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| issue date = 02/07/2012
| issue date = 02/07/2012
| title = IR 05000454-11-005, IR 05000455-11-005; 10/01/2011 - 12/31/2011; Byron Station, Units 1 & 2; Operability Evaluations and Functional Assessments; Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportati
| title = IR 05000454-11-005, IR 05000455-11-005; 10/01/2011 - 12/31/2011; Byron Station, Units 1 & 2; Operability Evaluations and Functional Assessments; Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportati
| author name = Duncan E R
| author name = Duncan E
| author affiliation = NRC/RGN-III/DRP/B3
| author affiliation = NRC/RGN-III/DRP/B3
| addressee name = Pacilio M J
| addressee name = Pacilio M
| addressee affiliation = Exelon Generation Co, LLC, Exelon Nuclear
| addressee affiliation = Exelon Generation Co, LLC, Exelon Nuclear
| docket = 05000454, 05000455
| docket = 05000454, 05000455
Line 14: Line 14:
| page count = 69
| page count = 69
}}
}}
See also: [[followed by::IR 05000454/2011005]]
See also: [[see also::IR 05000454/2011005]]


=Text=
=Text=
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532-4352 February 7, 2012 Mr. Michael J. Pacilio Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Office (CNO), Exelon Nuclear 4300 Warrenville Road Warrenville, IL 60555 SUBJECT: BYRON STATION, UNITS 1 AND 2, NRC INTEGRATED INSPECTION REPORT 05000454/2011005; 05000455/2011005 Dear Mr. Pacilio: On December 31, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Byron Station, Units 1 and 2. The enclosed inspection report documents the inspection findings which were discussed on January 12, 2012, with Mr. B. Youman and other members of your staff. The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. Three NRC-identified findings of very low safety significance (Green) were identified during this inspection.   These findings were determined to involve violations of NRC requirements. Further, a licensee-identified violation which was determined to be of very low safety significance is listed in this report. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the NRC Enforcement Policy.   If you contest these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Byron Station.   If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at the Byron Station.    
{{#Wiki_filter:UNITED STATES
M. Pacilio    -2-  In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS).  ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Sincerely,  /RA/  Eric R. Duncan, Chief Branch 3 Division of Reactor Projects Docket Nos. 50-454; 50-455 License Nos. NPF-37; NPF-66  Enclosure: Inspection Report No. 05000454/2011005 and 05000455/2011005    w/Attachment:  Supplemental Information cc w/encl: Distribution via ListServ   
                            NUCLEAR REGULATORY COMMISSION
Enclosure  U. S. NUCLEAR REGULATORY COMMISSION REGION III Docket Nos: 50-454; 50-455 License Nos: NPF-37; NPF-66 Report Nos: 05000454/2011005 and 05000455/2011005 Licensee: Exelon Generation Company, LLC Facility: Byron Station, Units 1 and 2 Location: Byron, IL Dates: October 1, 2011, through December 31, 2011 Inspectors: B. Bartlett, Senior Resident Inspector  J. Robbins, Resident Inspector  R. Ng, Project Engineer  J. Dalzell-Bishop, DRS Emergency Response Specialist  J. Cassidy, Senior Health Physicist  R. Jickling, Senior Emergency Preparedness Inspector  B. Palagi, Senior Operations Engineer  J. Nance, Reactor Engineer  J. Benjamin, Braidwood Senior Resident Inspector  C. Thompson, Resident Inspector, Illinois Emergency    Management Agency 
                                            REGION III
Approved by: E. Duncan, Chief Branch 3 Division of Reactor Projects       
                              2443 WARRENVILLE ROAD, SUITE 210
Enclosure  TABLE OF CONTENTS  REPORT DETAILS .................................................................................................................... 4 Summary of Plant Status ........................................................................................................ 4 1R01 Adverse Weather Protection (71111.01) ............................................................ 4 1R04 Equipment Alignment (71111.04) ...................................................................... 5 1R05 Fire Protection (71111.05) ................................................................................. 6 1R11 Licensed Operator Requalification Program (71111.11) .................................... 7 1R12 Maintenance Effectiveness (71111.12) .............................................................. 8 1R13  Maintenance Risk Assessments and Emergent Work Control (71111.13) ......... 9 1R15 Operability Evaluations (71111.15) ...................................................................10 1R19 Post-Maintenance Testing (71111.19) ..............................................................17 1R20 Outage Activities (71111.20) ............................................................................18 2. REACTOR SAFETY ...................................................................................................20 1EP4 Emergency Action Level and Emergency Plan Changes (71114.04) ................20 1EP6 Drill Evaluation (71114.06) ...............................................................................21 3. RADIATION SAFETY .................................................................................................21 2RS1 Radiological Hazard Assessment and Exposure Controls (71124.01) ..............21 2RS3 In-Plant Airborne Radioactivity Control and Mitigation (71124.03) ....................24 2RS4 Occupational Dose Assessment (71124.04) .....................................................25 2RS5 Radiation Monitoring Instrumentation (71124.05) .............................................26 2RS6 Radioactive Gaseous and Liquid Effluent Treatment (71124.06) ......................26 2RS7 Radiological Environmental Monitoring Program (71124.07) ............................32 2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation (71124.08) ...........................................................................34 4. OTHER ACTIVITIES ...................................................................................................40 4OA1 Performance Indicator Verification (71151).......................................................40 4OA2 Identification and Resolution of Problems (71152)............................................45 4OA3 Follow-Up of Events and Notices of Enforcement Discretion (71153) ...............47 4OA6  Management Meetings .....................................................................................48 4OA7  Licensee-Identified Violations ...........................................................................48 SUPPLEMENTAL INFORMATION ............................................................................................. 1 Key Points of Contact ............................................................................................................. 1 List of Items Opened, Closed, and Discussed ........................................................................ 1 List Of Documents Reviewed.................................................................................................. 3 List Of Acronyms Used ..........................................................................................................13   
                                        LISLE, IL 60532-4352
1 Enclosure  SUMMARY OF FINDINGS Inspection Report (IR) 05000454/2011005, 05000455/2011005; 10/01/2011 - 12/31/2011; Byron Station, Units 1 & 2; Operability Evaluations and Functional Assessments; Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation This report covers a 3-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors.  Three Green findings were identified by the inspectors.  The findings were considered Non-Cited Violations (NCVs) of NRC regulations.  The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP).  Assigned cross-cutting aspects were determined using IMC 0310, "Components Within the Cross-Cutting Areas."  Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review.  The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006. A. Cornerstone:  Mitigating Systems NRC-Identified and Self-Revealed Findings Green.  The inspectors identified a finding of very low safety significance and an associated NCV of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," when licensee personnel failed to identify voided piping between Unit 1 valves 1AF006B and 1AF017B and Unit 2 valves 2AF006B and 2AF017B of the auxiliary feedwater (AF) system.  The piping between these valves had been historically voided until they were recently re-designed to be filled and maintained filled with water to address an NRC-identified Green finding and an associated NCV of 10 CFR Part 50, Appendix B, Criterion III, "Design Control."  The licensee entered this issue into their Corrective Action Program (CAP) as IR 1296819, IR 1292337, and IR 1295760.  Corrective actions included instituting an Operations Standing Order, replacing the Unit 1 AF drain valve, and the isolation of the Unit 2 AF drain valve.  This finding was determined to be more than minor because it was associated with the Design Control attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability and capability of systems
                                        February 7, 2012
that respond to initiating events to prevent undesirable consequences (i.e., core damage).  The inspectors determined that the finding could be evaluated using the SDP in accordance with IMC 0609, "Significance Determination Process," Attachment 0609.04, "Phase 1 - Initial Screening and Characterization of Findings," Table 4a for the Mitigating Systems Cornerstone.  Specifically, the inspectors answered "Yes" to Question 1 - Is the finding a design or qualification deficiency confirmed not to result in a loss of operability or functionality?  Based upon this Phase 1 screening, the inspectors concluded that the finding was of very low safety significance (Green).  This finding had a cross-cutting aspect in the Resources component of the Human Performance cross-cutting area [H.2(c)] because the licensee did not have adequate procedures to ensure that piping between Unit 1 valves 1AF006B and 1AF017B and Unit 2 valves 2AF006B and 2AF017B were maintained filled with water. (Section 1R15) 
Mr. Michael J. Pacilio
2 Enclosure  GreenThis finding was determined to be more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage).  The inspectors determined that the finding could be evaluated using the SDP in accordance with IMC 0609, "Significance Determination Process," Attachment 0609.04, "Phase 1 - Initial Screening and Characterization of Findings," Table 4a, for the Mitigating Systems cornerstone.  Specifically, the inspectors answered "No" to all of the Mitigating Systems Cornerstone questions in Table 4a.  Based upon this Phase 1 screening, the inspectors concluded that the finding was of very low safety significance (Green).  This finding had a cross-cutting aspect in the Corrective Action Program component of the Problem Identification and Resolution cross-cutting area [P.1(c)] because the licensee failed to thoroughly evaluate the impact on operability of a non-conforming condition associated with hazard barrier damper closure times.  (Section 1R15) .  The inspectors identified a finding of very low safety significance and an associated NCV of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," when licensee personnel failed to adhere to Operability Determination Process standards after identifying a non-conservative assumption related to closure times for hazard barrier dampers separating the Turbine Building from various safety-related rooms within the Auxiliary Building.  In particular, the issues raised by the inspectors during their review of Operability Evaluation 11-006, Revision 1, resulted in the station re-evaluating the non-conservative assumptions against aspects of the current licensing basis (CLB) not previously considered, and substantially revising the Operability Evaluation.  The licensee entered these issues into their CAP as IR 1184258, IR 1237133, IR 1238611, IR 1240295, IR 1244251, and IR 1276895.  In addition to revising Operability Evaluation 2011-006, corrective actions included an assignment to reconstitute design basis calculation records and plans to re-design the hazard barrier dampers. Cornerstone:  Public Radiation Safety Green.  A self-revealed finding of very low safety significance and an associated NCV of 10 CFR 71.5, "Transportation of Licensed Material," was identified when licensee personnel failed to comply with 49 CFR 172.203(c) and shipped packages of radioactive material with transport manifests that did not document all applicable hazardous substances.  The issue was entered in the licensee's CAP as IR 1285148.  Immediate corrective actions included providing a corrected copy of the transport manifest to the waste processor.  Further, the licensee placed locks on the shipping containers to control items placed in the packages and to ensure that the manifest accurately represented the hazards contained in the shipping packages. 
