ML12038A072

IR 05000454-11-005, IR 05000455-11-005; 10/01/2011 - 12/31/2011; Byron Station, Units 1 & 2; Operability Evaluations and Functional Assessments; Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportati

ML12038A072
Person / Time
Site:	Byron
Issue date:	02/07/2012
From:	Eric Duncan Region 3 Branch 3
To:	Pacilio M Exelon Generation Co, Exelon Nuclear
References
IR-11-005
Download: ML12038A072 (69)

See also: IR 05000454/2011005

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE ROAD, SUITE 210

LISLE, IL 60532-4352

February 7, 2012

Mr. Michael J. Pacilio

Senior Vice President, Exelon Generation Company, LLC

President and Chief Nuclear Office (CNO), Exelon Nuclear

4300 Warrenville Road

Warrenville, IL 60555

SUBJECT: BYRON STATION, UNITS 1 AND 2, NRC INTEGRATED INSPECTION

REPORT 05000454/2011005; 05000455/2011005

Dear Mr. Pacilio:

On December 31, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an

integrated inspection at your Byron Station, Units 1 and 2. The enclosed inspection report

documents the inspection findings which were discussed on January 12, 2012, with

Mr. B. Youman and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and

compliance with the Commissions rules and regulations and with the conditions of your license.

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

personnel.

Three NRC-identified findings of very low safety significance (Green) were identified during this

inspection.

These findings were determined to involve violations of NRC requirements. Further, a

licensee-identified violation which was determined to be of very low safety significance is

listed in this report. The NRC is treating these violations as non-cited violations (NCVs)

consistent with Section 2.3.2 of the NRC Enforcement Policy.

If you contest these NCVs, you should provide a response within 30 days of the date of this

inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission,

ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional

Administrator, U.S. Nuclear Regulatory Commission - Region III, 2443 Warrenville Road,

Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory

Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Byron

Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a

response within 30 days of the date of this inspection report, with the basis for your

disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at

the Byron Station.

M. Pacilio -2-

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its

enclosure, and your response (if any) will be available electronically for public inspection in the

NRC Public Document Room or from the Publicly Available Records (PARS) component of

NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at

http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Eric R. Duncan, Chief

Branch 3

Division of Reactor Projects

Docket Nos. 50-454; 50-455

License Nos. NPF-37; NPF-66

Enclosure: Inspection Report No. 05000454/2011005 and 05000455/2011005

w/Attachment: Supplemental Information

cc w/encl: Distribution via ListServ

U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket Nos: 50-454; 50-455

License Nos: NPF-37; NPF-66

Report Nos: 05000454/2011005 and 05000455/2011005

Licensee: Exelon Generation Company, LLC

Facility: Byron Station, Units 1 and 2

Location: Byron, IL

Dates: October 1, 2011, through December 31, 2011

Inspectors: B. Bartlett, Senior Resident Inspector

J. Robbins, Resident Inspector

R. Ng, Project Engineer

J. Dalzell-Bishop, DRS Emergency Response Specialist

J. Cassidy, Senior Health Physicist

R. Jickling, Senior Emergency Preparedness Inspector

B. Palagi, Senior Operations Engineer

J. Nance, Reactor Engineer

J. Benjamin, Braidwood Senior Resident Inspector

C. Thompson, Resident Inspector, Illinois Emergency

Management Agency

Approved by: E. Duncan, Chief

Branch 3

Division of Reactor Projects

Enclosure

TABLE OF CONTENTS

REPORT DETAILS .................................................................................................................... 4

Summary of Plant Status ........................................................................................................ 4

1R01 Adverse Weather Protection (71111.01)............................................................ 4

1R04 Equipment Alignment (71111.04) ...................................................................... 5

1R05 Fire Protection (71111.05) ................................................................................. 6

1R11 Licensed Operator Requalification Program (71111.11) .................................... 7

1R12 Maintenance Effectiveness (71111.12).............................................................. 8

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13) ......... 9

1R15 Operability Evaluations (71111.15) ...................................................................10

1R19 Post-Maintenance Testing (71111.19) ..............................................................17

1R20 Outage Activities (71111.20) ............................................................................18

2. REACTOR SAFETY ...................................................................................................20

1EP4 Emergency Action Level and Emergency Plan Changes (71114.04) ................20

1EP6 Drill Evaluation (71114.06) ...............................................................................21

3. RADIATION SAFETY .................................................................................................21

2RS1 Radiological Hazard Assessment and Exposure Controls (71124.01) ..............21

2RS3 In-Plant Airborne Radioactivity Control and Mitigation (71124.03) ....................24

2RS4 Occupational Dose Assessment (71124.04) .....................................................25

2RS5 Radiation Monitoring Instrumentation (71124.05) .............................................26

2RS6 Radioactive Gaseous and Liquid Effluent Treatment (71124.06) ......................26

2RS7 Radiological Environmental Monitoring Program (71124.07) ............................32

2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,

and Transportation (71124.08) ...........................................................................34

4. OTHER ACTIVITIES ...................................................................................................40

4OA1 Performance Indicator Verification (71151).......................................................40

4OA2 Identification and Resolution of Problems (71152)............................................45

4OA3 Follow-Up of Events and Notices of Enforcement Discretion (71153) ...............47

4OA6 Management Meetings .....................................................................................48

4OA7 Licensee-Identified Violations ...........................................................................48

SUPPLEMENTAL INFORMATION............................................................................................. 1

Key Points of Contact ............................................................................................................. 1

List of Items Opened, Closed, and Discussed ........................................................................ 1

List Of Documents Reviewed.................................................................................................. 3

List Of Acronyms Used ..........................................................................................................13

Enclosure

SUMMARY OF FINDINGS

Inspection Report (IR) 05000454/2011005, 05000455/2011005; 10/01/2011 - 12/31/2011; Byron

Station, Units 1 & 2; Operability Evaluations and Functional Assessments; Radioactive Solid

Waste Processing and Radioactive Material Handling, Storage, and Transportation

This report covers a 3-month period of inspection by resident inspectors and announced

baseline inspections by regional inspectors. Three Green findings were identified by the

inspectors. The findings were considered Non-Cited Violations (NCVs) of NRC regulations.

The significance of most findings is indicated by their color (Green, White, Yellow, Red) using

Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Assigned

cross-cutting aspects were determined using IMC 0310, Components Within the Cross-Cutting

Areas. Findings for which the SDP does not apply may be Green or be assigned a severity

level after NRC management review. The NRCs program for overseeing the safe operation of

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

Revision 4, dated December 2006.

A. NRC-Identified and Self-Revealed Findings

Cornerstone: Mitigating Systems

Green. The inspectors identified a finding of very low safety significance and an

associated NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action,

when licensee personnel failed to identify voided piping between Unit 1 valves 1AF006B

and 1AF017B and Unit 2 valves 2AF006B and 2AF017B of the auxiliary feedwater (AF)

system. The piping between these valves had been historically voided until they were

recently re-designed to be filled and maintained filled with water to address an

NRC-identified Green finding and an associated NCV of 10 CFR Part 50, Appendix B,

Criterion III, Design Control. The licensee entered this issue into their Corrective

Action Program (CAP) as IR 1296819, IR 1292337, and IR 1295760. Corrective actions

included instituting an Operations Standing Order, replacing the Unit 1 AF drain valve,

and the isolation of the Unit 2 AF drain valve.

This finding was determined to be more than minor because it was associated with the

Design Control attribute of the Mitigating Systems Cornerstone and adversely affected

the cornerstone objective of ensuring the availability, reliability and capability of systems

that respond to initiating events to prevent undesirable consequences (i.e., core

damage). The inspectors determined that the finding could be evaluated using the

SDP in accordance with IMC 0609, Significance Determination Process,

Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings,

Table 4a for the Mitigating Systems Cornerstone. Specifically, the inspectors answered

Yes to Question 1 - Is the finding a design or qualification deficiency confirmed not to

result in a loss of operability or functionality? Based upon this Phase 1 screening, the

inspectors concluded that the finding was of very low safety significance (Green). This

finding had a cross-cutting aspect in the Resources component of the Human

Performance cross-cutting area H.2(c) because the licensee did not have adequate

procedures to ensure that piping between Unit 1 valves 1AF006B and 1AF017B and

Unit 2 valves 2AF006B and 2AF017B were maintained filled with water. (Section 1R15)

1 Enclosure

Green. The inspectors identified a finding of very low safety significance and an

associated NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures,

and Drawings, when licensee personnel failed to adhere to Operability Determination

Process standards after identifying a non-conservative assumption related to closure

times for hazard barrier dampers separating the Turbine Building from various safety-

related rooms within the Auxiliary Building. In particular, the issues raised by the

inspectors during their review of Operability Evaluation 11-006, Revision 1, resulted in

the station re-evaluating the non-conservative assumptions against aspects of the

current licensing basis (CLB) not previously considered, and substantially revising the

Operability Evaluation. The licensee entered these issues into their CAP as IR 1184258,

IR 1237133, IR 1238611, IR 1240295, IR 1244251, and IR 1276895. In addition to

revising Operability Evaluation 2011-006, corrective actions included an assignment to

reconstitute design basis calculation records and plans to re-design the hazard barrier

dampers.

This finding was determined to be more than minor because it was associated with the

Design Control attribute of the Mitigating Systems cornerstone and adversely affected

the cornerstone objective of ensuring the availability, reliability, and capability of systems

that respond to initiating events to prevent undesirable consequences (i.e., core

damage). The inspectors determined that the finding could be evaluated using the

SDP in accordance with IMC 0609, Significance Determination Process,

Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings,

Table 4a, for the Mitigating Systems cornerstone. Specifically, the inspectors answered

No to all of the Mitigating Systems Cornerstone questions in Table 4a. Based upon

this Phase 1 screening, the inspectors concluded that the finding was of very low safety

significance (Green). This finding had a cross-cutting aspect in the Corrective Action

Program component of the Problem Identification and Resolution cross-cutting area

P.1(c) because the licensee failed to thoroughly evaluate the impact on operability of a

non-conforming condition associated with hazard barrier damper closure times.

(Section 1R15)

Cornerstone: Public Radiation Safety

Green. A self-revealed finding of very low safety significance and an associated NCV of

10 CFR 71.5, Transportation of Licensed Material, was identified when licensee

personnel failed to comply with 49 CFR 172.203(c) and shipped packages of radioactive

material with transport manifests that did not document all applicable hazardous

substances. The issue was entered in the licensees CAP as IR 1285148. Immediate

corrective actions included providing a corrected copy of the transport manifest to the

waste processor. Further, the licensee placed locks on the shipping containers to

control items placed in the packages and to ensure that the manifest accurately

represented the hazards contained in the shipping packages.

This finding was determined to be more than minor because it was associated with the

Program and Process attribute of the Public Radiation Safety Cornerstone and adversely

affected the cornerstone objective of ensuring adequate protection of public health and

safety from exposure to radioactive materials released into the public domain as a result

of routine civilian nuclear reactor operation, in that, providing incorrect information, as

part of hazards communications, could impact the actions of response personnel. The

inspectors determined that the finding could be evaluated using the SDP in accordance

with IMC 0609, Significance Determination Process, Appendix D, Public Radiation

2 Enclosure

Safety Significance Determination Process. Using the Public Radiation Safety SDP, the

inspectors determined: (1) radiation limits were not exceeded; (2) there was no breach

of a package during transit; (3) this issue did not involve a certificate of compliance;

(4) this issue was not a low level burial ground nonconformance; and (5) this issue did

not involve a failure to make notifications or provide emergency information. As a result,

the finding screened as having very low safety significance (Green). This finding had a

cross-cutting aspect in the Work Control component of the Human Performance

cross-cutting area H.3(b) since the licensee failed to coordinate work activities by

incorporating actions to address the impact of the work on different job activities, and the

need for work groups to maintain interfaces with offsite organizations, and communicate,

coordinate, and cooperate with each other during activities in which interdepartmental

coordination was necessary to assure adequate human performance. Specifically, these

events occurred because the licensee did not control the items placed in the waste

packages and was not present when the boxes were loaded. (Section 2RS8)

B. Licensee-Identified Violations

One violation of very low safety significance that was identified by the licensee has been

reviewed by the inspectors. Corrective actions planned or taken by the licensee have

been entered into the licensees CAP. This violation and the associated corrective

action tracking number are listed in Section 4OA7 of this report.

3 Enclosure

REPORT DETAILS

Summary of Plant Status

Unit 1 operated at or near full power from the beginning of the inspection period until

November 11, 2011, when power was reduced to 89 percent to perform scheduled turbine

throttle and governor valve testing. The unit was returned to full power the following day and

operated at full power for the remainder of the assessment period.

Unit 2 began the inspection period shut down and in a planned refueling outage. The unit was

restarted and returned to service on October 10, 2011. On November 5, 2011, reactor power

was reduced to 96 percent to perform feedwater heater maintenance. The unit was returned to

full power on November 14, 2011, and operated at full power for the remainder of the inspection

period.

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity and

Emergency Preparedness

1R01 Adverse Weather Protection (71111.01)

.1 Winter Seasonal Readiness Preparations

a. Inspection Scope

The inspectors conducted a review of the licensees preparations for winter conditions to

verify that the plants design features and implementation of procedures were sufficient

to protect mitigating systems from the effects of adverse weather. Documentation for

selected risk-significant systems was reviewed to ensure that these systems would

remain functional when challenged by inclement weather. During the inspection, the

inspectors focused on plant specific design features and the licensees procedures used

to mitigate or respond to adverse weather conditions. Additionally, the inspectors

reviewed the Updated Final Safety Analysis Report (UFSAR) and performance

requirements for systems selected for inspection, and verified that operator actions were

appropriate as specified by plant specific procedures. Cold weather protection, such as

heat tracing and area heaters, was verified to be in operation where applicable. The

inspectors also reviewed Corrective Action Program (CAP) items to verify that the

licensee was identifying adverse weather issues at an appropriate threshold and

entering them into their CAP in accordance with station corrective action procedures.

Specific documents reviewed during this inspection are listed in the Attachment. The

inspectors reviews focused specifically on the following plant systems due to their risk

significance or susceptibility to cold weather issues:

• Station Heating System (SH);

• Auxiliary Building Heating, Ventilation, and Air-Conditioning (HVAC) [VA]; and

• Refueling Water Storage Tanks (RWSTs).

This inspection constituted one winter seasonal readiness preparation sample as

defined in Inspection Procedure (IP) 71111.01-05.

4 Enclosure

b. Findings

No findings were identified.

1R04 Equipment Alignment (71111.04)

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

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

systems:

• Unit 2 Train A Residual Heat Removal System Following Restoration to its

Standby Line-Up;

• Unit 2 Train B Essential Service Water (SX) with the Unit 2 Train A SX

Out-of-Service (OOS);

• Unit 2 Train B Auxiliary Feedwater (AF) with the Unit 2 Train A AF OOS; and

• Unit 1 Train A AF with the Unit 1 Train B AF OOS.

The inspectors selected these systems based on their risk significance relative to the

Reactor Safety Cornerstones at the time they were inspected. The inspectors attempted

to identify any discrepancies that could impact the function of the system, and, therefore,

potentially increase risk. The inspectors reviewed applicable operating procedures,

system diagrams, UFSAR, Technical Specification (TS) requirements, outstanding work

orders (WOs), condition reports, and the impact of ongoing work activities on redundant

trains of equipment in order to identify conditions that could have rendered the systems

incapable of performing their intended functions. The inspectors also walked down

accessible portions of the systems to verify system components and support equipment

were aligned correctly and operable. The inspectors examined the material condition of

the components and observed operating parameters of equipment to verify that there

were no obvious deficiencies. The inspectors also verified that the licensee had properly

identified and resolved equipment alignment problems that could cause initiating events

or impact the capability of mitigating systems or barriers and entered them into the CAP

with the appropriate significance characterization. Documents reviewed are listed in the

Attachment.

These activities constituted four partial system walkdown samples as defined in

IP 71111.04-05.

b. Findings

No findings were identified.

5 Enclosure

1R05 Fire Protection (71111.05)

.1 Routine Resident Inspector Tours (71111.05Q)

a. Inspection Scope

The inspectors conducted fire protection walkdowns which were focused on availability,

accessibility, and the condition of firefighting equipment in the following risk-significant

plant areas:

• Unit 1 426 Turbine Building (Fire Zone 8.5-1);

• Unit 1 426 Turbine Building (Fire Zone 8.5-1);

• Unit 1 Train B Auxiliary Feedwater Pump Room (Fire Zone 11.4A-1); and

• Unit 2 Train B Auxiliary Feedwater Pump Room (Fire Zone 11.4A-2 ).

The inspectors reviewed areas to assess if the licensee had implemented a fire

protection program that adequately controlled combustibles and ignition sources within

the plant, effectively maintained fire detection and suppression capability, maintained

passive fire protection features in good material condition, and implemented adequate

compensatory measures for out-of-service, degraded or inoperable fire protection

equipment, systems, or features in accordance with the licensees fire plan. The

inspectors selected fire areas based on their overall contribution to internal fire risk as

documented in the plants Individual Plant Examination of External Events with later

additional insights, their potential to impact equipment which could initiate or mitigate a

plant transient, or their impact on the plants ability to respond to a security event. Using

the documents listed in the Attachment, the inspectors verified that fire hoses and

extinguishers were in their designated locations and available for immediate use; that

fire detectors and sprinklers were unobstructed; that transient material loading was

within the analyzed limits; and fire doors, dampers, and penetration seals appeared to

be in satisfactory condition. The inspectors also verified that minor issues identified

during the inspection were entered into the licensees CAP. Documents reviewed are

listed in the Attachment.

These activities constituted four quarterly fire protection inspection samples as defined in

IP 71111.05-05.

b. Findings

No findings were identified.

