ML111530328

Completion of Temporary Instruction (Ti) 184, Availability and Readiness Inspection of Severe Accident Mitigation Guidelines (Samgs) at Region II Facilities - Revision

ML111530328
Person / Time
Site:	Hatch, Browns Ferry, Oconee, Mcguire, Catawba, Harris, Saint Lucie, Watts Bar, Sequoyah, Summer, Brunswick, Surry, North Anna, Turkey Point, Crystal River, Vogtle, Farley, Robinson, McGuire
Issue date:	06/02/2011
From:	Hopper G Reactor Projects Branch 7
To:	Kobetz T NRC/NRR/DIRS/IRIB
References
TI-184
Download: ML111530328 (68)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 June 2, 2011 MEMORANDUM TO: Timothy Kobetz Chief, Reactor Inspection Branch Division of Inspection and Regional Support FROM: George T. Hopper /RA/

Chief, Reactor Projects Branch 7 Division of Reactor Projects

SUBJECT:

COMPLETION OF TEMPORARY INSTRUCTION (TI)-184, AVAILABILITY AND READINESS INSPECTION OF SEVERE ACCIDENT MITIGATION GUIDELINES (SAMGS) AT REGION II FACILITIES - REVISION This memorandum documents completion of TI-184 at all Region II power reactor facilities.

The Enclosure to this memorandum lists the sites that were inspected and contains the responses to the specific questions asked in Section 03.01 of the TI. This Memorandum supersedes my Memorandum previously submitted on May 27, 2011, as it contains a correction for one inspection item. The completion of this TI will also be documented in the next NRC Integrated Inspection Report for each facility (05000xxx/2011003).

Please contact me at 404-997-4645 if you have any questions.

Enclosure:

As stated CONTACT: George Hopper, DRP/RII 404-997-4645

_ML111530328_______ X SUNSI REVIEW COMPLETE OFFICE RII:DRP RII:DRP SIGNATURE GTH /RA/ WBJ /RA/

NAME GHopper BJones DATE 06/02/2011 06/02/2011 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO TABLE OF CONTENTS Browns Ferry ................................................................................................................... 1 Brunswick ........................................................................................................................ 4 Catawba .......................................................................................................................... 7 Crystal River .................................................................................................................. 10 Farley ............................................................................................................................ 14 Harris ............................................................................................................................. 17 Hatch ............................................................................................................................. 20 McGuire ......................................................................................................................... 24 North Anna .................................................................................................................... 28 Oconee .......................................................................................................................... 31 Robinson ....................................................................................................................... 36 Sequoyah ...................................................................................................................... 39 St. Lucie ........................................................................................................................ 42 Summer ......................................................................................................................... 46 Surry .............................................................................................................................. 52 Turkey Point .................................................................................................................. 56 Vogtle ............................................................................................................................ 60 Watts Bar ....................................................................................................................... 62

BROWNS FERRY TABLE OF RESULTS Letter Inspection Item Yes No Response/Comments or Number a When were the SAMGs last Browns Ferry (BFN) program updated? documents are updated to the Revision 1 version of the BWR Owners Group Emergency Procedure and Severe Accident Guidelines, dated July 1997. The current Owners Group approved version is Revision 2, dated March 2001. The licensee is considering obtaining a contractor to upgrade the program to Revision 2. Note:

Revision 3 of the guidelines is in draft.

Are controlled copies of the SAMG Y located in the technical support center (TSC)? (Y/N)

Are controlled copies of the SAMG Y The licensee stated that controlled located in the emergency operations copies of the SAMGs are located at facility (EOF)? (Y/N) the Tennessee Valley Authoritys (TVA) Central Emergency Control Center (CECC) in Chattanooga, Tennessee, which is the offsite location of the EOF. Inspectors verified controlled copies of the SAMG were in the CECC location for all three TVA nuclear sites.

Are controlled copies of the SAMG Y located in the control room? (Y/N) b Are SAMGs covered by the N SAMGs are controlled under the licensees procedure control and licensees procedure program.

document management system, However, there are no requirements including the requirements for for periodic review and revision.

periodic review and revision? (Y/N) c Does the licensees configuration Y Specifically under NPG-SPP-9.3, control and change management Plant Modifications and Engineering systems cause the licensee to Change Control. For example, each update SAMGs to reflect design new core design for an upcoming changes? (Y/N/Partially-describe) fuel cycle.

Enclosure

2 Letter Inspection Item Yes No Response/Comments or Number d Perform a high-level comparison of Y The major sections of the the sites SAMGs with available guidance documents are covered.

industry guidance (e.g., owners However, they were developed group guidance document and other under an earlier revision of the industry standards as applicable). Owners Group guidance. See Are the SAMGs consistent with the Section a above.

owners group guidance (if any) having been incorporated (Y/N/comments)?

e How is training conducted on the SAMG training is conducted per SAMGs? site procedure TRN-34, Severe Who is trained on the SAMGs? Accident Management Training, What is the periodicity of training? which provides guidance on the development and implementation of SAMG training for Decision Makers (Site Emergency Directors), Evaluators (TSC Staff),

and Implementers (Licensed Operators). Initial training and retraining consists of classroom, self-study, and computer-based training with an examination.

Retraining is required to be completed once every four years.

Specific training includes SAMGs and technical support guidelines for decision makers and evaluators, and introduction to severe accident management and phenomenology for all SAMG positions.

f Interview 4 licensed operators (2 Inspectors interviewed 2 SROs, 2 reactor operators and 2 senior ROs, 2 TSC staff, and 2 TSC reactor operators), 2 TSC staff, and 2 managers assigned to apply the TSC managers assigned to apply the SAMGs during an emergency.

SAMGs during an emergency to determine:

(1) Did they receive initial training Y on the SAMGs? (Y/N)

Enclosure

3 Letter Inspection Item Yes No Response/Comments or Number Did they receive periodic Y Four year cycle for all SAMG training (Y/N/document positions.

periodicity) on the SAMGs and how they relate to their assigned duties?

(2) Can they articulate their Y The licensed operators will actually responsibilities with respect to implement the SAMGs based on the use of SAMGs TSC direction (SAMG team).

(Y/N/document who would actually implement the licensees SAMGs)?

g Have there been periodic exercises Y The licensee typically conducts at on the use of SAMGs by individuals least one annual exercise as a who would implement them during an severe accident management drill emergency (Y/N/document involving all SAMG positions. Over a periodicity)? four year period, the licensee conducts an exercise with each of four emergency response teams.

Enclosure

4 BRUNSWICK TABLE OF RESULTS Letter Inspection Item Yes No Response/Comments or Number a When were the SAMGs last Minor revisions to the main SAMG updated? procedures have been recently incorporated as follows:

SAMG-01, SAMG Primary Containment Flooding: 12/20/07 SAMG-02, Containment and Radioactivity Release Control: 1/5/10 SAMG-04, SAMG Users Guide:

4/11/11.

However, these revisions did not include significant owners group updates from BWR owners group revision 2 to EPG/SAG (Brunswick still uses rev. 1). Also, some outstanding revision 1 owners group issues have not been incorporated, the oldest is from 1996. An effort to update the SAMGs at Brunswick is underway.

Are controlled copies of the SAMG Y located in the technical support center (TSC)? (Y/N)

Are controlled copies of the SAMG Y located in the emergency operations facility (EOF)? (Y/N)

Are controlled copies of the SAMG Y located in the control room? (Y/N) b Are SAMGs covered by the Y All SAMG procedures are reviewed licensees procedure control and every two years. However, these document management system, reviews and revisions have not including the requirements for included significant updates from the periodic review and revision? (Y/N) BWR owners group (see block a).

c Does the licensees configuration Y Procedure EGR-NGGC-0005, control and change management Engineering Change governs design systems cause the licensee to changes and requires a review to update SAMGs to reflect design determine design change impacts on changes? (Y/N/Partially-describe) procedures, including SAMG procedures.

Enclosure

5 Letter Inspection Item Yes No Response/Comments or Number d Perform a high-level comparison of Y Brunswick SAMG procedures are the sites SAMGs with available consistent with BWR owners group industry guidance (e.g., owners revision 1 EPG/SAG procedures.

group guidance document and other However, revision 2 has introduced industry standards as applicable). many changes that have not been Are the SAMGs consistent with the incorporated. Additionally, not all owners group guidance (if any) BWR owners group revision 1 having been incorporated issues have been incorporated either (Y/N/comments)? (see block a above).

e How is training conducted on the Licensed operators receive initial SAMGs? classroom training and continuing Who is trained on the SAMGs? (every 2 years) classroom training.

What is the periodicity of training? Selected emergency response organization personnel receive initial computer based training and yearly computer based continuing training.

Non-licensed operators receive initial classroom training and continuing classroom training on local actions that they would be expected to take during use of SAMG procedures only, not overall SAMG training.

f Interview 4 licensed operators (2 reactor operators and 2 senior reactor operators), 2 TSC staff, and 2 TSC managers assigned to apply the SAMGs during an emergency to determine:

(1) Did they receive initial training Y on the SAMGs? (Y/N)

Did they receive periodic Y training (Y/N/document See(e) above periodicity) on the SAMGs and how they relate to their assigned duties?

Enclosure

6 Letter Inspection Item Yes No Response/Comments or Number (2) Can they articulate their Y Control room operators and non-responsibilities with respect to licensed operators for tasks outside the use of SAMGs the control room.

(Y/N/document who would actually implement the licensees SAMGs)?

g Have there been periodic exercises Y One general drill per assessment on the use of SAMGs by individuals cycle (every six years) includes a who would implement them during an walkthrough of a SAMG scenario.

emergency (Y/N/document This was last done in September, periodicity)? 2006.

Enclosure

7 CATAWBA TABLE OF RESULTS Letter Inspection Item Yes No Response/Comments or Number a When were the SAMGs last Unit 1 Severe Accident Control updated? Room Guidelines (SACRGs) - 1/10 Unit 2 SACRGs - 10/10 Diagnostic Flowchart (DFC), Severe Challenge Status Tree (SCST),

Severe Accident Exit Guide (SAEG),

Computational Aide (CA), Severe Challenge Guided (SCG), Severe Accident Guide (SAG) - 2/10 Are controlled copies of the SAMG Y All SAMGs located in the technical support center (TSC)? (Y/N)

Are controlled copies of the SAMG Y All SAMGs located in the emergency operations facility (EOF)? (Y/N)

Are controlled copies of the SAMG Y EG/1-2/A/CSAM/SACRG1 and located in the control room? (Y/N) EG/1-2/A/CSAM/SACRG2 b Are SAMGs covered by the N The original SAMG documents were licensees procedure control and controlled and were maintained in document management system, the Document Control Master File including the requirements for but were not maintained under their periodic review and revision? (Y/N) document control system.