Senior Vice President, Exelon Generation Company, LLC
This finding was determined to be more than minor because it was associated with the Program and Process attribute of the Public Radiation Safety Cornerstone and adversely affected the cornerstone objective of ensuring adequate protection of public health and safety from exposure to radioactive materials released into the public domain as a result
President and Chief Nuclear Office (CNO), Exelon Nuclear
of routine civilian nuclear reactor operation, in that, providing incorrect information, as part of hazards communications, could impact the actions of response personnel.  The inspectors determined that the finding could be evaluated using the SDP in accordance with IMC 0609, "Significance Determination Process," Appendix D, "Public Radiation 
4300 Warrenville Road
3 Enclosure  Safety Significance Determination Process."  Using the Public Radiation Safety SDP, the inspectors determined:  (1) radiation limits were not exceeded; (2) there was no breach of a package during transit; (3) this issue did not involve a certificate of compliance; (4) this issue was not a low level burial ground nonconformance; and (5) this issue did not involve a failure to make notifications or provide emergency information.  As a result, the finding screened as having very low safety significance (Green).  This finding had a cross-cutting aspect in the Work Control component of the Human Performance cross-cutting area [H.3(b)] since the licensee failed to coordinate work activities by incorporating actions to address the impact of the work on different job activities, and the need for work groups to maintain interfaces with offsite organizations, and communicate, coordinate, and cooperate with each other during activities in which interdepartmental
Warrenville, IL 60555
coordination was necessary to assure adequate human performance.  Specifically, these events occurred because the licensee did not control the items placed in the waste packages and was not present when the boxes were loaded.  (Section 2RS8)  B.      One violation of very low safety significance that was identified by the licensee has been reviewed by the inspectors.  Corrective actions planned or taken by the licensee have been entered into the licensee's CAP.  This violation and the associated corrective action tracking number are listed in Section 4OA7 of this report.  Licensee-Identified Violations   
SUBJECT:         BYRON STATION, UNITS 1 AND 2, NRC INTEGRATED INSPECTION
4 Enclosure  REPORT DETAILS Unit 1 operated at or near full power from the beginning of the inspection period until November 11, 2011, when power was reduced to 89 percent to perform scheduled turbine throttle and governor valve testing.  The unit was returned to full power the following day and operated at full power for the remainder of the assessment period.  Summary of Plant Status Unit 2 began the inspection period shut down and in a planned refueling outage.  The unit was restarted and returned to service on October 10, 2011.  On November 5, 2011, reactor power was reduced to 96 percent to perform feedwater heater maintenance.  The unit was returned to full power on November 14, 2011, and operated at full power for the remainder of the inspection period. 1. REACTOR SAFETY Cornerstones:  Initiating Events, Mitigating Systems, Barrier Integrity and Emergency Preparedness 1R01 Adverse Weather Protection.1  (71111.01) a. Winter Seasonal Readiness Preparations The inspectors conducted a review of the licensee's preparations for winter conditions to verify that the plant's design features and implementation of procedures were sufficient to protect mitigating systems from the effects of adverse weather.  Documentation for selected risk-significant systems was reviewed to ensure that these systems would remain functional when challenged by inclement weather.  During the inspection, the inspectors focused on plant specific design features and the licensee's procedures used to mitigate or respond to adverse weather conditions.  Additionally, the inspectors reviewed the Updated Final Safety Analysis Report (UFSAR) and performance requirements for systems selected for inspection, and verified that operator actions were appropriate as specified by plant specific procedures.  Cold weather protection, such as heat tracing and area heaters, was verified to be in operation where applicable.  The inspectors also reviewed Corrective Action Program (CAP) items to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into their CAP in accordance with station corrective action procedures. Specific documents reviewed during this inspection are listed in the Attachment.  The
                REPORT 05000454/2011005; 05000455/2011005
inspectors' reviews focused specifically on the following plant systems due to their risk significance or susceptibility to cold weather issues: Inspection Scope  Station Heating System (SH);  Auxiliary Building Heating, Ventilation, and Air-Conditioning (HVAC) [VA]; and  Refueling Water Storage Tanks (RWSTs).  This inspection constituted one winter seasonal readiness preparation sample as defined in Inspection Procedure (IP) 71111.01-05. 
Dear Mr. Pacilio:
5 Enclosure  b. No findings were identified. Findings 1R04 Equipment Alignment.1  (71111.04) a. Quarterly Partial System Walkdowns The inspectors performed partial system walkdowns of the following risk-significant systems: Inspection Scope  Unit 2 Train A Residual Heat Removal System Following Restoration to its Standby Line-Up;  Unit 2 Train B Essential Service Water (SX) with the Unit 2 Train A SX Out-of-Service (OOS);  Unit 2 Train B Auxiliary Feedwater (AF) with the Unit 2 Train A AF OOS; and  Unit 1 Train A AF with the Unit 1 Train B AF OOS. The inspectors selected these systems based on their risk significance relative to the Reactor Safety Cornerstones at the time they were inspected.  The inspectors attempted to identify any discrepancies that could impact the function of the system, and, therefore, potentially increase risk.  The inspectors reviewed applicable operating procedures, system diagrams, UFSAR, Technical Specification (TS) requirements, outstanding work
On December 31, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an
orders (WOs), condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems
integrated inspection at your Byron Station, Units 1 and 2. The enclosed inspection report
incapable of performing their intended functions.  The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and operable.  The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies.  The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the CAP with the appropriate significance characterization.  Documents reviewed are listed in the Attachment. These activities constituted four partial system walkdown samples as defined in IP 71111.04-05. b. No findings were identified. Findings 
documents the inspection findings which were discussed on January 12, 2012, with
6 Enclosure  1R05 Fire Protection.1  (71111.05) Routine Resident Inspector Toursa.  (71111.05Q) The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas: Inspection Scope  Unit 1 426' Turbine Building (Fire Zone 8.5-1);  Unit 1 426' Turbine Building (Fire Zone 8.5-1);  Unit 1 Train B Auxiliary Feedwater Pump Room (Fire Zone 11.4A-1); and  Unit 2 Train B Auxiliary Feedwater Pump Room (Fire Zone 11.4A-2 ). The inspectors reviewed areas to assess if the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and implemented adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems, or features in accordance with the licensee's fire plan.  The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plant's Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plant's ability to respond to a security event.  Using the documents listed in the Attachment, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that
Mr. B. Youman and other members of your staff.
fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition.  The inspectors also verified that minor issues identified during the inspection were entered into the licensee's CAP.  Documents reviewed are listed in the Attachment. These activities constituted four quarterly fire protection inspection samples as defined in
The inspection examined activities conducted under your license as they relate to safety and
IP 71111.05-05. b. No findings were identified. Findings .2 Annual Fire Protection Drill Observationa.  (71111.05A) On November 11, 2011, and December 17, 2011, the inspectors observed a fire brigade activation Fire Drill in the Unit 1 Auxiliary Boiler Room, 401' Elevation (Fire Zone 8.3-1 SE).  Based on this observation, the inspectors evaluated the readiness of the plant fire brigade to fight fires.  The inspectors verified that the licensee staff identified deficiencies; openly discussed them in a self-critical manner at the drill debrief, and took appropriate corrective actions.  Specific attributes evaluated were: Inspection Scope 
compliance with the Commissions rules and regulations and with the conditions of your license.
7 Enclosure  proper wearing of turnout gear and self-contained breathing apparatus;  proper use and layout of fire hoses;  employment of appropriate fire fighting techniques;  sufficient firefighting equipment brought to the scene;  effectiveness of fire brigade leader communications, command, and control;  search for victims and propagation of the fire into other plant areas;  smoke removal operations;  utilization of pre-planned strategies;  adherence to the pre-planned drill scenario; and  drill objectives.    Documents reviewed are listed in the Attachment to this report. These activities constituted one annual fire protection inspection sample as defined in IP 71111.05-05. b. No findings were identified. Findings 1R11 Licensed Operator Requalification Program.1  (71111.11) Annual Operating Test Resultsa.  (71111.11B) The inspectors reviewed the overall pass/fail results of the Annual Operating Test,
The inspectors reviewed selected procedures and records, observed activities, and interviewed
administered by the licensee from October 18, 2011 through December 8, 2011, required by 10 CFR 55.59(a).  The results were compared to the thresholds established in IMC 0609, Appendix I, "Licensed Operator Requalification Significance Determination Process (SDP)," to assess the overall adequacy of the licensee's Licensed Operator Requalification Program (LORT) to meet the requirements of 10 CFR 55.59. Inspection Scope This inspection constitutes one biennial and one annual licensed operator requalification inspection sample as defined in IP 71111.11B and IP71111.11A. b. No findings were identified. Findings .2 Resident Inspector Quarterly Reviewa.  (71111.11Q) On November 16, 2011, the inspectors observed a crew of licensed operators in the plant's simulator during licensed operator requalification examinations to verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems and training was being conducted in accordance with licensee procedures.  The inspectors evaluated the following areas: Inspection Scope 
personnel.
8 Enclosure  licensed operator performance;  crew's clarity and formality of communications;  ability to take timely actions in the conservative direction;  prioritization, interpretation, and verification of annunciator alarms;  correct use and implementation of abnormal and emergency procedures;  control board manipulations;  oversight and direction from supervisors; and  ability to identify and implement appropriate TS actions and emergency plan actions and notifications. The crew's performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements.  Documents reviewed are listed in the Attachment. In addition, the inspectors observed licensed operator performance in the actual plant and the main control room during this calendar quarter. This inspection constituted one quarterly licensed operator requalification program sample as defined in IP 71111.11. b. No findings were identified. Findings 1R12 Maintenance Effectiveness.1  (71111.12) Routine Quarterly Evaluationsa.  (71111.12Q) The inspectors evaluated degraded performance issues involving the following risk-significant systems: Inspection Scope  Unit 1 Rod Drive Motor Generator (MG) Set High Vibrations; and  High Energy Line Break (HELB) Dampers. The inspectors reviewed events including those in which ineffective equipment maintenance had resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:  implementing appropriate work practices;  identifying and addressing common cause failures;  scoping of systems in accordance with 10 CFR 50.65(b) of the Maintenance Rule;  characterizing system reliability issues for performance;  charging unavailability for performance;  trending key parameters for condition monitoring;  ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and  verifying appropriate performance criteria for structures, systems, and  components (SSCs)/functions classified as (a)(2) or appropriate and adequate  goals and corrective actions for systems classified as (a)(1). 
Three NRC-identified findings of very low safety significance (Green) were identified during this
9 Enclosure  The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system.  In addition, the inspectors verified maintenance effectiveness issues were entered into the CAP with the appropriate significance characterization.  Documents reviewed are listed in the Attachment. This inspection constituted two quarterly maintenance effectiveness sample as defined in IP 71111.12-05. b. No findings were identified. Findings 1R13  Maintenance Risk Assessments and Emergent Work Control.1  (71111.13) a. Maintenance Risk Assessments and Emergent Work Control The inspectors reviewed the licensee's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work: Inspection Scope  Shutdown Safety Associated with Cavity Drain;  Unit Common B Fire Pump OOS With SX as its Backup While One Train of SX was OOS;  Review of Planned Risk Significant Activities During Elevated Winds and Low River Level; and  Unit 2 Train B Auxiliary Feedwater Pump OOS. These activities were selected based on their potential risk significance relative to the Reactor Safety Cornerstones.  As applicable for each activity, the inspectors verified that risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate and complete.  When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed.  The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's
inspection.
probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment.  The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify risk
These findings were determined to involve violations of NRC requirements. Further, a
analysis assumptions were valid and applicable requirements were met. These maintenance risk assessments and emergent work control activities constituted four samples as defined in IP 71111.13-05. b. No findings were identified. Findings 
licensee-identified violation which was determined to be of very low safety significance is
10 Enclosure  1R15 Operability Evaluations.1  (71111.15) a. Operability Evaluations The inspectors reviewed the following issues: Inspection Scope  Unit 1 Embedment Plate 1SI06025V Due to Questions Regarding Supporting Analysis/Calculations;  Unit 1 Seismic Support 1FW01147X Due to Questions Regarding Impact to HELB Analysis;  Unit 1 and Unit 2 Train B AF Pumps Due to Questions Regarding Multiple Starts;  Unit 1 Leading Edge Flow Monitor Due to Identified Anomaly in Trended Data;  Unit 1 and Unit 2 Train B AF Pumps Due to Potential Pipe Voids in Cross-Tie Piping; and  Unit 1 Engineered Safety Features Switchgear Rooms Division 11 and 12 Due to Questions Regarding 1VX20Y and 1VX17Y Fire Damper "S" Hooks Preventing Closure of Dampers The inspectors selected these potential operability issues based on the risk significance of the associated components and systems.  The inspectors evaluated the technical adequacy of the evaluations to ensure that TS operability was properly justified and the
listed in this report. The NRC is treating these violations as non-cited violations (NCVs)
subject component or system remained available such that no unrecognized increase in
consistent with Section 2.3.2 of the NRC Enforcement Policy.
risk occurred.  The inspectors compared the operability and design criteria in the appropriate sections of the TS and UFSAR to the licensee's evaluations to determine whether the components or systems were operable.  Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled.  The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.  Additionally, the inspectors reviewed a sample of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations.  Documents reviewed are listed in the Attachment. This operability inspection constituted six samples as defined in IP 71111.15-05. b.      .1) Findings Failure to Identify Auxiliary Feedwater Pump Suction Voids  Introduction:  The inspectors identified a finding of very low safety significance (Green) and an associated NCV of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," when licensee personnel failed to identify voided piping between Unit 1 valves 1AF006B and 1AF017B and Unit 2 valves 2AF006B and 2AF017B of the auxiliary feedwater system.  The piping between these valves had been historically voided until they were recently re-designed to be filled and maintained filled with water to address an NRC-identified Green finding and an associated NCV of 10 CFR Part 50, Appendix B, Criterion III, "Design Control" (NCV 05000454/2011004-04; 05000455/-2011004-04, Design of Auxiliary Feedwater System Included Voids in Safety-Related Alternate Suction Flow Paths). 