.2 Annual Fire Protection Drill Observation (71111.05A)

a. Inspection Scope

On November 11, 2011, and December 17, 2011, the inspectors observed a fire brigade

activation Fire Drill in the Unit 1 Auxiliary Boiler Room, 401' Elevation (Fire Zone 8.3-1

SE). Based on this observation, the inspectors evaluated the readiness of the plant fire

brigade to fight fires. The inspectors verified that the licensee staff identified

deficiencies; openly discussed them in a self-critical manner at the drill debrief, and took

appropriate corrective actions. Specific attributes evaluated were:

6 Enclosure

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

• proper use and layout of fire hoses;

• employment of appropriate fire fighting techniques;

• sufficient firefighting equipment brought to the scene;

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

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

• smoke removal operations;

• utilization of pre-planned strategies;

• adherence to the pre-planned drill scenario; and

• drill objectives.

Documents reviewed are listed in the Attachment to this report.

These activities constituted one annual fire protection inspection sample as defined in

IP 71111.05-05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program (71111.11)

.1 Annual Operating Test Results (71111.11B)

a. Inspection Scope

The inspectors reviewed the overall pass/fail results of the Annual Operating Test,

administered by the licensee from October 18, 2011 through December 8, 2011,

required by 10 CFR 55.59(a). The results were compared to the thresholds established

in IMC 0609, Appendix I, Licensed Operator Requalification Significance Determination

Process (SDP)," to assess the overall adequacy of the licensees Licensed Operator

Requalification Program (LORT) to meet the requirements of 10 CFR 55.59.

This inspection constitutes one biennial and one annual licensed operator requalification

inspection sample as defined in IP 71111.11B and IP71111.11A.

b. Findings

No findings were identified.

.2 Resident Inspector Quarterly Review (71111.11Q)

a. Inspection Scope

On November 16, 2011, the inspectors observed a crew of licensed operators in the

plants simulator during licensed operator requalification examinations to verify that

operator performance was adequate, evaluators were identifying and documenting crew

performance problems and training was being conducted in accordance with licensee

procedures. The inspectors evaluated the following areas:

7 Enclosure

• licensed operator performance;

• crews clarity and formality of communications;

• ability to take timely actions in the conservative direction;

• prioritization, interpretation, and verification of annunciator alarms;

• correct use and implementation of abnormal and emergency procedures;

• control board manipulations;

• oversight and direction from supervisors; and

• ability to identify and implement appropriate TS actions and emergency plan

actions and notifications.

The crews performance in these areas was compared to pre-established operator action

expectations and successful critical task completion requirements. Documents reviewed

are listed in the Attachment.

In addition, the inspectors observed licensed operator performance in the actual plant

and the main control room during this calendar quarter.

This inspection constituted one quarterly licensed operator requalification program

sample as defined in IP 71111.11.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness (71111.12)

.1 Routine Quarterly Evaluations (71111.12Q)

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following

risk-significant systems:

• Unit 1 Rod Drive Motor Generator (MG) Set High Vibrations; and

• High Energy Line Break (HELB) Dampers.

The inspectors reviewed events including those in which ineffective equipment

maintenance had resulted in valid or invalid automatic actuations of engineered

safeguards systems and independently verified the licensee's actions to address

system performance or condition problems in terms of the following:

• implementing appropriate work practices;

• identifying and addressing common cause failures;

• scoping of systems in accordance with 10 CFR 50.65(b) of the Maintenance Rule;

• characterizing system reliability issues for performance;

• charging unavailability for performance;

• trending key parameters for condition monitoring;

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

• verifying appropriate performance criteria for structures, systems, and

components (SSCs)/functions classified as (a)(2) or appropriate and adequate

goals and corrective actions for systems classified as (a)(1).

8 Enclosure

The inspectors assessed performance issues with respect to the reliability, availability,

and condition monitoring of the system. In addition, the inspectors verified maintenance

effectiveness issues were entered into the CAP with the appropriate significance

characterization. Documents reviewed are listed in the Attachment.

This inspection constituted two quarterly maintenance effectiveness sample as defined

in IP 71111.12-05.

b. Findings

No findings were identified.

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

.1 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the licensee's evaluation and management of plant risk for the

maintenance and emergent work activities affecting risk-significant and safety-related

equipment listed below to verify that the appropriate risk assessments were performed

prior to removing equipment for work:

• Shutdown Safety Associated with Cavity Drain;

• Unit Common B Fire Pump OOS With SX as its Backup While One Train of SX

was OOS;

• Review of Planned Risk Significant Activities During Elevated Winds and Low

River Level; and

• Unit 2 Train B Auxiliary Feedwater Pump OOS.

These activities were selected based on their potential risk significance relative to the

Reactor Safety Cornerstones. As applicable for each activity, the inspectors verified that

risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate

and complete. When emergent work was performed, the inspectors verified that the

plant risk was promptly reassessed and managed. The inspectors reviewed the scope

of maintenance work, discussed the results of the assessment with the licensee's

probabilistic risk analyst or shift technical advisor, and verified plant conditions were

consistent with the risk assessment. The inspectors also reviewed TS requirements and

walked down portions of redundant safety systems, when applicable, to verify risk

analysis assumptions were valid and applicable requirements were met.

These maintenance risk assessments and emergent work control activities constituted

four samples as defined in IP 71111.13-05.

b. Findings

No findings were identified.

9 Enclosure

1R15 Operability Evaluations (71111.15)

.1 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following issues:

• Unit 1 Embedment Plate 1SI06025V Due to Questions Regarding Supporting

Analysis/Calculations;

• Unit 1 Seismic Support 1FW01147X Due to Questions Regarding Impact to HELB

Analysis;

• Unit 1 and Unit 2 Train B AF Pumps Due to Questions Regarding Multiple Starts;

• Unit 1 Leading Edge Flow Monitor Due to Identified Anomaly in Trended Data;

• Unit 1 and Unit 2 Train B AF Pumps Due to Potential Pipe Voids in Cross-Tie

Piping; and

• Unit 1 Engineered Safety Features Switchgear Rooms Division 11 and 12 Due to

Questions Regarding 1VX20Y and 1VX17Y Fire Damper S Hooks Preventing

Closure of Dampers

The inspectors selected these potential operability issues based on the risk significance

of the associated components and systems. The inspectors evaluated the technical

adequacy of the evaluations to ensure that TS operability was properly justified and the

subject component or system remained available such that no unrecognized increase in

risk occurred. The inspectors compared the operability and design criteria in the

appropriate sections of the TS and UFSAR to the licensees evaluations to determine

whether the components or systems were operable. Where compensatory measures

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

in place would function as intended and were properly controlled. The inspectors

determined, where appropriate, compliance with bounding limitations associated with the

evaluations. Additionally, the inspectors reviewed a sample of corrective action

documents to verify that the licensee was identifying and correcting any deficiencies

associated with operability evaluations. Documents reviewed are listed in the

Attachment.

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

b. Findings

.1) Failure to Identify Auxiliary Feedwater Pump Suction Voids

Introduction: The inspectors identified a finding of very low safety significance (Green)

and an associated NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective

Action, when licensee personnel failed to identify voided piping between Unit 1 valves

1AF006B and 1AF017B and Unit 2 valves 2AF006B and 2AF017B of the auxiliary

feedwater system. The piping between these valves had been historically voided until

they were recently re-designed to be filled and maintained filled with water to address an

NRC-identified Green finding and an associated NCV of 10 CFR Part 50, Appendix B,

Criterion III, Design Control (NCV 05000454/2011004-04; 05000455/-2011004-04,

Design of Auxiliary Feedwater System Included Voids in Safety-Related Alternate

Suction Flow Paths).

10 Enclosure

Description: On November 16, 2011, the inspectors notified licensee staff that there

appeared to be no visible water in tygon tubing attached to vent valves between Unit 1

valves 1AF006B and 1AF017B and Unit 2 valves 2AF006B and 2AF017B. Visible water

in tygon tubing attached to these vent valves was being used as an indication that the

piping between these valves was filled with water. The inspectors could not determine

whether there was water within the tygon tubing because the inside of the tubing was

coated with a brown and black substance suspected to be mold. The inspectors

concluded that without visible water in the tygon tubing, the space between these valves

could be voided, contrary to plant design requirements. The piping between Unit 1

valves 1AF006B and 1AF017B and Unit 2 valves 2AF006B and 2AF017B had been

historically voided, but were recently re-designed and filled with water to address an

NRC-identified Green finding and associated NCV of 10 CFR Part 50, Appendix B,

Criterion III, Design Control (NCV 05000454/2011004-04; 05000455/-2011004-04,

Design of Auxiliary Feedwater System Included Voids in Safety-Related Alternate

Suction Flow Paths). The basis for this Green finding and associated NCV was that the

licensee had not performed design reviews, calculations, or suitable tests that

demonstrated the voided piping between Unit 1 valves 1AF006B and 1AF017B and

Unit 2 valves 2AF006B and 2AF017B would not adversely impact the ability of the AF

system to perform its design function. This piping was downstream of the safety-related

essential service water (SX) supply for the diesel-driven AF pumps. The inspectors did

observe standing water in the tygon tubing between Unit 1 valves 1AF006A and

1AF017A and Unit 2 valves 2AF006A and 2AF017A associated with the Unit 1 and

Unit 2 motor-driven AF pumps.

On November 17, 2011, the inspectors reviewed the Inspection Reports (IRs) generated

the previous day and did not identify any that documented the issue discussed above.

The inspectors re-inspected the tygon tubing between Unit 1 valves 1AF006B and

1AF017B and Unit 2 valves 2AF006B and 2AF017B and could not determine whether

there was water in the tygon tubing. Licensee management was subsequently notified of

the inspectors observations. The licensee performed a system walkdown and

confirmed that there was no visible water level in the tygon tubing between Unit 1 valves

1AF006B and 1AF017B. The section of piping between the valves was subsequently

filled with water and verified full through ultrasonic testing.

On November 18, 2011, the inspectors re-inspected the tygon tubing between Unit 1

valves 1AF006B and 1AF017B and Unit 2 valves 2AF006B and 2AF017B and could not

determine whether there was water in the tygon tubing. The inspectors notified licensee

management and questioned the licensees actions to address the inspectors previous

questions and concerns. The licensee performed a walkdown of the system and

confirmed the inspectors concern that the tygon tube was again empty, which indicated

that the section of piping between Unit 1 valves AF006B and AF017B was likely voided.

The licensee entered this issue into their CAP. The section of piping between the valves

was again re-filled and verified full.

On November 29, 2011, the inspectors performed field walkdowns and identified, again,

that the tygon tubing attached to the vent line between Unit 2 valves 2AF006B and

2AF017B did not have a visible water level. The inspectors notified licensee

management and concluded that the licensee did not have adequate measures in place

to monitor or ensure the sections of piping between Unit 1 valves 1AF006B and

1AF017B and Unit 2 valves 2AF006B and 2AF017B were maintained full of water. The

licensee performed a walkdown of the system, confirmed the inspectors concerns, and

11 Enclosure

filled the voided sections of piping as before. In addition, the Operations department

instituted an Operations Standing Order that required a verification that the tygon tubing

was filled with water multiple times a shift. The licensee entered this issue into their

CAP as IR 1296819, IR 1292337, and IR 1295760. Corrective actions included

instituting the Operations Standing Order, replacing the Unit 1 AF drain valve, and

isolating the Unit 2 AF drain valve.

Analysis: The inspectors determined that the failure to identify voided sections of AF

piping prior to and following the inspectors observations and interactions with licensee

management was a performance deficiency.

This finding was determined to be more than minor because it was associated with the

Design Control attribute of the Mitigating Systems Cornerstone and adversely affected

the cornerstone objective of ensuring the availability, reliability and capability of systems

that respond to initiating events to prevent undesirable consequences (i.e., core

damage). Specifically, the unverified configuration might have rendered the Unit 1 and

Unit 2 diesel-driven AF pumps inoperable.

The inspectors determined that the finding could be evaluated using the SDP in

accordance with IMC 0609, Significance Determination Process, Attachment 0609.04,

Phase 1 - Initial Screening and Characterization of Findings, Table 4a for the Mitigating

Systems Cornerstone. Specifically, the inspectors answered Yes to Question 1 - Is

the finding a design or qualification deficiency confirmed not to result in a loss of

operability or functionality? This conclusion was reached after conservatively assuming

that both sections of piping for Unit 1 and Unit 2 were completely voided and after

reviewing tests performed by the licensee in response to the previously documented

design control Green finding and associated NCV. These tests demonstrated that under

the existing plant conditions, and even if the piping between Unit 1 valves 1AF006B and

1AF017B and Unit 2 valves 2AF006B and 2AF017B was completely voided, that the

diesel-driven AF pumps were not inoperable. However, these tests were not of sufficient

scope to demonstrate that under all possible plant conditions that the diesel-driven AF

pumps would have remained operable. Therefore, although the existing void did not

render the diesel-driven AF pumps inoperable, there remained the possibility that under

some conditions the unverified configuration discussed above could have rendered the

diesel-driven AF pumps inoperable. Based upon this Phase 1 screening, the inspectors

concluded that the finding was of very low safety significance (Green).

This finding had a cross-cutting aspect in the Resources component of the Human

Performance cross-cutting area H.2(c) because the licensee did not ensure that

procedures were adequate to ensure nuclear safety. In particular, licensee procedures

did not ensure that the sections of piping between Unit 1 valves 1AF006B and 1AF017B

and Unit 2 valves 2AF006B and 2AF017B were maintained filled with water as required

to support nuclear safety.

Enforcement: 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires,

in part, that measures shall be established to assure that conditions adverse to quality,

such as failures, malfunctions, deficiencies, deviations, defective material and

equipment, and non-conformances are promptly identified and corrected.

Contrary to the above, licensee personnel failed to identify non-conforming conditions

associated with the stations safety-related diesel-driven AF systems. Specifically, the

12 Enclosure

space between Unit 1 valves 1AF006B and 1AF017B and Unit 2 valves 2AF006B and

2AF017B had been re-designed to be full of water and was identified by the inspectors

prior to November 16, 2011; November 17, 2011; November 18, 2011; and

November 29, 2011 to be voided.

Corrective actions included filling the voided piping sections, replacing the Unit 1 drain

valve, isolating the Unit 2 drain valve, and monitoring tygon tubing water level on a more

frequent basis. Because this violation was of very low safety significance and was

entered into the licensees CAP as IR 1296819, IR 1292337, and IR 1295760, this

violation is being treated as a NCV consistent with Section 2.3.2 of the NRC

Enforcement Policy. (NCV 05000454/2011005-01; 05000455/2011005-01, Failure to

Identify Voided Sections of AF Piping)

.2) Operability Evaluation Not Performed in Accordance with Station Standards

Introduction: The inspectors identified a finding of very low safety significance (Green)

and an associated NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions,

Procedures, and Drawings, when licensee personnel failed to adhere to numerous

Operability Determination Process standards after identifying a non-conservative

assumption related to closure times for hazard barrier dampers separating the Turbine

Building from various safety-related rooms within the Auxiliary Building.

Description: On July 6, 2011, the licensee identified non-conservative assumptions in

the actuation time for fusible links used in hazard barrier dampers for the Engineered

Safety Feature (ESF) Rooms, Non-ESF Switchgear Rooms, Miscellaneous Electrical

Equipment Rooms (MEERs) and Emergency Diesel Generator (DG) Rooms. These

dampers protected these rooms from the effects of a Turbine Building fire or HELB

event. The applicable calculations of record assumed that these dampers shut within

about 5 seconds of reaching a temperature of 165 degrees fahrenheit (°F). These

dampers utilized a fusible link which was required to meet Underwriters Laboratories

(UL) specifications (Heat Responsive Links for Fire Protection Service: UL 33). This

specification provided a formula for calculating an acceptable fusible link response time

as a function of temperature. Using the UL formula, licensee personnel calculated that

the expected thermal link response times were up to 100 seconds for the ESF

Switchgear Room dampers and 200 seconds for the MEER and Non-ESF Switchgear

dampers based on projected HELB temperatures outside of these rooms. Therefore, the

station calculations of record assumed that these dampers would isolate the affected

rooms from a Turbine Building HELB much sooner than UL specifications. The licensee

evaluated this non-conservative condition in Operability Evaluation 11-006, Revision 1,

concluded that there was reasonable assurance that the equipment affected in the

identified rooms would remain operable during a licensing basis HELB event. This

conclusion was reached after the licensee had completed and approved Operability

Evaluation 11-006 in accordance with OP-AA-108-115, Operability Evaluation

Standard, Revision 9.

The inspectors reviewed Operability Evaluation 11-006, Revision 1, and identified a

number of examples in which the evaluation did not meet the standards in OP-AA-108-

115. Specifically, OP-AA-108-115, Operability Evaluation Standard, Revision 9

included the following requirements:

13 Enclosure

OP-AA-108-115, Operability Evaluation Standard, Revision 9

Section 4.4.2

The OpEval [Operability Evaluation] should contain sufficient detail for a knowledgeable

individual to independently reach the same conclusions as the Preparer (i.e., the OpEval

must be able to stand alone).

1. The Preparer should examine the CLB [Current Licensing Basis] requirements or

commitments, including the TSs and UFSAR, to establish the conditions and

performance requirements to be met for determining operability, as necessary.

The scope of an OpEval needs to be sufficient to address the capability of the

SSC to perform its specified safety functions.

The OpEval should address the following, as applicable . . . Determine the extent

of condition for all similarly affected SSCs.

The inspectors identified the following examples that did not meet this standard:

• Operability Evaluation 11-006, Revision 1, did not evaluate the non-conforming

condition against the CLB single failure criterion. This single failure criterion was

discussed in NRC Standard Review Plan (SRP) Section 3.6.1, Branch Technical

Position (BTP) ASB 3-1, Section B.3.b(2). Branch Technical Position ASB 3-1,

Section B.3.b(2) discussed how a single active component failure should be

assumed in systems used to mitigate the consequences of a postulated piping

failure to shut down the reactor. After the inspectors discussed this requirement

with the licensee, licensee personnel determined that the dampers needed to be

considered for single failure during a HELB event. This CLB single failure

criterion was readily available when the licensee examined the CLB requirements

for this issue during the development of Operability Evaluation 11-006. The

licensee entered this issue into their CAP as IR 1244251.