Procedure revisions were controlled under NSD 224, Severe Accident Management Guidance, and periodic reviews were performed annually under PT/0/B/4600/007, Review of Emergency Plan and Implementing Procedures.

c Does the licensees configuration N The licensees configuration control control and change management and change management systems cause the licensee to procedures did not reference the update SAMGs to reflect design SAMGs.

changes? (Y/N/Partially-describe) d Perform a high-level comparison of Y The licensees procedures were the sites SAMGs with available consistent with the owners group industry guidance (e.g., owners guidance with one exception.

group guidance document and other Catawba eliminated SAG-8, Flood industry standards as applicable). Containment, in 1997 as it was Are the SAMGs consistent with the determined to be redundant to SAG-Enclosure

8 Letter Inspection Item Yes No Response/Comments or Number owners group guidance (if any) 4, Inject into Containment. This was having been incorporated based on the containment size and (Y/N/comments)? resulting target water levels for SAG-4 and SAG-8 being the same value.

e How is training conducted on the The Nuclear Operations Training SAMGs? Group was responsible for Who is trained on the SAMGs? preparation, and administration of What is the periodicity of training? required SAMG training. This included both initial training for Operations and ERO personnel and requalification for Operations personnel. Operators requalification training was conducted within the 2 year requalification curriculum. ERO staff received requalification training every two years by participating in an ERO SAMG drill.

f Interview 4 licensed operators (2 reactor operators and 2 senior reactor operators), 2 TSC staff, and 2 TSC managers assigned to apply the SAMGs during an emergency to determine:

(1) Did they receive initial training Y on the SAMGs? (Y/N)

Did they receive periodic Y Operators received periodic training training (Y/N/document as part of their 2 year requalification periodicity) on the SAMGs and and TSC staff met requalification how they relate to their requirements by participating in an assigned duties? ERO SAMG drill at least once every two years. All interviewees indicated that their training related to their assigned SAMG duties.

(2) Can they articulate their Y Operations staff were the responsibilities with respect to implementers of the strategies the use of SAMGs developed, and would provide (Y/N/document who would feedback to the TSC on the ability to actually implement the execute the strategy. TSC staff licensees SAMGs)? provided expertise in the development of SAMG strategies based on requirements determined by the SAMG decision makers (TSC managers) who ultimately approved the strategies for implementation.

Enclosure

9 Letter Inspection Item Yes No Response/Comments or Number g Have there been periodic exercises Y SAMG drills were conducted by the on the use of SAMGs by individuals ERO organization at least five times who would implement them during an over a two year period. This allowed emergency (Y/N/document all SAMG qualified personnel in the periodicity)? TSC to participate in at least one drill to meet requalification requirements.

Operations also provided SROs and ROs to participate and provide Operations input to the strategy implementation; however, there was not a requirement for all operators to participate in a drill. Operators met requalification requirements through specific Operations SAMG training during Licensed Operator continuing training.

Enclosure

10 CRYSTAL RIVER TABLE OF RESULTS Letter Inspection Item Yes No Response/Comments or Number a When were the SAMGs last CR3 Severe Accident Guideline was updated? updated January 9, 2009, Revision 5.

Are controlled copies of the SAMG Y located in the technical support center (TSC)? (Y/N)

Are controlled copies of the SAMG Y located in the emergency operations facility (EOF)? (Y/N)

Are controlled copies of the SAMG Y located in the control room? (Y/N) b Are SAMGs covered by the N The SAMGs are covered by the licensees procedure control and licensees document management document management system, system but do not get a periodic including the requirements for review and revision.

periodic review and revision? (Y/N) c Does the licensees configuration Y Design changes are covered by control and change management Corporate Engineering Procedure systems cause the licensee to EGR-NCCG-0005, Engineering update SAMGs to reflect design Change (EC). The EC screening changes? (Y/N/Partially-describe) questions in an associated job aid entitled Design and Reviewer Considerations has a question related to the impact of the EC on SAMGs.

d Perform a high-level comparison of Y Sites SAMGs were compared to the the sites SAMGs with available CY 2000 version of the B&W Generic industry guidance (e.g., owners Severe Accident Guideline.

group guidance document and other Differences addressed site specific industry standards as applicable). information.

Are the SAMGs consistent with the owners group guidance (if any) having been incorporated (Y/N/comments)?

e How is training conducted on the 1.Initial classroom training, Computer SAMGs? Based Training and Table Top Exercises Who is trained on the SAMGs? 2. The implementers (SROs, ROs, STAs and Secondary plant What is the periodicity of training? operators) have initial training and annual SAMG computer based training (CBT) that includes:

Enclosure

11 Letter Inspection Item Yes No Response/Comments or Number introduction to Severe Accident Management; Severe Accident overview phenomenology and damage assessment; and mitigation strategy training.

The Decision Makers (TSC Emergency Coordinators (EC)) and the Evaluators (TSC Accident Assessment Team) are trained on the topics listed above plus the following training: Severe Accident guidance and usage (CBT), Practice Scenarios (CBT) and Table Top exercises.

3. Implementers: Annual CBT Evaluators: Biennial CBT and annual Table Top exercise.

Decision Makers: Initial training listed above only. (The licensee initiated nuclear condition report NCR 465189 to evaluate the need for TSC emergency coordinators who do not hold a licensee to have periodic SAMG training. If they hold a license, they receive the annual implementer training) f Interview 4 licensed operators (2 Personal interviewed:

reactor operators and 2 senior 2 onshift SROs reactor operators), 2 TSC staff, and 2 2 onshift ROs TSC managers assigned to apply the 2 TSC Emergency Coordinators SAMGs during an emergency to 2 Accident Assessment Engineers determine:

(3) Did they receive initial training Y All 8 received initial SAMG training.

on the SAMGs? (Y/N)

Did they receive periodic Y 4 licensed operators: All stated training (Y/N/document that they received periodic training periodicity) on the SAMGs and associated with SAMGs (Inspector how they relate to their confirmed through training record assigned duties? review that all licensed operators had taken CBT SAMG training in 2010 (Cycle 9 licensed operator continuing training (LOCT)).

Enclosure

12 Letter Inspection Item Yes No Response/Comments or Number 2 TSC Managers*. One TSC EC (licensed SRO) received periodic SAMG training as part of his LOCT.

The second TSC EC (non-licensed) received initial training (2005) but has not had periodic training (note:

currently, periodic training for TSC EC is not required). The inspector, through review of training records, determined that another TSC EC (non-licensed) had only initial training in 2002. (The licensee initiated nuclear condition report NCR 465189 to evaluate the need for TSC emergency coordinators who do not hold a licensee to have periodic SAMG training.)

2 TSC Staff: The inspector interviewed two accident assessment engineers (part of accident assessment team). Both completed periodic (biennial) training on SAMGs and an annual tabletop exercise.

ALL: All personnel interviewed were aware of their assigned duties with respect to SAMGs.

(4) Can they articulate their Y All personnel interviewed were able responsibilities with respect to to articulate their responsibilities with the use of SAMGs respect to SAMGs. The operations (Y/N/document who would staff (SROs, ROs, STA, and non-actually implement the licensed operators) would implement licensees SAMGs)? the SAMGs if needed.

Enclosure

13 Letter Inspection Item Yes No Response/Comments or Number g Have there been periodic exercises N The implementers (operations on the use of SAMGs by individuals licensed operators (SRO, ROs) who would implement them during an and non-licensed operators) do emergency (Y/N/document not have periodic exercises on periodicity)? SAMGs. They complete annual SAMG CBT.

The evaluators (accident assessment team) have periodic (annual) tabletop exercises Enclosure

14 FARLEY TABLE OF RESULTS Letter Inspection Item Yes No Response/Comments or Number a When were the SAMGs last The licensee last updated these updated? documents in 1997 in accordance with Revision 0 of WOG Guideline Document, dated 1994. These documents do not contain Revision 1 of WOG Guideline Document dated October, 2001. However, the licensee has revised these documents as design changes occurred at the site.

Are controlled copies of the SAMG Y These documents are available to located in the technical support the Emergency Director (ED) in the center (TSC)? (Y/N) TSC as hard copies. The licensee also maintains these procedures available on their internal web document resource.

Are controlled copies of the SAMG N Hard copies of these documents are located in the emergency operations not available. The licensee facility (EOF)? (Y/N) maintains these procedures available to the EOF via the licensee internal web document resource and on a stand-alone controlled document hard drive located within the EOF (drive is periodically backed up).

Are controlled copies of the SAMG Y A hard copy of SARCG-1 and located in the control room? (Y/N) SARG-2 are available in the main control room. All other procedures are contained on the licensee internal web document resource and on a stand-alone controlled document hard drive located in the main control room.

Enclosure

15 Letter Inspection Item Yes No Response/Comments or Number b Are SAMGs covered by the N The SAMGs are controlled as licensees procedure control and controlled copies per the licensee document management system, document management system.

including the requirements for *The requirement for periodic review periodic review and revision? (Y/N) is not specifically spelled out in their controls. (See item a above.)

c Does the licensees configuration Y* The licensees design control control and change management program requires impact systems cause the licensee to assessments by specified update SAMGs to reflect design departments which includes changes? (Y/N/Partially-describe) Emergency Planning. *However, the impact assessment does not include a line item to review the SAMGs.

The impact assessment only requires review against the Emergency Plan. The licensee does update the SAMGs when plant design changes are determined to impact these documents.

d Perform a high-level comparison of Y The licensees documents are the sites SAMGs with available missing Revision 1 of WOG industry guidance (e.g., owners Guideline Document, but include all group guidance document and other of the high-level steps required by industry standards as applicable). both Revision 0 and Revision 1.

Are the SAMGs consistent with the owners group guidance (if any) having been incorporated (Y/N/comments)?

e How is training conducted on the Initial reactor operators (RO) and SAMGs? senior reactor operators (SRO) receive classroom training on these Who is trained on the SAMGs? documents at the completion of their initial license training. The licensee What is the periodicity of training? includes computer based training (CBT) in their 2 year cycle plan for license operator requalification. TSC management receives a table top exercise annually to review implementation of the SAMGs. The TSC management has an annual requirement to complete the CBT training required of the licensed operators in requalification training.

Enclosure

16 Letter Inspection Item Yes No Response/Comments or Number f Interview 4 licensed operators (2 reactor operators and 2 senior reactor operators), 2 TSC staff, and 2 TSC managers assigned to apply the SAMGs during an emergency to determine:

(1) Did they receive initial training Y* *TSC staff does not complete any on the SAMGs? (Y/N) training on SAMGs. The reactor operators, senior reactor operators, and TSC management received training as listed in item e above.

Did they receive periodic Y The licensee includes computer training (Y/N/document based training (CBT) in their 2 year periodicity) on the SAMGs and cycle plan for license operator how they relate to their requalification (RO and SRO). TSC assigned duties? management receives a table top exercise annually to review implementation of the SAMGs. The TSC management also has to annually complete the CBT training that the licensed operators in requalification training perform.

(2) Can they articulate their Y Some weaknesses in knowledge of responsibilities with respect to implementation were discovered.

the use of SAMGs Generally, the SROs knew entry (Y/N/document who would criteria and their requirement to actually implement the implement SACRG-1. Most could licensees SAMGs)? not articulate individual steps or how the strategy worked. All knew their required interface with the TSC manager in implementing SACRG-2.

Generally, the TSC managers understood how to implement SACRG-2 and the diagnostic flow chart.

g Have there been periodic exercises Y TSC management receives a table on the use of SAMGs by individuals top exercise annually to review who would implement them during an implementation of the SAMGs. This emergency (Y/N/document was last accomplished in December, periodicity)? 2009. The table top exercise for 2010 was not completed and has been identified by the licensee and entered into their corrective action program (CR 2011106588).