If you contest these NCVs, you should provide a response within 30 days of the date of this
11 Enclosure  DescriptionOn November 17, 2011, the inspectors reviewed the Inspection Reports (IRs) generated the previous day and did not identify any that documented the issue discussed above.  The inspectors re-inspected the tygon tubing between Unit 1 valves 1AF006B and 1AF017B and Unit 2 valves 2AF006B and 2AF017B and could not determine whether there was water in the tygon tubing. Licensee management was subsequently notified of the inspector's observations.  The licensee performed a system walkdown and confirmed that there was no visible water level in the tygon tubing between Unit 1 valves 1AF006B and 1AF017B.  The section of piping between the valves was subsequently filled with water and verified full through ultrasonic testing. :  On November 16, 2011, the inspectors notified licensee staff that there appeared to be no visible water in tygon tubing attached to vent valves between Unit 1 valves 1AF006B and 1AF017B and Unit 2 valves 2AF006B and 2AF017B.  Visible water in tygon tubing attached to these vent valves was being used as an indication that the piping between these valves was filled with water.  The inspectors could not determine whether there was water within the tygon tubing because the inside of the tubing was coated with a brown and black substance suspected to be mold.  The inspectors concluded that without visible water in the tygon tubing, the space between these valves could be voided, contrary to plant design requirements.  The piping between Unit 1 valves 1AF006B and 1AF017B and Unit 2 valves 2AF006B and 2AF017B had been historically voided, but were recently re-designed and filled with water to address an NRC-identified Green finding and associated NCV of 10 CFR Part 50, Appendix B, Criterion III, "Design Control" (NCV 05000454/2011004-04; 05000455/-2011004-04, Design of Auxiliary Feedwater System Included Voids in Safety-Related Alternate Suction Flow Paths).  The basis for this Green finding and associated NCV was that the licensee had not performed design reviews, calculations, or suitable tests that demonstrated the voided piping between Unit 1 valves 1AF006B and 1AF017B and Unit 2 valves 2AF006B and 2AF017B would not adversely impact the ability of the AF system to perform its design function.  This piping was downstream of the safety-related essential service water (SX) supply for the diesel-driven AF pumps.  The inspectors did observe standing water in the tygon tubing between Unit 1 valves 1AF006A and 1AF017A and Unit 2 valves 2AF006A and 2AF017A associated with the Unit 1 and Unit 2 motor-driven AF pumps. On November 18, 2011, the inspectors re-inspected the tygon tubing between Unit 1 valves 1AF006B and 1AF017B and Unit 2 valves 2AF006B and 2AF017B and could not determine whether there was water in the tygon tubing.  The inspectors notified licensee management and questioned the licensee's actions to address the inspector's previous questions and concerns.  The licensee performed a walkdown of the system and confirmed the inspector's concern that the tygon tube was again empty, which indicated that the section of piping between Unit 1 valves AF006B and AF017B was likely voided.  The licensee entered this issue into their CAP.  The section of piping between the valves was again re-filled and verified full.  On November 29, 2011, the inspectors performed field walkdowns and identified, again, that the tygon tubing attached to the vent line between Unit 2 valves 2AF006B and 2AF017B did not have a visible water level.  The inspectors notified licensee management and concluded that the licensee did not have adequate measures in place to monitor or ensure the sections of piping between Unit 1 valves 1AF006B and
inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission,
1AF017B and Unit 2 valves 2AF006B and 2AF017B were maintained full of water.  The licensee performed a walkdown of the system, confirmed the inspector's concerns, and 
ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional
12 Enclosure  filled the voided sections of piping as before.  In addition, the Operations department instituted an Operations Standing Order that required a verification that the tygon tubing was filled with water multiple times a shift.  The licensee entered this issue into their CAP as IR 1296819, IR 1292337, and IR 1295760.  Corrective actions included instituting the Operations Standing Order, replacing the Unit 1 AF drain valve, and isolating the Unit 2 AF drain valve. AnalysisThis finding was determined to be more than minor because it was associated with the Design Control attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage).  Specifically, the unverified configuration might have rendered the Unit 1 and Unit 2 diesel-driven AF pumps inoperable. :  The inspectors determined that the failure to identify voided sections of AF piping prior to and following the inspector's observations and interactions with licensee management was a performance deficiency.  The inspectors determined that the finding could be evaluated using the SDP in accordance with IMC 0609, "Significance Determination Process," Attachment 0609.04, "Phase 1 - Initial Screening and Characterization of Findings," Table 4a for the Mitigating Systems Cornerstone.  Specifically, the inspectors answered "Yes" to Question 1 - Is the finding a design or qualification deficiency confirmed not to result in a loss of operability or functionality?  This conclusion was reached after conservatively assuming that both sections of piping for Unit 1 and Unit 2 were completely voided and after reviewing tests performed by the licensee in response to the previously documented
Administrator, U.S. Nuclear Regulatory Commission - Region III, 2443 Warrenville Road,
design control Green finding and associated NCV.  These tests demonstrated that under the existing plant conditions, and even if the piping between Unit 1 valves 1AF006B and 1AF017B and Unit 2 valves 2AF006B and 2AF017B was completely voided, that the diesel-driven AF pumps were not inoperable.  However, these tests were not of sufficient scope to demonstrate that under all possible plant conditions that the diesel-driven AF pumps would have remained operable.  Therefore, although the existing void did not render the diesel-driven AF pumps inoperable, there remained the possibility that under some conditions the unverified configuration discussed above could have rendered the diesel-driven AF pumps inoperable.  Based upon this Phase 1 screening, the inspectors concluded that the finding was of very low safety significance (Green). This finding had a cross-cutting aspect in the Resources component of the Human Performance cross-cutting area [H.2(c)] because the licensee did not ensure that procedures were adequate to ensure nuclear safety.  In particular, licensee procedures did not ensure that the sections of piping between Unit 1 valves 1AF006B and 1AF017B
Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory
and Unit 2 valves 2AF006B and 2AF017B were maintained filled with water as required to support nuclear safety.  EnforcementContrary to the above, licensee personnel failed to identify non-conforming conditions associated with the station's safety-related diesel-driven AF systems.  Specifically, the :  10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected. 
Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Byron
13 Enclosure  space between Unit 1 valves 1AF006B and 1AF017B and Unit 2 valves 2AF006B and 2AF017B had been re-designed to be full of water and was identified by the inspectors prior to November 16, 2011; November 17, 2011; November 18, 2011; and November 29, 2011 to be voided.  Corrective actions included filling the voided piping sections, replacing the Unit 1 drain valve, isolating the Unit 2 drain valve, and monitoring tygon tubing water level on a more frequent basis.  Because this violation was of very low safety significance and was entered into the licensee's CAP as IR 1296819, IR 1292337, and IR 1295760, this violation is being treated as a NCV consistent with Section 2.3.2 of the NRC Enforcement Policy.  (NCV 05000454/2011005-01; 05000455/2011005-01, Failure to Identify Voided Sections of AF Piping)      .2) Operability Evaluation Not Performed in Accordance with Station Standards Introduction:  The inspectors identified a finding of very low safety significance (Green) and an associated NCV of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," when licensee personnel failed to adhere to numerous Operability Determination Process standards after identifying a non-conservative assumption related to closure times for hazard barrier dampers separating the Turbine Building from various safety-related rooms within the Auxiliary Building.  DescriptionThe inspectors reviewed Operability Evaluation 11-006, Revision 1, and identified a number of examples in which the evaluation did not meet the standards in OP-AA-108-115.  Specifically, OP-AA-108-115, "Operability Evaluation Standard," Revision 9 included the following requirements: :  On July 6, 2011, the licensee identified non-conservative assumptions in the actuation time for fusible links used in hazard barrier dampers for the Engineered Safety Feature (ESF) Rooms, Non-ESF Switchgear Rooms, Miscellaneous Electrical Equipment Rooms (MEERs) and Emergency Diesel Generator (DG) Rooms.  These dampers protected these rooms from the effects of a Turbine Building fire or HELB event.  The applicable calculations of record assumed that these dampers shut within about 5 seconds of reaching a temperature of 165 degrees fahrenheit (°F).  These dampers utilized a fusible link which was required to meet Underwriters Laboratories (UL) specifications (Heat Responsive Links for Fire Protection Service: UL 33).  This specification provided a formula for calculating an acceptable fusible link response time as a function of temperature.  Using the UL formula, licensee personnel calculated that the expected thermal link response times were up to 100 seconds for the ESF Switchgear Room dampers and 200 seconds for the MEER and Non-ESF Switchgear dampers based on projected HELB temperatures outside of these rooms.  Therefore, the station calculations of record assumed that these dampers would isolate the affected rooms from a Turbine Building HELB much sooner than UL specifications.  The licensee evaluated this non-conservative condition in Operability Evaluation 11-006, Revision 1, concluded that there was reasonable assurance that the equipment affected in the identified rooms would remain operable during a licensing basis HELB event.  This conclusion was reached after the licensee had completed and approved Operability Evaluation 11-006 in accordance with OP-AA-108-115, "Operability Evaluation Standard," Revision 9. 
Station.
14 Enclosure  OP-AA-108-115, Operability Evaluation Standard, Revision 9 The OpEval [Operability Evaluation] should contain sufficient detail for a knowledgeable individual to independently reach the same conclusions as the Preparer (i.e., the OpEval must be able to stand alone). Section 4.4.2 1. The Preparer should examine the CLB [Current Licensing Basis] requirements or commitments, including the TSs and UFSAR, to establish the conditions and performance requirements to be met for determining operability, as necessary.  The scope of an OpEval needs to be sufficient to address the capability of the SSC to perform its specified safety functions.  The OpEval should address the following, as applicable . . . Determine the extent of condition for all similarly affected SSCs.  The inspectors identified the following examples that did not meet this standard:  Operability Evaluation 11-006, Revision 1, did not evaluate the non-conforming condition against the CLB single failure criterion.  This single failure criterion was discussed in NRC Standard Review Plan (SRP) Section 3.6.1, Branch Technical Position (BTP) ASB 3-1, Section B.3.b(2).  Branch Technical Position ASB 3-1, Section B.3.b(2) discussed how a single active component failure should be assumed in systems used to mitigate the consequences of a postulated piping failure to shut down the reactor.  After the inspectors discussed this requirement with the licensee, licensee personnel determined that the dampers needed to be considered for single failure during a HELB event.  This CLB single failure criterion was readily available when the licensee examined the CLB requirements for this issue during the development of Operability Evaluation 11-006.  The licensee entered this issue into their CAP as IR 1244251.    Operability Evaluation 11-006, Revision 1, did not adequately consider a pipe crack in accordance with the CLB.  The CLB requirements for a pipe crack included an assumed lower allowable stress threshold than for a broken or severed pipe.  Specifically, Operability Evaluation 11-006, Revision 1, did not address leakage cracks in accordance with Section III of the American Society of Mechanical Engineers (ASME) Code for Class 2 and Class 3 piping as referenced in Section 3.6.2.1.2.1.1, "Fluid System Piping Not in the Containment Penetration Area," of the UFSAR.  In particular, Section d of Section 3.6.2.1.2.1.1 stated, in part, "[L]eakage cracks in high energy ASME Section III Class 2 and 3 piping and seismically analyzed and supported ANSI [American Nuclear Standards Institute] B31.1 piping are postulated at locations where the stresses under the loadings resulting from normal and upset plant conditions and an OBE [Operating Basis Earthquake] event as calculated by equations (9) and (10) in Paragraph NC-3652 of ASME Section III exceed 0.4 (1.2 multiplied times Sh + Sa).  The licensee entered this issue into their CAP as IR 1240295.  Operability Evaluation 11-006, Revision 1, did not address the extent of condition review for all similarly affected SSCs.  The inspectors identified a number of safety-related rooms that utilized the same (or similar) style dampers in which the 
If you disagree with a cross-cutting aspect assignment in this report, you should provide a
15 Enclosure  non-conforming condition applied that were not evaluated.  Those rooms included the Unit 1 and Unit 2 Lower Cable Spreading Room Non-Segregated Bus Duct areas; an electrical cable chase located above the "B" Emergency Diesel Generator; the station Emergency Diesel Generator Diesel Oil Storage Tank Rooms; and the Control Room Ventilation Makeup System, which could be aligned to take makeup air from the Turbine Building.  The licensee entered this issue into their CAP as IR 1279759 and IR 12776277.  Operability Evaluation 11-006, Revision 1, as associated with MEER 12 and MEER 22, did not identify a potential common mode failure after the inspectors determined that the licensee had not adequately considered single failure.  These rooms contained both trains of Unit 1 and Unit 2 reactor trip and reactor trip bypass breakers, respectively.  The event of concern was a Turbine Building HELB combined with the failure of either the MEER 12 or MEER 22 hazard barrier dampers to shut, which would expose both trains of reactor trip breakers to a harsh steam environment.  This equipment was not environmentally qualified in accordance with 10 CFR 50.49.  The licensee entered this issue into their CAP as IR 1276895.  The inspectors were not able to reach the same conclusions as the Preparer when reviewing Operability Evaluation 11-006, Revision 1, since Operability Evaluation 11-006, Revision 1, lacked the necessary detail regarding assumptions and limitations for the inspectors to determine if the evaluation was consistent with station design.  The inspectors concluded that Operability Evaluation 11-006, Revision 1, did not meet the licensee's "stand alone" requirement in OP-AA-108-115.    On November 17, 2011, the licensee completed a substantial revision to Operability
response within 30 days of the date of this inspection report, with the basis for your
Evaluation 11-006, Revision 1, that addressed the issues previously identified by the inspectors.  In addition to the issues described above, the inspectors identified that the station's applicable HELB calculations of records had not considered the licensing basis single failure.  The inspectors determined that this historic issue contributed to the licensee's misunderstanding of their CLB. The licensee entered these issues into the their CAP as IR 1184258, IR 1237133, IR 1238611, IR 1240295, IR 1244251, and IR 1276895.  Corrective actions include two revisions of Operability Evaluation 11-006, an assignment to reconstitute the applicable design basis calculation records, and plans to re-design the hazard barrier dampers to provide additional margin. AnalysisThis performance deficiency was determined to be more than minor because it was similar to the "not minor if" aspect of Example 3j in IMC 0612, Appendix E, "Example of Minor Issues," since the errors in Operability Evaluation 11-006, Revision 1, resulted in a condition in which there was a reasonable doubt on the operability of the systems and :  The inspectors determined that the failure to meet the station Operability Determination process standards outlined in OP-AA-108-115, "Operability Evaluation Standard," Revision 9, during the evaluation of a non-conforming condition was a performance deficiency.   
disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at
16 Enclosure  components that were the subject of the evaluation and dissimilar from the "minor because" aspect of this example since the impact of the errors on Operability Determination 11-006, Revision 1, was not minimal.  In addition, the performance deficiency was determined to be more than minor because it was associated with the Design Control attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). The inspectors determined that the finding could be evaluated using the SDP in accordance with IMC 0609, "Significance Determination Process," Attachment 0609.04, "Phase 1 - Initial Screening and Characterization of Findings," Table 4a, for the Mitigating Systems Cornerstone.  Specifically, the inspectors answered "No" to all of the Mitigating Systems Cornerstone questions in Table 4a.  As a result, the finding screened as having very low safety significance (Green). This finding has a cross-cutting aspect in the CAP component of the Problem Identification and Resolution cross-cutting area [P.1(c)] since the licensee failed to thoroughly evaluate the impact on operability of a non-conforming condition associated with hazard barrier closure times.  EnforcementContrary to the above, the inspectors identified examples during the development of Operability Evaluation 11-006, Revision 1, in which licensee personnel failed to adhere to quality procedure OP-AA-108-115, "Operability Determinations (CM-1)," Revision 9. :  10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstance and shall be accomplished in accordance with these instructions,
the Byron Station.
procedures of drawings.  In particular, OP-AA-108-115, Revision 9, stated in part:  "The OpEval should contain sufficient detail for a knowledgeable individual to independently reach the same conclusions as the Preparer (i.e., the OpEval must be able to stand alone). The Preparer should examine the CLB [Current Licensing Basis] requirements or commitments, including the TSs and UFSAR, to establish the conditions and performance requirements to be met for determining operability, as necessary.  The scope of an OpEval needs to be sufficient to address the capability of the SSC to perform its specified safety functions. The OpEval should address the following, as applicable . . . Determine the extent of condition for all similarly affected SSCs." Contrary to this requirement:  On July 15, 2011, the licensee did not adequately examine the applicable CLB requirements or commitments to establish the performance requirements to be met 
17 Enclosure  for determining operability in the case of single failure, common mode, and leakage crack assumptions.  On July 15, 2011, the licensee's "OpEval" did not adequately address the extent of condition for all similarly affected SSCs.  On July 15, 2011, the "OpEval" did not contain sufficient detail for a knowledgeable individual to independently reach the same conclusions as the Preparer.  Because this violation was of very low safety significance and it was entered into the licensee's corrective actions program, this violation is being treated as a NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy.  (NCV 05000454/2011005-02; 05000455/2011005-02, Operability Evaluation Not Performed in Accordance with Station Standards) 1R19 Post-Maintenance Testing.1  (71111.19) a. Post-Maintenance Testing The inspectors reviewed the following post maintenance testing activities to verify that procedures and test activities were adequate to ensure system operability and functional capability: Inspection Scope  Unit 2 AF Check Valves 2AF014E, 2AF014G, and 2AF014H Following Disassembly and Inspection;  Unit 2 Reactor Coolant Pump Motor - 2D Following Refuel Maintenance and Inspection;  Unit 2 Charging Valve Stroke Time and Position Indication Test 2CV8804A Following Circuit Modification;  Unit 2 Solid State Protection System Following Unit 2 Refueling Outage Preventive Maintenance;  Unit 2 Train B Containment Spray Following Replacement of Timer Relay;  Unit 1 Train A Rod Drive Motor-Generator Following Bearing Replacement; and  Surveillance 2BOSR 0.5-2.RH.4-1 Following Maintenance on Valve 2RH610 These activities were selected based upon the structure, system, or component's ability to impact risk.  The inspectors evaluated these activities for the following (as applicable): the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as written in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing (temporary modifications or jumpers required for test performance were properly removed after test completion); and test documentation was properly evaluated.  The inspectors evaluated the activities against TSs, the UFSAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements.  In addition, the inspectors reviewed corrective action documents associated with post maintenance tests to determine whether the licensee was identifying problems and entering them in the CAP 
18 Enclosure  and that the problems were being corrected commensurate with their importance to safety.  Documents reviewed are listed in the Attachment. This inspection constituted seven post maintenance testing samples as defined in IP 71111.19-05. a. No findings were identified. Findings 1R20 Outage Activities.1  (71111.20) a. Refueling Outage Activities The inspectors reviewed the Outage Safety Plan (OSP) and contingency plans for the Unit 2 refueling outage (RFO) B2R16, conducted September 18 through October 10, 2011, to confirm that the licensee had appropriately considered risk, industry experience, and previous site-specific problems in developing and implementing a plan that assured maintenance of defense-in-depth.  During the RFO, the inspectors observed portions of the shutdown and cooldown processes and monitored licensee controls over the outage activities listed below.  Documents reviewed during the inspection are listed in the Attachment to this report. Inspection Scope  Licensee configuration management, including maintenance of defense-in-depth commensurate with the OSP for key safety functions and compliance with the applicable TS when taking equipment out of service.  Implementation of clearance activities and confirmation that tags were properly hung and equipment appropriately configured to safely support the work or
testing.  Installation and configuration of reactor coolant pressure, level, and temperature instruments to provide accurate indication, accounting for instrument error.  Controls over the status and configuration of electrical systems to ensure that
TS and OSP requirements were met, and controls over switchyard activities.  Monitoring of decay heat removal processes, systems, and components.  Controls to ensure that outage work was not impacting the ability of the operators to operate the spent fuel pool cooling system.  Reactor water inventory controls including flow paths, configurations, and alternative means for inventory addition, and controls to prevent inventory loss.  Controls over activities that could affect reactivity.  Maintenance of secondary containment as required by TS.  Licensee fatigue management, as required by 10 CFR 26, Subpart I.  Refueling activities, including fuel handling and sipping to detect fuel assembly
leakage.  Startup and ascension to full power operation, tracking of startup prerequisites, walkdown of the drywell (primary containment) to verify that debris had not been left which could block emergency core cooling system suction strainers, and reactor physics testing.  Licensee identification and resolution of problems related to RFO activities. 
19 Enclosure  This inspection constituted one RFO sample as defined in IP 71111.20-05. b. No findings were identified. Findings 1R22 Surveillance Testing  .1  (71111.22) a. Surveillance Testing The inspectors reviewed the test results for the following activities to determine whether risk significant systems and equipment were capable of performing their intended safety function and to verify testing was conducted in accordance with applicable procedural
and TS requirements: Inspection Scope  Unit 2 Train B Diesel Generator Sequence Test;  Unit 1 Train B AF Pump ASME Surveillance;  Unit 1 Train B AF Valve Strokes for 1AF013E-H;  Unit 1 Train B Residual Heat Removal (RHR) Check Valve 1SI8958B;  Unit 2 Reactor Coolant System (RCS) Water Inventory Balance Surveillance (Leak Detection); and  0BMSR FP-5, Fire Hydrant Yard Loop Annual Flush The inspectors observed in-plant activities and reviewed procedures and associated records to determine the following:    did preconditioning occur;  were the effects of the testing adequately addressed by control room personnel or engineers prior to the commencement of the testing;  were acceptance criteria clearly stated, demonstrated operational readiness, and consistent with the system design basis;  plant equipment calibration was correct, accurate, and properly documented;  as left setpoints were within required ranges; and the calibration frequency were in accordance with TSs, the USAR, procedures, and applicable commitments;  measuring and test equipment calibration was current;  test equipment was used within the required range and accuracy; applicable prerequisites described in the test procedures were satisfied;  test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; jumpers and lifted leads were controlled and restored where used;  test data and results were accurate, complete, within limits, and valid;  test equipment was removed after testing;  where applicable for inservice testing (IST) activities, testing was performed in accordance with the applicable version of Section XI of the ASME code, and reference values were consistent with the system design basis;  where applicable, test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable; 
20 Enclosure  where applicable for safety-related instrument control surveillance tests, reference setting data were accurately incorporated in the test procedure;  where applicable, actual conditions encountering high resistance electrical contacts were such that the intended safety function could still be accomplished;  prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test;  equipment was returned to a position or status required to support the
performance of its safety functions; and  all problems identified during the testing were appropriately documented and dispositioned in the CAP.  Documents reviewed are listed in the Attachment. This inspection constituted four routine surveillance testing samples, one IST sample, and one RCS Leak Detection sample, as defined in IP 71111.22, Sections -02 and -05. b. No findings were identified. Findings 2. REACTOR SAFETY Cornerstone:  Emergency Preparedness 1EP4 Emergency Action Level and Emergency Plan Changes.1  (71114.04) a. Emergency Action Level and Emergency Plan Changes Since the last NRC inspection of this program area, Emergency Action Levels (EALs) and Emergency Plan Revisions 27 and 28 were implemented based on the licensee's determination, in accordance with 10 CFR 50.54(q), that the changes resulted in no decrease in effectiveness of the Plan, and that the revised Plan as changed continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50.  The inspectors conducted a sampling review of the Emergency Plan changes and a review of the EAL changes to evaluate for potential decreases in effectiveness of the Plan.  However, these reviews do not constitute formal NRC approval of the changes.  Therefore, these changes remain subject to future NRC inspection in their entirety.  Inspection Scope This EAL and Emergency Plan changes inspection constituted one sample as defined in IP 71114.04-05. b. No findings were identified.  Findings 
21 Enclosure  1EP6 Drill Evaluation.1  (71114.06) a. Emergency Preparedness Drill Observation The inspectors evaluated the conduct of a routine licensee emergency drill on November 15, 2011, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities.  The inspectors observed emergency response operations in the Simulator Control Room and Technical Support Center to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures.  The inspectors also attended the licensee drill critique to compare any inspector-observed weakness with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensee staff was properly identifying weaknesses and entering them into the CAP.  As part of the inspection, the inspectors reviewed the drill package and other documents listed in the Attachment. Inspection Scope This emergency preparedness drill inspection constituted one sample as defined in IP 71114.06-05. b. No findings were identified. Findings 3. RADIATION SAFETY 2RS1 Radiological Hazard Assessment and Exposure ControlsThe inspection activities supplement those documented in Inspection Report 05000454/2011002; 05000455/2011002 and constitute one complete sample as defined in IP 71124.01-05.  (71124.01) .1 Inspection Planninga.  (02.01) The inspectors reviewed licensee performance indicators for the occupational exposure cornerstone for follow-up.  The inspectors reviewed the results of radiation protection program audits (e.g., licensee quality assurance audits or other independent audits).  The inspectors reviewed reports of operational occurrences related to occupational radiation safety since the last inspection.  The inspectors reviewed the results of the audit and operational report reviews to gain insights into overall licensee performance. Inspection Scope b. No findings were identified. Findings 