• Operability Evaluation 11-006, Revision 1, did not adequately consider a pipe

crack in accordance with the CLB. The CLB requirements for a pipe crack

included an assumed lower allowable stress threshold than for a broken or

severed pipe. Specifically, Operability Evaluation 11-006, Revision 1, did not

address leakage cracks in accordance with Section III of the American Society of

Mechanical Engineers (ASME) Code for Class 2 and Class 3 piping as

referenced in Section 3.6.2.1.2.1.1, "Fluid System Piping Not in the Containment

Penetration Area," of the UFSAR. In particular, Section d of Section 3.6.2.1.2.1.1

stated, in part, "[L]eakage cracks in high energy ASME Section III Class 2 and 3

piping and seismically analyzed and supported ANSI [American Nuclear

Standards Institute] B31.1 piping are postulated at locations where the stresses

under the loadings resulting from normal and upset plant conditions and an OBE

[Operating Basis Earthquake] event as calculated by equations (9) and (10) in

Paragraph NC-3652 of ASME Section III exceed 0.4 (1.2 multiplied times Sh +

Sa). The licensee entered this issue into their CAP as IR 1240295.

• Operability Evaluation 11-006, Revision 1, did not address the extent of condition

review for all similarly affected SSCs. The inspectors identified a number of

safety-related rooms that utilized the same (or similar) style dampers in which the

14 Enclosure

non-conforming condition applied that were not evaluated. Those rooms

included the Unit 1 and Unit 2 Lower Cable Spreading Room Non-Segregated

Bus Duct areas; an electrical cable chase located above the B Emergency

Diesel Generator; the station Emergency Diesel Generator Diesel Oil Storage

Tank Rooms; and the Control Room Ventilation Makeup System, which could be

aligned to take makeup air from the Turbine Building. The licensee entered this

issue into their CAP as IR 1279759 and IR 12776277.

• Operability Evaluation 11-006, Revision 1, as associated with MEER 12 and

MEER 22, did not identify a potential common mode failure after the inspectors

determined that the licensee had not adequately considered single failure.

These rooms contained both trains of Unit 1 and Unit 2 reactor trip and reactor

trip bypass breakers, respectively. The event of concern was a Turbine Building

HELB combined with the failure of either the MEER 12 or MEER 22 hazard

barrier dampers to shut, which would expose both trains of reactor trip breakers

to a harsh steam environment. This equipment was not environmentally qualified

in accordance with 10 CFR 50.49. The licensee entered this issue into their CAP

as IR 1276895.

• The inspectors were not able to reach the same conclusions as the

Preparer when reviewing Operability Evaluation 11-006, Revision 1, since

Operability Evaluation 11-006, Revision 1, lacked the necessary detail regarding

assumptions and limitations for the inspectors to determine if the evaluation was

consistent with station design. The inspectors concluded that Operability

Evaluation 11-006, Revision 1, did not meet the licensees stand alone

requirement in OP-AA-108-115.

On November 17, 2011, the licensee completed a substantial revision to Operability

Evaluation 11-006, Revision 1, that addressed the issues previously identified by the

inspectors.

In addition to the issues described above, the inspectors identified that the stations

applicable HELB calculations of records had not considered the licensing basis single

failure. The inspectors determined that this historic issue contributed to the licensees

misunderstanding of their CLB.

The licensee entered these issues into the their CAP as IR 1184258, IR 1237133,

IR 1238611, IR 1240295, IR 1244251, and IR 1276895. Corrective actions include two

revisions of Operability Evaluation 11-006, an assignment to reconstitute the applicable

design basis calculation records, and plans to re-design the hazard barrier dampers to

provide additional margin.

Analysis: The inspectors determined that the failure to meet the station Operability

Determination process standards outlined in OP-AA-108-115, Operability Evaluation

Standard, Revision 9, during the evaluation of a non-conforming condition was a

performance deficiency.

This performance deficiency was determined to be more than minor because it was

similar to the not minor if aspect of Example 3j in IMC 0612, Appendix E, Example of

Minor Issues, since the errors in Operability Evaluation 11-006, Revision 1, resulted in a

condition in which there was a reasonable doubt on the operability of the systems and

15 Enclosure

components that were the subject of the evaluation and dissimilar from the minor

because aspect of this example since the impact of the errors on Operability

Determination 11-006, Revision 1, was not minimal. In addition, the performance

deficiency was determined to be more than minor because it was associated with the

Design Control attribute of the Mitigating Systems Cornerstone and adversely affected

the cornerstone objective of ensuring the availability, reliability, and capability of systems

that respond to initiating events to prevent undesirable consequences (i.e., core

damage).

The inspectors determined that the finding could be evaluated using the SDP in

accordance with IMC 0609, Significance Determination Process, Attachment 0609.04,

Phase 1 - Initial Screening and Characterization of Findings, Table 4a, for the

Mitigating Systems Cornerstone. Specifically, the inspectors answered No to all of the

Mitigating Systems Cornerstone questions in Table 4a. As a result, the finding screened

as having very low safety significance (Green).

This finding has a cross-cutting aspect in the CAP component of the Problem

Identification and Resolution cross-cutting area P.1(c) since the licensee failed to

thoroughly evaluate the impact on operability of a non-conforming condition associated

with hazard barrier closure times.

Enforcement: 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures,

and Drawings, requires, in part, that activities affecting quality shall be prescribed

by documented instructions, procedures, or drawings, of a type appropriate to the

circumstance and shall be accomplished in accordance with these instructions,

procedures of drawings.

Contrary to the above, the inspectors identified examples during the development of

Operability Evaluation 11-006, Revision 1, in which licensee personnel failed to adhere

to quality procedure OP-AA-108-115, Operability Determinations (CM-1), Revision 9.

In particular, OP-AA-108-115, Revision 9, stated in part:

The OpEval should contain sufficient detail for a knowledgeable individual to

independently reach the same conclusions as the Preparer (i.e., the OpEval must

be able to stand alone).

The Preparer should examine the CLB [Current Licensing Basis] requirements or

commitments, including the TSs and UFSAR, to establish the conditions and

performance requirements to be met for determining operability, as necessary.

The scope of an OpEval needs to be sufficient to address the capability of the SSC

to perform its specified safety functions.

The OpEval should address the following, as applicable . . . Determine the extent of

condition for all similarly affected SSCs.

Contrary to this requirement:

• On July 15, 2011, the licensee did not adequately examine the applicable CLB

requirements or commitments to establish the performance requirements to be met

16 Enclosure

for determining operability in the case of single failure, common mode, and leakage

crack assumptions.

• On July 15, 2011, the licensees OpEval did not adequately address the extent of

condition for all similarly affected SSCs.

• On July 15, 2011, the OpEval did not contain sufficient detail for a knowledgeable

individual to independently reach the same conclusions as the Preparer.

Because this violation was of very low safety significance and it was entered into the

licensees corrective actions program, this violation is being treated as a NCV, consistent

with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000454/2011005-02;

05000455/2011005-02, Operability Evaluation Not Performed in Accordance with

Station Standards)

1R19 Post-Maintenance Testing (71111.19)

.1 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the following post maintenance testing activities to verify that

procedures and test activities were adequate to ensure system operability and functional

capability:

• Unit 2 AF Check Valves 2AF014E, 2AF014G, and 2AF014H Following

Disassembly and Inspection;

• Unit 2 Reactor Coolant Pump Motor - 2D Following Refuel Maintenance and

Inspection;

• Unit 2 Charging Valve Stroke Time and Position Indication Test 2CV8804A

Following Circuit Modification;

• Unit 2 Solid State Protection System Following Unit 2 Refueling Outage

Preventive Maintenance;

• Unit 2 Train B Containment Spray Following Replacement of Timer Relay;

• Unit 1 Train A Rod Drive Motor-Generator Following Bearing Replacement; and

• Surveillance 2BOSR 0.5-2.RH.4-1 Following Maintenance on Valve 2RH610

These activities were selected based upon the structure, system, or component's ability

to impact risk. The inspectors evaluated these activities for the following (as applicable):

the effect of testing on the plant had been adequately addressed; testing was adequate

for the maintenance performed; acceptance criteria were clear and demonstrated

operational readiness; test instrumentation was appropriate; tests were performed as

written in accordance with properly reviewed and approved procedures; equipment was

returned to its operational status following testing (temporary modifications or jumpers

required for test performance were properly removed after test completion); and test

documentation was properly evaluated. The inspectors evaluated the activities against

TSs, the UFSAR, 10 CFR Part 50 requirements, licensee procedures, and various

NRC generic communications to ensure that the test results adequately ensured that the

equipment met the licensing basis and design requirements. In addition, the inspectors

reviewed corrective action documents associated with post maintenance tests to

determine whether the licensee was identifying problems and entering them in the CAP

17 Enclosure

and that the problems were being corrected commensurate with their importance to

safety. Documents reviewed are listed in the Attachment.

This inspection constituted seven post maintenance testing samples as defined in

IP 71111.19-05.

a. Findings

No findings were identified.

1R20 Outage Activities (71111.20)

.1 Refueling Outage Activities

a. Inspection Scope

The inspectors reviewed the Outage Safety Plan (OSP) and contingency plans for the

Unit 2 refueling outage (RFO) B2R16, conducted September 18 through October 10,

2011, to confirm that the licensee had appropriately considered risk, industry experience,

and previous site-specific problems in developing and implementing a plan that assured

maintenance of defense-in-depth. During the RFO, the inspectors observed portions of

the shutdown and cooldown processes and monitored licensee controls over the outage

activities listed below. Documents reviewed during the inspection are listed in the

Attachment to this report.

• Licensee configuration management, including maintenance of defense-in-depth

commensurate with the OSP for key safety functions and compliance with the

applicable TS when taking equipment out of service.

• Implementation of clearance activities and confirmation that tags were properly

hung and equipment appropriately configured to safely support the work or

testing.

• Installation and configuration of reactor coolant pressure, level, and temperature

instruments to provide accurate indication, accounting for instrument error.

• Controls over the status and configuration of electrical systems to ensure that

TS and OSP requirements were met, and controls over switchyard activities.

• Monitoring of decay heat removal processes, systems, and components.

• Controls to ensure that outage work was not impacting the ability of the operators

to operate the spent fuel pool cooling system.

• Reactor water inventory controls including flow paths, configurations, and

alternative means for inventory addition, and controls to prevent inventory loss.

• Controls over activities that could affect reactivity.

• Maintenance of secondary containment as required by TS.

• Licensee fatigue management, as required by 10 CFR 26, Subpart I.

• Refueling activities, including fuel handling and sipping to detect fuel assembly

leakage.

• Startup and ascension to full power operation, tracking of startup prerequisites,

walkdown of the drywell (primary containment) to verify that debris had not been

left which could block emergency core cooling system suction strainers, and

reactor physics testing.

• Licensee identification and resolution of problems related to RFO activities.

18 Enclosure

This inspection constituted one RFO sample as defined in IP 71111.20-05.

b. Findings

No findings were identified.

1R22 Surveillance Testing (71111.22)

.1 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the test results for the following activities to determine whether

risk significant systems and equipment were capable of performing their intended safety

function and to verify testing was conducted in accordance with applicable procedural

and TS requirements:

• Unit 2 Train B Diesel Generator Sequence Test;

• Unit 1 Train B AF Pump ASME Surveillance;

• Unit 1 Train B AF Valve Strokes for 1AF013E-H;

• Unit 1 Train B Residual Heat Removal (RHR) Check Valve 1SI8958B;

• Unit 2 Reactor Coolant System (RCS) Water Inventory Balance Surveillance

(Leak Detection); and

• 0BMSR FP-5, Fire Hydrant Yard Loop Annual Flush

The inspectors observed in-plant activities and reviewed procedures and associated

records to determine the following:

• did preconditioning occur;

• were the effects of the testing adequately addressed by control room personnel or

engineers prior to the commencement of the testing;

• were acceptance criteria clearly stated, demonstrated operational readiness, and

consistent with the system design basis;

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

• as left setpoints were within required ranges; and the calibration frequency were

in accordance with TSs, the USAR, procedures, and applicable commitments;

• measuring and test equipment calibration was current;

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

prerequisites described in the test procedures were satisfied;

• test frequencies met TS requirements to demonstrate operability and reliability;

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

procedures; jumpers and lifted leads were controlled and restored where used;

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

• test equipment was removed after testing;

• where applicable for inservice testing (IST) activities, testing was performed in

accordance with the applicable version of Section XI of the ASME code, and

reference values were consistent with the system design basis;

• where applicable, test results not meeting acceptance criteria were addressed

with an adequate operability evaluation or the system or component was declared

inoperable;

19 Enclosure

• where applicable for safety-related instrument control surveillance tests, reference

setting data were accurately incorporated in the test procedure;

• where applicable, actual conditions encountering high resistance electrical

contacts were such that the intended safety function could still be accomplished;

• prior procedure changes had not provided an opportunity to identify problems

encountered during the performance of the surveillance or calibration test;

• equipment was returned to a position or status required to support the

performance of its safety functions; and

• all problems identified during the testing were appropriately documented and

dispositioned in the CAP.

Documents reviewed are listed in the Attachment.

This inspection constituted four routine surveillance testing samples, one IST sample,

and one RCS Leak Detection sample, as defined in IP 71111.22, Sections -02 and -05.

b. Findings

No findings were identified.

2. REACTOR SAFETY

Cornerstone: Emergency Preparedness

1EP4 Emergency Action Level and Emergency Plan Changes (71114.04)

.1 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

Since the last NRC inspection of this program area, Emergency Action Levels (EALs)

and Emergency Plan Revisions 27 and 28 were implemented based on the licensees

determination, in accordance with 10 CFR 50.54(q), that the changes resulted in no

decrease in effectiveness of the Plan, and that the revised Plan as changed continued to

meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. The

inspectors conducted a sampling review of the Emergency Plan changes and a review of

the EAL changes to evaluate for potential decreases in effectiveness of the Plan.

However, these reviews do not constitute formal NRC approval of the changes.

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

This EAL and Emergency Plan changes inspection constituted one sample as defined in

IP 71114.04-05.

b. Findings

No findings were identified.

20 Enclosure

1EP6 Drill Evaluation (71114.06)

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine licensee emergency drill on

November 15, 2011, to identify any weaknesses and deficiencies in classification,

notification, and protective action recommendation development activities. The

inspectors observed emergency response operations in the Simulator Control Room

and Technical Support Center to determine whether the event classification,

notifications, and protective action recommendations were performed in accordance

with procedures. The inspectors also attended the licensee drill critique to compare

any inspector-observed weakness with those identified by the licensee staff in order to

evaluate the critique and to verify whether the licensee staff was properly identifying

weaknesses and entering them into the CAP. As part of the inspection, the inspectors

reviewed the drill package and other documents listed in the Attachment.

This emergency preparedness drill inspection constituted one sample as defined in

IP 71114.06-05.

b. Findings

No findings were identified.

3. RADIATION SAFETY

2RS1 Radiological Hazard Assessment and Exposure Controls (71124.01)

The inspection activities supplement those documented in Inspection

Report 05000454/2011002; 05000455/2011002 and constitute one

complete sample as defined in IP 71124.01-05.

.1 Inspection Planning (02.01)

a. Inspection Scope

The inspectors reviewed licensee performance indicators for the occupational exposure

cornerstone for follow-up. The inspectors reviewed the results of radiation protection

program audits (e.g., licensee quality assurance audits or other independent audits).

The inspectors reviewed reports of operational occurrences related to occupational

radiation safety since the last inspection. The inspectors reviewed the results of the

audit and operational report reviews to gain insights into overall licensee performance.

b. Findings

No findings were identified.

21 Enclosure

.2 Instructions to Workers (02.03)

a. Inspection Scope

The inspectors reviewed selected occurrences where a workers electronic personal

dosimeter noticeably malfunctioned or alarmed. The inspectors evaluated whether

workers responded appropriately to the off-normal condition. The inspectors assessed

whether the issue was included in the CAP and dose evaluations were conducted as

appropriate.

b. Findings

No findings were identified.

.3 Radiological Hazards Control and Work Coverage (02.05)

a. Inspection Scope

The inspectors examined the licensees physical and programmatic controls for highly

activated or contaminated materials (nonfuel) stored within spent fuel and other storage

pools. The inspectors assessed whether appropriate controls (i.e., administrative and

physical controls) were in place to preclude inadvertent removal of these materials from

the pool.

The inspectors examined the posting and physical controls for selected high radiation

areas and very high radiation areas to verify conformance with the occupational radiation

performance indicator.

b. Findings

No findings were identified.

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

a. Inspection Scope

The inspectors discussed with the radiation protection manager the controls and

procedures for high-risk high radiation areas and very high radiation areas. The

inspectors discussed methods employed by the licensee to provide stricter control of

very high radiation area access as specified in 10 CFR 20.1602, Control of Access to

Very High Radiation Areas, and Regulatory Guide 8.38, Control of Access to High and

Very High Radiation Areas of Nuclear Plants. The inspectors assessed whether any

changes to licensee procedures substantially reduced the effectiveness and level of

worker protection.

The inspectors discussed the controls in place for special areas that have the potential

to become very high radiation areas during certain plant operations with health physics

supervisors (or equivalent positions having backshift health physics oversight authority).

The inspectors assessed whether these plant operations required communication

beforehand with the health physics group, so as to allow corresponding timely actions to

22 Enclosure

properly post, control, and monitor the radiation hazards including re-access

authorization.

The inspectors evaluated licensee controls for very high radiation areas and areas with

the potential to become very high radiation areas to ensure that an individual was not

able to gain unauthorized access to the very high radiation area.

b. Findings

No findings were identified.

.5 Radiation Worker Performance (02.07)

a. Inspection Scope

The inspectors reviewed radiological problem reports since the last inspection that found

the cause of the event to be human performance errors. The inspectors evaluated

whether there was an observable pattern traceable to a similar cause. The inspectors

assessed whether this perspective matched the corrective action approach taken by the

licensee to resolve the reported problems. The inspectors discussed with the radiation

protection manager any problems with the corrective actions planned or taken.

b. Findings

No findings were identified.

