IR 05000454/2020004

Integrated Inspection Report 05000454/2020004 and 05000455/2020004

ML21027A195
Person / Time
Site:	Byron
Issue date:	01/27/2021
From:	Hironori Peterson Region 3 Branch 3
To:	Rhoades D Exelon Generation Co, Exelon Nuclear
References
IR 2020004
Download: ML21027A195 (25)

Text

January 27, 2021

SUBJECT:

BYRON STATION - INTEGRATED INSPECTION REPORT 05000454/2020004 AND 05000455/2020004

Dear Mr. Rhoades:

On December 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Byron Station. On January 13, 2021, the NRC inspectors discussed the results of this inspection with Mr. M. Kanavos, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

No findings or violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Hironori Peterson, Chief Branch 3 Division of Reactor Projects Docket Nos. 05000454 and 05000455 License Nos. NPF-37 and NPF-66

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000454 and 05000455 License Numbers: NPF-37 and NPF-66 Report Numbers: 05000454/2020004 and 05000455/2020004 Enterprise Identifier: I-2020-004-0025 Licensee: Exelon Generation Company, LLC Facility: Byron Station Location: Byron, IL Inspection Dates: October 1, 2020 to December 31, 2020 Inspectors: D. Betancourt-Roldan, Senior Resident Inspector J. Bozga, Senior Reactor Inspector J. Cassidy, Senior Health Physicist M. Garza, Emergency Preparedness Inspector G. Hansen, Sr. Emergency Preparedness Inspector C. Hunt, Senior Resident Inspector D. Kimble, Senior Resident Inspector J. Park, Reactor Inspector P. Smagacz, Resident Inspector C. Thompson, Illinois Emergency Management Agency Approved By: Hironori Peterson, Chief Branch 3 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Byron Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

PLANT STATUS

Unit 1 began the inspection period operating at full power. With the exception of minor reductions in power to support scheduled testing activities or load changes requested by the transmission dispatcher, the unit remained at or near full power for the entire inspection period.

Unit 2 began the inspection period operating at 75 percent power and was in coast down for a scheduled refueling outage. On October 5, 2020, the unit began a refueling outage. The unit went critical again on October 19, 2020. The unit was returned to full power on October 20, 2020. With the exception of minor reductions in power to support scheduled testing activities, and load changes requested by the transmission dispatcher the unit remained at or near full power for the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the Coronavirus Disease 2019 (COVID-19),resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week; conducted plant status activities as described in IMC 2515, Appendix D, Plant Status; observed risk-significant activities; and completed on-site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on-site. The inspections documented below met the objectives and requirements for completion of the IP.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Low temperature over pressure system on October 6, 2020

(2) Fuel pool cooling and cleanup system while defueling on October 8, 2020

(3) Residual heat removal (RH) system while refueling on October 12, 2020

(4) 1A Auxiliary Feedwater (AF) train with 2B AF pump out of service for scheduled maintenance on November 12, 2020

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the 1B diesel generator (DG) on November 22, 2020.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Fire Zone (FZ) 12.1-0, fuel handling building, 401' elevation on October 8, 2020

(2) FZ 11.2A-2, 2A RH room on October 12, 2020

(3) FZ 9.2-2, 2A DG and day tank room on October 15, 2020

71111.08P - Inservice Inspection Activities (PWR) PWR Inservice Inspection Activities Sample (IP Section 03.01)

(1) The inspectors verified the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary were appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing documentation for the following activities from October 5, 2020 to October 16, 2020:

03.01.a - Nondestructive Examination and Welding Activities.

• Ultrasonic (UT) and visual (VT) examinations of component 2RC14AD-2 using procedures PDI-UT-2 and ER-AA-335-015-2013

• UT and VT examinations of component 2RC37A-3 using procedures PDI-UT-2 and ER-AA-335-015-2013

• Report No. B2R21-MT-001, Component ID 2RC-01-BA/SGN-02, with relevant indications identified during prior outage accepted for continued service

• Pressure boundary welds 1 and 2 fabricated during elbow replacement on 2SXE5A-3" under Work Order 04826853-01

• Pressure boundary welds 1 and 3 fabricated during repair of 2SXL1AA-4" under Work Order 04899280-01 03.01.b - Pressurized-Water Reactor Vessel Upper Head Penetration Examination Activities.

• Liquid penetrant (PT) surface examination of reactor upper head penetrations No. 6 and 68 using procedure ER-AA-335-002

• Bare metal visual (VT) examination of reactor upper head penetrations No. 1, 24, 45, 60 and 76 using procedure ER-AP-335-001 03.01.c - Pressurized-Water Reactor Boric Acid Corrosion Control Activities.

• Boric Acid Leakage Evaluation of Component ID 2RH8703B, IR 04238047

• Boric Acid Leakage Evaluation of Component ID 2CV8444, IR 04280514

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

Requalification Examination Results (IP Section 03.03) (1 Sample)

(1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam administered from September 17, 2020 to December 4, 2020.

71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)

(1) Biennial Requalification Written Examinations The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered on November 20, 2020.

Annual Requalification Operating Tests The inspectors evaluated the adequacy of the facility licensees annual requalification operating test.

Administration of an Annual Requalification Operating Test The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.