22 Enclosure  .2 Instructions to Workersa.  (02.03) The inspectors reviewed selected occurrences where a worker's electronic personal dosimeter noticeably malfunctioned or alarmed.  The inspectors evaluated whether workers responded appropriately to the off-normal condition.  The inspectors assessed whether the issue was included in the CAP and dose evaluations were conducted as appropriate. Inspection Scope b. No findings were identified. Findings .3 Radiological Hazards Control and Work Coveragea.  (02.05) The inspectors examined the licensee's physical and programmatic controls for highly activated or contaminated materials (nonfuel) stored within spent fuel and other storage pools.  The inspectors assessed whether appropriate controls (i.e., administrative and physical controls) were in place to preclude inadvertent removal of these materials from
the pool.  Inspection Scope The inspectors examined the posting and physical controls for selected high radiation areas and very high radiation areas to verify conformance with the occupational radiation performance indicator. b. No findings were identified. Findings .4 Risk-Significant High Radiation Area and Very High Radiation Area Controls a. (02.06) The inspectors discussed with the radiation protection manager the controls and procedures for high-risk high radiation areas and very high radiation areas.  The inspectors discussed methods employed by the licensee to provide stricter control of
very high radiation area access as specified in 10 CFR 20.1602, "Control of Access to Very High Radiation Areas," and Regulatory Guide 8.38, "Control of Access to High and Very High Radiation Areas of Nuclear Plants."  The inspectors assessed whether any changes to licensee procedures substantially reduced the effectiveness and level of worker protection.  Inspection Scope The inspectors discussed the controls in place for special areas that have the potential to become very high radiation areas during certain plant operations with health physics supervisors (or equivalent positions having backshift health physics oversight authority).  The inspectors assessed whether these plant operations required communication beforehand with the health physics group, so as to allow corresponding timely actions to 
23 Enclosure  properly post, control, and monitor the radiation hazards including re-access authorization. The inspectors evaluated licensee controls for very high radiation areas and areas with the potential to become very high radiation areas to ensure that an individual was not able to gain unauthorized access to the very high radiation area. b. No findings were identified. Findings .5 Radiation Worker Performancea.  (02.07) The inspectors reviewed radiological problem reports since the last inspection that found the cause of the event to be human performance errors.  The inspectors evaluated whether there was an observable pattern traceable to a similar cause.  The inspectors assessed whether this perspective matched the corrective action approach taken by the licensee to resolve the reported problems.  The inspectors discussed with the radiation
protection manager any problems with the corrective actions planned or taken. Inspection Scope b. No findings were identified. Findings .6 Radiation Protection Technician Proficiencya.  (02.08) The inspectors reviewed radiological problem reports since the last inspection that found the cause of the event to be radiation protection technician error.  The inspectors evaluated whether there was an observable pattern traceable to a similar cause.  The inspectors assessed whether this perspective matched the corrective action approach taken by the licensee to resolve the reported problems. Inspection Scope b. No findings were identified. Findings .7 Problem Identification and Resolutiona.  (02.09) The inspectors evaluated whether problems associated with radiation monitoring and exposure control were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensee's CAP.  The inspectors assessed the appropriateness of the corrective actions for a selected sample of problems
documented by the licensee that involved radiation monitoring and exposure controls.  The inspectors assessed the licensee's process for applying operating experience to their plant. Inspection Scope 
24 Enclosure  b. No findings were identified. Findings 2RS3 In-Plant Airborne Radioactivity Control and MitigationThe inspection activities supplement those documented in Inspection Report 05000454/2011002; 05000455/2011002 and constitute one complete sample as defined in IP 71124.03-05.  (71124.03) .1 Engineering Controlsa.  (02.02) The inspectors reviewed the licensee's use of permanent and temporary ventilation to determine whether the licensee used ventilation systems as part of its engineering controls (in-lieu of respiratory protection devices) to control airborne radioactivity.  The inspectors reviewed procedural guidance for use of installed plant systems, such as
containment purge, spent fuel pool ventilation, and auxiliary building ventilation, and assessed whether the systems were used, to the extent practicable, during high-risk activities (e.g., using containment purge during cavity flood-up). Inspection Scope The inspectors selected installed ventilation systems used to mitigate the potential for airborne radioactivity, and evaluated whether the ventilation airflow capacity, flow path (including the alignment of the suction and discharges), and filter/charcoal unit
efficiencies, as appropriate, were consistent with maintaining concentrations of airborne radioactivity in work areas below the concentrations of an airborne area to the extent practicable. The inspectors selected temporary ventilation system setups (high efficiency particulate air/charcoal negative pressure units, down draft tables, tents, metal "Kelly buildings," and other enclosures) used to support work in contaminated areas.  The inspectors assessed whether the use of these systems was consistent with licensee procedural
guidance and the As-Low-As-Reasonably-Achievable (ALARA) concept. The inspectors reviewed airborne monitoring protocols by selecting installed systems used to monitor and warn of changing airborne concentrations in the plant and evaluating whether the alarms and setpoints were sufficient to prompt licensee/worker action to ensure that doses were maintained within the limits of 10 CFR Part 20 and the
ALARA concept. The inspectors assessed whether the licensee had established trigger points (e.g., the
Electric Power Research Institute's "Alpha Monitoring Guidelines for Operating Nuclear Power Stations") for evaluating levels of airborne beta-emitting (e.g., plutonium-241) and alpha-emitting radionuclides. b. No findings were identified. Findings 
25 Enclosure  .2 Use of Respiratory Protection Devicesa.  (02.03) For those situations where it was impractical to employ engineering controls to minimize airborne radioactivity, the inspectors assessed whether the licensee provided respiratory protective devices such that occupational doses were ALARA.  The inspectors selected work activities where respiratory protection devices were used to limit the intake of radioactive materials, and assessed whether the licensee performed an evaluation concluding that further engineering controls were not practical and that the use of respirators was ALARA.  The inspectors also evaluated whether the licensee had established means (such as routine bioassay) to determine if the level of protection (protection factor) provided by the respiratory protection devices during use was at least
as good as that assumed in the licensee's work controls and dose assessment. Inspection Scope b. No findings were identified. Findings 2RS4 Occupational Dose AssessmentThe inspection activities supplement those documented in Inspection Report 05000454/2011002; 05000455/2011002 and constitute one complete sample as defined in IP 71124.04-05.  (71124.04) .1 External Dosimetrya.  (02.02) The inspectors evaluated whether the licensee's dosimetry vendor was National Voluntary Laboratory Accreditation Program (NVLAP) accredited and if the approved irradiation test categories for each type of personnel dosimeter used were consistent with the types and energies of the radiation present and the way the dosimeter was
being used (e.g., to measure deep dose equivalent, shallow dose equivalent, or lens dose equivalent).    Inspection Scope b. Findings Introduction:  The inspectors identified that the licensee's use of dosimeters (TLDs) may not be consistent with the methods used by the NVLAP accreditation process.  As a result, the inspectors identified an Unresolved Item (URI) for the apparent non-compliance with 10 CFR 20.1501(c)(2) because the accreditation process for the types of radiation included in the NVLAP program may not approximate the types of radiation for which the individual wearing the dosimeter is monitored. Discussion:  The licensee used a vendor to supply and process dosimeters used to measure radiation exposure for the monitored workers.  This vendor was NVLAP accredited for beta, gamma, neutron, mixture of beta/gamma, and mixture neutron/gamma radiations.  However, the licensee used the dosimeters when workers may be exposed to beta, gamma, and neutron radiations within the same monitoring 
26 Enclosure  period.  The inspectors determined that this mixture of three radiation types may not be aligned with the accreditation process.  The issue was categorized as a URI pending NRC evaluation of this practice and determination whether a single TLD can accurately measure occupational dose to three types of radiation (URI 05000454/2011005-03; 05000455/2011005-03; Use of TLDs May Not be Consistent with the Methods Used by the NVLAP Accreditation Process) 2RS5 Radiation Monitoring InstrumentationThe inspection activities supplement those documented in Inspection Report 05000454/2011002; 05000455/2011002 and constitute one complete sample as defined in IP 71124.05-05.  (71124.05) .1 Inspection Planninga.  (02.01) The inspectors reviewed the area radiation monitor alarm setpoint values and setpoint bases as provided in the TSs and the Final Safety Analysis Report. Inspection Scope The inspectors reviewed effluent monitor alarm setpoint bases and the calculation methods provided in the Offsite Dose Calculation Manual (ODCM).  b. No findings were identified. Findings 2RS6 Radioactive Gaseous and Liquid Effluent TreatmentThis inspection constituted one complete sample as defined in IP 71124.06-05.  (71124.06) .1 Inspection Planning and Program Reviews (02.01) a. Event Report and Effluent Report Reviews The inspectors reviewed the radiological effluent release reports issued since the last
inspection to determine if the reports were submitted as required by the ODCMl/TSs.  The inspectors reviewed anomalous results, unexpected trends, or abnormal releases identified by the licensee for further inspection to determine if they were evaluated, were entered in the CAP, and were adequately resolved. Inspection Scope The inspectors identified radioactive effluent monitor operability issues reported by the licensee in effluent release reports and reviewed these issues during the onsite inspection, as warranted, and determined if the issues were entered into the CAP and adequately resolved. b. No findings were identified. Findings 
27 Enclosure  c. Offsite Dose Calculation Manual and Final Safety Analysis Report Review The inspectors reviewed Final Safety Analysis Report descriptions of the radioactive effluent monitoring systems, treatment systems, and effluent flow paths so they could be evaluated during inspection walkdowns.  Inspection Scope The inspectors reviewed changes to the ODCM made by the licensee since the last
inspection against the guidance in NUREG-1301, NUREG-0133, and Regulatory Guides 1.109, 1.21 and 4.1.  When differences were identified, the inspectors reviewed the technical basis or evaluations of the change during the onsite inspection to determine whether they were technically justified and maintain effluent releases ALARA. The inspectors reviewed licensee documentation to determine if the licensee had identified any non-radioactive systems that had become contaminated as disclosed either through an event report or the ODCM since the last inspection.  This review provided an intelligent sample list for the onsite inspection of any 10 CFR 50.59 evaluations and allowed a determination if any newly contaminated systems had an unmonitored effluent discharge path to the environment, whether any required ODCM revisions were made to incorporate these new pathways and whether the associated
effluents were reported in accordance with Regulatory Guide 1.21.  d. No findings were identified. Findings e. Groundwater Protection Initiative Program The inspectors reviewed reported groundwater monitoring results and changes to the licensee's written program for identifying and controlling contaminated spills/leaks to groundwater. Inspection Scope f. No findings were identified. Findings g. Procedures, Special Reports, and Other Documents The inspectors reviewed Licensee Event Reports, event reports and/or special reports related to the effluent program issued since the previous inspection to identify any additional focus areas for the inspection based on the scope/breadth of problems described in these reports.  Inspection Scope The inspectors reviewed effluent program implementing procedures, particularly those associated with effluent sampling, effluent monitor setpoint determinations, and dose calculations.   
28 Enclosure  The inspectors reviewed copies of licensee and third party (independent) evaluation reports of the effluent monitoring program since the last inspection to gather insights into the licensee's program and aid in selecting areas for inspection review (smart sampling). h. No findings were identified. Findings .2 Walkdowns and Observationsa.  (02.02) The inspectors walked down selected components of the gaseous and liquid discharge systems to evaluate whether equipment configuration and flow paths aligned with the documents reviewed in 02.01 above and to assess equipment material condition. 