Enclosure

17 HARRIS TABLE OF RESULTS Letter Inspection Item Yes No Response/Comments or Number a When were the SAMGs last There have been several updates to updated? the SAMG procedures, they span from 2001 to the most recent, which occurred in 2010. However, the SAMGs have not been revised to incorporate Revision 1 of the Westinghouse Owners Group (WOG) background documents which was released in June, 1994. Some more recent modifications were added and procedures updated to reflect changes such as NFPA805 implementation/modifications and Alternate Seal Injection (ASI) modification. However, other modifications have not been reviewed for SAMG calculation document changes to reflect current plant conditions such as; new steam generators, containment sump level, and RCS press parameters (AR 406767).

Are controlled copies of the SAMG Y There are controlled copies of located in the technical support SAMGs in the TSC. There were center (TSC)? (Y/N) outdated revisions in place, i.e.,

SAMG-9AG-003 (5/10/11) Revision 7 vs. Revision 8. Procedures were updated (AR 464673).

Are controlled copies of the SAMG Y There are controlled copies of located in the emergency operations SAMGs in EOF. There were facility (EOF)? (Y/N) outdated revisions in place, i.e.,

SAMG SAMP-001, Revision 5 vs.

Revision 6 SAMG SAG 008.

Procedures were updated (AR 464673).

Are controlled copies of the SAMG Y There is a controlled copy of SAMGs located in the control room? (Y/N) in the control room.

b Are SAMGs covered by the N Harris (via docketed letter 94-1890) licensees procedure control and no longer performs a biennial review document management system, of all their controlled procedures.

including the requirements for They review a sample of those periodic review and revision? (Y/N) procedures not revised in the last two Enclosure

18 Letter Inspection Item Yes No Response/Comments or Number years, to ensure the intent of the biennial review is met (HNP Procedure Biennial Review Process AP-043). AR 406767 was generated 6/10 to document and investigate why the SAMGs were not updated to reflect Revision 1 of the Westinghouse Owners group severe accident management guidance document.

c Does the licensees configuration Y Documents were updated for control and change management modifications installed during systems cause the licensee to refueling outage 16. However, update SAMGs to reflect design several older relevant modifications changes? (Y/N/Partially-describe) were not incorporated. Changes are in process to address these mods (AR 406767) and are scheduled to be complete by 6/11.

d Perform a high-level comparison of Y It appears the SAMGs are consistent the sites SAMGs with available with the general intent of the owners industry guidance (e.g., owners group document. However, updates group guidance document and other to reflect WOG, Revision 1 are in industry standards as applicable). progress (AR 406767).

Are the SAMGs consistent with the owners group guidance (if any) having been incorporated (Y/N/comments)?

e How is training conducted on the Initial classroom training is SAMGs? conducted for implementers (the control room staff per SAMG-SAMP-Who is trained on the SAMGs? 001, Attachment 1), decision makers (Plant Operations Director, Site What is the periodicity of training? Emergency Coordinator-TSC and Emergency Response Manager) and evaluators (Technical Analysis Director, TSC SRO,TSC AAT- STA, TSC- Core Performance Engineer, TSC-Mechanical Engineer, TSC-Electrical/I&C Engineer, Technical Analysis Manager and EOF SRO).

Also, decision makers and evaluators participate in a practical table-top exercise.

Enclosure

19 Letter Inspection Item Yes No Response/Comments or Number Requalification training occurs every two years and is similar to initial training. All participants receive classroom/computer based training.

Decision makers and evaluators participate in a table-top exercise.

f Interview 4 licensed operators (2 reactor operators and 2 senior reactor operators), 2 TSC staff, and 2 TSC managers assigned to apply the SAMGs during an emergency to determine:

(1) Did they receive initial training Y on the SAMGs? (Y/N)

Did they receive periodic Y Every two years continuing training is training (Y/N/document required and conducted.

periodicity) on the SAMGs and how they relate to their assigned duties?

(2) Can they articulate their Y Those interviewed could articulate responsibilities with respect to their role in implementation of the the use of SAMGs SAMG procedures. There was (Y/N/document who would discussion and differing opinions actually implement the during the interviews relative to who licensees SAMGs)? are the implementers of the SAMG procedures, i.e., does the control room or TSC actually implement the procedures. AR 465394 was generated to review this disparity.

g Have there been periodic exercises N Periodic exercises, table-top and on the use of SAMGs by individuals classroom computer based training who would implement them during an are provided for decision makers and emergency (Y/N/document evaluators to participate in every two periodicity)? years. The control room staff (implementers per SAMG-SAMP-001, Attachment 1) is only provided with classroom training every two years.

Enclosure

20 HATCH TABLE OF RESULTS Letter Inspection Item Yes No Response/Comments or Number a When were the SAMGs last Unit 1:

updated? 31EO-SAG-001-1 Ver. 2 3/8/06 31EO-SAG-001-2 Ver. 2 3/8/06 Unit 2:

31EO-SAG-002-1 Ver. 5 5/23/06 31EO-SAG-002-2 Ver. 3 5/23/06 Are controlled copies of the SAMG Y Procedure 31EO-SAG-001-1, 31EO-located in the technical support SAG-002-1, 31EO-SAG-001-2, and center (TSC)? (Y/N) 31EO-SAG-002-2 contain a procedure cover page and the controlled version of the SAG-1 or SAG-2 flowchart. This procedure is available to the TSC in both hardcopy and via the licensee internal web document resource and a standalone backed up controlled document hard drive located within the TSC.

Are controlled copies of the SAMG N The EOF located at SNC Corporate located in the emergency operations HQs in Birmingham Al did not have facility (EOF)? (Y/N) the above Hatch SAG procedures printed and maintained as controlled documents in hardcopy. However, these procedures are available to the EOF via the licensee internal web document resource and a standalone backed up controlled document hard drive located within the EOF.

Are controlled copies of the SAMG Y Each control room contained current located in the control room? (Y/N) revisions of SAG-1 and SAG-2 flowcharts.

b Are SAMGs covered by the Y The SAGs are controlled to the same licensees procedure control and requirements as EOPs in document management system, accordance with 30AC-OPS-007-0, including the requirements for Emergency Operating Procedures periodic review and revision? (Y/N) Revision Requirements.

c Does the licensees configuration Y NMP-ES-022, DCP Site Approval, control and change management Implementation and Closure and systems cause the licensee to 30AC-OPS-007-0 require SAGs to update SAMGs to reflect design be updated for plant design changes.

changes? (Y/N/Partially-describe)

Enclosure

21 Letter Inspection Item Yes No Response/Comments or Number d Perform a high-level comparison of Y Hatch Severe Accident Guidelines the sites SAMGs with available (SAGs) are consistent with the BWR industry guidance (e.g., owners owners group SAGs.

group guidance document and other industry standards as applicable).

Are the SAMGs consistent with the owners group guidance (if any) having been incorporated (Y/N/comments)?

e How is training conducted on the Hatch Severe Accident Management SAMGs? Training Program System Master Plan Rev02 contains the qualification Who is trained on the SAMGs? requirements for all severe accident management emergency response What is the periodicity of training? positions. This qualification is broken into the following categories:

A) Decision Maker is a qualified TSC Operations Supervisor.

B) Evaluator is a qualified TSC Operations Supervisor, or TSC Operations Support, or Plant Status Communicator.

C) Implementer - SROs, ROs Initial Training for each of the above Accident Management Team (AMT) positions includes: Completion of classroom presented courses EP-51000, Severe Accident Guidelines and EP-50200, Technical Support Guidelines. In additions to the above classroom courses Decision Makers and Evaluators must participate in at least one Tabletop Training Exercise and be evaluated in the Tabletop Exercise prior to being assigned as an Accident Management Team Member.

Continuing Training: Each of the three categories above must complete computer based training course EP-50100, Severe Accident Guidelines continuing training at least every two calendar years.

Enclosure

22 Letter Inspection Item Yes No Response/Comments or Number Through license continuing training AMT members will be informed of major equipment and guideline changes that could affect their job.

Also as part of license continuing training AMT members will review the Technical Support Guidelines flowchart once every two years. In addition to the above, Decision Makers and Evaluators are required to at least once every three calendar years demonstrate through tabletop exercise the capability to implement Severe Accident Guidelines.

f Interview 4 licensed operators (2 reactor operators and 2 senior reactor operators), 2 TSC staff, and 2 TSC managers assigned to apply the SAMGs during an emergency to determine:

(1) Did they receive initial training Y on the SAMGs? (Y/N)

Did they receive periodic Y training (Y/N/document periodicity) on the SAMGs and how they relate to their assigned duties?

(2) Can they articulate their Y Personnel qualified as Decision responsibilities with respect to Maker in the TSC would direct SAG the use of SAMGs action(s) to be taken.

(Y/N/document who would actually implement the Personnel qualified as Evaluator in licensees SAMGs)? the TSC would aid the Decision Maker in determining which SAG action(s) to take.

Personnel qualified as Implementer (includes all licensed ROs and SROs) receive direction from the Decision Maker and personnel qualified as implementers are the ones who actually implement the SAG action(s).

Enclosure

23 Letter Inspection Item Yes No Response/Comments or Number g Have there been periodic exercises N Only those qualified as Decision on the use of SAMGs by individuals Makers and Evaluators are required who would implement them during an to conduct SAG table top exercises emergency (Y/N/document every three years.

periodicity)?

Those designated as Implementers (ROs and SROs) do not conduct periodic exercises specifically covering SAG procedures.

However, Implementers do review SAG procedures through the licensed operator continuing training classroom process as well as perform some procedures utilized by the SAGs during licensed operator continuing training simulator scenarios.

Enclosure

24 McGUIRE TABLE OF RESULTS Letter Inspection Item Yes No Response/Comments or Number a When were the SAMGs last Unit 1 & 2 Severe Accident Control updated? Room Guidelines (SACRG) -

11/19/09 Diagnostic Flowchart (DFC), Severe Challenge Status Tree (SCST),

Severe Accident Exit Guide (SAEG),

Computational Aide (CA), Severe Challenge Guided (SCG), Severe Accident Guide (SAG) - 2/15/05 SAG 2 9/21/06 Are controlled copies of the SAMG Y All SAMGs were located in Technical located in the technical support Support Center (TSC).

center (TSC)? (Y/N)

Are controlled copies of the SAMG Y All SAMGs were located in the located in the emergency operations Emergency Operations Facility facility (EOF)? (Y/N) (EOF)

Are controlled copies of the SAMG Y SACRGs Unit 1 and 2 located in the control room? (Y/N) b Are SAMGs covered by the N The original SAMGs were a licensees procedure control and controlled document maintained in document management system, the Document Control Master File including the requirements for and were maintained separately from periodic review and revision? (Y/N) the licensees document control system.

NSD 224, Severe Accident Management Guidance, provided the guidance for the development, maintenance, training, and usage of the SAMGs.

SAMGs were reviewed by Nuclear Engineering PRA Models and Initiatives Group based on plant modifications, information received from Owners Groups, and feedback from drills. Resulting revisions were tracked and documented in the deviation document as required.