Requalification Examination Security The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.

Remedial Training and Re-examinations The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.

Operator License Conditions The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.

Control Room Simulator The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.

Problem Identification and Resolution The inspectors evaluated the licensees ability to identify and resolve problems associated with licensed operator performance.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the Control Room during refueling outage U2R22 from October 4 through October 7, 2020, including:

• Shutdown evolutions

• Emergency core cooling system full flow testing

• Reactor head lift

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated licensed operator annual requalification training on November 3, 2020.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) 2B AF pump on November 2, 2020

(2) Unit 2 diesel fuel oil transfer system on December 16, 2020

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (2 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Unit 2 yellow shutdown safety window with pressurizer level < 5 percent and short time to boil on October 6, 2020

(2) 2PS9356B is not operable as documented in Action Request (AR) 04377380 on October 18, 2020

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (8 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) 1B turbine driven feedwater stop valve test as documented in AR 04372705 on October 1, 2020

(2) Nuclear instrument N32 spiking as documented in AR 04374650 on October 6, 2020

(3) 2B reactor coolant pump (RCP) oil leaks as documented in AR 04374472 on October 8, 2020

(4) Valve 2SI8807B, will not open as documented in AR 04375187 on October 8, 2020.

(5) Fuel moves suspended due to TRM 3.9a decay time requirements as documented in AR 04375665 on October 10, 2020

(6) 2SX02K heat exchanger failed GL 89-13 acceptance criteria as documented in AR 04375807 on October 13, 2020

(7) 2DG01KB-X2 lower jacket water cooler leaking 2B DG as documented in AR 04376393 on October 14, 2020

(8) Through wall leak branch leg of tee with lines 1SX311B-6 and 1SXA3A-6 as documented in AR 04392079 on December 30, 2020

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (8 Samples)

The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:

(1) Valve 2SI8807B will not open as set forth in Work Order (WO) 05085974 on October 13, 2020

(2) TS/Repair 2RH606 valve positioner as set forth in WO 05086643 on October 13, 2020

(3) Valve 2RH610 not functioning in auto as set forth in WO 05084875 on October 13, 2020

(4) 2BOSR 5.5.8.CV.5-2A, Group A Inservice Testing (IST) requirements for 2B charging pump 2CV01PB, revision 12, following maintenance on October 14, 2020

(5) 2B AF pump as set forth in WO 4649471 following maintenance on October 15, 2020

(6) 2B RCP following repair on October 14, 2020

(7) SPP-20-016, Ovation U2 N-Outage MAT, Revision 0 on October 15, 2020

(8) Low power physics testing as set forth in WO 04915374 on October 19, 2020

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated refueling outage U2R22 activities from October 5 through October 24, 2020.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) Main steam safety valve operability test as set forth in WO 04911628 on October 2, 2020

(2) Local leak-rate test (LLRT) for P-47; 2RF026, 2RF027, and 2RF055 as set forth in WO 0491196 on October 13, 2020

71114.02 - Alert and Notification System Testing

Inspection Review (IP Section 02.01-02.04) (1 Sample)

(1) The inspectors evaluated the following maintenance and testing of the alert and notification system:

• Annual siren inspection and maintenance records for the period from September 2018 to September 2020.

• Monthly alert notification system (siren) tests for the period from September 2018 to September 2020.

71114.03 - Emergency Response Organization Staffing and Augmentation System

Inspection Review (IP Section 02.01-02.02) (1 Sample)

(1) The inspectors evaluated the readiness of the Emergency Preparedness Organization.

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The inspectors completed an evaluation of submitted emergency action level and emergency plan changes on December 2, 2020. This evaluation does not constitute NRC approval.

71114.05 - Maintenance of Emergency Preparedness

Inspection Review (IP Section 02.01 - 02.11) (1 Sample)

(1) The inspectors evaluated the maintenance of the emergency preparedness program.

71124.01 - Radiological Hazard Assessment and Exposure Controls

Instructions to Workers (IP Section 03.02) (1 Partial)

(1) (Partial)

The inspectors evaluated radiological protection-related instructions to plant workers.

However, the completion of the sample requires direct inspector observations which could not be performed due to COVID-19 restrictions.

71124.04 - Occupational Dose Assessment

Source Term Characterization (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.

External Dosimetry (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to external dosimetry that is used to assign occupational dose.

Internal Dosimetry (IP Section 03.03) (1 Sample)

The inspectors evaluated the following internal dose assessments for actual internal exposures:

(1) Dose assessment for an individual potentially exposed to airborne radioactivity during temporary ventilation system malfunction in the Unit 1 containment on

===March 14, 2020.

Special Dosimetric Situations (IP Section 03.04) (1 Sample)===

The inspectors evaluated the following special dosimetric situations:

(1) Effective Dose Equivalent for External Exposures related to Control Rod Drive Mechanism (CRDM) Inspections on Radiation Work Permit (RWP) BY-1-20-0067 (Task 1).