Special attention was made to identify potential unmonitored release points (such as open roof vents in boiling water reactor turbine decks, temporary structures butted against turbine, auxiliary or containment buildings), building alterations which could impact airborne or liquid effluent controls, and ventilation system leakage that
communicated directly with the environment. Inspection Scope For equipment or areas associated with the systems selected for review that were not readily accessible due to radiological conditions, the inspectors reviewed the licensee's material condition surveillance records, as applicable. The inspectors walked down filtered-ventilation systems to assess for conditions such as degraded high-efficiency particulate air/charcoal banks, improper alignment, or system installation issues that would impact the performance or the effluent monitoring capability of the effluent system. As available, the inspectors observed selected portions of the routine processing and discharge of radioactive gaseous effluent (including sample collection and analysis) to evaluate whether appropriate treatment equipment was used and the processing activities aligned with discharge permits. The inspectors determined if the licensee had made significant changes to their effluent release points (e.g., changes subject to a 10 CFR 50.59 review or requiring NRC approval of alternate discharge points). As available, the inspectors observed selected portions of the routine processing and
discharge of liquid waste (including sample collection and analysis) to determine if appropriate effluent treatment equipment was being used and whether radioactive liquid waste was being processed and discharged in accordance with procedure requirements and aligned with discharge permits. b. No findings were identified. Findings 
29 Enclosure  .3 Sampling and Analysesa.  (02.03) The inspectors selected effluent sampling activities, consistent with smart sampling, and assessed whether adequate controls had been implemented to ensure representative samples were obtained (e.g., provisions for sample line flushing, vessel recirculation, composite samplers, etc.) Inspection Scope The inspectors selected effluent discharges made with inoperable (declared out-of-service) effluent radiation monitors to assess whether controls were in place to ensure compensatory sampling was performed consistent with the radiological effluent TSs/ODCM and that those controls were adequate to prevent the release of unmonitored liquid and gaseous effluents. The inspectors determined whether the facility was routinely relying on the use of compensatory sampling in lieu of adequate system maintenance, based on the
frequency of compensatory sampling since the last inspection. The inspectors reviewed the results of the inter-laboratory comparison program to evaluate the quality of the radioactive effluent sample analyses and assessed whether the inter-laboratory comparison program included hard-to-detect isotopes as appropriate. b. No findings were identified. Findings .4 Instrumentation and Equipment (02.04) a. Effluent Flow Measuring Instruments The inspectors reviewed the methodology the licensee used to determine the effluent stack and vent flow rates to determine if the flow rates were consistent with radiological effluent TSs/ODCM or Final Safety Analysis Report values, and that differences between assumed and actual stack and vent flow rates did not affect the results of the projected public doses. Inspection Scope b. No findings were identified. Findings c. Air Cleaning Systems The inspectors assessed whether surveillance test results since the previous inspection for TS required ventilation effluent discharge systems (high-efficiency particulate air and charcoal filtration), such as the Standby Gas Treatment System
and the Containment/Auxiliary Building Ventilation System, met TS acceptance criteria. Inspection Scope 
30 Enclosure  d. No findings were identified. Findings .5 Dose Calculationsa.  (02.05) The inspectors reviewed all significant changes in reported dose values compared to the previous radiological effluent release report (e.g., a factor of 5, or increases that approach Appendix I criteria) to evaluate the factors which may have resulted in the change.  Inspection Scope The inspectors reviewed radioactive liquid and gaseous waste discharge permits to assess whether the projected doses to members of the public were accurate and based on representative samples of the discharge path. The inspectors evaluated the methods used to determine the isotopes that were included in the source term to ensure all applicable radionuclides were included within
detectability standards.  The review included the current Part 61 analyses to ensure hard-to-detect radionuclides were included in the source term. The inspectors reviewed changes in the licensee's offsite dose calculations since the last inspection to evaluate whether changes were consistent with the ODCM and Regulatory Guide 1.109.  The inspectors reviewed meteorological dispersion and deposition factors used in the ODCM and effluent dose calculations to evaluate whether appropriate factors were being used for public dose calculations. The inspectors reviewed the latest Land Use Census to assess whether changes (e.g.,
significant increases or decreases to population in the plant environs, changes in critical exposure pathways, the location of nearest member of the public or critical receptor, etc.) had been factored into the dose calculations. For the releases reviewed above, the inspectors evaluated whether the calculated doses (monthly, quarterly, and annual dose) were within the 10 CFR Part 50, Appendix I, and TS dose criteria. The inspectors reviewed, as available, records of any abnormal gaseous or liquid tank discharges (e.g., discharges resulting from misaligned valves, valve leak-by, etc) to ensure the abnormal discharge was monitored by the discharge point effluent monitor. 
Discharges made with inoperable effluent radiation monitors, or unmonitored leakages were reviewed to ensure that an evaluation was made of the discharge to satisfy 10 CFR 20.1501 so as to account for the source term and projected doses to the public. b. No findings were identified. Findings 
31 Enclosure  .6 Groundwater Protection Initiative Implementationa.  (02.06) The inspectors reviewed monitoring results of the Groundwater Protection Initiative to determine if the licensee had implemented its program as intended and to identify any anomalous results.  For anomalous results or missed samples, the inspectors assessed whether the licensee had identified and addressed deficiencies through its CAP. Inspection Scope The inspectors reviewed identified leakage or spill events and entries made into 10 CFR 50.75 (g) records.  The inspectors reviewed evaluations of leaks or spills and reviewed any remediation actions taken for effectiveness.  The inspectors reviewed onsite contamination events involving contamination of ground water and assessed whether the source of the leak or spill was identified and mitigated. For unmonitored spills, leaks, or unexpected liquid or gaseous discharges, the inspectors assessed whether an evaluation was performed to determine the type and amount of radioactive material that was discharged by:  Assessing whether sufficient radiological surveys were performed to evaluate the
extent of the contamination and the radiological source term and assessing whether a survey/evaluation had been performed to include consideration of hard-to-detect radionuclides.  Determining whether the licensee completed offsite notifications, as provided in its Groundwater Protection Initiative implementing procedures. The inspectors reviewed the evaluation of discharges from onsite surface water bodies that contained or potentially contained radioactivity, and the potential for ground water leakage from these onsite surface water bodies.  The inspectors assessed whether the licensee was properly accounting for discharges from these surface water bodies as part of their effluent release reports. The inspectors assessed whether on-site ground water sample results and a description of any significant on-site leaks/spills into ground water for each calendar year were documented in the Annual Radiological Environmental Operating Report for the radiological environmental monitoring program or the Annual Radiological Effluent Release Report for the Radiological Effluent TSs. For significant, new effluent discharge points (such as significant or continuing leakage to ground water that continued to impact the environment if not remediated), the inspectors evaluated whether the ODCM was updated to include the new release point. b. No findings were identified. Findings 
32 Enclosure  .7 Problem Identification and Resolutiona.  (02.07) Inspectors assessed whether problems associated with the effluent monitoring and control program were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensee CAP.  In addition, the inspectors evaluated the appropriateness of the corrective actions for a selected sample of problems documented by the licensee involving radiation monitoring and exposure controls. Inspection Scope b. No findings were identified. Findings 2RS7 Radiological Environmental Monitoring ProgramThis inspection constituted one complete sample as defined in IP 71124.07-05.  (71124.07) .1 Inspection Planninga.  (02.01) The inspectors reviewed the annual radiological environmental operating reports and the results of any licensee assessments since the last inspection to assess whether the radiological environmental monitoring program was implemented in accordance with the TSs and ODCM.  This review included reported changes to the ODCM with respect to environmental monitoring, commitments in terms of sampling locations, monitoring and measurement frequencies, land use census, inter-laboratory comparison program, and analysis of data. Inspection Scope The inspectors reviewed the ODCM to identify locations of environmental monitoring stations. The inspectors reviewed the Final Safety Analysis Report for information regarding the environmental monitoring program and meteorological monitoring instrumentation. The inspectors reviewed quality assurance audit results of the program to assist in
choosing inspection "smart samples" and audits and technical evaluations performed on the vendor laboratory program. The inspectors reviewed the annual effluent release report and the 10 CFR Part 61, "Licensing Requirements for Land Disposal of Radioactive Waste," report, to determine if the licensee was sampling, as appropriate, for the predominant and dose-causing radionuclides likely to be released in effluents. b. No findings were identified. Findings 
33 Enclosure  .2 Site Inspectiona.  (02.02) The inspectors walked down select air sampling stations and thermoluminescent dosimeter monitoring stations to determine whether they were located as described in the ODCM and to determine the equipment material condition.  Consistent with smart sampling, the air sampling stations were selected based on the locations with the highest X/Q, D/Q wind sectors, and thermoluminescent dosimeters were selected based on the most risk-significant locations (e.g., those that have the highest potential for public dose impact).  Inspection Scope For the air samplers and thermoluminescent dosimeters selected, the inspectors
reviewed the calibration and maintenance records to evaluate whether they demonstrated adequate operability of these components.  Additionally, the review included the calibration and maintenance records of select composite water samplers. The inspectors assessed whether the licensee had initiated sampling of other appropriate media upon loss of a required sampling station. The inspectors observed the collection and preparation of environmental samples from different environmental media (e.g., ground and surface water, milk, vegetation, sediment, and soil) as available to determine if environmental sampling was representative of the release pathways as specified in the ODCM and if sampling techniques were in accordance with procedures. Based on direct observation and review of records, the inspectors assessed whether the meteorological instruments were operable, calibrated, and maintained in accordance with guidance contained in the Final Safety Analysis Report; NRC Regulatory Guide 1.23, "Meteorological Monitoring Programs for Nuclear Power Plants;" and licensee procedures.  The inspectors assessed whether the meteorological data readout and recording instruments in the control room and, if applicable, at the tower were operable. The inspectors evaluated whether missed and/or anomalous environmental samples were identified and reported in the annual environmental monitoring report.  The inspectors selected events that involved a missed sample, inoperable sampler, lost
thermoluminescent dosimeter, or anomalous measurement to determine if the licensee had identified the cause and had implemented corrective actions.  The inspectors reviewed the licensee's assessment of any positive sample results (i.e., licensed radioactive material detected above the lower limits of detection) and reviewed the associated radioactive effluent release data that was the source of the released material. The inspectors selected structures, systems, or components that involved or could reasonably involve licensed material for which there was a credible mechanism for licensed material to reach ground water, and assessed whether the licensee had implemented a sampling and monitoring program sufficient to detect leakage of these structures, systems, or components to ground water. 