Enclosure

25 Letter Inspection Item Yes No Response/Comments or Number The deviation document was included as part of the SAMG initial issue and subsequent revision packages. This deviation document provided written justification to ensure the actions were consistent with associated Westinghouse Owners Group (WOG) SAMGs as they apply to the site.

c Does the licensees configuration N The licensees configuration and control and change management control documents made no systems cause the licensee to reference to SAMGs. The licensee update SAMGs to reflect design generated PIP M-11-03789 on changes? (Y/N/Partially-describe) 5/12/11 which documented that the administrative process to ensure plant modifications were reviewed for impact to SAMGs needs to be clarified.

d Perform a high-level comparison of Y Deviations from the WOG generic the sites SAMGs with available SAMGs were documented in the industry guidance (e.g., owners deviation document and included as group guidance document and other part of the initial issue and industry standards as applicable). subsequent revision packages.

Are the SAMGs consistent with the owners group guidance (if any) The licensees procedures were having been incorporated consistent with the WOG guidance (Y/N/comments)? with the exception of the deletion of SAG-8, Flood Containment, in a 2003 revision.

The licensee deleted SAG-8 using the analysis for plant-specific containment flooding level setpoints located in WOG Executive Volume, Section 6. In accordance with the setpoint basis, Setpoint L02, Lower Target Containment Water Level, and Setpoint L03, Upper Target Containment Water Level, all had the same value. Therefore, the licensee determined there were no technical differences between SAG-4 and SAG-8 and SAG-4 meets the intent of SAG-8. Based upon this justification, SAG-8 was deleted.

Enclosure

26 Letter Inspection Item Yes No Response/Comments or Number e How is training conducted on the The Nuclear Operations Training SAMGs? group is responsible for the administration of required SAMG Who is trained on the SAMGs? training, both initial training and continuing training for Emergency What is the periodicity of training? Response Organization (ERO) staff and Operations personnel.

SAMG Initial and continuing training requirements are implemented in accordance with the licensees Employee Training and Qualification System Standard (ETQS Standard 7111.0) and Emergency Response Training guideline (MTP 7111.0).

There were five ERO positions that are required to be SAMG qualified.

They are: Emergency Coordinator, Assistant Emergency Coordinator, Operations Procedure Support, Reactor Engineer, and System Engineering Manager.

There are four Operations positions that are required to SAMG qualified.

They are: Control Room Operator, Shift Supervisor, Operations Shift Manager, and Shift Technical Advisor.

Under the requirements, SAMG-qualified ERO staff members are required to participate in a SAMG drill once per 24 months. Operations personnel receive classroom training once per 24 months through the Operations License Requalification Training program Enclosure

27 Letter Inspection Item Yes No Response/Comments or Number f Interview 4 licensed operators (2 reactor operators and 2 senior reactor operators), 2 TSC staff, and 2 TSC managers assigned to apply the SAMGs during an emergency to determine:

(1) Did they receive initial training Y on the SAMGs? (Y/N)

Did they receive periodic Y All interviewed personnel training (Y/N/document acknowledged that they received periodicity) on the SAMGs and biennial SAMG training in how they relate to their accordance with their continuing assigned duties? training requirements.

(2) Can they articulate their Y All interviewees were able to responsibilities with respect to articulate their assigned duties.

the use of SAMGs Control room operators understood (Y/N/document who would their roles as implementers and were actually implement the cognizant of their responsibilities for licensees SAMGs)? SACRG-1 and SACRG-2. The TSC interviewees were knowledgeable of their individual responsibilities and were also able to demonstrate a general knowledge of all three SAMG-designated roles (Implementer, Evaluator, and Decision Maker).

g Have there been periodic exercises Y EROs target is to conduct five on the use of SAMGs by individuals SAMG drills every two years (2-3 who would implement them during an drills / yr) in order to allow each staff emergency (Y/N/document member in a SAMG-qualified TSC periodicity)? position to participate in a drill exercise. Within ERO, there are five TSC positions that are required to be SAMG-qualified and required to participate in a drill biennially.

Operations personnel are not required to participate in SAMG drills.

Enclosure

28 NORTH ANNA TABLE OF RESULTS Letter or Inspection Item Yes No Response/Comments Number a When were the SAMGs last A review of the SAMG procedure updated? collection effective dates determined a date range from January 1998 to February 2010 which demonstrates periodic procedure review and revision.

Are controlled copies of the SAMG Y located in the technical support center (TSC)? (Y/N)

Are controlled copies of the SAMG Y located in the emergency operations facility (EOF)? (Y/N)

Are controlled copies of the SAMG Y located in the control room? (Y/N) b Are SAMGs covered by the N Virginia Power administrative licensees procedure control and procedure, VPAP-2604, Severe document management system, Accident Mitigation Guideline including the requirements for (SAMG) Program Administration, periodic review and revision? (Y/N) Revision 2, stipulates the requirements for procedure review and revisions in section 6.2, Review, in accordance with VPAP-0502, Procedure Process Control, Revision 54. The SAMGs are reviewed when required due to a station change initiated by modifications, Westinghouse Owners Group (WOG) guidance, etc. The inspector found no program that specified a review and revision on a regular periodic frequency, e.g.,

yearly.

c Does the licensees configuration Y VPAP-0301, Design Change control and change management Process, Revision 30, stipulates a systems cause the licensee to requirement for SAMG review and update SAMGs to reflect design revision based on new modifications changes? (Y/N/Partially-describe) or design changes.

d Perform a high-level comparison of Y VPAP-2604, section 6.1, Guidelines the sites SAMGs with available Development, states; SAMGs are industry guidance (e.g., owners based upon the WOG generic group guidance document and other SAMGs. Deviations from the WOG industry standards as applicable). Generic SAMGs shall be Enclosure

29 Letter or Inspection Item Yes No Response/Comments Number Are the SAMGs consistent with the documented and included as part of owners group guidance (if any) the initial set and any subsequent having been incorporated revision package. This (Y/N/comments)? documentation shall provide written justification to ensure the actions are consistent with the basis of the associated WOG SAMG. SAMGs will be written in accordance with SPAP-0504, Technical Procedure Writers Guide, and VPAP-0505, Writers Guide for Dual-Column Procedures, as determined by the Supervisor(s) Station Procedures.

The cross references to NA&Fs setpoint basis document should be maintained as part of the text. For processing purposes, Computational Aids (CAs) will be treated as distinct guidelines, even though they are supplemental information used in the performance of the guidelines.

SAMGs are non-safety related.

The inspector performed a high level comparison between the Westinghouse Owners Group SAMG guidelines and verified that the licensees SAMGs compared favorably with the WOG guidelines.

e How is training conducted on the VPAP-2604 provides the training SAMGs? requirements for initial training and periodic training that is conducted on Who is trained on the SAMGs? a 3 year frequency. Each of the required positions, Decision Maker, What is the periodicity of training? Evaluator and Implementor, receive training as specified in section 6.5 of the procedure. Section 6.5.4 states, SAMG training lessons and requirements are specified in accordance with guidance provided by the Westinghouse Owners Group.

Enclosure

30 Letter Inspection Item Yes No Response/Comments or Number f Interview 4 licensed operators (2 The inspector performed interviews reactor operators and 2 senior with selected licensee personnel.

reactor operators), 2 TSC staff, and 2 TSC managers assigned to apply the SAMGs during an emergency to determine:

(1) Did they receive initial training Y on the SAMGs? (Y/N)

Did they receive periodic Y VPAP-2604 section 6.5.6 states that training (Y/N/document all 3 positions, Decision Maker, periodicity) on the SAMGs and Evaluator and Implementor will how they relate to their normally require refresher training assigned duties? every 3 years. The inspector confirmed that forthcoming training was scheduled for the week of May 25, 2011.

(2) Can they articulate their Y VPAP-2604, section 6.5, states, responsibilities with respect to Based on a philosophy adopted the use of SAMGs from the WOG SAMG, personnel (Y/N/document who would assigned to work with the SAMGs actually implement the have been categorized into one of licensees SAMGs)? three positions. The Decision Maker and Evaluator positions will normally work out of the TSC. The Implementor works out of the Control Room. All of the personnel interviewed were able to articulate their responsibilities from a high level viewpoint.

g Have there been periodic exercises N The licensee does not incorporate on the use of SAMGs by individuals SAMGs in their normal emergency who would implement them during an preparedness drills or exercises.

emergency (Y/N/document Rather, the licensee performs periodicity)? training using the classroom setting for formal presentations and or table-top drills as specified by VPAP-2604, section 6.5. Table-top drills are used for initial training or may be used for validation of a SAMG guideline revision.

Enclosure

31 OCONEE TABLE OF RESULTS Letter Inspection Item Yes No Response/Comments or Number a When were the SAMGs last January 7, 2008 updated?

Are controlled copies of the SAMG Y Document Control listed one located in the technical support controlled copy in the TSC; however, center (TSC)? (Y/N) three copies were found of which only one was the current revision.

The other two copies were updated to reflect the current revision and the distribution list will be updated to identify the need for three copies in the TSC. This discrepancy was entered into the licensees corrective action program (CAP).

Are controlled copies of the SAMG N Document Control did not distribute located in the emergency operations copies of the Oconee Severe facility (EOF)? (Y/N) Accident Guidelines (OSAG) to the EOF; however, a copy was in the EOF which was not the current revision. A current revision was placed in the EOF and the distribution list will be updated to identify the need for two controlled copies in the EOF. This discrepancy was entered into the licensees CAP.

Are controlled copies of the SAMG N The TSC & OSC at Oconee are located in the control room? (Y/N) within the Control Room envelope.

The licensee determined that there was no need to stage additional controlled copies of the OSAG in the control room horseshoe area because the actual usage will take place in the TSC.

b Are SAMGs covered by the The OSAGs are covered by the licensees procedure control and licensees Document Control process document management system, N which maintains the distribution list including the requirements for and ensures revisions are sent to all periodic review and revision? (Y/N) holders of controlled copies.

Enclosure

32 Letter Inspection Item Yes No Response/Comments or Number There was no requirement to periodically review the OSAGs to ensure they remained updated with the vendor SAMGs or that the guidance contained in the OSAG was valid based on changes to other plant procedures, equipment or structures. This issue was entered into the licensees CAP for evaluation.

c Does the licensees configuration N The OSAGs were not in the control and change management electronic document system (NEDL) systems cause the licensee to which could complicate searching for update SAMGs to reflect design components or other information changes? (Y/N/Partially-describe) when developing modifications or changes to the station. The OSAGs were not listed specifically in the Modification Process manual (EDM-601) as a document to be reviewed during the mod process as the 10 CFR 50.59 screening was conducted which introduced the potential for a mod to adversely affect the ability to perform specific actions called for in other procedures (OP, AP, EP, RP.

EM, OSAG, etc.).

The licensee entered this issue into the CAP and implemented interim actions to ensure the mod process reviews OSAGs for potential impacts or challenges to being able to perform specific actions.

d Perform a high-level comparison of Oconee used the GSAGs for the the sites SAMGs with available majority of the OSAG development; industry guidance (e.g., owners however, based on some unique group guidance document and other design features such as the standby industry standards as applicable). shutdown facility and specific areas Are the SAMGs consistent with the where the lack of train separation Y

owners group guidance (if any) was a factor, these unique aspects having been incorporated were factored into the OSAG (Y/N/comments)? guidance. A high level review identified some differences, which were noted and communicated to the licensee. The licensee concurred Enclosure

33 Letter Inspection Item Yes No Response/Comments or Number that a detailed comparison between the two documents to identify differences and reconcile them had not been performed in a number of years and entered this into the CAP with the intent of developing both immediate corrective actions to perform the review and long-term actions to ensure the reviews were done periodically.

e How is training conducted on the The stations training department SAMGs? develops and provides the OSAG training to the various groups of Who is trained on the SAMGs? personnel that would be involved in the implementation of the OSAG What is the periodicity of training? guidance. This includes Implementers (control room staff and OSC teams), Evaluators (STA, Reactor Engineers and Assistant Operations Superintendent) and Decision Makers (TSC Emergency Coordinator, Operations Superintendent and Engineering Manager). The training is given in two formats - classroom or computer based training (CBT). There was a table top drill that was used as part of the classroom training which was given during licensed operator requalification (LOR) on a biennial basis and was open to personnel other than those in the LOR crew; i.e., Evaluators and Decision Makers.