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

EP01: Drill/Exercise Performance (IP Section 02.12) ===

(1) January 1, 2019 - June 30, 2020

EP02: ERO Drill Participation (IP Section 02.13) (1 Sample)

(1) January 1, 2019 - June 30, 2020

EP03: Alert & Notification System Reliability (IP Section 02.14) (1 Sample)

(1) January 1, 2019 - June 30, 2020

BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)

(1) Unit 1 (October 1, 2019 - September 30, 2020)

(2) Unit 2 (October 1, 2019 - September 30, 2020)

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) April 2019 - September 2020

71152 - Problem Identification and Resolution

Semiannual Trend Review (IP Section 02.02) (1 Sample)

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends in GL 89-13 heat exchanger (HX) failures that might be indicative of a more significant safety issue on November 10, 2020.

Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) RCCA R785 has a bent rodlet as documented in IR 04375784 on October 16,

INSPECTION RESULTS

Observation: Rod Cluster Control Assembly R785 has a bent rodlet 71152 On October 10, 2020, during insert shuffles in support of the Unit 2 refueling outage, while attempting to insert a Rod Cluster Control Assembly (RCCA) into the host assembly the crew observed a rodlet bending and immediately stopped the evolution. The licensee inspected the affected RCCA and made the decision to remove it from service. The licensee performed inspections of the RCCA tool visually and functionally, as well as the associated fuel assemblies, and did not identify any additional issues. After inspections were completed, the licensee resumed transferring the other 24 RCCAs without incident, including a replacement for the damaged RCCA.

In conjunction with the fuel vendor, the licensee chose a suitable RCCA for replacement after evaluating the available RCCAs in the spent fuel pool. The evaluation included mechanical integrity testing, to include a visual inspection and a drag test. The fuel vendor also performed an engineering evaluation to support the lifetime extension of the chosen RCCA for one additional refueling cycle. The evaluation included an evaluation of swelling, mechanical wear, risk of potential manufacturing issues, and corrosion. The vendor concluded that the chosen RCCA was an acceptable replacement for use provided it not be used in a shutdown bank, the RCCA be parked at 231 steps or at 225 steps for the upcoming cycle, and that the exposure for the RCCA does not exceed 16 effective full power years.

On November 22, 2020, while performing training with a dummy fuel assembly and dummy RCCA, the licensee observed a similar bending of a rodlet while lowering the RCCA into the assembly. The licensee removed the RCCA tool from service pending an investigation of the tool by the vendor.

The inspectors reviewed the corrective action program (CAP) causal evaluation performed by the licensee for the initial occurrence of the rodlet bending during insert shuffles. The inspectors determined that the actions taken by the licensee were commensurate with the safety significance of the issue and in accordance with site procedures. The inspectors reviewed the engineering evaluation on the replacement RCCA chosen from the spent fuel pool and concluded that there is reasonable assurance that the replacement RCCA will perform as required for the upcoming cycle. At the time of this report, the investigation of the RCCA tool by the vendor is scheduled to be complete in February of 2021 and is being tracked in the licensee's CAP.

The inspectors did not identify any findings or violations during this inspection sample.

Observation: Generic Letter 89-13 Heat Exchanger Inspection Failures 71152 Inspectors performed a semi-annual trend review of as-found heat exchanger inspections performed by the licensee between May 1, 2020, and December 15, 2020. Inspections were performed in accordance with licensee procedure BVP 800-30, Essential Service Water Fouling Monitoring Program, which is the licensee's Generic Letter (GL) 89-13 program basis document and identifies the procedures and methodology used to control and monitor fouling of the safety related service water system piping, components, and heat exchangers at Byron in accordance with the licensees official response to NRC. Over this time period, the licensee performed seven as-found heat exchanger inspections. Of the seven inspections, five inspections failed to meet the acceptance criteria for tube blockage and were entered in the CAP as listed below:

• AR 04343226 2SX01AB HX Failed GL 89-13 Acceptance Criteria on May 14, 2020;

• AR 04349085 2SX01AA HX Failed GL 89-13 Acceptance Criteria on June 09, 2020;

• AR 04370066 1SI01SB HX Failed GL 89-13 Acceptance Criteria on September 17, 2020;

• AR 04375807 2SX02K HX Failed GL 89-13 Acceptance Criteria on October 10, 2020; and

• AR 04387841 2SX01AA As found Heat Exchanger Inspection on December 03, 2020.

The inspectors reviewed the past operability evaluation performed by the licensee for each as-found heat exchanger inspection failure. The inspectors determined that in each case, the licensee provided reasonable assurance that the safety related components supported by each heat exchanger would have been able to perform their safety functions as required during a design basis accident.

During their review, inspectors reviewed GL 89-13 inspections from previous years on the heat exchangers listed above to determine if an adverse trend existed. Inspectors noted that the 2A essential service water pump lube oil cooler (2SX01AA) has failed six out of its last seven GL 89-13 heat exchanger inspections since 2016. The 2B essential service water pump lube oil cooler (2SX01AB) has failed two out of three GL 89-13 heat exchanger inspections since 2016. The acceptance criteria for tube blockage on the 2SX01AA and 2SX01AB heat exchangers, as determined by Byron calculation BYR03-115 (EC 628987), is no greater than four total blocked tubes.