.6 Radiation Protection Technician Proficiency (02.08)

a. Inspection Scope

The inspectors reviewed radiological problem reports since the last inspection that found

the cause of the event to be radiation protection technician error. The inspectors

evaluated whether there was an observable pattern traceable to a similar cause. The

inspectors assessed whether this perspective matched the corrective action approach

taken by the licensee to resolve the reported problems.

b. Findings

No findings were identified.

.7 Problem Identification and Resolution (02.09)

a. Inspection Scope

The inspectors evaluated whether problems associated with radiation monitoring and

exposure control were being identified by the licensee at an appropriate threshold and

were properly addressed for resolution in the licensees CAP. The inspectors assessed

the appropriateness of the corrective actions for a selected sample of problems

documented by the licensee that involved radiation monitoring and exposure controls.

The inspectors assessed the licensees process for applying operating experience to

their plant.

23 Enclosure

b. Findings

No findings were identified.

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

The inspection activities supplement those documented in Inspection

Report 05000454/2011002; 05000455/2011002 and constitute one

complete sample as defined in IP 71124.03-05.

.1 Engineering Controls (02.02)

a. Inspection Scope

The inspectors reviewed the licensees use of permanent and temporary ventilation to

determine whether the licensee used ventilation systems as part of its engineering

controls (in-lieu of respiratory protection devices) to control airborne radioactivity. The

inspectors reviewed procedural guidance for use of installed plant systems, such as

containment purge, spent fuel pool ventilation, and auxiliary building ventilation, and

assessed whether the systems were used, to the extent practicable, during high-risk

activities (e.g., using containment purge during cavity flood-up).

The inspectors selected installed ventilation systems used to mitigate the potential for

airborne radioactivity, and evaluated whether the ventilation airflow capacity, flow path

(including the alignment of the suction and discharges), and filter/charcoal unit

efficiencies, as appropriate, were consistent with maintaining concentrations of airborne

radioactivity in work areas below the concentrations of an airborne area to the extent

practicable.

The inspectors selected temporary ventilation system setups (high efficiency particulate

air/charcoal negative pressure units, down draft tables, tents, metal Kelly buildings, and

other enclosures) used to support work in contaminated areas. The inspectors

assessed whether the use of these systems was consistent with licensee procedural

guidance and the As-Low-As-Reasonably-Achievable (ALARA) concept.

The inspectors reviewed airborne monitoring protocols by selecting installed systems

used to monitor and warn of changing airborne concentrations in the plant and

evaluating whether the alarms and setpoints were sufficient to prompt licensee/worker

action to ensure that doses were maintained within the limits of 10 CFR Part 20 and the

ALARA concept.

The inspectors assessed whether the licensee had established trigger points (e.g., the

Electric Power Research Institutes Alpha Monitoring Guidelines for Operating Nuclear

Power Stations) for evaluating levels of airborne beta-emitting (e.g., plutonium-241) and

alpha-emitting radionuclides.

b. Findings

No findings were identified.

24 Enclosure

.2 Use of Respiratory Protection Devices (02.03)

a. Inspection Scope

For those situations where it was impractical to employ engineering controls to minimize

airborne radioactivity, the inspectors assessed whether the licensee provided respiratory

protective devices such that occupational doses were ALARA. The inspectors selected

work activities where respiratory protection devices were used to limit the intake of

radioactive materials, and assessed whether the licensee performed an evaluation

concluding that further engineering controls were not practical and that the use of

respirators was ALARA. The inspectors also evaluated whether the licensee had

established means (such as routine bioassay) to determine if the level of protection

(protection factor) provided by the respiratory protection devices during use was at least

as good as that assumed in the licensees work controls and dose assessment.

b. Findings

No findings were identified.

2RS4 Occupational Dose Assessment (71124.04)

The inspection activities supplement those documented in Inspection

Report 05000454/2011002; 05000455/2011002 and constitute one

complete sample as defined in IP 71124.04-05.

.1 External Dosimetry (02.02)

a. Inspection Scope

The inspectors evaluated whether the licensees dosimetry vendor was National

Voluntary Laboratory Accreditation Program (NVLAP) accredited and if the approved

irradiation test categories for each type of personnel dosimeter used were consistent

with the types and energies of the radiation present and the way the dosimeter was

being used (e.g., to measure deep dose equivalent, shallow dose equivalent, or lens

dose equivalent).

b. Findings

Introduction: The inspectors identified that the licensees use of dosimeters (TLDs)

may not be consistent with the methods used by the NVLAP accreditation process.

As a result, the inspectors identified an Unresolved Item (URI) for the apparent

non-compliance with 10 CFR 20.1501(c)(2) because the accreditation process for the

types of radiation included in the NVLAP program may not approximate the types of

radiation for which the individual wearing the dosimeter is monitored.

Discussion: The licensee used a vendor to supply and process dosimeters used to

measure radiation exposure for the monitored workers. This vendor was NVLAP

accredited for beta, gamma, neutron, mixture of beta/gamma, and mixture

neutron/gamma radiations. However, the licensee used the dosimeters when workers

may be exposed to beta, gamma, and neutron radiations within the same monitoring

25 Enclosure

period. The inspectors determined that this mixture of three radiation types may not be

aligned with the accreditation process.

The issue was categorized as a URI pending NRC evaluation of this practice and

determination whether a single TLD can accurately measure occupational dose to three

types of radiation (URI 05000454/2011005-03; 05000455/2011005-03; Use of TLDs May

Not be Consistent with the Methods Used by the NVLAP Accreditation Process)

2RS5 Radiation Monitoring Instrumentation (71124.05)

The inspection activities supplement those documented in Inspection

Report 05000454/2011002; 05000455/2011002 and constitute one

complete sample as defined in IP 71124.05-05.

.1 Inspection Planning (02.01)

a. Inspection Scope

The inspectors reviewed the area radiation monitor alarm setpoint values and setpoint

bases as provided in the TSs and the Final Safety Analysis Report.

The inspectors reviewed effluent monitor alarm setpoint bases and the calculation

methods provided in the Offsite Dose Calculation Manual (ODCM).

b. Findings

No findings were identified.

2RS6 Radioactive Gaseous and Liquid Effluent Treatment (71124.06)

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

.1 Inspection Planning and Program Reviews (02.01)

Event Report and Effluent Report Reviews

a. Inspection Scope

The inspectors reviewed the radiological effluent release reports issued since the last

inspection to determine if the reports were submitted as required by the ODCMl/TSs.

The inspectors reviewed anomalous results, unexpected trends, or abnormal releases

identified by the licensee for further inspection to determine if they were evaluated, were

entered in the CAP, and were adequately resolved.

The inspectors identified radioactive effluent monitor operability issues reported by the

licensee in effluent release reports and reviewed these issues during the onsite

inspection, as warranted, and determined if the issues were entered into the CAP and

adequately resolved.

b. Findings

No findings were identified.

26 Enclosure

Offsite Dose Calculation Manual and Final Safety Analysis Report Review

c. Inspection Scope

The inspectors reviewed Final Safety Analysis Report descriptions of the radioactive

effluent monitoring systems, treatment systems, and effluent flow paths so they could be

evaluated during inspection walkdowns.

The inspectors reviewed changes to the ODCM made by the licensee since the last

inspection against the guidance in NUREG-1301, NUREG-0133, and Regulatory

Guides 1.109, 1.21 and 4.1. When differences were identified, the inspectors reviewed

the technical basis or evaluations of the change during the onsite inspection to

determine whether they were technically justified and maintain effluent releases ALARA.

The inspectors reviewed licensee documentation to determine if the licensee had

identified any non-radioactive systems that had become contaminated as disclosed

either through an event report or the ODCM since the last inspection. This review

provided an intelligent sample list for the onsite inspection of any 10 CFR 50.59

evaluations and allowed a determination if any newly contaminated systems had an

unmonitored effluent discharge path to the environment, whether any required ODCM

revisions were made to incorporate these new pathways and whether the associated

effluents were reported in accordance with Regulatory Guide 1.21.

d. Findings

No findings were identified.

Groundwater Protection Initiative Program

e. Inspection Scope

The inspectors reviewed reported groundwater monitoring results and changes to the

licensees written program for identifying and controlling contaminated spills/leaks to

groundwater.

f. Findings

No findings were identified.

Procedures, Special Reports, and Other Documents

g. Inspection Scope

The inspectors reviewed Licensee Event Reports, event reports and/or special reports

related to the effluent program issued since the previous inspection to identify any

additional focus areas for the inspection based on the scope/breadth of problems

described in these reports.

The inspectors reviewed effluent program implementing procedures, particularly those

associated with effluent sampling, effluent monitor setpoint determinations, and dose

calculations.

27 Enclosure

The inspectors reviewed copies of licensee and third party (independent) evaluation

reports of the effluent monitoring program since the last inspection to gather insights into

the licensees program and aid in selecting areas for inspection review (smart sampling).

h. Findings

No findings were identified.

.2 Walkdowns and Observations (02.02)

a. Inspection Scope

The inspectors walked down selected components of the gaseous and liquid discharge

systems to evaluate whether equipment configuration and flow paths aligned with the

documents reviewed in 02.01 above and to assess equipment material condition.

Special attention was made to identify potential unmonitored release points (such as

open roof vents in boiling water reactor turbine decks, temporary structures butted

against turbine, auxiliary or containment buildings), building alterations which could

impact airborne or liquid effluent controls, and ventilation system leakage that

communicated directly with the environment.

For equipment or areas associated with the systems selected for review that were not

readily accessible due to radiological conditions, the inspectors reviewed the licensee's

material condition surveillance records, as applicable.

The inspectors walked down filtered-ventilation systems to assess for conditions such as

degraded high-efficiency particulate air/charcoal banks, improper alignment, or system

installation issues that would impact the performance or the effluent monitoring capability

of the effluent system.

As available, the inspectors observed selected portions of the routine processing and

discharge of radioactive gaseous effluent (including sample collection and analysis) to

evaluate whether appropriate treatment equipment was used and the processing

activities aligned with discharge permits.

The inspectors determined if the licensee had made significant changes to their

effluent release points (e.g., changes subject to a 10 CFR 50.59 review or requiring

NRC approval of alternate discharge points).

As available, the inspectors observed selected portions of the routine processing and

discharge of liquid waste (including sample collection and analysis) to determine if

appropriate effluent treatment equipment was being used and whether radioactive liquid

waste was being processed and discharged in accordance with procedure requirements

and aligned with discharge permits.

b. Findings

No findings were identified.

28 Enclosure

.3 Sampling and Analyses (02.03)

a. Inspection Scope

The inspectors selected effluent sampling activities, consistent with smart sampling, and

assessed whether adequate controls had been implemented to ensure representative

samples were obtained (e.g., provisions for sample line flushing, vessel recirculation,

composite samplers, etc.)

The inspectors selected effluent discharges made with inoperable (declared out-of-

service) effluent radiation monitors to assess whether controls were in place to ensure

compensatory sampling was performed consistent with the radiological effluent

TSs/ODCM and that those controls were adequate to prevent the release of

unmonitored liquid and gaseous effluents.

The inspectors determined whether the facility was routinely relying on the use of

compensatory sampling in lieu of adequate system maintenance, based on the

frequency of compensatory sampling since the last inspection.

The inspectors reviewed the results of the inter-laboratory comparison program to

evaluate the quality of the radioactive effluent sample analyses and assessed whether

the inter-laboratory comparison program included hard-to-detect isotopes as

appropriate.

b. Findings

No findings were identified.

.4 Instrumentation and Equipment (02.04)

Effluent Flow Measuring Instruments

a. Inspection Scope

The inspectors reviewed the methodology the licensee used to determine the effluent

stack and vent flow rates to determine if the flow rates were consistent with radiological

effluent TSs/ODCM or Final Safety Analysis Report values, and that differences between

assumed and actual stack and vent flow rates did not affect the results of the projected

public doses.

b. Findings

No findings were identified.

Air Cleaning Systems

c. Inspection Scope

The inspectors assessed whether surveillance test results since the previous

inspection for TS required ventilation effluent discharge systems (high-efficiency

particulate air and charcoal filtration), such as the Standby Gas Treatment System

and the Containment/Auxiliary Building Ventilation System, met TS acceptance criteria.

29 Enclosure

d. Findings

No findings were identified.

.5 Dose Calculations (02.05)

a. Inspection Scope

The inspectors reviewed all significant changes in reported dose values compared to the

previous radiological effluent release report (e.g., a factor of 5, or increases that

approach Appendix I criteria) to evaluate the factors which may have resulted in the

change.

The inspectors reviewed radioactive liquid and gaseous waste discharge permits to

assess whether the projected doses to members of the public were accurate and based

on representative samples of the discharge path.

The inspectors evaluated the methods used to determine the isotopes that were

included in the source term to ensure all applicable radionuclides were included within

detectability standards. The review included the current Part 61 analyses to ensure

hard-to-detect radionuclides were included in the source term.

The inspectors reviewed changes in the licensees offsite dose calculations since the

last inspection to evaluate whether changes were consistent with the ODCM and

Regulatory Guide 1.109. The inspectors reviewed meteorological dispersion and

deposition factors used in the ODCM and effluent dose calculations to evaluate whether

appropriate factors were being used for public dose calculations.

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

significant increases or decreases to population in the plant environs, changes in critical

exposure pathways, the location of nearest member of the public or critical receptor,

etc.) had been factored into the dose calculations.

For the releases reviewed above, the inspectors evaluated whether the calculated doses

(monthly, quarterly, and annual dose) were within the 10 CFR Part 50, Appendix I, and

TS dose criteria.

The inspectors reviewed, as available, records of any abnormal gaseous or liquid tank

discharges (e.g., discharges resulting from misaligned valves, valve leak-by, etc) to

ensure the abnormal discharge was monitored by the discharge point effluent monitor.

Discharges made with inoperable effluent radiation monitors, or unmonitored leakages

were reviewed to ensure that an evaluation was made of the discharge to satisfy

10 CFR 20.1501 so as to account for the source term and projected doses to the public.

b. Findings

No findings were identified.

30 Enclosure

.6 Groundwater Protection Initiative Implementation (02.06)

a. Inspection Scope

The inspectors reviewed monitoring results of the Groundwater Protection Initiative to

determine if the licensee had implemented its program as intended and to identify any

anomalous results. For anomalous results or missed samples, the inspectors assessed

whether the licensee had identified and addressed deficiencies through its CAP.

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

10 CFR 50.75 (g) records. The inspectors reviewed evaluations of leaks or spills

and reviewed any remediation actions taken for effectiveness. The inspectors

reviewed onsite contamination events involving contamination of ground water and

assessed whether the source of the leak or spill was identified and mitigated.

For unmonitored spills, leaks, or unexpected liquid or gaseous discharges, the

inspectors assessed whether an evaluation was performed to determine the type and

amount of radioactive material that was discharged by:

• Assessing whether sufficient radiological surveys were performed to evaluate the

extent of the contamination and the radiological source term and assessing whether

a survey/evaluation had been performed to include consideration of hard-to-detect

radionuclides.

• Determining whether the licensee completed offsite notifications, as provided in its

Groundwater Protection Initiative implementing procedures.

The inspectors reviewed the evaluation of discharges from onsite surface water bodies

that contained or potentially contained radioactivity, and the potential for ground water

leakage from these onsite surface water bodies. The inspectors assessed whether the

licensee was properly accounting for discharges from these surface water bodies as part

of their effluent release reports.

The inspectors assessed whether on-site ground water sample results and a description

of any significant on-site leaks/spills into ground water for each calendar year were

documented in the Annual Radiological Environmental Operating Report for the

radiological environmental monitoring program or the Annual Radiological Effluent

Release Report for the Radiological Effluent TSs.

For significant, new effluent discharge points (such as significant or continuing leakage

to ground water that continued to impact the environment if not remediated), the

inspectors evaluated whether the ODCM was updated to include the new release point.

b. Findings

No findings were identified.

31 Enclosure

.7 Problem Identification and Resolution (02.07)

a. Inspection Scope

Inspectors assessed whether problems associated with the effluent monitoring and

control program were being identified by the licensee at an appropriate threshold and

were properly addressed for resolution in the licensee CAP. In addition, the inspectors

evaluated the appropriateness of the corrective actions for a selected sample of

problems documented by the licensee involving radiation monitoring and exposure

controls.

b. Findings

No findings were identified.

2RS7 Radiological Environmental Monitoring Program (71124.07)

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

.1 Inspection Planning (02.01)

a. Inspection Scope

The inspectors reviewed the annual radiological environmental operating reports and the

results of any licensee assessments since the last inspection to assess whether the

radiological environmental monitoring program was implemented in accordance with the

TSs and ODCM. This review included reported changes to the ODCM with respect to

environmental monitoring, commitments in terms of sampling locations, monitoring and

measurement frequencies, land use census, inter-laboratory comparison program, and

analysis of data.

The inspectors reviewed the ODCM to identify locations of environmental monitoring

stations.

The inspectors reviewed the Final Safety Analysis Report for information regarding the

environmental monitoring program and meteorological monitoring instrumentation.

The inspectors reviewed quality assurance audit results of the program to assist in

choosing inspection smart samples and audits and technical evaluations performed on

the vendor laboratory program.

The inspectors reviewed the annual effluent release report and the 10 CFR Part 61,

Licensing Requirements for Land Disposal of Radioactive Waste, report, to determine

if the licensee was sampling, as appropriate, for the predominant and dose-causing

radionuclides likely to be released in effluents.

b. Findings

No findings were identified.

32 Enclosure

.2 Site Inspection (02.02)

a. Inspection Scope

The inspectors walked down select air sampling stations and thermoluminescent

dosimeter monitoring stations to determine whether they were located as described in

the ODCM and to determine the equipment material condition. Consistent with smart

sampling, the air sampling stations were selected based on the locations with the

highest X/Q, D/Q wind sectors, and thermoluminescent dosimeters were selected based

on the most risk-significant locations (e.g., those that have the highest potential for

public dose impact).