The CBT module allowed people to obtain credit for the classroom portion; however, they still needed to take part in the table top drill/exercise to get full credit for the required training. The drill was a 5-year requirement while the classroom/CBT was a biennial requirement. Since the table top drill was done in conjunction with the classroom, those opting for the classroom/CBT received both every Enclosure

34 Letter Inspection Item Yes No Response/Comments or Number classroom/CBT received both every two years.

There was also one Emergency Preparedness drill each year which progressed into OSAG implementation. Credit was given to people that participated, evaluated or mentored others as a qualified Emergency Response Organization (ERO) member for this portion of the training requirements. All ERO personnel that were designated as being OSAG qualified needed this training every 5 years; however, in reviewing the training records for qualified individuals, most received the training through participation every two years or less.

f Interview 4 licensed operators (2 reactor operators and 2 senior reactor operators), 2 TSC staff, and 2 TSC managers assigned to apply the SAMGs during an emergency to determine:

(1) Did they receive initial training Y All licensed personnel received the on the SAMGs? (Y/N) OSAG / B.5.b training during their initial license class before they were approved to stand watch. Other ERO members that were involved in the implementation of the OSAGs received initial training before they were designated as being able to fill a specific role in the ERO.

Did they receive periodic Y The specifics of the training provided training (Y/N/document and the periodicity is described in periodicity) on the SAMGs and Section (e) above.

how they relate to their assigned duties?

(2) Can they articulate their Y All of the personnel that were responsibilities with respect to interviewed understood how the the use of SAMGs OSAG guidance would be implemented; i.e., who would develop the specific guidance based Enclosure

35 Letter Inspection Item Yes No Response/Comments or Number (Y/N/document who would on the specific plant conditions, the actually implement the process to review the developed licensees SAMGs)? guidance, and then how the control room staff would be directed to perform the actions in the control room or OSC members directed to perform actions in the plant. See Section e for implementation of OSAGs.

g Have there been periodic exercises Y Training in the form of drills and table on the use of SAMGs by individuals tops was conducted on a regular who would implement them during an basis by the licensee. There was emergency (Y/N/document one OSAG drill each year which periodicity)? dovetailed into a normal ERO drill.

In addition, there were table top drills provided to ERO personnel through the LOR cycles and the training was attended by personnel from all three groups in the TSC / control room structure.

The Oconee training group also conducted training twice a year in Charlotte for personnel that would be staffing the EOF during an event.

The training that was provided (including the table top drills) included the B.5.b strategies and allowed the personnel to determine how to use B.5.b equipment to provide cooling to the core, feed the steam generators or provide cooling to equipment or structures in the plant. This was also included in the training provided to the EOF staff.

Enclosure

36 ROBINSON TABLE OF RESULTS Letter Inspection Item Yes No Response/Comments or Number a When were the SAMGs last The most recent revision to a SAMG updated? procedure was issued on 1/12/2011 (SACM-4, Control Containment Vacuum). The oldest revision to a SAMG procedure was issued on 11/13/2003 (SACRM-1, Severe Accident Control Room Management-Initial Response). The remaining SAMGs have been revised once since 2003. There is no programmatic periodic review of the SAMGs at Robinson.

Are controlled copies of the SAMG Y The Technical Support Center (TSC) located in the technical support contains controlled hard copies of center (TSC)? (Y/N) SAMGs and the capability to view controlled copies via facility computers.

Are controlled copies of the SAMG Y The Emergency Operations Facility located in the emergency operations (EOF) contains controlled hard facility (EOF)? (Y/N) copies of SAMGs and the capability to view controlled copies via facility computers.

Are controlled copies of the SAMG Y The control room contains controlled located in the control room? (Y/N) hard copies of SAMGs and the capability to view controlled copies via facility computers.

b Are SAMGs covered by the N SAMGs are covered by the licensee licensees procedure control and procedure PRO-NGGC-0204, document management system, Procedure Review and Approval, including the requirements for rev. 19. Biennial reviews of all plant periodic review and revision? (Y/N) procedures were abandoned in 1994 and replaced with periodic self assessments that review a sample of the plant procedures that have not been revised in the last 2 years.

c Does the licensees configuration Y Licensee procedure EGR-NGGC-control and change management 0005, Engineering Change, rev. 31 systems cause the licensee to provides guidance on updating plant update SAMGs to reflect design procedures including SAMGs to changes? (Y/N/Partially-describe) reflect design changes.

Enclosure

37 Letter Inspection Item Yes No Response/Comments or Number d Perform a high-level comparison of Y Westinghouse Owners Group the sites SAMGs with available (WOG) SAMG rev. 1 has not been industry guidance (e.g., owners incorporated at Robinson. Robinson group guidance document and other SAMG procedures and industry standards as applicable). Computational Aids are based on Are the SAMGs consistent with the WOG SAMG rev. 0, which was owners group guidance (if any) issued in 1994. The current SAMGs having been incorporated are consistent with rev. 0. The (Y/N/comments)? licensee has initiated actions to update current SAMG procedures to reflect the guidance in rev. 1.

Robinson has concluded that the use of the existing SAMGs will not result in any inappropriate diagnosis or recommendation of strategy implementation.

e How is training conducted on the Reactor Operator/ Senior Reactor SAMGs? Operator:

Initial training on the use of SAMGs Who is trained on the SAMGs? is given during initial license operator qualification training. Operators are What is the periodicity of training? given additional training every two years during license operator requalification training (LORT). All training is given through classroom instruction.

TSC Managers/TSC Staff:

Initial qualification for a Severe Accident Management (SAM) position consists of successful completion of Emergency Response Organization (ERO) training and participation in one tabletop or drill exercise. All ERO personnel participate in a SAMG tabletop or drill except for Damage Control Team members and on-shift operations personnel. Damage Control Team members and on-shift operations staff are excluded from table tops or drills because they are performing the same tasks as their regular Emergency Preparedness duties. After initial qualification, SAM Enclosure

38 Letter Inspection Item Yes No Response/Comments or Number positions must participate in a SAMG tabletop or drill every 2 years to maintain qualification.

f Interview 4 licensed operators (2 reactor operators and 2 senior reactor operators), 2 TSC staff, and 2 TSC managers assigned to apply the SAMGs during an emergency to determine:

(1) Did they receive initial training Y on the SAMGs? (Y/N)

Did they receive periodic Y Operations and TSC personnel training (Y/N/document receive training on SAMGs every two periodicity) on the SAMGs and years.

how they relate to their assigned duties?

(2) Can they articulate their Y Control Room operators and responsibilities with respect to Operational Support Center (OSC) the use of SAMGs Damage Control Teams will (Y/N/document who would implement the actions recommended actually implement the by TSC staff (Accident Assessment licensees SAMGs)? Team, Plant Operations Director and Technical Analysis Director) and approved by the Site Emergency Coordinator or Emergency Response Manager to mitigate the accident.

g Have there been periodic exercises Y The licensee conducts approximately on the use of SAMGs by individuals five SAMG table top or drill exercises who would implement them during an each year.

emergency (Y/N/document periodicity)?

Enclosure

39 SEQUOYAH TABLE OF RESULTS Letter Inspection Item Yes No Response/Comments or Number a When were the SAMGs last The licensee SAMG procedures updated? consist of 26 individual procedures, each of which is separately maintained and updated as necessary. The most recently updated procedures were revised on March 21, 2011. The procedures having the oldest current revisions were dated December 29, 1998.

Are controlled copies of the SAMG Y The inspectors physically verified located in the technical support these copies.

center (TSC)? (Y/N)

Are controlled copies of the SAMG Y The inspectors physically verified located in the emergency operations these copies.

facility (EOF)? (Y/N)

Are controlled copies of the SAMG Y The inspectors physically verified located in the control room? (Y/N) these copies.

b Are SAMGs covered by the N The inspectors reviewed NPG-SPP-licensees procedure control and 18.3.1, Severe Accident document management system, Management Guideline (SAMG) including the requirements for Program Administration, revision 0, periodic review and revision? (Y/N) as well as NPG-SPP-01.2, Administration of Site Technical Procedures, revision 1, which include the SAMG revision process. The SAMGs procedures (controlled hard copies and electronic versions) are maintained via the licensees procedure control program and electronic business support library (BSL).

The above procedures do not specifically require periodic review of technical procedures (including SAMGs). SAMGs are periodically reviewed by way of their use during recurring licensed operator requalification training and annual training drills. SAMGs are reviewed for impact as part of the sites design Enclosure

40 Letter Inspection Item Yes No Response/Comments or Number change process, and indicated below.

c Does the licensees configuration Y The inspectors reviewed NPG-SPP-control and change management 09.3, Plant Modifications and systems cause the licensee to Engineering Change Control, update SAMGs to reflect design revision 4, which includes changes? (Y/N/Partially-describe) consideration of SAMG impact during the change development and review processes.

d Perform a high-level comparison of Y Yes, the licensees SAMG the sites SAMGs with available procedures are consistent with the industry guidance (e.g., owners applicable owners group guidance.

group guidance document and other The inspectors reviewed the industry standards as applicable). Westinghouse Owners Group Are the SAMGs consistent with the (WOG) guidelines, as well as owners group guidance (if any) licensee procedure SPM-SAMG-0, having been incorporated Deviation Document for Severe (Y/N/comments)? Accident Management Guidelines, revision 0. The licensees SAMG procedures contain only minor site-specific deviations from the WOG guidelines, with the exception that the licensee procedures do not include one of the guideline procedures: SAG-8, Flood Containment. The licensee performed an evaluation to demonstrate that SAG-8 is unnecessary given the specific containment characteristics of the plant.

e How is training conducted on the The inspectors reviewed licensee SAMGs? procedure TRN-34, Severe Accident Management Training, revision 5.

Who is trained on the SAMGs? Initial SAMG training is conducted for personnel assigned to SAMG What is the periodicity of training? positions via classroom sessions or by self study, followed by the administration of an exam. An annual training session and table top drill is conducted annually, with individuals participating in at least one drill every four years. The licensees program defines three Enclosure

41 Letter Inspection Item Yes No Response/Comments or Number types of SAMG positions (Implementors, Decision Makers, and Evaluators) as well as a list of emergency response positions and their corresponding SAMG position and training requirements.

f Interview 4 licensed operators (2 reactor operators and 2 senior reactor operators), 2 TSC staff, and 2 TSC managers assigned to apply the SAMGs during an emergency to determine:

(1) Did they receive initial training Y Through interviews, the inspectors on the SAMGs? (Y/N) determined that the required Did they receive periodic Y positions and individuals have had training (Y/N/document initial and periodic training on the periodicity) on the SAMGs and SAMGs in accordance with the how they relate to their licensees SAMG training program.

assigned duties?