ER-AA-340-1001, "GL 89-13 Program Implementation Instructional Guide," states, in part, that the licensee should evaluate past heat exchanger cleaning and inspection frequency against as found conditions to determine if the frequency is adequate. Additionally, the licensee should document the justification for the chosen frequency of cleaning and inspecting to ensure that the heat removal requirements for the system are satisfied. Based on the inspectors review of previous GL 89-13 inspections, the licensees practice is to reduce the inspection frequency by one half upon a failure to meet the acceptance criteria for tube blockage (e.g., from two years to one year). The current inspection frequency for 2SX01AA is every six months while the inspection frequency for 2SX01AB is every year.

The inspectors reviewed the most recent licensee evaluation of the inspection frequencies for both heat exchangers after their respective inspection failures. In both cases, the licensee determined that the heat exchanger inspection frequencies would remain unchanged. The licensee highlighted previous engineering calculations concerning the heat removal capability of the coolers and noted that reducing the frequency further would increase unavailability on a mitigating system perform index (MSPI) related train in order to perform the inspections.

Inspectors noted that one particular GL 89-13 inspection failure captured under AR 02735109 on October 31, 2016, documented a failed inspection for the 2SX01AA heat exchanger in which five tubes were fully blocked and seven tube were partially blocked on the inlet/outlet tube side, and seven tubes were found fully blocked and four tubes were partially blocked on the reversing end of the heat exchanger. The licensee performed an evaluation of the condition under Engineering Change (EC) 617320 and determined that lube oil temperatures would have remained acceptable under design basis conditions even with the reported tube blockage.

Following the condition evaluated in AR 02735109, programmatically driven evaluations performed by the licensee for subsequent inspection failures have continuously highlighted EC 617320 as justification for why exceeding the tube plugging limit in BYR03-115 would not have challenged the safety function of the essential service water (SX) pump. Additionally, the licensee has also repeatedly highlighted an evaluation performed at the Braidwood Station of a similar condition deemed acceptable under EC 619171. The Byron and Braidwood Station essential service water pumps are a similar design.

On February 12, 2019, the licensee completed a GL 89-13 program self-assessment. An action from that assessment was generated in the CAP under AR 04136180-11 for the site to determine if the essential service water pump lube oil coolers could be removed from the GL 89-13 program based on previous EC evaluations. The licensee stated that preliminary information received from the vendor verified that the oil coolers heat exchanging properties are not required for SX pump bearing health and that eliminating the oil coolers would be acceptable for normal and accident operation. The due date for this action item, however, has been pushed to March 25, 2022, awaiting the final decision on the permanent shutdown of Byron Station.

Specifically concerning the 2SX01AA and 2SX01AB heat exchangers, the inspectors determined that by waiting to evaluate whether the heat exchangers can be removed from the GL 89-13 program until March 25, 2022, combined with not taking any additional programmatic actions for GL 89-13 inspection failures, the licensee appears to be creating a de facto alternate set of acceptance criteria by which the heat exchangers are being evaluated against after an inspection failure occurs. In doing this, the licensee has set up a rear looking program in which there is a presumption that any failure to meet the acceptance criteria given in BYR03-115 will be acceptable because EC 617320 will justify past operation of the heat exchanger, given a certain amount of tube blockage, and therefore the safety related function of the components supported by each heat exchanger will have been preserved. As such, by entering each inspection failure into the CAP and generating actions to perform programmatic evaluations the licensee is meeting the requirements of BVP 800-30; however, without taking action to either change the acceptance criteria, change the inspection frequency, or justify the exclusion of the heat exchangers from the program, the likely outcome is that the whole scenario will repeat itself upon the next inspection failure. This practice has the potential to put an undue strain on site resources and can reduce the sites focus on other safety significant work.

The inspectors did not identify any findings or violations during this sample.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On January 13, 2021, the inspectors presented the integrated inspection results to Mr. M. Kanavos, Site Vice President, and other members of the licensee staff.

• On October 2, 2020, the inspectors presented the emergency preparedness baseline inspection results to Mr. M. Kanavos, Site Vice President, and other members of the licensee staff.

• On October 16, 2020, the inspectors presented the Inservice Inspection results to Mr. Harris Welt, Plant Manager, and other members of the licensee staff.

• On October 26, 2020, the inspectors presented the radiation protection inspection results to Mr. J. Reed, Radiation Protection Manager, and other members of the licensee staff.

• On December 2, 2020, the inspectors presented the emergency action level and emergency plan changes inspection results to Mr. D. Moore, Senior Manager -

Emergency Preparedness, and other members of the licensee staff.

• On December 8, 2020, the inspectors presented the biennial licensed operator requalification program inspection results to Mr. K. McGuire, Operations Director, and other members of the licensee staff.