For the air samplers and thermoluminescent dosimeters selected, the inspectors

reviewed the calibration and maintenance records to evaluate whether they

demonstrated adequate operability of these components. Additionally, the review

included the calibration and maintenance records of select composite water samplers.

The inspectors assessed whether the licensee had initiated sampling of other

appropriate media upon loss of a required sampling station.

The inspectors observed the collection and preparation of environmental samples from

different environmental media (e.g., ground and surface water, milk, vegetation,

sediment, and soil) as available to determine if environmental sampling was

representative of the release pathways as specified in the ODCM and if sampling

techniques were in accordance with procedures.

Based on direct observation and review of records, the inspectors assessed whether

the meteorological instruments were operable, calibrated, and maintained in

accordance with guidance contained in the Final Safety Analysis Report; NRC

Regulatory Guide 1.23, Meteorological Monitoring Programs for Nuclear Power Plants;

and licensee procedures. The inspectors assessed whether the meteorological data

readout and recording instruments in the control room and, if applicable, at the tower

were operable.

The inspectors evaluated whether missed and/or anomalous environmental samples

were identified and reported in the annual environmental monitoring report. The

inspectors selected events that involved a missed sample, inoperable sampler, lost

thermoluminescent dosimeter, or anomalous measurement to determine if the licensee

had identified the cause and had implemented corrective actions. The inspectors

reviewed the licensees assessment of any positive sample results (i.e., licensed

radioactive material detected above the lower limits of detection) and reviewed the

associated radioactive effluent release data that was the source of the released material.

The inspectors selected structures, systems, or components that involved or could

reasonably involve licensed material for which there was a credible mechanism for

licensed material to reach ground water, and assessed whether the licensee had

implemented a sampling and monitoring program sufficient to detect leakage of these

structures, systems, or components to ground water.

33 Enclosure

The inspectors evaluated whether records, as required by 10 CFR 50.75(g), of leaks,

spills, and remediation since the previous inspection were retained in a retrievable

manner.

The inspectors reviewed any significant changes made by the licensee to the ODCM as

the result of changes to the land census, long-term meteorological conditions (3-year

average), or modifications to the sampler stations since the last inspection. The

inspectors reviewed technical justifications for any changed sampling locations to

evaluate whether the licensee performed the reviews required to ensure that the

changes did not affect the ability to monitor the impact of radioactive effluent releases on

the environment.

The inspectors assessed whether the appropriate detection sensitivities with respect to

TSs/ODCM were used for counting samples (i.e., the samples met the TSs/ODCM

required lower limits of detection). The inspectors reviewed quality control charts for

maintaining radiation measurement instrument status and actions taken for degrading

detector performance. The licensee used a vendor laboratory to analyze the radiological

environmental monitoring program samples so the inspectors reviewed the results of the

vendors quality control program, including the interlaboratory comparison, to assess the

adequacy of the vendors program.

The inspectors reviewed the results of the licensees interlaboratory comparison

program to evaluate the adequacy of environmental sample analyses performed by the

licensee. The inspectors assessed whether the interlaboratory comparison test included

the media/nuclide mix appropriate for the facility. If applicable, the inspectors reviewed

the licensees determination of any bias to the data and the overall effect on the

radiological environmental monitoring program.

b. Findings

No findings were identified.

.3 Identification and Resolution of Problems (02.03)

a. Inspection Scope

The inspectors assessed whether problems associated with the radiological

environmental monitoring program were being identified by the licensee at an

appropriate threshold and were properly addressed for resolution in the licensees CAP.

Additionally, the inspectors assessed the appropriateness of the corrective actions for a

selected sample of problems documented by the licensee that involved the radiological

environmental monitoring program.

b. Findings

No findings were identified.

2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and

Transportation (71124.08)

This inspection constituted one complete sample as defined in IP 71124.08-05.

34 Enclosure

.1 Inspection Planning (02.01)

a. Inspection Scope

The inspectors reviewed the solid radioactive waste system description in the Final

Safety Analysis Report, the process control program, and the recent radiological effluent

release report for information on the types, amounts, and processing of radioactive

waste disposed.

The inspectors reviewed the scope of any quality assurance audits in this area since the

last inspection to gain insights into the licensees performance and inform the smart

sampling inspection planning.

b. Findings

No findings were identified.

.2 Radioactive Material Storage (02.02)

a. Inspection Scope

The inspectors selected areas where containers of radioactive waste were stored, and

evaluated whether the containers were labeled in accordance with 10 CFR 20.1904,

Labeling Containers, or controlled in accordance with 10 CFR 20.1905, Exemptions to

Labeling Requirements, as appropriate.

The inspectors assessed whether the radioactive material storage areas were controlled

and posted in accordance with the requirements of 10 CFR Part 20, Standards for

Protection against Radiation. For materials stored or used in controlled or unrestricted

areas, the inspectors evaluated whether they were secured against unauthorized

removal and controlled in accordance with 10 CFR 20.1801, Security of Stored

Material, and 10 CFR 20.1802, Control of Material Not in Storage, as appropriate.

The inspectors evaluated whether the licensee established a process for monitoring the

impact of long term storage (e.g., buildup of any gases produced by waste

decomposition, chemical reactions, container deformation, loss of container integrity, or

re-release of free-flowing water) that was sufficient to identify potential unmonitored,

unplanned releases or nonconformance with waste disposal requirements.

The inspectors selected containers of stored radioactive material, and inspected the

containers for signs of swelling, leakage, and deformation.

b. Findings

No findings were identified.

.3 Radioactive Waste System Walkdown (02.03)

a. Inspection Scope

The inspectors walked down accessible portions of select radioactive waste processing

systems to assess whether the current system configuration and operation agreed with

35 Enclosure

the descriptions in the Final Safety Analysis Report, ODCM, and process control

program.

The inspectors reviewed administrative and/or physical controls (i.e., drainage and

isolation of the system from other systems) to assess whether the equipment which was

not in service or abandoned in place would contribute to an unmonitored release path

and/or affect operating systems or be a source of unnecessary personnel exposure.

The inspectors assessed whether the licensee reviewed the safety significance of

systems and equipment abandoned in place in accordance with 10 CFR 50.59,

Changes, Tests, and Experiments.

The inspectors reviewed the adequacy of changes made to the radioactive waste

processing systems since the last inspection. The inspectors evaluated whether

changes from what was described in the Final Safety Analysis Report were reviewed

and documented in accordance with 10 CFR 50.59, as appropriate and to assess the

impact on radiation doses to members of the public.

The inspectors selected processes for transferring radioactive waste resin and/or sludge

discharges into shipping/disposal containers and assessed whether the waste stream

mixing, sampling procedures, and methodology for waste concentration averaging were

consistent with the process control program, and provided representative samples of the

waste product for the purposes of waste classification as described in 10 CFR 61.55,

Waste Classification.

For those systems that provided tank recirculation, the inspectors evaluated whether the

tank recirculation procedures provided sufficient mixing.

The inspectors assessed whether the licensees process control program correctly

described the current methods and procedures for dewatering and waste stabilization

(e.g., removal of freestanding liquid).

b. Findings

No findings were identified.

.4 Waste Characterization and Classification (02.04)

a. Inspection Scope

The inspectors selected the following radioactive waste streams for review:

• Primary Resin;

• Secondary Resin;

• Secondary Radwaste Filter; and

• Dry Active Waste (DAW).

For the waste streams listed above, the inspectors assessed whether the licensees

radiochemical sample analysis results (i.e., 10 CFR Part 61" analysis) were sufficient to

support radioactive waste characterization as required by 10 CFR Part 61, Licensing

Requirements for Land Disposal of Radioactive Waste. The inspectors evaluated

whether the licensees use of scaling factors and calculations to account for difficult-to-

36 Enclosure

measure radionuclides was technically sound and based on current 10 CFR Part 61

analyses for the selected radioactive waste streams.

The inspectors evaluated whether changes to plant operational parameters were taken

into account to: (1) maintain the validity of the waste stream composition data between

the annual or biennial sample analysis update; and (2) assure that waste shipments

continued to meet the requirements of 10 CFR Part 61 for the waste streams selected

above.

The inspectors evaluated whether the licensee had established and maintained an

adequate quality assurance program to ensure compliance with the waste classification

and characterization requirements of 10 CFR 61.55 and 10 CFR 61.56, Waste

Characteristics.

b. Findings

No findings were identified.

.5 Shipment Preparation (02.05)

a. Inspection Scope

The inspectors observed shipment packaging, surveying, labeling, marking, placarding,

vehicle checks, emergency instructions, disposal manifest, shipping papers provided to

the driver, and licensee verification of shipment readiness. The inspectors assessed

whether the requirements of applicable transport cask certificates of compliance had

been met. The inspectors evaluated whether the receiving licensee was authorized to

receive the shipment packages. The inspectors evaluated whether the licensees

procedures for cask loading and closure were consistent with the vendors current

approved procedures.

The inspectors observed radiation workers during the conduct of radioactive waste

processing and radioactive material shipment preparation and receipt activities. The

inspectors assessed whether the shippers were knowledgeable of the shipping

regulations and whether shipping personnel demonstrated adequate skills to accomplish

the package preparation requirements for public transport with respect to the licensees

response to NRC Bulletin 79-19, Packaging of Low-Level Radioactive Waste for

Transport and Burial, dated August 10, 1979; and Title 49 CFR Part 172, Hazardous

Materials Table, Special Provisions, Hazardous Materials Communication, Emergency

Response Information, Training Requirements, and Security Plans, Subpart H,

Training.

Due to limited opportunities for direct observation, the inspectors reviewed the technical

instructions presented to workers during routine training. The inspectors assessed

whether the licensees training program provided training to personnel responsible for

the conduct of radioactive waste processing and radioactive material shipment

preparation activities.

b. Findings

No findings were identified.

37 Enclosure

.6 Shipping Records (02.06)

a. Inspection Scope

The inspectors evaluated whether the shipping documents indicated the proper shipper

name; emergency response information and a 24-hour contact telephone number;

accurate curie content and volume of material; and appropriate waste classification,

transport index, and UN number for the following radioactive shipments:

• Shipment RWS10-011; Dewatered Bead Resin; low specific activity (LSA-II);

• Shipment RWS10-013; DAW Trash and TR Pond Sludge; low specific activity

(LSA-II);

• Shipment RWS10-012; DAW Trash; low specific activity (LSA-II);

• Shipment RMS09-094; Rx Vessel Dosimetry; Type A Package; and

• Shipment RMS11-078; Dirty Laundry; low specific activity (LSA-II).

Additionally, the inspectors assessed whether the shipment placarding was consistent

with the information in the shipping documentation.

b. Findings

Introduction: A self-revealed finding of very low safety significance (Green) and an

associated NCV of 10 CFR 71.5, Transportation of Licensed Material, was identified

when licensee personnel failed to comply with 49 CFR 172.203(c) and shipped

packages of radioactive material with transport manifests that did not document all

applicable hazardous substances.

Description: On multiple dates, the licensee shipped containers of radioactive material

to a waste processor with incomplete information on the transport manifest. Specifically,

the transport manifest that accompanied the shipments failed to identify hazardous

materials, including asbestos, lead, and other chemicals that were contained in the

packages. Upon arrival at the waste processors facility, the waste processor identified

the non-conformances in the shipping containers and notified the licensee. Follow-up

actions by the licensee included performing a revised characterization of the shipped

packages. The revised radiological characterization identified negligible impact relative

to the initial radiological assessment and package characterization. This event was

documented in the licensees CAP as:

• IR 1221229; RWS11-006 Contained Un-Manifested Asbestos;

• IR 1173307; RWS10-013 Contained Unapproved Mixed Waste;

• IR 928393; Non-Conforming Metal Shipped to Bear Creek Processing;

• IR 1015646; Non-Conforming Waste Found in Radwaste Shipment; and

• IR 1067394; Non-Conforming Radioactive Waste in Shipment.

38 Enclosure

Immediate corrective actions included providing a corrected copy of the transport

manifest to the waste processor. Additionally, the licensee initiated IR 1285148

to evaluate the human performance issues associated with the shipping

non-conformances. Further, the licensee placed locks on the shipping containers

to control items placed in the packages and to ensure that the manifest accurately

represented the hazards contained in the shipping package.

Analysis: The failure to completely identify all required package contents on a transport

manifest was a performance deficiency. The finding was determined to be more than

minor because it was associated with the Program and Process attribute of the Public

Radiation Safety Cornerstone and adversely affected the cornerstone objective of

ensuring the adequate protection of public health and safety from exposure to

radioactive materials released into the public domain as a result of routine civilian

nuclear reactor operation, in that, providing incorrect information, as part of hazard

communication, could impact the actions of response personnel. The finding involved

an occurrence of the licensees radioactive material transportation program that was

contrary to NRC regulatory requirements. The inspectors determined that the finding

could be evaluated using the SDP in accordance with IMC 0609, Significance

Determination Process, Appendix D, Public Radiation Safety Significance

Determination Process. Using the Public Radiation Safety SDP, the inspectors

determined: (1) radiation limits were not exceeded; (2) there was no breach of a

package during transit; (3) it did not involve a certificate of compliance issue; (4) it was

not a low level burial ground nonconformance; and (5) it did not involve a failure to make

notifications or provide emergency information. As a result, the finding screened as

having very low safety significance (Green).

This finding has a cross-cutting aspect in the Work Control component of the Human

Performance cross-cutting area H.3(b) since the waster shipper failed to coordinate

work activities by incorporating actions to address the impact of the work on different job

activities, and the need for work groups to maintain interfaces with offsite organizations,

and communicate, coordinate, and cooperate with each other during activities in which

interdepartmental coordination is necessary to assure adequate human performance.

Specifically, these events occurred because the radioactive material shipper did not

control the items placed in the waste packages and was not present when the boxes

were loaded.

Enforcement: Title 10 CFR 71.5, Transportation of Licensed Material, requires

licensees to comply with the Department of Transportation (DOT) regulations in

49 CFR Parts 170 through 189 relative to the transportation of licensed material.

Title 49 CFR 172.203, Additional Description Requirements, required, in part,

that hazardous materials be listed on the transport manifest.

Contrary to the above, between May 10, 2010 and May 26, 2011, the licensee failed to

list relevant hazardous materials on the transport manifest for a shipment also containing

DAW. This violation was entered into the licensees CAP as IR 1285148. Because this

violation was of very low safety significance and it was entered into the licensees CAP,

this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC

Enforcement Policy. (NCV 05000454/2011005-04, Failure to Identify Hazardous

Materials on Transportation Manifest)

39 Enclosure

.7 Identification and Resolution of Problems (02.07)

a. Inspection Scope

The inspectors assessed whether problems associated with radioactive waste

processing, handling, storage, and transportation, were being identified by the licensee

at an appropriate threshold, were properly characterized, and were properly addressed

for resolution in the licensee CAP. Additionally, the inspectors evaluated whether the

corrective actions were appropriate for a selected sample of problems documented by

the licensee that involve radioactive waste processing, handling, storage, and

transportation.

The inspectors reviewed results of selected audits performed since the last inspection of

this program and evaluated the adequacy of the licensees corrective actions for issues

identified during those audits.

b. Findings

No findings were identified.

4. OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and

Emergency Preparedness

4OA1 Performance Indicator Verification (71151)

.1 Reactor Coolant System Leakage

a. Inspection Scope

The inspectors sampled licensee submittals for the Unit 1 and Unit 2 RCS Leakage

Performance Indicator (PI) for the period from the third quarter 2010 through the second

quarter 2011. To determine the accuracy of the PI data reported during those periods,

PI definitions and guidance contained in Nuclear Energy Institute (NEI) 99-02,

Regulatory Assessment Performance Indicator Guideline, Revision 6, dated

October 2009, was used. The inspectors reviewed the licensees operator logs,

RCS leakage tracking data, issue reports, event reports and NRC Integrated Inspection

Reports for the period of June 2010 through June 2011 to validate the accuracy of the

submittals. The inspectors also reviewed the licensees issue report database to

determine if any problems had been identified with the PI data collected or transmitted

for this indicator. Documents reviewed are listed in the Attachment.

This inspection constituted two RCS leakage samples as defined in IP 71151-05.

b. Findings

No findings were identified.

40 Enclosure

.2 Unplanned Transients Per 7000 Critical Hours

a. Inspection Scope

The inspectors sampled licensee submittals for the Unplanned Transients per 7000

Critical Hours performance indicator for Unit 1 and Unit 2 for the period from the second

quarter of 2010 through the 3rd quarter of 2011. To determine the accuracy of the PI

data reported during those periods, PI definitions and guidance contained in NEI 99-02,

Regulatory Assessment Performance Indicator Guideline, Revision 6, dated

October 2009, was used. The inspectors reviewed the licensees operator narrative

logs, issue reports, maintenance rule records, event reports and NRC Integrated

Inspection Reports for the period of April 2010 through September 2011 to validate the

accuracy of the submittals. The inspectors also reviewed the licensees issue report

database to determine if any problems had been identified with the PI data collected or

transmitted for this indicator. Documents reviewed are listed in the Attachment.

This inspection constituted two unplanned transients per 7000 critical hours samples as

defined in IP 71151-05.

b. Findings

No findings were identified.

.3 Safety System Functional Failures

a. Inspection Scope

The inspectors sampled licensee submittals for the Safety System Functional Failures

performance indicator for Unit 1 and Unit 2 for the period from the second quarter of

2010 through the third quarter of 2011. To determine the accuracy of the PI data

reported during those periods, PI definitions and guidance contained in NEI 99-02,

Regulatory Assessment Performance Indicator Guideline, Revision 6, dated

October 2009, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and

50.73" definitions and guidance, were used. The inspectors reviewed the licensees

operator narrative logs, operability assessments, maintenance rule records,

maintenance work orders, issue reports, event reports and NRC Integrated Inspection

Reports for the period of June 2010 through September 2011 to validate the accuracy of

the submittals. The inspectors also reviewed the licensees issue report database to

determine if any problems had been identified with the PI data collected or transmitted

for this indicator. Documents reviewed are listed in the Attachment.

This inspection constituted two safety system functional failures samples as defined in

IP 71151-05.

b. Findings

No findings were identified.