34 Enclosure  The inspectors evaluated whether records, as required by 10 CFR 50.75(g), of leaks, spills, and remediation since the previous inspection were retained in a retrievable manner.  The inspectors reviewed any significant changes made by the licensee to the ODCM as the result of changes to the land census, long-term meteorological conditions (3-year average), or modifications to the sampler stations since the last inspection.  The inspectors reviewed technical justifications for any changed sampling locations to evaluate whether the licensee performed the reviews required to ensure that the changes did not affect the ability to monitor the impact of radioactive effluent releases on the environment. The inspectors assessed whether the appropriate detection sensitivities with respect to TSs/ODCM were used for counting samples (i.e., the samples met the TSs/ODCM required lower limits of detection).  The inspectors reviewed quality control charts for
maintaining radiation measurement instrument status and actions taken for degrading detector performance.  The licensee used a vendor laboratory to analyze the radiological environmental monitoring program samples so the inspectors reviewed the results of the
vendor's quality control program, including the interlaboratory comparison, to assess the adequacy of the vendor's program. The inspectors reviewed the results of the licensee's interlaboratory comparison program to evaluate the adequacy of environmental sample analyses performed by the licensee.  The inspectors assessed whether the interlaboratory comparison test included the media/nuclide mix appropriate for the facility.  If applicable, the inspectors reviewed the licensee's determination of any bias to the data and the overall effect on the
radiological environmental monitoring program. b. No findings were identified. Findings .3 Identification and Resolution of Problemsa.  (02.03) The inspectors assessed whether problems associated with the radiological environmental monitoring program were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensee's CAP.  Additionally, the inspectors assessed the appropriateness of the corrective actions for a selected sample of problems documented by the licensee that involved the radiological environmental monitoring program. Inspection Scope b. No findings were identified. Findings 2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and TransportationThis inspection constituted one complete sample as defined in IP 71124.08-05.  (71124.08) 
35 Enclosure  .1 Inspection Planninga.  (02.01) The inspectors reviewed the solid radioactive waste system description in the Final Safety Analysis Report, the process control program, and the recent radiological effluent release report for information on the types, amounts, and processing of radioactive waste disposed. Inspection Scope The inspectors reviewed the scope of any quality assurance audits in this area since the last inspection to gain insights into the licensee's performance and inform the "smart sampling" inspection planning. b. No findings were identified. Findings .2 Radioactive Material Storagea.  (02.02) The inspectors selected areas where containers of radioactive waste were stored, and evaluated whether the containers were labeled in accordance with 10 CFR 20.1904, "Labeling Containers," or controlled in accordance with 10 CFR 20.1905, "Exemptions to Labeling Requirements," as appropriate.  Inspection Scope The inspectors assessed whether the radioactive material storage areas were controlled
and posted in accordance with the requirements of 10 CFR Part 20, "Standards for Protection against Radiation."  For materials stored or used in controlled or unrestricted areas, the inspectors evaluated whether they were secured against unauthorized
removal and controlled in accordance with 10 CFR 20.1801, "Security of Stored Material," and 10 CFR 20.1802, "Control of Material Not in Storage," as appropriate. The inspectors evaluated whether the licensee established a process for monitoring the impact of long term storage (e.g., buildup of any gases produced by waste decomposition, chemical reactions, container deformation, loss of container integrity, or re-release of free-flowing water) that was sufficient to identify potential unmonitored, unplanned releases or nonconformance with waste disposal requirements. The inspectors selected containers of stored radioactive material, and inspected the containers for signs of swelling, leakage, and deformation. b. No findings were identified. Findings .3 Radioactive Waste System Walkdowna.  (02.03) The inspectors walked down accessible portions of select radioactive waste processing systems to assess whether the current system configuration and operation agreed with Inspection Scope 
36 Enclosure  the descriptions in the Final Safety Analysis Report, ODCM, and process control program. The inspectors reviewed administrative and/or physical controls (i.e., drainage and isolation of the system from other systems) to assess whether the equipment which was not in service or abandoned in place would contribute to an unmonitored release path and/or affect operating systems or be a source of unnecessary personnel exposure.  The inspectors assessed whether the licensee reviewed the safety significance of systems and equipment abandoned in place in accordance with 10 CFR 50.59, "Changes, Tests, and Experiments." The inspectors reviewed the adequacy of changes made to the radioactive waste processing systems since the last inspection.  The inspectors evaluated whether
changes from what was described in the Final Safety Analysis Report were reviewed and documented in accordance with 10 CFR 50.59, as appropriate and to assess the impact on radiation doses to members of the public. The inspectors selected processes for transferring radioactive waste resin and/or sludge discharges into shipping/disposal containers and assessed whether the waste stream mixing, sampling procedures, and methodology for waste concentration averaging were consistent with the process control program, and provided representative samples of the waste product for the purposes of waste classification as described in 10 CFR 61.55, "Waste Classification."  For those systems that provided tank recirculation, the inspectors evaluated whether the tank recirculation procedures provided sufficient mixing.  The inspectors assessed whether the licensee's process control program correctly described the current methods and procedures for dewatering and waste stabilization (e.g., removal of freestanding liquid). b. No findings were identified. Findings .4 Waste Characterization and Classificationa.  (02.04) The inspectors selected the following radioactive waste streams for review: Inspection Scope  Primary Resin;  Secondary Resin;  Secondary Radwaste Filter; and  Dry Active Waste (DAW). For the waste streams listed above, the inspectors assessed whether the licensee's radiochemical sample analysis results (i.e., "10 CFR Part 61" analysis) were sufficient to support radioactive waste characterization as required by 10 CFR Part 61, "Licensing Requirements for Land Disposal of Radioactive Waste."  The inspectors evaluated whether the licensee's use of scaling factors and calculations to account for difficult-to-
37 Enclosure  measure radionuclides was technically sound and based on current 10 CFR Part 61 analyses for the selected radioactive waste streams. The inspectors evaluated whether changes to plant operational parameters were taken into account to:  (1) maintain the validity of the waste stream composition data between the annual or biennial sample analysis update; and (2) assure that waste shipments
continued to meet the requirements of 10 CFR Part 61 for the waste streams selected above.  The inspectors evaluated whether the licensee had established and maintained an adequate quality assurance program to ensure compliance with the waste classification and characterization requirements of 10 CFR 61.55 and 10 CFR 61.56, "Waste Characteristics." b. No findings were identified. Findings .5 Shipment Preparationa.  (02.05) The inspectors observed shipment packaging, surveying, labeling, marking, placarding, vehicle checks, emergency instructions, disposal manifest, shipping papers provided to the driver, and licensee verification of shipment readiness.  The inspectors assessed
whether the requirements of applicable transport cask certificates of compliance had been met.  The inspectors evaluated whether the receiving licensee was authorized to
receive the shipment packages.  The inspectors evaluated whether the licensee's procedures for cask loading and closure were consistent with the vendor's current approved procedures. Inspection Scope The inspectors observed radiation workers during the conduct of radioactive waste processing and radioactive material shipment preparation and receipt activities.  The inspectors assessed whether the shippers were knowledgeable of the shipping regulations and whether shipping personnel demonstrated adequate skills to accomplish the package preparation requirements for public transport with respect to the licensee's response to NRC Bulletin 79-19, "Packaging of Low-Level Radioactive Waste for Transport and Burial," dated August 10, 1979; and Title 49 CFR Part 172, "Hazardous Materials Table, Special Provisions, Hazardous Materials Communication, Emergency Response Information, Training Requirements, and Security Plans," Subpart H, "Training."  Due to limited opportunities for direct observation, the inspectors reviewed the technical instructions presented to workers during routine training.  The inspectors assessed
whether the licensee's training program provided training to personnel responsible for the conduct of radioactive waste processing and radioactive material shipment preparation activities. b. No findings were identified. Findings 
38 Enclosure  .6 Shipping Recordsa.  (02.06) The inspectors evaluated whether the shipping documents indicated the proper shipper name; emergency response information and a 24-hour contact telephone number; accurate curie content and volume of material; and appropriate waste classification,
transport index, and UN number for the following radioactive shipments: Inspection Scope  Shipment RWS10-011; Dewatered Bead Resin; low specific activity (LSA-II);  Shipment RWS10-013; DAW Trash and TR Pond Sludge; low specific activity (LSA-II);  Shipment RWS10-012; DAW Trash; low specific activity (LSA-II);  Shipment RMS09-094; Rx Vessel Dosimetry; Type A Package; and  Shipment RMS11-078; Dirty Laundry; low specific activity (LSA-II). Additionally, the inspectors assessed whether the shipment placarding was consistent with the information in the shipping documentation. b. Findings Introduction:  A self-revealed finding of very low safety significance (Green) and an associated NCV of 10 CFR 71.5, "Transportation of Licensed Material," was identified when licensee personnel failed to comply with 49 CFR 172.203(c) and shipped packages of radioactive material with transport manifests that did not document all applicable hazardous substances.  Description IR 1221229; RWS 11-006 Contained Un-Manifested Asbestos;  :  On multiple dates, the licensee shipped containers of radioactive material to a waste processor with incomplete information on the transport manifest.  Specifically, the transport manifest that accompanied the shipments failed to identify hazardous materials, including asbestos, lead, and other chemicals that were contained in the packages.  Upon arrival at the waste processor's facility, the waste processor identified the non-conformances in the shipping containers and notified the licensee.  Follow-up actions by the licensee included performing a revised characterization of the shipped packages.  The revised radiological characterization identified negligible impact relative to the initial radiological assessment and package characterization.  This event was documented in the licensee's CAP as:  IR 1173307; RWS 10-013 Contained Unapproved Mixed Waste;  IR  928393; Non-Conforming Metal Shipped to Bear Creek Processing;  IR 1015646; Non-Conforming Waste Found in Radwaste Shipment; and  IR 1067394; Non-Conforming Radioactive Waste in Shipment. 
39 Enclosure  Immediate corrective actions included providing a corrected copy of the transport manifest to the waste processor.  Additionally, the licensee initiated IR 1285148 to evaluate the human performance issues associated with the shipping non-conformances.  Further, the licensee placed locks on the shipping containers to control items placed in the packages and to ensure that the manifest accurately represented the hazards contained in the shipping package. AnalysisThis finding has a cross-cutting aspect in the Work Control component of the Human Performance cross-cutting area [H.3(b)] since the waster shipper failed to coordinate work activities by incorporating actions to address the impact of the work on different job
activities, and the need for work groups to maintain interfaces with offsite organizations, and communicate, coordinate, and cooperate with each other during activities in which interdepartmental coordination is necessary to assure adequate human performance.  Specifically, these events occurred because the radioactive material shipper did not control the items placed in the waste packages and was not present when the boxes were loaded.  :  The failure to completely identify all required package contents on a transport manifest was a performance deficiency.  The finding was determined to be more than minor because it was associated with the Program and Process attribute of the Public Radiation Safety Cornerstone and adversely affected the cornerstone objective of ensuring the adequate protection of public health and safety from exposure to radioactive materials released into the public domain as a result of routine civilian nuclear reactor operation, in that, providing incorrect information, as part of hazard communication, could impact the actions of response personnel.  The finding involved an occurrence of the licensee's radioactive material transportation program that was contrary to NRC regulatory requirements.  The inspectors determined that the finding could be evaluated using the SDP in accordance with IMC 0609, "Significance Determination Process," Appendix D, "Public Radiation Safety Significance Determination Process."  Using the Public Radiation Safety SDP, the inspectors determined:  (1) radiation limits were not exceeded; (2) there was no breach of a package during transit; (3) it did not involve a certificate of compliance issue; (4) it was not a low level burial ground nonconformance; and (5) it did not involve a failure to make notifications or provide emergency information.  As a result, the finding screened as having very low safety significance (Green). EnforcementContrary to the above, between May 10, 2010 and May 26, 2011, the licensee failed to list relevant hazardous materials on the transport manifest for a shipment also containing DAW.  This violation was entered into the licensee's CAP as IR 1285148.  Because this violation was of very low safety significance and it was entered into the licensee's CAP, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy.  (NCV 05000454/2011005-04, Failure to Identify Hazardous Materials on Transportation Manifest) :  Title 10 CFR 71.5, "Transportation of Licensed Material," requires licensees to comply with the Department of Transportation (DOT) regulations in 49 CFR Parts 170 through 189 relative to the transportation of licensed material.  Title 49 CFR 172.203, "Additional Description Requirements," required, in part, that hazardous materials be listed on the transport manifest. 