(2) Can they articulate their Y Some TSC staff members who were responsibilities with respect to interviewed have not had the SAMG the use of SAMGs training, which is allowed per the (Y/N/document who would licensees procedure since not all actually implement the TSC positions are designated as licensees SAMGs)? being in one of the three applicable SAMG position categories.

g Have there been periodic exercises Y Licensed Operators assume the on the use of SAMGs by individuals duties of implementers during SAMG who would implement them during an performance. SAMG training is emergency (Y/N/document incorporated into the Licensed periodicity)? Operator Requalification training program every 2 years. Drill exercises are also held on an annual basis for refresher training for all SAMG roles (i.e. Implementors, Decision Makers, and Evaluators).

The site requirement is that each individual assigned to a SAMG position participate in a drill exercise at least once every four years.

Enclosure

42 ST. LUCIE TABLE OF RESULTS Letter Inspection Item Yes No Response/Comments or Number a When were the SAMGs last SAMG-01 (Phase 1 - Diagnostic) updated? was last updated in January 2011.

SAMG-02 (Phase 2 - Verification of Diagnosis) was last updated in June 2006.

SAMG-03 series & SAMG-04 (Phase 3 and Restorative SAMGs) were all last updated in March 2011.

Are controlled copies of the SAMG Y located in the technical support center (TSC)? (Y/N)

Are controlled copies of the SAMG Y Found one out of date revision of located in the emergency operations one of the controlled copies of the facility (EOF)? (Y/N) SAMG procedures in the EOF.

AR 01651884 was initiated.

Are controlled copies of the SAMG N Copies of the SAMGs were not located in the control room? (Y/N) located in the Unit 1 or Unit 2 Control Rooms. However, controlled copies were located in the TSC, which is adjacent to the Unit 1 Control Room.

b Are SAMGs covered by the Y Covered by licensees Administrative licensees procedure control and Procedure ADM-11.11 (Severe document management system, Accident Management Guidelines including the requirements for Program Administration) and FPL periodic review and revision? (Y/N) Nuclear Fleet Procedure AD-AA-100-1004 (Preparation, Revision, Review/Approval of Procedures).

Periodic reviews of SAMGs are to be completed once every 3 years per ADM-11.11.

c Does the licensees configuration Y Updates to the SAMGs are control and change management controlled by the normal procedure systems cause the licensee to control process per AD-AA-100-update SAMGs to reflect design 1004.

changes? (Y/N/Partially-describe) d Perform a high-level comparison of Y Site SAMGs are consistent with the the sites SAMGs with available owners group guidance (1995 industry guidance (e.g., owners Combustion Engineering Owners group guidance document and other Group) industry standards as applicable).

Enclosure

43 Letter Inspection Item Yes No Response/Comments or Number Are the SAMGs consistent with the owners group guidance (if any) having been incorporated (Y/N/comments)?

e How is training conducted on the 1. SAMG training is classroom and SAMGs? tabletop.

Who is trained on the SAMGs? 2. Plant staff assigned to work with SAMGs are assigned to specific What is the periodicity of training? Emergency Response Organization (ERO) position titles. These positions are:

Licensed Emergency Coordinator (EC), Technical Support Center (TSC) Reactor Engineer, TSC Electrical Problem Solving Team (PST) Representative, TSC Mechanical PST Rep, TSC Operations Coordinator, TSC PST Leader, TSC I&C PST Rep, TSC SRO PST Rep, TSC EC Assistant/Logkeeper, and Emergency Offsite Facility (EOF)

Nuclear Fuels Engineer. They receive initial and continuing training on SAMGs in accordance with ADM-11.11 (Severe Accident Management Guidelines Program Administration).

ADM 11.11 describes the training requirements as follows:

Initial

• Implementers - SAMG process training, including SAMG entry criteria

• Decision Makers - SAMG process training, including SAMG entry criteria; in-depth training in all the SAMG Enclosure

44 Letter Inspection Item Yes No Response/Comments or Number

• series procedures; post-accident plant response; and EOP use & contents

• Evaluators - Use of the Calculation Aids

• Implementers, Decision-Makers, and Evaluators -

table top drill or specialized coaching activity to ensure understanding of principles and techniques of SAMG Functional Roles.

Continuing training for Decision Makers, Evaluators, and Implementers is required at least every three calendar years per ADM-11.11.

f Interview 4 licensed operators (2 Personnel Interviewed:

reactor operators and 2 senior

• 2 SROs reactor operators), 2 TSC staff, and 2

• 2 ROs TSC managers assigned to apply the

• 2 TSC Evaluators (Problem SAMGs during an emergency to Solving Team members) determine:

• 2 TSC Emergency Coordinators (1) Did they receive initial training Y All individuals interviewed stated that on the SAMGs? (Y/N) they had received initial training in a classroom format including tabletops.

Did they receive periodic Y All individuals interviewed stated that training (Y/N/document they received periodic training either periodicity) on the SAMGs table top, classroom, or combination and how they relate to their of both.

assigned duties?

(2) Can they articulate their Y All individuals interviewed could responsibilities with respect articulate their responsibilities. The to the use of SAMGs main implementers would be those (Y/N/document who would in the TSC, with operators in the actually implement the Control Room providing a supporting licensees SAMGs)? role.

Enclosure

45 Letter Inspection Item Yes No Response/Comments or Number g Have there been periodic exercises Y Three of the last seven Emergency on the use of SAMGs by individuals Preparedness Drills have included who would implement them during an the use of the SAMG-01, Phase 1 emergency (Y/N/document Diagnostic (on 2/24/10, 10/7/09, and periodicity)? 3/11/09). There is no set periodicity.

Two TSC Problem Solving Team Table Top Exercises were performed on 3/19/11, which involved the use of SAMGs. Two b.5.b drills were performed on 3/19/11, which utilized SAMG-03J Appendix 4, Manually Depressurize Steam Generators and Use Portable Diesel Fire Pump, and SAMG-03J Appendix 6, Containment Flooding with the Portable Diesel Fire Pump. These b.5.b drills involved hooking up and routing b.5.b hoses. The activities performed on 3/18 and 3/19/11 were done in response to INPO IER 11-1.

Enclosure

46 SUMMER TABLE OF RESULTS Letter Inspection Item Yes No Response/Comments or Number a When were the SAMGs last The licensees plant specific, i.e.,

updated? Summer SAMG document, was titled Severe Accident Management Guideline (SAMG) Scope, Training, Users Guide and Guidelines, Revision 0D, dated 6/30/2003. While the document was last updated 6/30/2003, it was still based on the generic Westinghouse Owners Group (WOG) SAMG version MUHP-2313, dated 9/13/1996. The licensee incorporated the WOG SAMG into this plant specific document and included not only the WOG guidelines, but also station developed background and guidance for the training and rules of usage on the SAMGs.

Are controlled copies of the SAMG Y The inspectors obtained from the located in the technical support licensees document control center (TSC)? (Y/N) management system, a listing of where each controlled copy of the Summer SAMG document was supposed to be located. The inspectors verified the location of the controlled copies and found that, of the five controlled copies that were designated to be in the TSC, only one copy was found. This copy was found in the TSC Engineering support group area in an unmarked overhead storage cubicle. Two of the designated TSC copies were subsequently found in another building located in the Emergency Services Unit (i.e., Emergency Preparedness department) area.

Also, the inspectors identified that the controlled copy of the Summer SAMG designated for the Operations Support Center (OSC) and the copy designated for the plant simulator Enclosure

47 Letter Inspection Item Yes No Response/Comments or Number control room were not in their intended locations.

The inspectors reviewed licensee procedure Emergency Plan Procedure (EPP)-103, Emergency Equipment Checklist, Revision 9E, dated 12/20/2010, which contains a listing of equipment (including procedures) designated for each emergency response facility location.

The inspectors noted that EPP-103 did not include explicit direction that the Summer SAMG document be in any of the emergency response locations even though other emergency response procedures were listed.

The licensee initiated a condition report (i.e., CR-11-02600) to document these control copy discrepancy observations, as well as other general Summer SAMG implementation issues noted by the inspectors.

Are controlled copies of the SAMG Y No comments located in the emergency operations facility (EOF)? (Y/N)

Are controlled copies of the SAMG Y No comments located in the control room? (Y/N) b Are SAMGs covered by the Y The inspectors noted that the licensees procedure control and Summer SAMG document states that document management system, it was a guide and not a procedure, it including the requirements for was not intended to delineate periodic review and revision? (Y/N) administrative or safety-related requirements and the document was not considered a procedure subject to the station procedure review and approval control program, nor governed under 10CFR50.59 requirements, nor required to be reviewed by the station onsite safety Enclosure

48 Letter Inspection Item Yes No Response/Comments or Number review group (i.e., Plant Safety Review Committee).

The inspectors noted that Section 2.4, Assessment of SAMGs of the Summer SAMG document stated that the ESU department will conduct an assessment of the SAMG biennially which would be based on SAMG table top training results, training attendance, and input from SAMG feedback forms. The inspectors found that ESU was performing a limited assessment annually, however, this assessment was only on the SAMG guideline itself. Also, only a few SAMG feedback forms had been submitted over the past years, with the date of the last one in 2003.

c Does the licensees configuration N The inspectors noted that Section control and change management 2.3, Guideline Development, Review systems cause the licensee to and Approval, of the Summer SAMG update SAMGs to reflect design document stated the following:

changes? (Y/N/Partially-describe)

A committee with members from Operations Procedure Group, Design Engineering and ESU will review SAMG setpoints and calculation aids for changes required due to modifications, etc. This will be performed annually during the calendar year, typically in the first quarter. The committee will initiate a SAMG feedback form if required.

Based on interviews with licensee personnel in the ESU department and from operations and design engineering, the inspectors found that currently, there was no committee officially operating that was implementing the activities as intended in Section 2.3. The licensee included this observation in Enclosure

49 Letter Inspection Item Yes No Response/Comments or Number CR-11-02600. The inspectors also reviewed the station modification program procedures and found no formal expectation that the Summer SAMG be reviewed for impact as part the process for making plant design modification changes.

d Perform a high-level comparison of N As previously discussed in Section a.

the sites SAMGs with available of this table, the current revision of industry guidance (e.g., owners the licensees SAMG was based on group guidance document and version MUHP-2313, dated other industry standards as 9/13/1996, of the generic WOG applicable). Are the SAMGs SAMG. The inspectors determined consistent with the owners group that the latest WOG SAMG is version guidance (if any) having been MUHP-2315, dated October 2001.

incorporated (Y/N/comments)? The licensee acknowledged that they had not updated their Summer SAMG document with the latest WOG version and planned to evaluate this as part of their evaluation in CR-11-02600.

e How is training conducted on the The Summer SAMG document SAMGs? contained a detailed description of the SAMG training programs. The Who is trained on the SAMGs? training program was based on three categories of personnel that would What is the periodicity of training? be involved with implementing the SAMGs, i.e., decision makers, evaluators (or assistant evaluators),

and implementors. The position title of decision maker was given to individuals assigned as either the Emergency Director positions or Interim Emergency Director positions of the emergency response organization. Evaluators were designated as TSC Operations Engineers or TSC Engineering positions. Implementors were designated as the control room staff personnel (i.e., senior reactor and reactor operator positions). Specific initial and continuing training programs were setup for each of Enclosure

50 Letter Inspection Item Yes No Response/Comments or Number these three groups. For initial training, training modules were developed for each SAMG guideline document and the training requirements included either classroom table-top training, or self-study read and sign of the SAMGs.