41 Enclosure

.4 Reactor Coolant System Specific Activity

a. Inspection Scope

The inspectors sampled licensee submittals for the RCS specific activity PI for Unit 1

and Unit 2 for the period from the 4th quarter of 2010 through the 3rd quarter of 2011.

The inspectors used PI definitions and guidance contained in NEI 99-02, Regulatory

Assessment Performance Indicator Guideline, Revision 6, dated October 2009 to

determine the accuracy of the PI data reported during those periods. The inspectors

reviewed the licensees reactor coolant system chemistry samples, TS requirements,

issue reports, event reports, and NRC Integrated Inspection Reports for the period of the

4th quarter 2010 through the 3rd quarter of 2011 to validate the accuracy of the

submittals. The inspectors also reviewed the licensees issue report database to

determine if any problems had been identified with the PI data collected or transmitted

for this indicator. In addition to record reviews, the inspectors observed a chemistry

technician obtain and analyze a reactor coolant system sample. Documents reviewed

are listed in the Attachment.

This inspection constituted two RCS specific activity samples as defined in IP 71151-05.

b. Findings

No findings were identified.

.5 Mitigating Systems Performance Index - Heat Removal System

a. Inspection Scope

The inspectors sampled licensee submittals for the Mitigating Systems Performance

Index (MSPI) - Heat Removal System performance indicator for Unit 1 and Unit 2 for the

period from the fourth quarter of 2010 through the third quarter of 2011. To determine

the accuracy of the PI data reported during those periods, PI definitions and guidance

contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline,

Revision 6, dated October 2009, was used. The inspectors reviewed the licensees

operator narrative logs, issue reports, event reports, MSPI derivation reports, and NRC

Integrated IRs for the period of October 2010 through September 2011 to validate the

accuracy of the submittals. The inspectors reviewed the MSPI component risk

coefficient to determine if it had changed by more than 25 percent in value since the

previous inspection, and if so, that the change was in accordance with applicable NEI

guidance. The inspectors also reviewed the licensees issue report database to

determine if any problems had been identified with the PI data collected or transmitted

for this indicator. Documents reviewed are listed in the Attachment.

This inspection constituted two MSPI heat removal system samples as defined in

IP 71151-05.

b. Findings

No findings were identified.

42 Enclosure

.6 Mitigating Systems Performance Index - Cooling Water Systems

a. Inspection Scope

The inspectors sampled licensee submittals for the MSPI - Cooling Water Systems

performance indicator for Unit 1 and Unit 2 for the period from the fourth quarter of 2010

through the third quarter of 2011. To determine the accuracy of the PI data reported

during those periods, PI definitions and guidance contained in NEI 99-02, Regulatory

Assessment Performance Indicator Guideline, Revision 6, dated October 2009, was

used. The inspectors reviewed the licensees operator narrative logs, issue reports,

MSPI derivation reports, event reports and NRC Integrated Inspection Reports for the

period of October 2010 through September 2011 to validate the accuracy of the

submittals. The inspectors reviewed the MSPI component risk coefficient to determine if

it had changed by more than 25 percent in value since the previous inspection, and if so,

whether the change was in accordance with applicable NEI guidance. The inspectors

also reviewed the licensees issue report database to determine if any problems had

been identified with the PI data collected or transmitted for this indicator. Documents

reviewed are listed in the Attachment.

This inspection constituted two MSPI cooling water system samples as defined in

IP 71151-05.

b. Findings

No findings were identified.

.7 Mitigating Systems Performance Index - High Pressure Injection Systems

a. Inspection Scope

The inspectors sampled licensee submittals for the MSPI - High Pressure Injection

Systems performance indicator for Unit 1 and Unit 2 for the period from the fourth

quarter of 2010 through the third quarter of 2011. To determine the accuracy of the PI

data reported during those periods, PI definitions and guidance contained in NEI 99-02,

Regulatory Assessment Performance Indicator Guideline, Revision 6, dated

October 2009, were used. The inspectors reviewed the licensees operator narrative

logs, issue reports, MSPI derivation reports, event reports and NRC Integrated

Inspection Reports for the period of October 2010 through September of 2011 to validate

the accuracy of the submittals. The inspectors reviewed the MSPI component risk

coefficient to determine if it had changed by more than 25 percent in value since the

previous inspection, and if so, that the change was in accordance with applicable

NEI guidance. The inspectors also reviewed the licensees issue report database to

determine if any problems had been identified with the PI data collected or transmitted

for this indicator. Documents reviewed are listed in the Attachment.

This inspection constituted two MSPI high pressure injection system samples as defined

in IP 71151-05.

b. Findings

No findings were identified.

43 Enclosure

.8 Occupational Exposure Control Effectiveness

a. Inspection Scope

The inspectors sampled licensee submittals for the occupational radiological

occurrences PI for the period from the fourth quarter of 2010 through the 3rd quarter

of 2011. To determine the accuracy of the PI data reported during these periods, the

inspectors used PI definitions and guidance contained in NEI 99-02, Regulatory

Assessment Performance Indicator Guideline, Revision 6, dated October 2009. The

inspectors reviewed the licensees assessment of the PI for occupational radiation safety

to determine if indicator-related data was adequately assessed and reported. To assess

the adequacy of the licensees PI data collection and analyses, the inspectors discussed

with radiation protection staff, the scope, and breadth of its data review and the results of

those reviews. The inspectors independently reviewed electronic personal dosimetry

dose rate and accumulated dose alarms and dose reports and the dose assignments for

any intakes that occurred during the time period reviewed to determine if there were

potentially unrecognized occurrences. The inspectors also conducted walkdowns of

numerous locked high and very high radiation area entrances to determine the adequacy

of the controls in place for these areas. Documents reviewed are listed in the

Attachment.

This inspection constituted one occupational exposure control effectiveness sample as

defined in IP 71151-05.

b. Findings

No findings were identified.

.9 Radiological Effluent Technical Specification/Offsite Dose Calculation Manual

Radiological Effluent Occurrences

a. Inspection Scope

The inspectors sampled licensee submittals for the radiological effluent TS/ODCM

radiological effluent occurrences PI for the period from the fourth quarter of 2010 through

the third quarter of 2011. To determine the accuracy of the PI data reported during

these periods, the inspectors used PI definitions and guidance contained in NEI 99-02,

Regulatory Assessment Performance Indicator Guideline, Revision 6, dated

October 2009. The inspectors reviewed the licensees issue report database and

selected individual reports generated since this indicator was last reviewed to identify

any potential occurrences such as unmonitored, uncontrolled, or improperly calculated

effluent releases that may have impacted offsite dose. The inspectors reviewed

gaseous effluent summary data and the results of associated offsite dose calculations

for selected dates between the fourth quarter of 2010 through the third quarter of 2011 to

determine if indicator results were accurately reported. The inspectors also reviewed the

licensees methods for quantifying gaseous and liquid effluents and determining effluent

dose. Documents reviewed are listed in the Attachment.

44 Enclosure

This inspection constituted one Radiological Effluent TS/ODCM radiological effluent

occurrences sample as defined in IP 71151 05.

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems (71152)

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency

Preparedness, Public Radiation Safety, Occupational Radiation Safety, and

Physical Protection

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

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of

this report, the inspectors routinely reviewed issues during baseline inspection activities

and plant status reviews to verify that they were being entered into the licensees CAP at

an appropriate threshold, that adequate attention was being given to timely corrective

actions, and that adverse trends were identified and addressed. Attributes reviewed

included: the complete and accurate identification of the problem; that timeliness was

commensurate with the safety significance; that evaluation and disposition of

performance issues, generic implications, common causes, contributing factors, root

causes, extent-of-condition reviews, and previous occurrence reviews were proper and

adequate; and that the classification, prioritization, focus, and timeliness of corrective

actions were commensurate with safety and sufficient to prevent recurrence of the issue.

Minor issues entered into the licensees CAP as a result of the inspectors observations

are included in the attached List of Documents Reviewed.

These routine reviews for the identification and resolution of problems did not constitute

any additional inspection samples. Instead, by procedure they were considered an

integral part of the inspections performed during the quarter and documented in

Section 1 of this report.

b. Findings

No findings were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

In order to assist with the identification of repetitive equipment failures and specific

human performance issues for follow-up, the inspectors performed a daily screening

of items entered into the licensees CAP. This review was accomplished through

inspection of the stations daily condition report packages.

45 Enclosure

These daily reviews were performed by procedure as part of the inspectors daily plant

status monitoring activities and, as such, did not constitute any separate inspection

samples.

b. Findings

No findings were identified.

.3 Selected Issue Follow-Up Inspection: Licensee Issue Report on Auxiliary Feedwater

System Crosstie Modification

a. Inspection Scope

The inspectors performed a review of the item below that was identified by an NRC

inspector at a different but similar facility:

• Auxiliary Feedwater System Modification.

This review constituted one in-depth problem identification and resolution sample as

defined in IP 71152-05.

b. Findings

No findings were identified.

.4 Annual Sample: Review of Operator Workarounds

a. Inspection Scope

The inspectors evaluated the licensees implementation of their process used to identify,

document, track, and resolve operational challenges. Inspection activities included, but

were not limited to, a review of the cumulative effects of the operator workarounds

(OWAs) on system availability and the potential for improper operation of the system, for

potential impacts on multiple systems, and on the ability of operators to respond to plant

transients or accidents.

The inspectors performed a review of the cumulative effects of OWAs. The documents

listed in the Attachment were reviewed to accomplish the objectives of the inspection

procedure. The inspectors reviewed both current and historical operational challenge

records to determine whether the licensee was identifying operator challenges at an

appropriate threshold, had entered them into their CAP, and proposed or implemented

appropriate and timely corrective actions which addressed each issue. Reviews were

conducted to determine if any operator challenge could increase the possibility of an

Initiating Event, if the challenge was contrary to training, required a change from

long-standing operational practices, or created the potential for inappropriate

compensatory actions. Additionally, all temporary modifications were reviewed to

identify any potential effect on the functionality of Mitigating Systems, impaired access to

equipment, or required equipment uses for which the equipment was not designed.

Daily plant and equipment status logs, degraded instrument logs, and operator aids or

tools being used to compensate for material deficiencies were also assessed to identify

any potential sources of unidentified operator workarounds.

46 Enclosure

This review constituted one operator workaround annual inspection sample as defined in

IP 71152-05.

b. Findings

No findings were identified.

4OA3 Follow-Up of Events and Notices of Enforcement Discretion (71153)

.1 (Closed) Licensee Event Report 05000455/2011-001, Revision 0 and Revision 1, Unit 2

Emergency Diesel Generator Inoperable for Longer Than Allowed by Technical

Specifications Due to Inadequate Work Instructions

The Licensee Event Report (LER) involved a Unit 2 DG that was unknowingly inoperable

for approximately 6 months due to loose bolting on the upper lubricating oil cooler.

During a routine surveillance on November 17, 2010, a significant oil leak was identified

by the equipment operator. The DG was shut down before damage could occur. The

licensee determined that a bolted flanged connection was misaligned during

reinstallation following maintenance in January of 2010.

NRC Follow-Up inspection 05000455/2011011 determined that the issue was an

apparent violation and a White Finding (EA-11-014). The IR was issued February 11,

2011. On October 4, 2011, an NRC IP 95001 Supplemental IR was issued documenting

the closure of finding 05000455/2011011-01. As the enforcement actions have been

issued, and the Supplemental Inspection has been completed with no significant issues

identified, these LERs are closed.

.2 (Closed) Licensee Event Report 05000455/2011-002, Revision 0, Containment

Pressure Not Within Limits Longer than Allowed By Technical Specifications Due to

Personnel Error

The LER involved a licensee-identified mistaken plugging of a pressure sensor inside of

containment during the previous refueling outage. The plugged was placed during a

routine surveillance on September 28, 2011 and on October 13, 2011, licensee

personnel determined that while the instrument indicated that Unit 2 containment

pressure was within limits, that, in fact containment pressure was above the TS limit. A

containment entry was made, the plug was removed, containment pressure was reduced

and the peak pressure was determined to be approximately 1.91 pounds per square inch

gauge (psig). The TS allowed value was 1.0 psig and the amount of time that the

pressure could be above the limit was 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> with the plant required to be shut down

within the following 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br />. By the time the situation was identified, understood, and

corrected a total time of 95 hours0.0011 days <br />0.0264 hours <br />1.570767e-4 weeks <br />3.61475e-5 months <br /> and 48 minutes had elapsed.

The licensee determined and the inspectors verified that the licensees safety margin

between peak containment pressure and the initial maximum allowed pressure was

10 psig. The technicians error and the delay in correcting the error resulted in 0.91 psig

of the 10 psig margin being used. There was a minor adverse safety consequence due

to the licensee personnels error.

The technicians error identified by the licensee resulted in a minor failure to comply with

TS 3.6.4, Containment Pressure. This LER is closed.

47 Enclosure

4OA6 Management Meetings

.1 Exit Meeting Summary

On January 12, 2012, the inspectors presented the inspection results to Mr. B. Youman,

and other members of the licensee staff. The licensee acknowledged the issues

presented. The inspectors confirmed that none of the potential report input discussed

was considered proprietary.

.2 Interim Exit Meetings

Interim exits were conducted for:

• The results of an Operator Licensing inspection with the Lead Operations Training

staff instructor, Mr. M. McCue, via telephone on December 8, 2011.

• The results of an annual review of Emergency Action Level and Emergency Plan

changes with the Emergency Preparedness Coordinator, Mr. R. Kartheiser, via

telephone on December 7, 2011.

• The results of Occupational and Public Radiation Safety programs inspections

with the Site Vice President, Mr. T. Tulon, on November 10, 2011 and with the

Acting Plant Manager, E. Hernandez, on December 28, 2011.

The licensee acknowledged the issues presented. The inspectors confirmed that none

of the potential report input discussed was considered proprietary. Proprietary material

received during the inspection was returned to the licensee.

4OA7 Licensee-Identified Violations

The following violation of very low safety significance was identified by the licensee. The

violation met the criteria of Section VI of the NRC Enforcement Policy for being

dispositioned as a Non-Cited Violation.

.1 Effluent Monitors Alarms Setpoints Incorrectly Established

Technical Specification 5.5.1 states that the ODCM shall contain the methodology and

parameters used in the calculation of offsite doses resulting from radioactive gaseous

and liquid effluents, and in the calculation of gaseous and liquid monitoring alarm and

trip setpoints.

Contrary to the above, on August 26, 2010, the licensee identified a potential for

non-conservative alarm setpoints for effluent monitors. Subsequently, the licensee

calculated new setpoints for these monitors using the methodology prescribed in the

ODCM and determined that the previous alarm setpoints were incorrectly established

and were non-conservative (too high). The inspectors determined that this finding was

of more than minor significance because it was similar to Example 6.c in IMC 0612,

Appendix E, Example of Minor Issues. Specifically, the effluent monitors with its alarm

set points would have failed to perform its intended function (i.e., trip or isolation

function) to prevent an instantaneous effluent release in excess of the applicable TS

instantaneous dose rate limits for gases. In accordance with IMC 0609, Appendix D,

48 Enclosure

Public Radiation Safety, the inspectors determined the violation to be of very low safety

significance, (Green) because the dose impact to a member of the public from the

radiological release was less than the dose values in Appendix I to 10 CFR Part 50 and

10 CFR 20.1301(e). This violation of TS 5.5.1 is being treated as a NCV consistent with

Section 2.3.2 of the NRC Enforcement Policy. The licensee entered this issue into their

CAP as IR 1106461.

ATTACHMENT: SUPPLEMENTAL INFORMATION

49 Enclosure

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

T. Tulon, Site Vice President

B. Youman, Plant Manager

D. Coltman, Operations Manager

J. Feimster, Design Engineering Manager

D. Damptz, Acting Maintenance Director

S. Swanson, Nuclear Oversight Manager

R. Gayheart, Training Director

B. Barton, Radiation Protection Manager

K. Anderson, Acting Radiation Protection Manager

A. Creamean, Chemistry Manager

D. Gudger, Regulatory Assurance Manager

R. Cameron, Licensed Operator Requalification Lead

Nuclear Regulatory Commission

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

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000454/2011005-001 NCV Failure to Identify Voided Sections of AF Piping

(Section 1R15)05000455/2011005-001 NCV Failure to Identify Voided Sections of AF Piping

(Section 1R15)05000454/2011005-002 NCV High Energy Line Break Operability Evaluation

(Section 1R15)05000455/2011005-002 NCV High Energy Line Break Operability Evaluation

(Section 1R15)05000454/2011005-003 URI Use of TLDs May Not be Consistent with the Methods

Used by the NVLAP Accreditation Process (Section 2RS4)05000455/2011005-003 URI Use of TLDs may not be consistent with the methods used

by the NVLAP accreditation process (Section 2RS4)05000454/2011005-004 NCV Failure to Identify Hazardous Materials on Transportation

Manifest (Section 3RS8)

1 Attachment

Closed

05000455/2011011-00 LER Unit 2 Emergency Diesel Generator Inoperable for

Longer Than Allowed by Technical Specifications

Due to Inadequate Work Instructions, Revision 0

05000455/2011011-01 LER Unit 2 Emergency Diesel Generator Inoperable for

Longer Than Allowed by Technical Specifications

Due to Inadequate Work Instructions, Revision

2 Attachment

LIST OF DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection. Inclusion on this list does

not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that

selected sections of portions of the documents were evaluated as part of the overall inspection

effort. Inclusion of a document on this list does not imply NRC acceptance of the document or

any part of it, unless this is stated in the body of the inspection report.

