents

AD-PI-ALL-0100, Corrective Action Program, Rev. 006

ARs: 01534067, 01537455, 01899485, 01900248, and 02018036

Section 2RS4: Occupational Dose Assessment

Procedures, Guidance Documents, and Manuals

AD-RP-ALL-2009, Personnel Contamination, Monitoring and Reporting, Rev. 002

AD-RP-ALL-2010, Skin Dose from Contamination, Rev. 000

AD-RP-ALL-4001, RP Number Issue and Rad Worker Activation, Rev. 005

AD-RP-ALL-4005, Dose Management, Rev. 002

AD-RP-ALL-4010, Internal Dose Assessment, Rev. 000

AD-RP-ALL-4011, In Vitro Bioassay, Rev. 000

AD-RP-ALL-4013, Area TLD Monitoring Program, Rev. 000

AD-RP-ALL-7008, APEX INVIVO Whole Body Counter Operation, Quality Control Checks and

Data Review, Rev. 000

ENRAD-PROC-839, Calibration of Canberra GEM-5 Portal Monitor, Rev. 002

RD/0/B/7000/13, Operation and Calibration of the IDCHF Electronic Dosimeter Calibrator,

Rev. 009

TE-RP-ALL-4001, Declared Pregnant Worker, Rev. 001

TE-RP-ALL-4003, Placement of Personnel Dosimetry for Non-Uniform Radiation Fields,

Rev. 000

TE-RP-ALL-4004, Multiple Dosimetry, Rev. 003

Records and Data

Apex-InVivo Whole Body Count Analysis Nuclide Libraries: Medical, CNS Routine, Fastscan

Calibration, Eu-152, and Qalib. 9/15/16

10

Apex-InVivo Whole Body Count Analysis Results: Multiple counts for RP Badge # V604976,

4/30/14

Apex-InVivo Whole Body Counter Background and QA Parameter report 4/2/2016 through

9/27/2016, 9/7/2016

Catawba Nuclear Station - TLD-ED Correlations for 1st Semi-Annual 2016, 8/17/2016

Catawba ISFSI Boundary TLD Dose Trending Report, 3/1/2015 through 7/21/2016, 7/21/2016

CNS Alpha Radiation Characterization, 12/18/15

CNS Radiation Protection Daily Status Reports: 9/14/2016 and 9/27/2016

List, Positive Whole Body Counts Since June 2014, undated

Internal Dose Assessment, RP Badge # V604976, 6/1/14

Map, 2014 ISFSI Boundary TLD Locations, 8/26/2016

Memo Catawba GEM-5 Passive Whole Body Sensitivity, 1/28/2014

NVLAP Proficiency Testing Report, Third Quarter 2014, 11/24/2014

NVLAP Certificate of Accreditation to ISO/IEC 17025:2005: Effective dates 4/1/2014 through

3/31/2015; 4/1/2015 through 3/31/2106; and 4/1/2016 through 3/31/2017

Personnel Contamination Event (PCE) Logsheet January 2014 through July 2016, 7/12/2016

Report, CNS ISFSI Neutron to Gamma Ratio Characterization, undated

Report, Determination of Quarterly and Annual Baseline and Investigation Level for Catawba

Nuclear Station Radiological Environmental Monitoring Program TLD Locations, 4/9/15

Report, Top 10 Doses [Highest Dose Individuals] Catawba Nuclear Station 1/1/2015 to

12/31/2015

Report, Top 10 Doses [Highest Dose Individuals] Catawba Nuclear Station 1/1/2016 to

9/13/2016

VSDS Survey # CNS-M-20160127-7, Annual ISFSI Boundary Survey, 1/27/2016

VSDS Survey # CNS-M-20160517-2, Survey for placement of Cask 79 on ISFSI Pad, 5/17/2016

VSDS Survey # CNS-M-20160531-1, Survey for placement of Cask 80 and ISFSI Boundary