• On December 10, 2020, the inspectors presented the radiation protection inspection results to Mr. J. Reed, Radiation Protection Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.04 Procedures BOP AF-E2A Auxiliary Feedwater Train A Electrical Lineup 1

BOP AF-M2 Auxiliary Feedwater System Valve Lineup 16

BOP AF-M2A Auxiliary Feedwater System Train A Valve Lineup 7

BOP FC-E1 Fuel Pool Cooling - Electrical Lineup 2

BOP FC-M1 Fuel Pool Cooling and Cleanup System Valve Lineup 17

71111.05 Fire Plans FZ 1.2A-2 Aux Building 346'0" ELE. 2A RHR Pump Room 2

FZ 12.1-0 Fuel Handling Building 401'-0" Elevation 3

FZ 9.2-2 Aux Building 401'0" Elevation 2A Diesel Generator & Day 3

Tank Room

71111.08P Corrective Action 04238047 Boric Acid Leakage Evaluation for Component ID 04/19/2020

Documents 2RH8703B

238994 Indications Observed During ISI Exam of 2RC-01-BA/SGN- 04/12/2019

280514 Boric Acid Leakage Evaluation for Component ID 2CV8444 10/14/2019

04362874 B2R22 ISI Scope Deferred Due to Ongoing COVID-19 08/13/2020

Pandemic

Corrective Action 04374742 Incorrect NDE Report # Entered in B2R21 WO# 04826853- 10/06/2020

Documents 01 WDR

Resulting from

Inspection

Miscellaneous 1-53B Procedure Qualification Record (PQR) 01/29/1986

2-53A Procedure Qualification Record (PQR) 02/12/1986

WPS 1-1-GTSM- ASME Welding Procedure Specification Record 4

PWHT

WPS 1-8-GTSM ASME Welding Procedure Specification Record 1

NDE Reports 2019-034 03/20/2019

2019-035 03/20/2019

2019-036 03/20/2019

2019-037 03/21/2019

2019-039 03/21/2019

2019-MT-012 04/13/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

2019-MT-013 04/13/2019

20-UT-047 10/07/2020

20-VT-010 10/07/2020

B2R22-PT-001 10/08/2020

B2R22-PT-002 10/08/2020

B2R22-UT-001 10/07/2020

B2R22-VEN-001 Reactor Vessel Head Bare Metal Visual Examination Record 10/11/2020

B2R22-VT-001 10/07/2020

Procedures Guidance for Performing Thermal Fatigue Examinations 1

When Utilizing Generic Procedure PDI-UT-2

ER-AA-335-002 Liquid Penetrant (PT) Examination 11

ER-AA-335-015- VT-2 Visual Examination in Accordance with ASME 2013 1

2013 Edition

ER-AA-335-031 Ultrasonic Examination of Austenitic Piping Welds 9

ER-AP-335-001 Bare Metal Visual Examination for Nickel Alloy Materials 7

PDI-UT-2 Generic Procedure for the Ultrasonic Examination of H

Austenitic Pipe Welds

PDI-UT-2 Table 1 49

PDI-UT-2 Table 2 03/04/2020

Work Orders 04826853-01 MM Repair Leak by Replacing Elbow 04/13/2019

04899280-01 MM - Potential Inactive Leak on 2SXL1AA-4" Line 04/04/2019

71111.11B Corrective Action AR 04189569 4.0 Critique FOR 2FW-541A Failure 10/30/2018

Documents AR 04209528 4.0 Critique for U-1 Main Condenser Vacuum Degrading - 01/09/2019

Prompt Investigation and Site Communication Actions Will

be Performed Under IR 4209128

AR 04273574 4.0 Critique - 2C MSIV Standby Actuation Train Leak 08/21/2019

AR 04317378 4.0 Critique - EH Return Filter Response 02/12/2020

AR 4341834 Trend in HU Fundamental Usage in Operations (CAPE) 06/12/2020

Corrective Action AR 04384222 Simulator Set-up Procedure TQ-BY-201-0113 Was Not 11/16/2020

Documents Followed, Challenging LORT Exam Security During the

Resulting from Annual Exam

Inspection SWR 0136543 Simulator Work Request (SWR) Written to Investigate 11/18/2020

Status Lights on 1PM04J. When the Valves were Closed the

Inspection Type Designation Description or Title Revision or

Procedure Date

Light Needed Tapping to Light and Show That Valves Were

Closed.

Miscellaneous 2020 JPM Wk 1 2020 Byron Annual Operating Test Week 1 Job 06/12/2020 -

Performance Measures (N001a, N019, N089a, N136, N144, 06/22/2020

S033t)

20 JPM Wk 5 2020 Byron Annual Operating Test Week 5 Job 06/15/2020 -

Performance Measures (N042, N046, N088, N128a, N147a, 06/23/2020

S035t)

20 Op-Test 2020 Byron Annual Operating Test Outline 11/09/2020

Outline

20 Scn Wk 1 2020 Byron Annual Operating Test Week 1 Scenarios 09/09/2020

(BY-59R3, BY-70R3)

20 Scn Wk 5 2020 Byron Annual Operating Test Week 5 Scenarios 06/09/2020

(BY-44R7, BY-73R9)