Section 1R01: Adverse Weather Protection (Quarterly)

- IR 1067880; Byron 2010/2011 Winter Readiness Critique, March 30, 2011

- IR 1186291; 2010/2011 Winter Readiness Critique, March 11, 2011

- IR 1193076; Action Tracking Process Versus Work Control Process, December 2, 2010

- IR 1238947; SX Chemical Feed Lines Need Insulating, July 12, 2011

- IR 1262839; Winter Readiness Work Rescheduled, September 14, 2011

- IR 1265348; Unable to Resolve Parts Required Issue, September 14, 2011

- IR 1265934; Winter Readiness Challenge - No CST Heaters Available, September 21, 2011

- IR 1280434; Switchyard Winter Readiness PM, October 24, 2011

- IR 1280750; Freeze Protection - CWPH Louvers LV48, 142 Stuck Open, October 24, 2011

- IR 1280755; Freeze Protection - Electric Heater 0VV37C Fan Motor, October 24, 2011

- IR 1280755; Freeze Protection: Electric Heater 0VV37C Fan Motor, October 24, 2011

- IR 1280757; 0VH09Y - Damper Stuck Open, October 24, 2011

- IR 1281870; Roof Access Hatch Will Not Remain Closed, October 26, 2011

- IR 1285676; Winter Readiness Walkdown, November 2, 2011

- IR 1286684; 0VT17J LV-82 Has a Louver Broke Preventing Set From Closing,

November 5, 2011

- IR 1286686; 0VT11J LV-8 Has a Set of Louvers Not Fully closed, November 5, 2011

- IR 1286687; 0VT16J LV-80 Has a Broken Louver Preventing Set From Closing,

November 5, 2011

- IR 1286688; 0VT13J LV-17 Has 2 Sets of Louvers Not Fully Closed, November 5, 2011

- IR 1286689; 0VT18J LV-83 Has Broken Louvers Preventing Set From Closing,

November 5, 2011

- IR 1286693; 0VT20J LV-86 Sets of Louvers Not Fully Closed, November 5, 2011

- IR 1286904; 0VT07J LV-4 Has Broken Louvers, November 5, 2011

- IR 1286907; 0VT08J LV-5 Has 2 Sets of Louvers Not Fully Closed, November 5, 2011

- IR 1286908; 0VT10J LV-7 Has One Broken Louver, November 5, 2011

- IR 1286910; 0VT14J LV-18 Has a Set of Louvers Not Fully Closed, November 5, 2011

- IR 1286912; 0VT12J LV-9 Has Broken Louvers and Sets Not Fully Closed, November 5, 2011

- IR 1289988; Freeze Protection Concern, November 13, 2011

- IR 1293508; Winter Readiness System Review Work Removed From 2011,

November 15, 2011

- IR 1297625; 0BOSR XFT-A1, SH Area Heaters Testing Discrepancies, December 3, 2011

- Unit 2 Standing Order; Station Heat Coil Degradation in Unit 2 VA Plenum, Log #11-053

- 0BOSR XFT-A1; Freezing Temperature Equipment Protection SH and Department Support

Requirements, Revision 13

- 0BOSR XFT-A3; Freezing Temperature Equipment Protection Plant Ventilation Systems,

Revision 8

- 0BOSR XFT-A4; Freezing Temperature Equipment Protection Area Buildings Ventilation

Systems and Tanks, Revision 7

- 0BOSR XFT-A5; Freezing Temperature Equipment Protection Non-Protected Area Buildings

Ventilation Systems, Revision 6

3 Attachment

- BOP XFT-1; Cold Weather Operations, Revision 2

- IR 1298335; 0BOSR XFT-A3 Freezing Temperature Protection Discrepancies,

December 05, 2011

Section 1R04: Equipment Alignment (Quarterly)

- Drawing M-62; Diagram of Residual Heat Removal, Revision BD

- BAP 300-1A1; At The Controls Area, Revision 52

- BOP RH-E2A; Unit 2 Residual Heat Removal System Train A Electrical Lineup, Revision 4

- BOP RH-M2A; Unit 2 Residual Heat Removal System Train A Valve Lineup, Revision 10

- IR 0332862; 1B AF Pump Air Box Leakage, May 07, 2005

- IR 1289049; Fireproofing on Column Outside 1B AF Pump Room Degraded,

November 10, 2011

- IR 1299293; AF005 Flow Control Valve Trim Clearance Low Margin Issue,

November 21, 2011

IR 1304078; Fire Drill Observation - SCBA Voice Amplifiers Not Working, December 17, 2011

- EC 355468; Evaluation of Diesel Driven Auxiliary Feedwater Air Box Gaps, Revision 0

- SPEC. L-2722 Proposed Seal for 2AB-1086 Unit 2; Sheet Numbers 1A, 1, 2, and 3, Revision 1

Section 1R04: Complete System Walkdown (Semi-Annual)

- BOP AF-M2B; Auxiliary Feedwater Train B Valve Lineup, Revision 4

Section 1R05: Fire Protection (Quarterly)

- IR 1076490; Fire Damper 2VE04Y Access Door Hinge Tack Welds Broken, May 28, 2011

- IR 1075765; Electro-Thermo-Link Separated, June 1, 2010

- IR 1077737; Need CO2 OSS for 2 ICSRs on the T.S. Fire Tamper Surveillance, June 7, 2010

- IR 1072592; 2VD23YA Flexible Conduit Support Clip not Holding Conduit, May 24, 2010

- IR 1072640; Debris in Tray Below Damper 2VD63Y, May 24, 2010

- IR 1073509; Flexible Conduit Loose at Upper, South ETL on Fire Damper, May 26, 2010

- IR 1081618; Difficult to Access Damper, 1VE06Y for Surveillance/Repair, June 17, 2010

- IR 1289049; Fireproofing on Column Outside 1B AF Pump Room Degraded,

November 10, 2011

- IR 1250346; Fire Brigade Leader Training Issue, August 12, 2011

- Fire Drill Scenario No. 11-04; Unit 1 Auxiliary Boiler Room Fire, September 16, 2011

- Pre-Fire Plan; Fire Area/Zone - FZ 8.3-1 Southeast, Revision 1

- EC 350613; Evaluation of Fire Damper S-Hook Orientation Impact on Dampers 2VD24&B,

VC191Y, and 0VC193Y, Revision 0

- WO 1197473; Tech Spec Fire Damper 18-Month Visual Inspection, December 3, 2009

- WO 1028736; Tech Spec Fire Damper 18-Month Visual Inspection, August 4, 2008

- WO 1124519; Tech Spec Fire Damper 18-Month Visual Inspection, April 14, 2008

- WO 0848826; Tech Spec Fire Damper 18-Month Visual Inspection, December 15, 2006

- 0BMSR 3.10.g.7; TRM Fire Damper 18-Month Visual Inspection, Revision 13

- IR 1304076; Fire Drill Observation - Personnel Walking Through SIM Smoke,

December 17, 2011

- RM-AA-101; Records Management Program, Revision 9

- OP-AA-201-003; Fire Drill Performance, Revision 12

4 Attachment

Corrective Action Documents As a Result of NRC Inspection

IR 1291986; NRC Identified Fire Damper S-Hook Orientation Issue, November 17, 2011

IR 1304063; NRC Identified Issues with S-Hooks Not Resolved, December 17, 2011

Section 1R12: Maintenance Effectiveness (Quarterly)

- IR 1058790; Bad Fuse Found in 2RD06J Panel, April 20, 2011

- IR 1061760; MG Set Motor Smoked on Attempted PM Start, April 26, 2011

- IR 1062164; Motor Cutoff Switch Replaced for 2RD 05E-1B, April 27, 2011

- IR 1065922; Unit 2 Rods Will Not Manually Withdraw, May 5, 2010

- IR 1066455; Unit 2 RD07J Cabinet Capacitor Found Broken, May 6, 2011

- IR 1066490; 2A RD MG Set 1 OVT Timer Failed, May 6, 2011

- IR 1067031; Vibrations Levels on 2B Rod Drive MG Set Remain Unchanged, May 8, 2011

- IR 1290831; 1A RD MG Set Increased Vibrations, November 15, 2011

- BOP RD-5; Control Rod Drive MG Set Up and Paralleling to Operating Control Rod Drive MG

Set, Revision 10

Section 1R13: Maintenance Risk Assessments and Emergent Work Control (Quarterly)

- ER-AA-600-1042; On-Line Risk Management, Revision 7

- ER-AA-600-1021; Risk Management Application Methodologies, Revision 4

- PC-AA-1014; Risk Management, Revision 2

- 0BOA ENV-1; Adverse Weather Conditions Unit 0, Rev. 108

- 1BOA ENV-1; Adverse Weather Conditions Unit 0, Rev. 102

- 0BOA ENV-2; Rock River Abnormal Water Level Unit 0, Rev. 100

- IR 1285254; Rock River Level Low, November 2, 2011

Section 1R15: Operability Evaluations (Quarterly)

- IR 240597; Unplanned LOCAR Entry for 2A Emergency Diesel Generator Due to 2VD024YB

Damper

- IR 240972; Fire Damper S Hook Installed Improperly, August 2, 2004

- IR 240985; Need Work Request for Fire Damper Inspections, August 2, 2004

- IR 248940; Fire Damper Issues Identified by NRC, August 31, 2004

- IR 249486; Fire Damper S Hook Issue Identified by NRC, September 2, 2004

- IR 297682; NRC Question About Fire Damper S-Hooks, February 4, 2005

- IR 757875; Fire Damper S-Hooks, April 1, 2008

- IR 1285361; Potential Multiple Starts of Diesel Driven AF Pump, November 2, 2011

- IR 1291986; NRC Identified Fire Damper S-Hook Orientation Issue, November 17, 2011

- IR 1292337; Piping Between 2AF006B and 2AF017B Found Not Full, November 18, 2011

- IR 1295958; AF Improvement Suggestion, November 18, 2011

- IR 1295958; AF Improvement Suggestion, November 18, 2011

- IR 1295488; EOC Review of Byron IP 1291986 Fire Damper S-Hooks, November 29, 2011

- Three Mile Island Corrective Action Program Number TI999-0943 linked to ETTS # 25169;

One Section of Fire Damper AH-FD-22 Did Not Close During Test, October 1, 1999

- EC 350613; Evaluation of Fire Damper S-Hook Orientation Impact on Dampers 2VD24YB,

VC191Y and OVC193Y, August 11, 2004

- EC 350550; Evaluation of Fire Damper S-Hook Orientation Impact, August 31, 2004

- WO 1197473 01; Technical Specification Fire Damper 18 Month Visual Inspection,

December 3, 2009

5 Attachment

- EC 383229; Fill Empty Pipe Between 1AF006A and 1AF017A, Close Drain Valve 1AF018A,

and Throttle Open Vent Valve 1AF030A, Revision 0

- EC 383308; OP EVAL 11-003, Small Voids in 2A and 2B SX to AF Suction Piping, Revision 0

- EC 386578; OP Evaluation 11-009 Multiple Starts of Diesel AF Pump, November 8, 2011

- WO 1124519 01; Technical Specification Fire Damper 18 Month Visual Inspection,

April 14, 2008

- WO 848828 01; Technical Specification Fire Damper 18 Month Visual Inspection,

December 15, 2006

- BOP AF-3, Filling and Venting the Auxiliary Feedwater System, Revision 4

- M-1FW01147X; Drawing, Byron Unit 1 Support M-1FW01147X, Rev. D

- M-1SI06010X; Drawing, Byron Unit 1 M-1SI06010X Sub. E

- 13.1.29; Calculation for Mechanical Component Support M-1SI06010X, Rev. D

- 13.1.29; Calculation for Mechanical Component Support M-1SI06010X, Rev. E

- 13.1.29; Calculation for Mechanical Component Support M-1SI06025V, Rev. F

- 13.1.29-BYR97-359; 1SI06010X, 1SI06012X, 1SI06031X, 1SI06075X, 1SI06105X, and

1SI06155X. Evaluate Subsystem 1SI06 Supports for Additional Loads, Rev. 5

- 14.1.18-1FW01147; Calculation for Mechanical Component Support Number M-1FW01147X,

Rev. 0

- IR 1272187; Issues Applicable to Byron from Braidwood Mod/50.59 Inspection,

October 4, 2011

- BRW-97-0827-M; Piping Evaluation for Lead Shielding on Subsystem 2SI06, Rev. 0

- RH-2; Large Bore Isometric, Residual Heat Removal System, Rev. 22

- IR 1276280; UFSAR Section 3.6 and Piping Design Specifications are Inconsistent,

October 13, 2011

- IR 1276069; 1/2FW01 Piping Calculation Revisions Do Not Meet UFSAR Requirements,

October 13, 2011

- IR 1272834; Incorrect Coding of Support Skew on 1FW01 Piping, October 5, 2011

- EMD-064195; Calculation, Addendum E to Piping Stress Report for Subsystem 1SI06, Rev. 5

- IR 1262559; BOP ID: Small Shift Trend in Major Plant Parameters, September 13, 2011

- IR 1265515; U1 RX Power Lowered Below 99.5% for LEFM Troubleshooting,

September 16, 2011

- IR 1253439; LEFM Computer Point Is Off Normal Per 1BOSR CX-M1, August 19, 2011

- IR 1263929; LEFM Alarms in IR 1241271 and Card Analysis- OEM Review Results,

September 16, 2011

- IR 1241271; LEFM Trouble Alarm - Ramp Back, July 19, 2011

- IR 1241629; LEFM Trouble Alarm Causing Unit 1 Ramp Back Again, July 19, 2011

- IR 1277627; NRC Questions on HELB - Presence of Openings, October 17, 2011

- IR 1279759; Added Scope to Turbine Building HELB Effort, October 21, 2011

- IR 1244251; HELB Discussion with the NRC Residents, July 26, 2011

- IR 1240295; Two New Line Break Locations Identified During HELB Analysis, July 15, 2011

- IR 1238611; Inoperability of ESF Components Due To HELB, July 11, 2011

- IR 1237133; Non-Conservatism in Turbine Building HELB Analysis, July 6, 2011

- IR 1184258; Non-Conservatism in Turbine Building HELB Analysis, March 7, 2011

- IR 1276895; NRC Question - Effect of Turbine Building HELB on Reactor Trip Breakers,

October 14, 2011

Section 1R19: Post Maintenance Testing (Quarterly)

- IR 1272802; 2B CS Pump Did Not Auto Start During 2B DG Sequence Test, October 5, 2011

- WO 1476986 02; 2B CS Pump Did Not Auto Start During 2B DG Sequence Test,

October 5, 2011

6 Attachment

- WO 1476986 03; 2B CS Pump Did Not Auto Start During 2B DG Sequence Test,

October 5, 2011

- ER-AA-1200; Critical Component Failure Clock, Revision 7

- WO 1324847; 2AF014E IST Disassembly and Inspection, October 5, 2011

- WO 1324407; 2AF014G IST Disassembly and Inspection, October 5, 2011

- WO 1365478; 2AF014H IST Disassembly and Inspection, October 5, 2011

- 2BOSR 7.5.7-2; Unit 2 Train B Auxiliary Feedwater Flow Path Operability Surveillance

Following Shutdown, Rev. 6

- IR 1272927; 2B AF Static Pressure Gauge Indication Failed Low, October 5, 2011

- 2BOSR 0.5-2.RH.4-1; Unit 2 ASME Surveillance Requirements for Residual Heat Removal

Pump Miniflow Valve 2RH610, Revision 5

Section 1R20: Refueling and Other Outage Activities

- 2BGP 100-1; Plant Heatup, Revision 50

- 2BGP 100-2; Plant Startup, Revision 40

- 2BGP 100-3; Power Ascension, Revision 73

Section 1R22: Surveillance Testing (Quarterly)

- IR 128875; Error in RCS Leakrate Data in MCR Logs, November 10, 2011

- BOP AF-1; Diesel Driven Aux Feedwater Pump Alignment to Standby Condition, Revision 24

- BOP AF-7; Diesel Driven Auxiliary Feedwater Pump 1B Startup on Recirc, Revision 37

- BOP AF-7T1; Diesel Driven Auxiliary Feedwater Pump Operating Log, Revision 21

- BOP AF-8; Diesel Driven Auxiliary Feedwater Pump 1B Shutdown, Revision 22

- WO 1459476 01; 1AF01PB Group B IST Requirements for Diesel Driven AF Pump,

October 28, 2011

- 1BOSR 7.5.4-2; Unit 1 Diesel Driven Auxiliary Feedwater Pump Monthly Surveillance,

Revision 14

- 2BOSR 8.1.11-2; 2B Diesel Generator Sequencer Test 18 Month, Revision 11

- WO 1337989 01; 2B Diesel Generator Sequencer Test, October 5, 2011

- IR 1281160; 1SI8958B Failed Acceptance Criteria During 1B RH PP IST, October 25, 2011

- IR 1298289; Unit 2 RCS Leakrate Surveillance Needs Improvements, December 05, 2011

- 0BMSR FP-5; Fire Hydrant Yard Loop Annual Flush, Revision 8

- WO 1454082; 1RH01PB Group A IST Requirements for Residual Heat Removal Pump,

October 25, 2011

- IR 1281160; 1SI8958B Failed Acceptance Criteria During 1B RH PP IST, October 25, 2011

Corrective Action Documents As a Result of NRC Inspection

- IR 1304054; Surveillance Improvements Needed, December 17, 2011

2RS1: Radiological Hazard Assessment and Exposure Controls (71124.01)

- AR 1214604; NOS ID B1R17 RP Outage Adverse Trend; 5/11/2011

- AR 1243013; RP Response to Fire Alarm Did Not Meet Expectations; 7/22/2011

- AR 1248312; NOS ID Poor Contamination Boundary Controls in FHB; 8/5/2011

- BRP 5800-3; Area Radiation Monitoring System Alert/High Alarm Setpoints; Revision 25

- BRP 5820-14; Process Radiation Monitoring System Alert/High Alarm Setpoints; Revision 42

- RP-AA-460; Controls for High and Locked High Radiation Areas; Revision 20

- RP-AA-460-001; Controls for Very High Radiation Areas; Revision 2

7 Attachment

- RP-AA-460-003; Access to HRAs/LHRAs in Response to a Potential or Actual Emergency;

Revision 1

- RP-AP-460; Access to Reactor In-Core Sump Area; Revision 2

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

- Work Order 1094446 01; Non Accessible Charcoal Adsober Operability Test; 8/31/2009

- Work Order 1149597 01; Perform Recirc Charcoal Halide Test Control Room Ventilation

System; 3/16/2010

2RS4: Occupational Dose Assessment (71124.04)

- National Voluntary Laboratory Accreditation Program; Selected Records; Various Dates

2RS5: Radiation Monitoring Instrumentation (71124.05)

- AR 1106461; Non-Conservative Liquid Discharge Alarm Setpoints; 8/26/2010

- AR 1107149; Additional Investigation Required for ODCM/LCO Implementation; 8/29/2010

- AR 1302586; Non-Conservative Setpoints Found for TRM Rad Monitors; 12/14/2011

- AR 1303888; Potential RETS Impact Due to Non-Conservative PRM Setpoints; 12/16/2011

- BRP 5800-3; Area Radiation Monitoring System Alert/High Alarm Setpoints; Revision 25

- BRP 5820-12; Response to Area and Process Radiation Monitor LCOARS or Out of Service

Conditions; Revision 28

- BRP 5820-14; Process Radiation Monitoring System Alert/High Alarm Setpoints; Revision 42

- BYR-10-001; Calculation of Liquid Process Radiation Monitor Set Points; 8/30/2010

- RP-BR-951; Set Point Changes for Process Radiation Monitors; ODCM (Effluent) Monitors;

Revision 0.