Continuing training requirements included similar training activities that were required to be completed every two years. The inspectors reviewed training records for the three positions and determined that continuing training was being conducted at the prescribed frequency; however, the training was limited to personnel read and sign of the SAMGs versus classroom training or the use of table top instructional training aids. The last SAMG table top conducted was found to have taken place in 2003.

f Interview 4 licensed operators (2 The inspectors interviewed two reactor operators and 2 senior senior reactor operators, two reactor reactor operators), 2 TSC staff, operators, two TSC engineering staff, and 2 TSC managers assigned to and two TSC managers assigned to apply the SAMGs during an apply the SAMGs during an emergency to determine: emergency.

(1) Did they receive initial Y No comments training on the SAMGs?

(Y/N)

Did they receive periodic Y training (Y/N/document See (e) above periodicity) on the SAMGs and how they relate to their assigned duties?

(2) Can they articulate their Y responsibilities with respect to the use of SAMGs See (e) above (Y/N/document who would actually implement the licensees SAMGs)?

Enclosure

51 Letter Inspection Item Yes No Response/Comments or Number g Have there been periodic exercises N The inspectors noted that Section on the use of SAMGs by 4.7, Table Top Drills, of the individuals who would implement Summer SAMG states that one TSC them during an emergency table top drill will normally be (Y/N/document periodicity)? conducted each calendar year and the decision makers and evaluators from all teams will participate in a SAMG table top drill once every five years. However, based on interviews with the ESU Manager, a table top drill had not been conducted since 2003. The ESU Manager indicated that plans were being developed to start implementing table tops in the near future.

Enclosure

52 SURRY TABLE OF RESULTS Letter or Inspection Item Yes No Response/Comments Number a When were the SAMGs last April 12, 2011 based on changes updated? recommended after walkdowns performed as a response to INPO IER L1 11-1.

Are controlled copies of the SAMG Y VPAP-2604, Severe Accident located in the technical support Management Guideline (SAMG) center (TSC)? (Y/N) Program Administration, step 6.6.2 requires copies of all SAMGs to be kept in the TSC, local EOF (LEOF),

and corporate EOF (CEOF).

However, the inspector found that uncontrolled binders of SAMG procedures, none of which were the current revision, were being stored in the TSC, MCR, and LEOF. The uncontrolled binders were marked SAMG Procedures while the controlled binder was marked B.5.b Procedures and also included B.5.b material. The binder markings caused multiple licensee personnel to erroneously identify the out of date SAMGs as being the correct copies.

The licensee has removed the uncontrolled procedures and updated the marking on the controlled procedure binder. This issue has been entered this issue into the licensees CAP as CR 427889.

Are controlled copies of the SAMG Y See above.

located in the emergency operations facility (EOF)? (Y/N)

Are controlled copies of the SAMG Y VPAP-2604, Severe Accident located in the control room? (Y/N) Management Guideline (SAMG)

Program Administration, Step 6.6.1 requires copies of SACRGs only, to be kept in the MCR and simulator.

See the discrepancy noted above.

Enclosure

53 Letter or Inspection Item Yes No Response/Comments Number b Are SAMGs covered by the N VPAP-2604, Severe Accident licensees procedure control and Management Guideline (SAMG) document management system, Program Administration, provides including the requirements for instructions for development, periodic review and revision? (Y/N) revision, approval, training, and distribution of SAMG procedures.

VPAP-2604, Section 6.2, Review, requires SAMGs to conform with VPAP-0502, Procedure Process Control, which does not require a periodic review for non safety related procedures. The SAMGs are not safety related. The inspector found no program that specified a review and revision on a regular periodic frequency, e.g., yearly.

c Does the licensees configuration Y SAMG procedures are included in control and change management the scoping for revision as a result of systems cause the licensee to design changes. These changes are update SAMGs to reflect design typically made to coincide with changes? (Y/N/Partially-describe) changes to SM-1497, Severe Accident Management Guidelines (SAMG) Setpoints and Computational Aids, Surry Power Station Unit 1 and Unit 2, which is developed by the Nuclear Safety Analysis group. Recent examples of updates due to design changes include: the GSI-191 Containment Sump Modifications and the Measurement Uncertainty Recapture (MUR) Power Upgrade.

Westinghouse Owners Group Severe Accident Management Guideline, Revision 1, was incorporated with the MUR changes.

Enclosure

54 Letter or Inspection Item Yes No Response/Comments Number d Perform a high-level comparison of Y The Surry SAMGs are consistent the sites SAMGs with available with the latest revision WOG industry guidance (e.g., owners guidance and this is also required by group guidance document and other VPAP-2604, Severe Accident industry standards as applicable). Management Guideline (SAMG)

Are the SAMGs consistent with the Program Administration, step 6.1.1, owners group guidance (if any) which also requires written having been incorporated justification for deviations from the (Y/N/comments)? WOG SAMGs.

e How is training conducted on the Initial and refresher training SAMGs? requirements will include either classroom or self-study training Who is trained on the SAMGs? followed by participation in a table top drill. Recently, due to advances What is the periodicity of training? in simulator modeling of advanced accident phenomenology, the licensee has started instituting simulator training on the SAMGs for both initial and refresher training, although the use of the simulator for SAMG training is not a requirement.

[VPAP 2604,steps 6.5.5, 6.5.6]

The licensees procedures define three designated SAMG positions, which are based off of the WOG SAMGs: Decision Maker, Implementer, and Evaluator. All licensed operators and STAs are at least Implementers, SROs with an ERO manager role also receive Decision Maker training. ERO team members with extensive engineering experience are trained as Evaluators and other top site managers with ERO management roles are Decision Maker trained. [VPAP 2604,steps 6.5.1, 6.5.2, 6.5.3]

Personnel newly assigned to an ERO position are required to complete SAMG training within 6 months of their assignment.

Refresher training is required once Enclosure

55 Letter Inspection Item Yes No Response/Comments or Number every three calendar years. [VPAP 2604,steps 6.5.5, 6.5.6]

f Interview 4 licensed operators (2 reactor operators and 2 senior reactor operators), 2 TSC staff, and 2 TSC managers assigned to apply the SAMGs during an emergency to determine:

(1) Did they receive initial Y IAW VPAP 2604, step 6.5.5 as training on the SAMGs? (Y/N) described in part (e) above.

Did they receive periodic Y IAW VPAP 2604, step 6.5.6 as training (Y/N/document described in part (e) above. With periodicity) on the SAMGs and the exception that some individuals how they relate to their interviewed had been first licensed assigned duties? in the past 3 years and had not yet received their first refresher training.

(2) Can they articulate their Y To the various levels of detail given responsibilities with respect to their experience, all individuals the use of SAMGs interviewed were able to express (Y/N/document who would their responsibilities as they pertain actually implement the to the SAMGs during an event.

licensees SAMGs)?

g Have there been periodic exercises Y The licensee does not incorporate on the use of SAMGs by individuals SAMGs in their normal emergency who would implement them during preparedness drills or exercises.

an emergency (Y/N/document Rather, the licensee performs periodicity)? training using the classroom setting for formal presentations and or table-top drills as specified IAW VPAP 2604, step 6.5.6 as described in part (e) above, i.e. refresher training.

Enclosure

56 TURKEY POINT TABLE OF RESULTS Letter Inspection Item Yes No Response/Comments or Number a When were the SAMGs last CA Computational Aids - 2009 updated? DFC-TSC diagnostic flow chart-2002 SACRG-1 Severe Accident Control Room Guideline Initial Response-2011 SACRG-2 Severe Accident Control Room Guideline-2011 SAG-1 Injection into Steam Generators-2011 SAG-2 Depressurize the RCS-2011 SAG-3 Injection into the RCS-2002 SAG-4 Injection into Containment-2010 SAG-5 Reduce Fission Product Releases-2011 SAG-6 Control Containment conditions-2002 SAG-7 Reduce Containment Hydrogen-2002 SAG-8 Flood Containment-2011 SCG-1 Mitigate Fission Product Releases-2002 SCG-2 Depressurize Containment-2002 SCG-3 Control Hydrogen Flammability- 2002 SCG-4 Control Containment Vacuum-2002 SAEG-1 TSC Long Term Monitoring-2002 SAEG-2 SAMG Termination-2002 SCST-Severe Challenge Status Tree-2002 Are controlled copies of the SAMG Y YES-all listed above located in the technical support center (TSC)? (Y/N)

Are controlled copies of the SAMG Y YES-all listed above located in the emergency operations facility (EOF)? (Y/N)

Enclosure

57 Letter Inspection Item Yes No Response/Comments or Number Are controlled copies of the SAMG Y Specifically SACRG-1, SACRG-2, located in the control room? (Y/N) CA Computational Aid. These are the only procedures of the SAMGs the control room uses and implements prior to TSC becoming functional. A complete set of SAMG procedures are located in the TSC and the EOF.

b Are SAMGs covered by the N SAMGs are controlled in accordance licensees procedure control and with Fleet standard procedure AD-document management system, AA-100-1004, Preparation, including the requirements for Revision/Approval of Procedures.

periodic review and revision? (Y/N) There are no periodic review requirements as identified in the Quality Assurance Topical Report.

c Does the licensees configuration N No. A condition report has been control and change management written to address this issue, to systems cause the licensee to include SAMG impact as part of update SAMGs to reflect design modification process.

changes? (Y/N/Partially-describe) d Perform a high-level comparison of Y Yes, a comparison was performed the sites SAMGs with available between Westinghouse Owners industry guidance (e.g., owners Group SAMGs Rev. 0 reference group guidance document and other documents (onsite) and the site industry standards as applicable). SAMGs and they were found to be Are the SAMGs consistent with the consistent with the WOG guidance.

owners group guidance (if any) having been incorporated (Y/N/comments)?

e How is training conducted on the All Operations (both licensed and SAMGs? non-licensed) and Engineering personnel receive SAGs training in Who is trained on the SAMGs? their Initial Training Programs along with others as assigned by the What is the periodicity of training? Emergency Planning group.

Licensed operators receive biennial training in their Continuing Training Program. Engineers receive biennial training on the SAGs. This training can be tabletop exercises, review of overall program, specific awareness training of various guidelines and tools or other training as delineated by their Training Review Committee.

The engineers to be assigned to the Enclosure

58 Letter Inspection Item Yes No Response/Comments or Number TSC as SAG evaluator will receive direction from their manager to review and become familiar with all SAG tools they are required to use in the TSC. This must be done before they are assigned to the TSC by EP.

Joint tabletops with evaluators, decision makers, and implementers have been performed to test the SAGs. A web based SAG overview training module was developed for annual training for assignment per EP to site personnel.

f Interview 4 licensed operators (2 a. RO#1 reactor operators and 2 senior b. RO#2 reactor operators), 2 TSC staff, and 2 c. SRO#1 (Shift Manager)

TSC managers assigned to apply the d. SRO#2 (Unit Supervisor)

SAMGs during an emergency to e. TSC Lead Engineer determine: f. TSC Lead Engineer

g. TSC Emergency Coordinator

h. TSC Operations Manager (1) Did they receive initial training Y Yes, with one exception: **RO #2 on the SAMGs? (Y/N) did not receive initial training on SAMGs Did they receive periodic Y All personnel receive periodic training (Y/N/document training on SAMGs every 2 years.

periodicity) on the SAMGs and how they relate to their assigned duties?