JPM N147a LORT Annual Exam JPM Performed 11/17/2020 in the 6/22/2020

Simulator

NRC FORM 396 Reviewed 6 Medical Records (3 RO and 3 SRO) to Assess 12/2019

Compliance with 10CFR55.53 and Medical Fitness

OP-AA-105-102, Several Active License Tracking Logs (Record of 8 / 12 Hour 15

ATTACHMENT 1 Shifts Worked During Quarter) to Assess the Licensees

Program for Ensuring that Licensed Operators Meet the

Conditions of their Licenses

TQ-AA-224-F100 Reviewed 15 Individual "Remedial Training Notification and 7-8

Action on Failure" Forms for LORT Remediations Performed

from 2018 to 2020

TQ-AA-306-J002 Test Report Documenting the Simulator's Testing 1

Completed Since the Previous Report on 11/5/2018

Documenting Conformance to the Requirements of ANSI 3.5

2009 and Regulatory Guide 1.149 Revision 4

Vision ID 337340 2020 Week 5 Biennial SRO Written Exam 11/11/2020

Vision ID 342306 2020 Week 5 Biennial RO Written Exam 11/06/2020

Procedures TQ-AA-150-J202 LORT Annual Exam Development Job Aid 005

TQ-AA-155 Conduct of Simulator Training and Evaluation 010

TQ-AA-201 Examination Security and Administration 017

Inspection Type Designation Description or Title Revision or

Procedure Date

TQ-BY-201-0113, The Examination Security Checklist That Was Not 11/12/2020

1, Performed Properly, Resulting in the Exam Security

PRE - Simulator Challenge Documented by AR 4384222 and Subsequent

Examination Reviews

Security Checklist

71111.11Q Miscellaneous Operations Scenarios 11/03/2020

71111.12 Procedures ER-AA-320 Maintenance Rule Implementation Per NEI 18-19 00

71111.13 Corrective Action 04375187 2SI8807B Will Not Open 10/08/2020

Documents 04377380 2PS9356B is Not Operable 10/17/2020

Engineering EC367380 Documentation of the Basis for Maximum Allowed Leakage 2

Changes Rate in Procedures 1/2BVSR 6.1.1-26

Miscellaneous Penetration/Valve: Containment Boundary Repair Deferral Form 10/17/2020

P-70, 2PS9356B

71111.15 Calculations BYRON-00-5043 Generic Jacket Water Leakage Evaluation for Emergency 06/02/2000

Diesel Generators

EC623441 Design Attribute Review CC-AA-102-F-01

Corrective Action 04372705 1B TDFW Pump Stop Valve Test Failure 09/28/2020

Documents 04373650 N32 Spiking 11/05/2020

04374472 2B RCP Oil Leaks 10/05/2020

04375187 2SI8807B Will Not Open 10/08/2020

04375665 TRM 3.9A, Decay Time Requirements and Fuel Moves 10/09/2020

04375807 2SX02K HX Failed GL 89-13 Acceptance Criteria 10/10/2020

04376393 2DG01KB-X2 LWR JKT Water Cooler Leaking 2B DG 10/13/2020

04392079 Through Wall Leak Branch Leg of Tee with Lines 1SX211B- 12/25/2020

6" & 1SXA3A=6"

Engineering 633450 Operability Evaluation 20-002 0

Changes EC357755 Past Operability Evaluation for 2B AF Pump Right Angle 0

Gear Lube Oil Cooler - 2SX02K

Procedures ER-AA-340-1001 GL 89-13 Program Implementation Instructional Guide 11

71111.19 Corrective Action 04374416 2RH610 Not Functioning in Auto 10/05/2020

Documents 04375187 2SI8807B Will Not Open 10/08/2020

04375247 2RH606 is Not Full Open 10/08/2020

04375488 2RH606 Valve Control Issue 10/09/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

Procedures 04375187 2SI8807B Will Not Open 10/08/2020

NF-BY-510 Low Power Physics Testing 18

SFP-20-016 Ovation U2 N-Outage MAT 0

Work Orders 04915374 Low Power Physics Testing 10/19/2020

04942198 EWP MM: 2CV01PB Repair Inboard Bearing Housing Oil 10/09/2020

Leak

05084875 EWP IM Troubleshoot 2FIS-0610 10/10/2020

05085974 2SI8807B Will Not Open 10/09/2020

4649471 Replace 2B AF Pump Outboard Seal and PMT 10/14/2020

4948255 Unexpected Alarm: 2B RCP Upper Oil Reservoir 10/09/2020

71111.20 Engineering BY-MODE-030 TS 3.0.4.B Evaluation - Mode Change with Technical 1

Evaluations Specifications Equipment Out of Service

Procedures 2BGP 100-2A1 Reactor Startup 35

BOP PC-1T1 Unit 1/2 - Containment Closure Verification Checklist 11

71111.22 Procedures 2BOSR 6.1.1-18 Unit 2 Primary Containment Type C Local Leakage Rate 9

Tests and IST Tests of Containment Floor Drains System

BVP 800-39 Byron Containment Leakage Rate Testing Program 14

ER-AA-380 Primary Containment Leakrate Testing Program 14

Work Orders 0491196 Main Steam Safety Valves Operability Tests 10/02/2020

71114.02 Corrective Action AR 04269605 EP-Siren Failure (BY17) 08/05/2019

Documents AR 04271146 EP-Siren Failure (BY53) 08/12/2019

AR 04271957 EP-Siren Failure (BY05) 08/14/2019

AR 04279867 EP-Siren Failure (BY02) 09/17/2019

AR 04294772 EP-Siren Failure (BY53) 11/05/2019

AR 04308190 EP-Siren Failure (BY02) 01/06/2020

AR 04344000 EP-Siren Failure (BY59) 05/18/2020

AR 04345690 EP-Siren Failure (BY27) 05/26/2020

Miscellaneous Exelon Nuclear Manager, Midwest Emergency 10/01/2018

Preparedness Letter to Program Enhancement Manager,

Illinois Emergency Management Agency; Submission of

Byron Generating Station Public Alert and Notification

System (ANS) Design Report, Revision 3

Byron Station 2018 Warning System Maintenance & 01/01/2018 -

Inspection Type Designation Description or Title Revision or

Procedure Date

Operational Reports 12/31/2018

Byron Station 2019 Warning System Maintenance & 01/01/2019 -

Operational Reports 12/31/2019

Byron Station 2020 Warning System Maintenance & 01/01/2020 -

Operational Reports 12/31/2020

Byron Station Monthly Siren Availability Reports 09/01/2018 -

08/31/2020

Byron Station Siren Corrective Maintenance Reports 09/01/2018 -

08/31/2020

2019/2020 Emergency Planning for the Byron Area 7/19/2019

(Community Information Booklet)