2RS6: Radioactive Gaseous and Liquid Effluent Treatment (71124.06)

- 2009 Byron Station Annual Radioactive Effluent Release Report; April 30, 2010

- 2010 Byron Station Annual Radioactive Effluent Release Report; April 29, 2011

- AR 00978684; Effluent Monitor Surveillance Not Performed Per Procedure; dated October 13,

2009

- AR 00996917; Effluent Release Process - Potential Gaps; dated November 22, 2009

- AR 01106461; Non-Conservative Liquid Discharge Alarm Setpoints; dated August 26, 2010

- AR 01107146; Additional Investigation Required for ODCM/LCO Implementation; dated

August 29, 2010

- AR 01108146; Treatment of Ar-41 in Gaseous Effluents; dated August 31, 2010

- AR 1247902; 1/2 RE-PR-028 Particulate Filters Could Not Be Located; 8/4/2011

- BCP-400-TWX01; Liquid Radwaste Release from Release Tank OWX01T; Revision 59

- CY-AA-120-400; Closed Cooling Water Chemistry; Revision 13

- CY-AA-120-420; Auxiliary Boiler Chemistry; Revision 10

- CY-AA-130-201; Radiochemistry Quality Control; Revision 1

- CY-AA-170-000; Radioactive Effluent and Environmental Monitoring Programs; Revision 5

- CY-BY-170-301; Offsite Dose Calculation Manual; Revision 6

- CY-BY-170-301; Offsite Dose Calculation Manual; Revision 7

- FASA 1013272; Radioactive Gaseous and Liquid Effluents (RETS); 9/17/2010

- FASA 831375; Radioactive Gaseous and Liquid Effluents (RETS); 3/31/2009

- Gaseous Discharge Permit Number 110411; dated October 13, 2011

- Gaseous Discharge Permit Number 110445; dated October 31, 2011

8 Attachment

- Liquid Discharge Permit Number 110437; dated October 25, 2011

- RP-BY-900-1PR29J; 1PR29J Process Radiation Monitor Radiological Air Sampling;

Revision 2

- RP-BY-900-2PR29J; 2PR29J Process Radiation Monitor Radiological Air Sampling;

Revision 2

- Work Order 1110220 01; Fuel Handling Building Exhaust Charcoal Adsorber Bank Operability

Test; 12/21/2009

- Work Order 1236016 01; Perform Calibration of Rad Monitor 1PR28J; 1/18/2011

- Work Order 1249358 01; Perform Surveillance Test of 2PR28J; 4/26/2011

2RS7: Radiological Environmental Monitoring Program (71124.07)

- 2009 Byron Station Annual Radiological Environmental Operating Report; May 2010

- 2010 Byron Station Annual Radiological Environmental Operating Report; May 2011

- 2010 Land Use Census; dated August 30, 2010

- AR 00958298; ODCM Vent Stack Coordinates Inaccurate; dated August 27, 2009

- AR 01034880; REMP Milk Sample - Invalid Result; dated February 24, 2010

- AR 01090911; REMP Groundwater Sample Location No Longer Participating; dated July 15,

2010

- AR 01122156; REMP Sample Results above Detection Limit; dated October 5, 2010

- AR 01129610; Check-In Self-Assessment on the Radiological Environmental Monitoring

Program (REMP); Approved June 20, 2011

- AR 01223226; REMP Air Samples - Positive Detects for I-131; dated June 1, 2011

- Environmental, Inc. Sampling Manual, Revision 13

2RS8: Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,

and Transportation (71124.08)

- AR 1015646; Non-Conforming Waste Found in Radwaste Shipment; 1/12/2010

- AR 1067394; Non-Conforming Radioactive Waste in Shipment; 5/10/2010

- AR 1173307; RWS10-013 Contained Unapproved Mixed Waste; 2/10/2011

- AR 1221229; RWS11-006 Contained Un-Manifested Asbestos; 5/26/2011

- AR 1231158; RWS11-001 Manifested for Material Not Present; 6/21/2011

- AR 1233858; NOS ID: Cause of IR Incorrect RW Shipping Paperwork Not Identified;

6/28/2011

- AR 1250262; NOS ID: RP Failed to Address NOS Issues - Finding; 8/11/2011

- AR 1270337; Sea/Land Inventory Not Documented in Accordance with T&RM; 9/30/2011

- AR 1285148; QHPI Request for RP - RWS Manifest; 11/2/2011

- AR 1285591; NRC Identified: DAW Container Inspections Outside of Procedure Guidance;

11/3/2011

- AR 928393; Non-Conforming Metal Shipped to Bear Creek Processing; 6/5/2009

- Course Code N-RPCTAR; DBIG RAM Shipping/Inspection; Revision 0

- FASA 9866572-03; Radioactive Solid Waste Processing and Radioactive Material Handling,

Storage and Transportation; 4/26/2011

- Letter BYRON-2008-0123; Report of Changes, Tests, and Experiments; 12/12/2008

- Letter BYRON-2010-0147; Report of Changes, Tests, and Experiments; 12/13/2010

- Module/LP ID RPTI 8.05; Radioactive Material Shipments; Revision 18

- NOSA-BYR-10-04 (AR 969170); Chemistry, Radwaste, Effluent and Environmental Monitoring

Audit Report; 6/2/2010

- NOSA-BYR-11-06 (AR 1130876); Radiation Protection; 8/18/2011

9 Attachment

- Performance Training and Evaluation; Task 509-004; Provide Radiological Protection

Coverage During the Preparation of a Shipment of Radioactive Material; 11/5/2009

- Performance Training and Evaluation; Task 509-010; Perform Surveys on Radioactive

Material Transport Vehicles; date not provided

- Performance Training and Evaluation; Task 509-013; Receipt Survey of Radioactive Material;

- Radiation Protection Technician/Continuing Training; DBIG: Waste Acceptance Guidelines;

Revision 0

- RP-AA-100; Process Control Program for Radioactive Wastes; Revision 7

- RP-AA-600; Radioactive Material/Waste Shipments; Revision 12

- RP-AA-600-1001; Exclusive Use and Emergency Response Information; Revision 6

- RP-AA-600-1003; Radioactive Waste Shipments to Barnwell and Defense Consolidation

Facility (DCF); Revision 7

- RP-AA-600-1004; Radioactive Waste Shipments to Energy Solutions Clive Utah Disposal Site

Containerized Waste Facility; Revision 9

- RP-AA-600-1005; Radioactive Material and Non Disposal Site Waste Shipments; Revision 12

- RP-AA-601; Surveying Radioactive Material Shipments; Revision 13

- RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 01/20/2011

- RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 06/02/2011

- RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 10/03/2009

- RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 10/19/2010

- RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 2/17/2010

- RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 8/18/2010

- RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 9/16/2011

- RP-AA-605 Attachment 2; Waste Stream Results Review; DAW; 1/20/2011

- RP-AA-605 Attachment 2; Waste Stream Results Review; DAW; 3/30/2011

- RP-AA-605 Attachment 2; Waste Stream Results Review; DAW; 4/18/2010

- RP-AA-605 Attachment 2; Waste Stream Results Review; Primary Resin; 3/10/2010

- RP-AA-605 Attachment 2; Waste Stream Results Review; Secondary Radwaste Filter;

4/24/2010

- RP-AA-605 Attachment 2; Waste Stream Results Review; Secondary Resin; 3/25/2010

- RP-AA-605; 10 CFR Part 61 Program; Revision 4

- Shipment RMS09-094; Rx Vessel Dosimetry; Type A Package; 11/18/2009

- Shipment RMS11-078; Dirty Laundry; Low Specific Activity (LSA-II); 4/27/2011

- Shipment RWS10-011; Dewatered Bead Resin; Low Specific Activity (LSA-II); 6/29/2010

- Shipment RWS10-012; DAW Trash; Low Specific Activity (LSA-II); 9/1/2010

- Shipment RWS10-013; DAW Trash and TR Pond Sludge; Low Specific Activity (LSA-II);

9/1/2010

Section 4OA1: Performance Indicator Verification (71151)

- IR 1139610; Potential Non-Conservative Tech Specs for Component Cooling;

November 12, 2010

- IR 1139728; CC System OLR Impact From IR 1139610; November 12, 2010

- IR 1141591; 2A DG Emergency Stopped Due to Oil Leak; November 17, 2010

- IR 1158910; RH System Issue Resulting in LER - Tracking; January 05, 2011

- IR 1128409; Threshold for SSFF Approaching White Region; June 14, 2011

- IR 1284054; Legacy Issues with Main Steam Tunnel Pressurization Calculation;

October 31, 2011

- LS-AA-2080; NRC Safety System Functional Failure - July 2010 to July 2011, Revision 4

- EC 382262; Byron OpEval #10-006 - U-0 CC Pump Potential Non-Conservative Tech Spec

10 Attachment

- LER 454/2010-001; Technical Specifications Allowed Outage Time Extension Request for

Component Cooling System Contained Inaccurate Design Information that Significantly

Impacted the Technical Justification, November 12, 2010

- LER 454/2011-001; Potential Loss of Residual Heat Removal System Safety Function in Mode

4 When Aligned for Shutdown Cooling Due to Potential for Flashing or Voiding of Coolant

During a Shutdown Loss of Cooling Accident, January 5, 2011

- LER 455/2011-001; Unit 2 Emergency Diesel Generator Inoperable for Longer than Allowed

by Technical Specifications Due to Inadequate Work, November 17, 2011

- NEI 99-02 Revision 6; Regulatory Assessment Performance Indicator Guideline, October 2009

- Reactor Oversight Program MSPI Basis Document Revision 3; December 2006

- Monthly Data Elements for NRC Reactor Coolant System (RCS) Specific Activity, October

2010 - September 2011

- PWR High Pressure Safety Injection Function, October 2010 - September 2011

- Residual Heat Removal Function, October 2010 - September 2011

- PWR Auxiliary Feedwater/Emergency Feedwater Function, October 2010 - September 2011

- Cooling Water Support Function, October 2010 - September 2011

- IR 1154673; Unable to Perform Manual Stroke Surveillance of 1SX150A, December 20, 2010

- IR 1152376; Unit 2 CWS MSPI Exelon At-Risk, December 14, 2010

- IR 1263487; CWS2 (SX) MSPI Low Margin, September 15, 2011

- IR 1090691; Unit 1 CWS MSPI At-Risk, July 14, 2010

- Monthly Data Elements for NRC Unplanned Power Changes Per 7000 Critical Hours, June

2010 - October 2011

- IR 1259684; Byron PI in Variance - P.8.1.2 Unplanned Power Changes, September 6, 2011

- IR 1116305; Runback of Byron Station U-1 Due to 1A FW PP Trip, September 22, 2010

Section 4OA2: Identification and Resolution of Problems (71152)

- IR 1271650; Difference Between Byron & Braidwood PPC Point Calcs Y2021 & Y2022

- IR 1282689; Pin Hole Leak in Area 7 on 2RY8028 P-44

- IR 1289655; IR Indicates DG Fire Pump Started in Over Ride for Test CCP,

November 04, 2011

- 2BwOSR 3.8.1.14-2; 2B DG 24 Hour Endurance Run, Revision 5

- WO 1323726; 2B DG 24 Hour Endurance Run 18 Month, September 13, 2011

- Analysis BYR11-036; Turbine Building HELB and Room Heat Up Analyses for MUR PU,

Revision 0

- EC 383599; Op Eval 11-005, Turbine Building HELB Analysis Input Errors, Revision 1

- OWA Board Meeting Minutes; Year 2010 Quarter 4, December 28, 2010

- OWA Board Meeting Minutes; Year 2011 Quarter 1, April 5, 2011

- OWA Board Meeting Minutes; Year 2011 Quarter 2, June 30, 2011

- OWA Board Meeting Minutes; Year 2011 Quarter 3, October 14, 2011

- OWA Related IRs; 4Q2010 - 3Q2011

- IR 806396; Both Units SD Systems Degraded for >5 Years, August 12, 2008

- IR 1007239; Review SJAE Strainer Plugging for OWA/OC, December 18, 2009

- IR 1106359; Common Cause - Recommend Venting SD During Stroke Time Surveillance,

August 26, 2010

- IR 1118055; 2A Main Feed Pump Recirc Not Modulating Properly, September 26, 2010

- IR 1122751; Missed Fire Watches in the Past, October 06, 2010

- IR 1151298; Unit 1 Tower Overflow, December 12, 2010

- IR 1155725; Caustic Dilution Flow Only Reading 6 GPM, December 24, 2010

- IR 1158940; Multiple Failure of Employee Alarm System, January 1, 2011

- IR 1169182; MMD Support for 2B FW Pump Turning Gear Operation, January 31, 2011

11 Attachment

- IR 1172246; 0CW278A, Through Wall Crack on Valve Body, February 08, 2011

- IR 1172509; 0CW220 Flow Control Valve Not Repositioning Upon Demand,

February 08, 2011

- IR 1194212; Operator Work Around, March 29, 2011

- IR 1194754; RSH CO2 TK Repair(s) Need to Be Expedited, March 30, 2011

- IR 1194754; Missed Closure of ATI, January 09, 2004

- IR 1211839; 2WG046 Drip Pan is Removed Consider Operator Challenge, May 4, 2011

- IR 1212344; Degradation of RSH CO2 Worsens, May 5, 2011

- IR 1216461; 2B CW PP Intake DP 9 Jumped to 2, May 16, 2011

Corrective Action Documents As a Result of NRC Inspection

- IR 1276895; NRC Question - Effect of TB HELB on Reactor Trip Breakers, October 14, 2011

- IR 1278980; NRC Question - Maintaining VCT Pressure High for Chemistry, October 18, 2011

Section 1EP4: Emergency Action Level and Emergency Plan Changes

- EP-AA-1002; Exelon Nuclear Radiological Emergency Plan Annex for Byron Station;

Revisions 26, 27, and 28

- EP-AA-120-1001; 50.54(q) Program Evaluation and Effectiveness Reviews for Revisions 27

and 28

- EP-AA-120-F-01; EP Document Approval Forms for Revisions 27 and 28

12 Attachment

LIST OF ACRONYMS USED

ADAMS Agencywide Document Access Management System

AF Auxiliary Feedwater

ALARA As-Low-As-Is-Reasonably-Achievable

ANSI American National Standards Institute

ASME American Society of Mechanical Engineers

CAP Corrective Action Program

CFR Code of Federal Regulations

CLB Current Licensing Basis

DAW Dry Active Waste

DG Emergency Diesel Generator

DOT Department of Transportation

EAL Emergency Action Level

ESF Engineered Safety Feature

HELB High Energy Line Break

HVAC Heating, Ventilation, and Air Conditioning

IMC Inspection Manual Chapter

IP Inspection Procedure

IR Inspection Report

IR Issue Report

IST Inservice Testing

LER Licensee Event Report

LORT Licensed Operator Requalification Training

MEER Miscellaneous Electrical Equipment Room

MG Motor Generator

NEI Nuclear Energy Institute

OBE Operating Basis Earthquake

ODCM Offsite Dose Calculation Manual

OOS Out of Service

OpEval Operability Evaluation

OSP Outage Safety Plan

OWA Operator Workaround

psig pound per square inch gauge

MSPI Mitigating Systems Performance Index

NCV Non-Cited Violation

NRC U.S. Nuclear Regulatory Commission

NVLAP National Voluntary Laboratory Accreditation Program

PI Performance Indicator

RCS Reactor Coolant System

RFO Refueling Outage

RHR Residual Heat Removal

RWST Refueling Water Storage Tank

SDP Significance Determination Process

SH Station Heating

SRP Standard Review Plan

SSC Structure, System, and Component

SX Essential Service Water

TLD Thermoluminescent Detector

TS Technical Specification

13 Attachment

UFSAR Updated Final Safety Analysis Report

UL Underwriters Laboratory

URI Unresolved Item

VA Auxiliary Building Ventilation

WO Work Order 14 Attachment

M. Pacilio -2-

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its

enclosure will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Records (PARS) component of NRC's document system

(ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the

Public Electronic Reading Room).

Sincerely,

/RA/

Eric R. Duncan, Chief

Branch 3

Division of Reactor Projects

Docket Nos. 50-454; 50-455

License Nos. NPF-37; NPF-66

Enclosure: Inspection Report No. 05000454/2011005 and 05000455/2011005

w/Attachment: Supplemental Information

cc w/encl: Distribution via ListServ

DOCUMENT NAME: G:\DRPIII\BYRO\Byron 2011 005.docx

Publicly Available Non-Publicly Available Sensitive Non-Sensitive

To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy

OFFICE RIII

NAME EDuncan:dtp

DATE 02/07/12

OFFICIAL RECORD COPY

Letter to M. Pacilio from E. Duncan dated February 7, 2012.

SUBJECT: BYRON STATION, UNITS 1 AND 2, NRC INTEGRATED INSPECTION

REPORT 05000454/2011005; 05000455/2011005

DISTRIBUTION:

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