Survey, 5/31/2016

TE-RP-ALL-4001, Attachment 1, Pregnancy Exposure Agreement for four workers, various

dates

TE-RP-All-4004, Attachment 2, Multipack Forms: Multipack ID#4135, 4/8/14; Multipack

ID#4136, 4/8/14; and Multipack ID#4166, 11/4/14

Tritium In-Vitro Analysis Results (Urine), RP ID# 703831: Multiple samples 4/2/14 through

4/11/2014; Multiple samples 10/30/14 through 11/7/2014

Tritium In-Vitro Analysis Results (Urine), RP ID# 308115: Multiple samples 10/30/14 through

11/7/2014

Tritium In-Vitro Analysis Results (Urine), RP ID# 211096: Multiple samples 4/2/14 through

4/11/2014

CAP Documents

AD-PI-ALL-0100, Corrective Action Program, Rev.00 6

Self-Assessment G-DOS-SA-14-03, TLD Lab NVLAP Onsite Assessment, 10/23/2014

Self-Assessment G-DOS-SA-15-03, 1st and 2nd Quarter 2015 TLD Data Review, 11/15/2015

Self-Assessment G-FRPS-SA-15-08, Catawba Internal Dosimetry Program Assessment,

1/27/2016

Benchmark Report C-RPS-B-14-03, Effective Dose Equivalent for External Exposures (EDEX)

Improvements, 12/30/2014

ARs: 01538606, 01541479, 01901277, 01901336, 01983630, 01995469, and 02028825

11

Section 2RS5: Radiation Monitoring Instrumentation

Procedures, Guidance Documents, and Manuals

AD-RP-ALL-705, Radiation Protection Portable Instrument Source Check, Rev. 000

ENRAD-PROC-824, Calibration of SAM-19, SAM-11 Small Articles Monitor, Rev. 001

ENRAD-PROC-831, Calibration of AMS-4, Rev. 002

ENRAD-PROC-841, Calibration of Ludlum Model 3 (MR/HR), Rev. 001

ENRAD-PROC-835, Calibration of the MGPI Telepole, Rev. 007

ENRAD-PROC-839, Calibration of Canberra GEM-5 Portal Monitor, Rev. 002

ENRAD-PROC-842, Calibration of Ludlum Model 3 (CPM), Rev. 001

ENRAD-PROC-857, Calibration and Quality Assurance of Canberra Cronos-4 Small Article

Monitor, Rev. 001

HP/0/B/1000/010, Determination of Radiation Monitor Setpoints, Rev. 064

IP/0/A/3314/004, Radiation Monitoring System RP-2C High Range Process Channel

Calibration, Rev. 039 and Rev. 040

Position Paper - Source Response Check Frequencies for Instruments Used for Contamination

Monitoring at Radiologically Control Area and Restricted Area Exit Points, 06/16/2016

RA/0/1300/003, Calibration of Apex Gamma Spectroscopy System, Rev. 000

RA/0/1300/005, Quality Control Check of Count Room Equipment, Rev. 003

RA/0/1400/006, Radiation Protection Fixed Instruments Response Check, Rev. 028

RA/0/1400/014, Radiation Protection Portable Instruments Response Check, Rev. 001

RA/0/1400/013, Operation of Irradiators, Rev. 000

SRPMP 9-2, Interlaboratory Cross Check Program, Rev. 000

Data and Records

Calibration of the J.L. Shepherd Model 89 Shielded Calibration Range Irradiator, EnRad No.

1999, 8/14/14, 8/13/15, and 8/16/16

EnRad Certificate of Calibration, AMS-4, EnRad ID 01704, 08/11/2016

EnRad Certificate of Calibration, AMP-100, EnRad ID 11205, 03/16/2016

EnRad Certificate of Calibration, Cronos-4, EnRad ID 12245, 02/10/2016

EnRad Certificate of Calibration, RO-20, EnRad ID 00391, 03/09/2016

EnRad Certificate of Calibration, Argos-5AB, EnRad ID 12955, 02/22/2016

EnRad Certificate of Calibration, GEM-5, EnRad ID 02800, 01/05/2016

EnRad Certificate of Calibration, Ludlum Model 19, EnRad ID 03613, 06/08/2016

EnRad Certificate of Calibration, Telepole, EnRad ID 02708, 10/22/2015

Quality Control and Calibration of Apex InVivo Whole Body Counting System, 9/21/15, 9/16/14,

and 8/4/2016

Work Order (WO) 01987407-01, 2EMF-53B Containment High Range Monitor Calibration,