U.S. Department of Homeland Security, FEMA Letter; 12/10/2012

Backup Alert and Notification System

KLD-TR-986 Byron Generating Station Alert and Notification System 09/19/2018

(ANS) Design Report

Procedures EP-AA-1000 Exelon Nuclear Standardized Radiological Emergency Plan 33

Section E

EP-AA-1002 Exelon Nuclear Radiological Emergency Plan Annex for 35

Byron Station, Section 4

71114.03 Corrective Action 04294834 Byron EP Unannounced ERO Augmentation Call in Drill 10/26/2019

Documents Results

AR 04304810 Annual Test of ERO Back-Up Notification System 12/18/2019

AR 04323634 ERO Vacancy - Replacement Needed 03/04/2020

Miscellaneous Quarterly Unannounced Off-Hours Call-In Augmentation Drill 09/01/2018 -

Results 08/31/2020

Emergency Response Organization Duty Team Roster 08/31/2020

ERO Staff Training Records Review (Sample - 10)

Procedures EP-AA-1000 Exelon Nuclear Standardized Radiological Emergency Plan, 33

Sections B and N

EP-AA-1000, ERO Staffing and Augmentation 33

Appendix 5

EP-AA-1002 Exelon Nuclear Radiological Emergency Plan Annex for 36

Byron Station, Section 2

EP-AA-1002 Exelon Nuclear Radiological Emergency Plan Annex for 2

Inspection Type Designation Description or Title Revision or

Procedure Date

Byron Station, Addendum 1, On-Shift Staffing Technical

Basis

EP-AA-112-100- ERO Notification or Augmentation X

F-06

EP-AA-112-200 TSC Activation and Operation 14

EP-AA-112-300 OSC Activation and Operation 14

EP-AA-112-400 EOF Activation and Operation 15

EP-AA-120-F-02 EP Staff Initial Developmental Checklist H

TQ-AA-113 ERO Training and Qualification 39

71114.04 Corrective Action IR 4325295 Perform Impact Review of EAL Revisions for EOP/SAMG 03/10/2020

Documents IR 4328154 EP FAQ EAL Change License Amendment Implementation 03/20/2020

Actions

IR 4329864 NOS ID: Revise Standardized Emergency Plan 03/26/2020

IR 4334253 EPlan: CDAM 50.54(q) Potential Deficiencies 04/09/2020

Miscellaneous Eval No. 19-29 Exelon Nuclear Standardized Radiological Emergency Plan 09/04/2019

Eval No. 19-65 Exelon Nuclear Standardized Radiological Emergency Plan 09/06/2019