(2) Can they articulate their Y All personnel interviewed were able responsibilities with respect to to articulate their responsibilities; the use of SAMGs individual responsibilities are (Y/N/document who would described below for each actually implement the interviewee.

licensees SAMGs)? a. Follow and implement SACRGs

b. Follow and implement SACRGs

c. Oversight, take recommendations from TSC and implement recommendations in the control room Enclosure

59 Letter Inspection Item Yes No Response/Comments or Number

d. Direct/implement the SACRGs and SAGs in the control room with the ROs

e. Delegate to tech staff in TSC for recommendations, also review SAGs and SACRGs and make recommendations to Emergency Coordinator

f. Make recommendations to Emergency Coordinator, provide oversight to engineering staff using SAGs and SACRGs

g. Assume responsibility from control room EC and lead SAGs implementation in coordination with EOF and Operational Support Center

h. Coordinate with TSC EC to make recommendations, request assistance from Operational Support Center as determined by procedure and plant conditions an implement SAMGs from TSC g Have there been periodic exercises N Emergency Preparedness Drills are on the use of SAMGs by individuals terminated at or prior to SAMG entry.

who would implement them during an emergency (Y/N/document periodicity)?

Enclosure

60 VOGTLE TABLE OF RESULTS Letter Inspection Item Yes No Response/Comments or Number a When were the SAMGs last Procedures are reviewed on a updated? biennial basis with revisions being made as required by site procedures.

All procedures except one (SAEG-1) were verified within the two year periodicity for biennial update.

SAEG-1 last updated in December 2007. CR 2011107234 initiated to document deficiency.

Are controlled copies of the SAMG Y located in the technical support center (TSC)? (Y/N)

Are controlled copies of the SAMG N Procedure 91900-C, Control and Use located in the emergency operations of Severe Accident Management facility (EOF)? (Y/N) Guidelines, section 4.3.2, required hardcopies to be in the EOF.

Controlled hardcopies are not located in the EOF. Electronic versions are available on both Webtop application and a stand-alone computer terminal. CR 2011107135 initiated to document deficiency.

Are controlled copies of the SAMG Y Only SACRG-1 and SACRG-2.

located in the control room? (Y/N) b Are SAMGs covered by the Y licensees procedure control and document management system, including the requirements for periodic review and revision? (Y/N) c Does the licensees configuration Y Site procedure NMP-ES-022-F07, control and change management Impact Review Evaluation Form systems cause the licensee to specifically lists SAMG procedures update SAMGs to reflect design impact under section B: Operations changes? (Y/N/Partially-describe) Impact Review Evaluation.

d Perform a high-level comparison of Y the sites SAMGs with available industry guidance (e.g., owners group guidance document and other industry standards as applicable).

Enclosure

61 Letter Inspection Item Yes No Response/Comments or Number Are the SAMGs consistent with the owners group guidance (if any) having been incorporated? (Y/N) e How is training conducted on the Both initial and continuing SAMG SAMGs? training is provided to both licensed operators (Implementers) and Who is trained on the SAMGs? designated TSC staff members (Evaluator/Decision Makers). All What is the periodicity of training? SRO candidates receive SAMG training as part of their initial license training program and then every two years during requalification training.

All TSC Emergency Directors, TSC Managers, Operations Supervisors and Engineering Supervisors receive initial SAMG training through the ERO qualification process then every two years as refresher training.

f Interview 4 licensed operators (2 reactor operators and 2 senior reactor operators), 2 TSC staff, and 2 TSC managers assigned to apply the SAMGs during an emergency to determine:

(1) Did they receive initial training Y on the SAMGs? (Y/N)

Did they receive periodic Y Every two years.

training (Y/N/document periodicity) on the SAMGs and how they relate to their assigned duties?

(2) Can they articulate their Y Control room operators i.e. shift responsibilities with respect to supervisor would implement SAMG the use of SAMGs (Y/N/ procedures as directed by TSC staff.

document who would actually implement the licensees SAMGs)?

g Have there been periodic exercises Y Table top exercises are conducted on the use of SAMGs by individuals annually during continuing training who would implement them during an cycles. SAMG exercises are not emergency (Y/N/document performed during licensed operator periodicity)? requalification simulator scenarios and/or scheduled EP drills. CR 2011-107136 initiated to document deficiency.

Enclosure

62 WATTS BAR TABLE OF RESULTS Letter Inspection Item Yes No Response/Comments or Number a When were the SAMGs last Oldest update - 12/03/2010 updated? Newest update - 02/02/2011 All other procedures in between these two dates.

Are controlled copies of the SAMG Y All 25 SAMG procedures are in the located in the technical support TSC controlled copy # 000746 center (TSC)? (Y/N)

Are controlled copies of the SAMG Y All 25 SAMG procedures are in the located in the emergency operations CECC (EOF) controlled copy #

facility (EOF)? (Y/N) 000846 Are controlled copies of the SAMG Y All 25 SAMG procedures are in the located in the control room? (Y/N) Control Room controlled copy #

000747 b Are SAMGs covered by the Y Controlled by NPG-SPP-18.3.1, Rev licensees procedure control and 0, Severe Accident Management document management system, Guideline (SAMG) Program including the requirements for Administration, Section 3.2, periodic review and revision? (Y/N) Guideline Revision, Review, and Approval c Does the licensees configuration Y Controlled by NPG-SPP-09.3, Rev 4, control and change management Plant Modifications and Engineering systems cause the licensee to Change Control, Section 3.1.4B, update SAMGs to reflect design Design Development which directs changes? (Y/N/Partially-describe) preparer to Appendix D, Potential Effects on Design of this procedure, item 42, Severe Accident Management Guideline (SAMG)

Program Impact (eg, change to ECCS setpoints, plant power)

d. Perform a high-level comparison of Y The site SAMGs are based on the the sites SAMGs with available generic owners group reference industry guidance (e.g., owners plant configuration and generic group guidance document and other IPE/PSA studies and insights. Site industry standards as applicable). specific equipment and alignments, Are the SAMGs consistent with the IPE insights, and capabilities are owners group guidance (if any) incorporated into the generic owners having been incorporated group guidance in producing the site-(Y/N/comments)? specific SAMGs.

Enclosure

63 Letter Inspection Item Yes No Response/Comments or Number A high level review by the residents determined that the above plant philosophy for procedure development had been implemented.

Two exceptions in format are SACRG-1, Severe Accident Control Room Guideline Initial Response and SACRG-2, Severe Accident Control Room Guideline for Transients After the TSC is Functional which are written in a standard 2 column format for EOP/AOPs. The balance of the procedures are consistent w/ the WOG generic material. Inspectors expected the numbers to be less conservative than design basis numbers, but some of the numbers may not be realistic. For example; containment design pressure is 13.5 psig and SAMG pressure is 56 psig, containment design vacuum is -2 psig w/ - 4 psig in the SAMG. This will require follow-up and more time than is available for the TI. Also, one procedure was not utilized by the licensee, SAG-8, Flood Containment.

They have a justification which looks reasonable, but not verified.

• • See item below table e How is training conducted on the How:

SAMGs? Training is conducted per TRN-34, Severe Accident Management Who is trained on the SAMGs? Training.

Who:

What is the periodicity of training? Implementers - Responsible for performing those steps necessary to accomplish the objectives of the strategies (e.g., hands-on control of valves, breakers, controller, and special equipment). (Control Room Staff and OPS Support Center Advisor)

Decision Makers - Designated to assess and select the strategies to Enclosure

64 Letter Inspection Item Yes No Response/Comments or Number be implemented. (Site Emergency Director)

Evaluators - Responsible for assessing plant symptoms in order to determine the plant damage conditions(s) of interest and potential strategies that may be utilized to mitigate an event. (Technical Assessment Team)

• See items listed below table Periodicity: 4 years f Interview 4 licensed operators (2 reactor operators and 2 senior reactor operators), 2 TSC staff, and 2 TSC managers assigned to apply the SAMGs during an emergency to determine:

(1) Did they receive initial training Y Last training was received in 2009 on the SAMGs? (Y/N) for the technical staff. Operations initial training was some years ago.

Interviews w/ some recently licensed RO and SROs indicates that they received the training as part of gap training. Gap is the difference between initial license training and requal.

Did they receive periodic Y Operations and Engineering get training (Y/N/document SAMG at least once per 4 years.

periodicity) on the SAMGs and Most of the training is classroom and how they relate to their is more abstract w/ the relation to assigned duties? specific duties. Those that have participated in tabletop exercises receive a more practical concept of the relationship of training to duties (2) Can they articulate their Y The Engineers had an idea, but responsibilities with respect to would most likely need some specific the use of SAMGs direction from the operational (Y/N/document who would personnel in the TSC to focus them actually implement the on the correct tasks. Operations licensees SAMGs)? appears to have a better understanding w/ regards to 50.54x and how the shift from EOPs to SAMGs occurs.

Enclosure

65 Letter Inspection Item Yes No Response/Comments or Number g Have there been periodic exercises Y Classroom training includes some on the use of SAMGs by individuals tabletop exercises. Recently, March who would implement them during an of 2011, a separate table top emergency (Y/N/document exercise was done w/ one of the periodicity)? Emergency Response Staffs.

Inspectors were told by the EP Manager that he planned to make these type exercises periodic (no commitment).

• PER 342222 Enhancement Recommendation: SAMG training is specified in TRN-34, Severe Accident Management, for certain responders to the Technical Support Center (TSC) and the Operations Support Center (OSC). However, this training requirement is not specified in TRN-30, Emergency Preparedness Training. This has led to 8 of 33 ERO members specified in TRN-34 to be assigned to their ERO position without the training or has allowed their SAMG qualifications to lapse.

NOTE: Included in the above, inspectors determined that 2 of the 4 Site Emergency Directors had not had SAMG training. The other two are SROs or former SROs who have had a history of training in the area. The two which have not had the training are the Training Manager and the Unit1/Unit2 Interface Manager.

• PER 342322 TRN-34, Severe Accident Management Training, does not require any SAMG training for the TSC Ops Manager. TRN-34 does not require any SAMG training for the TSC Operations Manager. Consideration should be given to requiring that the TSC Operations Manager at all 3 sites be trained and qualified as a SAMG Decision Maker, since the only person in the TSC required to be trained and qualified as a decision maker is the SED. This arrangement leaves the SED in the TSC with no one trained and qualified to provide a peer check or independent verification for the SED when performing the SAMGs

• • PER 352687, The H2 Recombiners were removed from Technical Specifications, and there is a DCN in place to remove them from service. Surveillance Instructions are no longer being performed on the H2 Recombiners, and the PMs are not being maintained current. The U1 B-Train Recombiner has a ground on the heater that makes it non-functional. The recombiners are used as a strategy for controlling H2 in the context of the SAMGs. Specifically, procedures SAG-7 and SCG-1 address using the H2 recombiners during Severe Accident Scenarios.

Enclosure