03/21/12

WO 02034633-01, 2EMF-13 Area Steamline Monitor Calibration, 09/09/13

WO 02037362-01, 2EMF-2 Reactor Building Refuel Bridge Area Monitor Calibration, 09/12/13

WO 02034544-01, 2EMF-11 Area Steamline Monitor Calibration, 07/16/13

WO 02066403-01, 2EMF-12 Area Steamline Monitor Calibration, 01/17/14

WO 02067315-01, 2EMF-10 Area Steamline Monitor Calibration, 02/17/16

WO 02072509-01, 2EMF-53A Containment High Range Monitor Calibration, 10/08/13

WO 02072510-01, 2EMF-53B Containment High Range Monitor Calibration, 10/08/13

WO 02096388-01, 2EMF-4 Area Fuel Bridge Monitor Calibration, 01/10/14

WO 02133686-01, 2EMF-53A Erratic Readings and Trip 1 Lit, 06/06/14

WO 02155685-01, 2EMF-53A Containment High Range Monitor Calibration, 03/29/15

12

WO 02155686-01, 2EMF-53A Containment High Range Monitor Calibration, 03/28/15

WO 02188711-01, 2EMF-4 Area Fuel Bridge Monitor Calibration, 08/08/15

WO 02189993-01, 1EMF-12 Control Room Monitor Calibration, 03/17/16

WO 02194318-01, 1EMF-53A Containment High Range Monitor Calibration, 11/29/15

WO 02194319-01, 1EMF-53B Containment High Range Monitor Calibration, 11/29/15

1EMF-53A/B Computer Data Point Plots [Background with keep alive source] from 12/1/2015 to

9/23/2016

Corrective Action Program (CAP) Documents

AD-PI-ALL-0100, Corrective Action Program, Rev. 006

G-FRPS-SA-15-22, 2015 Catawba Nuclear Station Radiation Protection Source Term Review

ARs: 01520531, 01521846, 01522067, 01526565, 01531121, 01537239, 01538269, 01540316,

01897249, 01897749, 01932781, 01945732, 01995470, 02013189, 02041936, 02061912, and

02062253

Section 4OA1: Performance Indicator Verification

Procedures and Guidance Documents

AD-PI-ALL-0100, Corrective Action Program, Rev. 006

AD-RP-ALL-1101, Performance Indicators for the Occupational and Public Radiation

Cornerstones, Rev. 000

Records and Data Reviewed

Dose Commitment Data Sheets, Dose Estimates for dates from January 2015 to July 2016

Monthly PI Reports, January 2015 - July 2016

Unexpected Dose Rate Alarms, CNS, (January 2015 - July 2016)

Corrective Action Program (CAP) Documents

ARs: 01945732, 01945823, 01977533, 01977538, 01978081, 02062132

4OA3 - Fire Protection LERs

Calc CNC-1535.00-00-0170, PRA Input to CNS LER 413/2014-002-00, Unanalyzed Condition

Due to Deviations From Fire Protection Current Licensing Basis Identified During NFPA 805

Transition, Rev. 001

Calc CNC-1435.00-00-0067, NFPA 805 Transition - Fire Risk Evaluation (FRE) Rev. 003

Calc CNC-1435.00-00-0044, Fire Protection Nuclear Safety Capability Assessment. Rev. 002

Calc CNC-1535.00-00-0110, CNS Fire PRA (FPRA) Scenario Development Report, Rev. 002

Calc CNC-1205.19-00-0189, Evaluation of MOV Pressure Boundaries and Operator Manual

Actuation Capabilities for IN 92-18 Hot Short Events, Rev. 000

ML16307A004

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