Eval No. 19-79 Various Station Emergency Plan Annexes 11/08/2019

Eval No. 19-80 On-Shift Staffing Assessments 11/08/2019

Eval No. 20-25 EALs for Byron Station 06/04/2020

71114.05 Corrective Action AR 04183230 EP Benchmark Recommendation #1 10/13/2018

Documents AR 04249481 EMNET Phone Issues 05/13/2019

AR 0428273 Byron EP Dixon Alt Facility - Supplies Missing 09/27/2019

AR 04303221 NRC Red Phone Not Working in Main Control Room 12/12/2019

AR 04309602 MET Tower 250 Ft. Wind Speed Instrument Failure 01/10/2020

AR 04321869 EP OSC Inventory Issue 02/26/2020

AR 04338733 NRC ENS (Red) Phone Not Working 04/27/2020

AR 04339367 Outdated URI Software Found on Three TSC Computers 04/29/2020

AR 04341130 EP CFAM Indicators - 3 Month Decline - March 05/05/2020

AR 04342423 Byron NRC FTS Phones Will Not Ring in the TSC 05/11/2020

AR 04353687 Byron 2020 HP Drill - Lessons Learned 06/12/2020

AR 04359810 NRC (ENS) Red Phone Not Working in Main Control Room 07/30/2020

Corrective Action AR 04373275 NRC ID - Inventory Observations 09/30/2020

Documents

Inspection Type Designation Description or Title Revision or

Procedure Date

Resulting from

Inspection

Miscellaneous EP-MW-124- Control Room/Simulator Inventory Records 10/01/2018 -

1001-F-01 06/30/2020

EP-MW-124- CR/Simulator/TSC/OSC Equipment Test - TSC Software 10/01/2018 -

1001-F-02 and Reference Document Inventory Records 06/30/2020

EP-MW-124- Technical Support Center Inventory Records 10/01/2018 -

1001-F-03 06/30/2020

KLD-TR-1001 Byron Generating Station 2018 Population Update Analysis 07/05/2018

KLD-TR-1081 Byron Generating Station 2019 Population Update Analysis 09/07/2019

KLD-TR-1180 Byron Generating Station 2020 Population Update Analysis 09/05/2020

KLD-TR-637 Evacuation Time Estimates for Byron Station Plume 0

Exposure Pathway Emergency Planning Zone

Procedures EP-AA-1000 Exelon Nuclear Standardized Radiological Emergency Plan 33

Section J, Protective Response

EP-AA-1002 Exelon Nuclear Radiological Emergency Plan Annex for 36

Byron Station, Section 3, Classification of Emergencies

EP-AA-1002 EP-AA-1002; Exelon Nuclear Radiological Emergency Plan 36

Annex for Byron Station, Section 5.1, Emergency Response

Facilities

EP-AA-1002, Emergency Action Levels for Byron Station 4

Addendum 3

EP-AA-122 Drills and Exercise Program 22

71124.01 ALARA Plans BY-2-20-00613 Rx Head Dis-Assembly / Re-Assembly 09/26/2020

BY-2-20-00623 Rx Cavity Decontamination - TASK 1 / 2 09/29/2020

Radiation Work BY-2-20-00513 Aux / Containment RP Activities 00

Permits (RWPs)

71124.04 Corrective Action AR 04326700 Containment Evacuation Required Due to Airborne 03/14/2020

Documents Radiation

Miscellaneous BYR-20-002 2020 Bioassay Program Annual Review at Byron Nuclear 0

Power Station

NCS-19-002 Removing SRD/DLR Bias 0

Inspection Type Designation Description or Title Revision or

Procedure Date

NVLAP Lab Code Certificate of Accreditation to ISO/IEC 17025:2005 01/01/2020 -

100518-0 12/31/2020

Project ID# Report of Analysis/Certificate of Conformance 09/23/2019

EX001-

3P61BYRON-05

RP-AA-210-1001 Multiple Dosimetry EDE Evaluation Sheet 03/12/2020

13

EID KRAME4049

RP-AA-220 Intake Investigation Form and Supporting Documents 03/24/2020

EID Garci8849

RP-AA-302 Alpha Area Level Assessment - Unit 1 07/05/2020

RP-AA-403 Planned Dose Rate Alarm Form 10/04/2019

RWP BY-0-19-

00305

Teledyne Brown Report of Analysis/Certificate of Conformance 09/23/2019

Engineering

Project ID#

EX001-

3P61BYRON-05

Procedures NISP-RP-003 Radiological Air Sampling 1

RP-AA-210 Dosimetry Issue, Usage, and Control 30

RP-AA-222 Methods for Estimating Internal Exposure from In Vivo and 6

In Vitro Bioassay Data

Radiation 2020-066849 B/C Steam Generator Platform 03/12/2020

Surveys

Radiation Work BY-1-20-00608 Rx Head and Vessel Internal ISI (Bare Metal Exam) 00

Permits (RWPs)

Self-Assessments AR 4198147 Radiation Protection Dosimetry - Exelon Stations 11/20/2019

71151 Miscellaneous RCS Data 10/01/2019 - 09/30/2020

LS-AA-2140 Monthly Data Elements for NRC Occupational Exposure April 2019 -

Control Effectiveness September

20

Inspection Type Designation Description or Title Revision or

Procedure Date

71152 Calculations BYR03-115 (EC SX Pump Oil Cooler Allowable Tube Blockage 3

28987)

EC339308 Acceptance Criteria for As-Found Heat Exchanger Tube 0

Blockage

EC357755 Past Operability Evaluation for 2B AF Pump Right Angle 0

Gear Lube Oil Cooler- 2SX02K

EC617320 Reportability Evaluation for 2A SX Pump Oil Cooler Silting 0

EC619171 Review of Calculation BRW-95-218 for Application to 0

Identified Low Flow Condition on SX Oil Cooler

Corrective Action 04083000 2SX01AA Heat Exchanger Failed GL 89-13 Inspection 12/11/2017

Documents 04230570 2SX01AB HX Failed GL 89-13 Acceptance Criteria 03/18/2019

245333 2SX01AA HX Failed GL 89-13 Acceptance Criteria 05/01/2019

04302832 2SX01AA HX Failed GL 89-13 Acceptance Criteria 12/10/2019

04349085 2SX01AA HX Failed GL 89-13 Acceptance Criteria 06/04/2020

04375785 RCCA R785 Has a Bent Rodlet 10/10/2020

04379007 Bent RCCA Rodlet 10/23/2020

Engineering EC390906 Past Operability Evaluation for the 1B SI Pump 0

Changes

Engineering NF-CB-30-150 Review of RCCA R609 at Byron Unit 2 10/16/2020

Evaluations

Procedures BVP 800-30 Essential Service Water Fouling Monitoring Program (GL 18

89-13 Program Basis Document)

ER-AA-340-1001 GL 89-13 Program Implementation Instructional Guide 11

ER-AA-340-1002 Service Water Heat Exchanger Inspection Guide 9

Self-Assessments 4136180 GL 89-13 Triennial Ultimate Heat Sink Inspection 2

23