40 Enclosure  .7 Identification and Resolution of Problemsa.  (02.07) The inspectors assessed whether problems associated with radioactive waste processing, handling, storage, and transportation, were being identified by the licensee at an appropriate threshold, were properly characterized, and were properly addressed for resolution in the licensee CAP.  Additionally, the inspectors evaluated whether the corrective actions were appropriate for a selected sample of problems documented by the licensee that involve radioactive waste processing, handling, storage, and transportation. Inspection Scope The inspectors reviewed results of selected audits performed since the last inspection of
this program and evaluated the adequacy of the licensee's corrective actions for issues identified during those audits. b. No findings were identified. Findings 4. OTHER ACTIVITIES Cornerstones:  Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness 4OA1 Performance Indicator Verification.1  (71151)    a. Reactor Coolant System Leakage The inspectors sampled licensee submittals for the Unit 1 and Unit 2 RCS Leakage Performance Indicator (PI) for the period from the third quarter 2010 through the second quarter 2011.  To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in Nuclear Energy Institute (NEI) 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, dated October 2009, was used.  The inspectors reviewed the licensee's operator logs, RCS leakage tracking data, issue reports, event reports and NRC Integrated Inspection Reports for the period of June 2010 through June 2011 to validate the accuracy of the submittals.  The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator.  Documents reviewed are listed in the Attachment. Inspection Scope This inspection constituted two RCS leakage samples as defined in IP 71151-05. b. No findings were identified. Findings 
41 Enclosure  .2 a. Unplanned Transients Per 7000 Critical Hours The inspectors sampled licensee submittals for the Unplanned Transients per 7000 Critical Hours performance indicator for Unit 1 and Unit 2 for the period from the second quarter of 2010 through the 3rd quarter of 2011.  To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, dated October 2009, was used.  The inspectors reviewed the licensee's operator narrative logs, issue reports, maintenance rule records, event reports and NRC Integrated
Inspection Reports for the period of April 2010 through September 2011 to validate the accuracy of the submittals.  The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator.  Documents reviewed are listed in the Attachment. Inspection Scope This inspection constituted two unplanned transients per 7000 critical hours samples as defined in IP 71151-05. b. No findings were identified. Findings .3 a. Safety System Functional Failures The inspectors sampled licensee submittals for the Safety System Functional Failures performance indicator for Unit 1 and Unit 2 for the period from the second quarter of 2010 through the third quarter of 2011.  To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, dated October 2009, and NUREG-1022, "Event Reporting Guidelines 10 CFR 50.72 and 50.73" definitions and guidance, were used.  The inspectors reviewed the licensee's operator narrative logs, operability assessments, maintenance rule records, maintenance work orders, issue reports, event reports and NRC Integrated Inspection Reports for the period of June 2010 through September 2011 to validate the accuracy of the submittals.  The inspectors also reviewed the licensee's issue report database to
determine if any problems had been identified with the PI data collected or transmitted for this indicator.  Documents reviewed are listed in the Attachment. Inspection Scope This inspection constituted two safety system functional failures samples as defined in IP 71151-05. b. No findings were identified. Findings 
42 Enclosure  .4 a. Reactor Coolant System Specific Activity The inspectors sampled licensee submittals for the RCS specific activity PI for Unit 1 and Unit 2 for the period from the 4th quarter of 2010 through the 3rd quarter of 2011.  The inspectors used PI definitions and guidance contained in NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, dated October 2009 to determine the accuracy of the PI data reported during those periods.  The inspectors reviewed the licensee's reactor coolant system chemistry samples, TS requirements, issue reports, event reports, and NRC Integrated Inspection Reports for the period of the 4th quarter 2010 through the 3rd quarter of 2011 to validate the accuracy of the submittals.  The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator.  In addition to record reviews, the inspectors observed a chemistry technician obtain and analyze a reactor coolant system sample.  Documents reviewed are listed in the Attachment. Inspection Scope This inspection constituted two RCS specific activity samples as defined in IP 71151-05. b. No findings were identified. Findings .5 a. Mitigating Systems Performance Index - Heat Removal System The inspectors sampled licensee submittals for the Mitigating Systems Performance
Index (MSPI) - Heat Removal System performance indicator for Unit 1 and Unit 2 for the period from the fourth quarter of 2010 through the third quarter of 2011.  To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, dated October 2009, was used.  The inspectors reviewed the licensee's operator narrative logs, issue reports, event reports, MSPI derivation reports, and NRC Integrated IRs for the period of October 2010 through September 2011 to validate the accuracy of the submittals.  The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI
guidance.  The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator.  Documents reviewed are listed in the Attachment. Inspection Scope This inspection constituted two MSPI heat removal system samples as defined in
IP 71151-05. b. No findings were identified. Findings 
43 Enclosure  .6 a. Mitigating Systems Performance Index - Cooling Water Systems The inspectors sampled licensee submittals for the MSPI - Cooling Water Systems performance indicator for Unit 1 and Unit 2 for the period from the fourth quarter of 2010 through the third quarter of 2011.  To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, dated October 2009, was used.  The inspectors reviewed the licensee's operator narrative logs, issue reports, MSPI derivation reports, event reports and NRC Integrated Inspection Reports for the period of October 2010 through September 2011 to validate the accuracy of the submittals.  The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, whether the change was in accordance with applicable NEI guidance.  The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator.  Documents reviewed are listed in the Attachment. Inspection Scope This inspection constituted two MSPI cooling water system samples as defined in IP 71151-05. b. No findings were identified. Findings .7 a. Mitigating Systems Performance Index - High Pressure Injection Systems The inspectors sampled licensee submittals for the MSPI - High Pressure Injection Systems performance indicator for Unit 1 and Unit 2 for the period from the fourth quarter of 2010 through the third quarter of 2011.  To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, dated October 2009, were used.  The inspectors reviewed the licensee's operator narrative logs, issue reports, MSPI derivation reports, event reports and NRC Integrated Inspection Reports for the period of October 2010 through September of 2011 to validate the accuracy of the submittals.  The inspectors reviewed the MSPI component risk
coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance.  The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the PI data collected or transmitted
for this indicator.  Documents reviewed are listed in the Attachment. Inspection Scope This inspection constituted two MSPI high pressure injection system samples as defined in IP 71151-05. b. No findings were identified. Findings 
44 Enclosure  .8 a. Occupational Exposure Control Effectiveness The inspectors sampled licensee submittals for the occupational radiological occurrences PI for the period from the fourth quarter of 2010 through the 3rd quarter of 2011.  To determine the accuracy of the PI data reported during these periods, the inspectors used PI definitions and guidance contained in NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, dated October 2009.  The inspectors reviewed the licensee's assessment of the PI for occupational radiation safety to determine if indicator-related data was adequately assessed and reported.  To assess the adequacy of the licensee's PI data collection and analyses, the inspectors discussed with radiation protection staff, the scope, and breadth of its data review and the results of those reviews.  The inspectors independently reviewed electronic personal dosimetry dose rate and accumulated dose alarms and dose reports and the dose assignments for any intakes that occurred during the time period reviewed to determine if there were potentially unrecognized occurrences.  The inspectors also conducted walkdowns of numerous locked high and very high radiation area entrances to determine the adequacy of the controls in place for these areas.  Documents reviewed are listed in the Attachment. Inspection Scope This inspection constituted one occupational exposure control effectiveness sample as defined in IP 71151-05. b. No findings were identified. Findings .9 a. Radiological Effluent Technical Specification/Offsite Dose Calculation Manual Radiological Effluent Occurrences The inspectors sampled licensee submittals for the radiological effluent TS/ODCM
radiological effluent occurrences PI for the period from the fourth quarter of 2010 through the third quarter of 2011.  To determine the accuracy of the PI data reported during these periods, the inspectors used PI definitions and guidance contained in NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, dated October 2009.  The inspectors reviewed the licensee's issue report database and selected individual reports generated since this indicator was last reviewed to identify any potential occurrences such as unmonitored, uncontrolled, or improperly calculated effluent releases that may have impacted offsite dose.  The inspectors reviewed gaseous effluent summary data and the results of associated offsite dose calculations for selected dates between the fourth quarter of 2010 through the third quarter of 2011 to determine if indicator results were accurately reported.  The inspectors also reviewed the
licensee's methods for quantifying gaseous and liquid effluents and determining effluent dose.  Documents reviewed are listed in the Attachment. Inspection Scope 
45 Enclosure  This inspection constituted one Radiological Effluent TS/ODCM radiological effluent occurrences sample as defined in IP 71151 05. b. No findings were identified. Findings 4OA2 Identification and Resolution of ProblemsCornerstones:  Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical Protection  (71152) .1 a. Routine Review of Items Entered into the Corrective Action Program As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensee's CAP at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed.  Attributes reviewed included:  the complete and accurate identification of the problem; that timeliness was commensurate with the safety significance; that evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent-of-condition reviews, and previous occurrence reviews were proper and adequate; and that the classification, prioritization, focus, and timeliness of corrective actions were commensurate with safety and sufficient to prevent recurrence of the issue.  Minor issues entered into the licensee's CAP as a result of the inspectors' observations
are included in the attached List of Documents Reviewed. Inspection Scope These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples.  Instead, by procedure they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report. b. No findings were identified. Findings .2 a. Daily Corrective Action Program Reviews In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensee's CAP.  This review was accomplished through inspection of the station's daily condition report packages. Inspection Scope 
46 Enclosure  These daily reviews were performed by procedure as part of the inspectors' daily plant status monitoring activities and, as such, did not constitute any separate inspection samples. b. No findings were identified. Findings .3 a. Selected Issue Follow-Up Inspection:  Licensee Issue Report on Auxiliary Feedwater System Crosstie Modification The inspectors performed a review of the item below that was identified by an NRC inspector at a different but similar facility: Inspection Scope  Auxiliary Feedwater System Modification. This review constituted one in-depth problem identification and resolution sample as defined in IP 71152-05. b. No findings were identified. Findings .4 a. Annual Sample:  Review of Operator Workarounds The inspectors evaluated the licensee's implementation of their process used to identify, document, track, and resolve operational challenges.  Inspection activities included, but were not limited to, a review of the cumulative effects of the operator workarounds (OWAs) on system availability and the potential for improper operation of the system, for potential impacts on multiple systems, and on the ability of operators to respond to plant transients or accidents. Inspection Scope The inspectors performed a review of the cumulative effects of OWAs.  The documents listed in the Attachment were reviewed to accomplish the objectives of the inspection procedure.  The inspectors reviewed both current and historical operational challenge records to determine whether the licensee was identifying operator challenges at an appropriate threshold, had entered them into their CAP, and proposed or implemented appropriate and timely corrective actions which addressed each issue.  Reviews were
conducted to determine if any operator challenge could increase the possibility of an Initiating Event, if the challenge was contrary to training, required a change from long-standing operational practices, or created the potential for inappropriate compensatory actions.  Additionally, all temporary modifications were reviewed to identify any potential effect on the functionality of Mitigating Systems, impaired access to equipment, or required equipment uses for which the equipment was not designed.  Daily plant and equipment status logs, degraded instrument logs, and operator aids or tools being used to compensate for material deficiencies were also assessed to identify any potential sources of unidentified operator workarounds. 
47 Enclosure  This review constituted one operator workaround annual inspection sample as defined in IP 71152-05. b. No findings were identified. Findings 4OA3 Follow-Up of Events and Notices of Enforcement Discretion.1  (71153) The Licensee Event Report (LER) involved a Unit 2 DG that was unknowingly inoperable for approximately 6 months due to loose bolting on the upper lubricating oil cooler.  During a routine surveillance on November 17, 2010, a significant oil leak was identified by the equipment operator.  The DG was shut down before damage could occur.  The licensee determined that a bolted flanged connection was misaligned during
reinstallation following maintenance in January of 2010. (Closed) Licensee Event Report 05000455/2011-001, Revision 0 and Revision 1, "Unit 2 Emergency Diesel Generator Inoperable for Longer Than Allowed by Technical Specifications Due to Inadequate Work Instructions" NRC Follow-Up inspection 05000455/2011011 determined that the issue was an apparent violation and a White Finding (EA-11-014).  The IR was issued February 11, 2011.  On October 4, 2011, an NRC IP 95001 Supplemental IR was issued documenting the closure of finding 05000455/2011011-01.  As the enforcement actions have been issued, and the Supplemental Inspection has been completed with no significant issues identified, these LERs are closed. .2 The LER involved a licensee-identified mistaken plugging of a pressure sensor inside of containment during the previous refueling outage.  The plugged was placed during a routine surveillance on September 28, 2011 and on October 13, 2011, licensee personnel determined that while the instrument indicated that Unit 2 containment
pressure was within limits, that, in fact containment pressure was above the TS limit.  A containment entry was made, the plug was removed, containment pressure was reduced and the peak pressure was determined to be approximately 1.91 pounds per square inch gauge (psig).  The TS allowed value was 1.0 psig and the amount of time that the pressure could be above the limit was 1 hour with the plant required to be shut down within the following 42 hours.  By the time the situation was identified, understood, and corrected a total time of 95 hours and 48 minutes had elapsed. (Closed) Licensee Event Report 05000455/2011-002, Revision 0, "Containment Pressure Not Within Limits Longer than Allowed By Technical Specifications Due to Personnel Error" The licensee determined and the inspectors verified that the licensee's safety margin between peak containment pressure and the initial maximum allowed pressure was 10 psig.  The technicians' error and the delay in correcting the error resulted in 0.91 psig of the 10 psig margin being used.  There was a minor adverse safety consequence due to the licensee personnel's error. The technicians' error identified by the licensee resulted in a minor failure to comply with
TS 3.6.4, "Containment Pressure".  This LER is closed. 
48 Enclosure  4OA6  .1 Management Meetings On January 12, 2012, the inspectors presented the inspection results to Mr. B. Youman, and other members of the licensee staff.  The licensee acknowledged the issues presented.  The inspectors confirmed that none of the potential report input discussed was considered proprietary. Exit Meeting Summary .2 Interim exits were conducted for: Interim Exit Meetings  The results of an Operator Licensing inspection with the Lead Operations Training staff instructor, Mr. M. McCue, via telephone on December 8, 2011.  The results of an annual review of Emergency Action Level and Emergency Plan changes with the Emergency Preparedness Coordinator, Mr. R. Kartheiser, via telephone on December 7, 2011.    The results of Occupational and Public Radiation Safety programs inspections with the Site Vice President, Mr. T. Tulon, on November 10, 2011 and with the Acting Plant Manager, E. Hernandez, on December 28, 2011.  The licensee acknowledged the issues presented.  The inspectors confirmed that none of the potential report input discussed was considered proprietary.  Proprietary material received during the inspection was returned to the licensee. 4OA7  The following violation of very low safety significance was identified by the licensee.  The violation met the criteria of Section VI of the NRC Enforcement Policy for being dispositioned as a Non-Cited Violation. Licensee-Identified Violations .1 Technical Specification 5.5.1 states that the ODCM shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, and in the calculation of gaseous and liquid monitoring alarm and trip setpoints.  Effluent Monitors Alarms Setpoints Incorrectly Established  Contrary to the above, on August 26, 2010, the licensee identified a potential for non-conservative alarm setpoints for effluent monitors.  Subsequently, the licensee  calculated new setpoints for these monitors using the methodology prescribed in the ODCM and determined that the previous alarm setpoints were incorrectly established and were non-conservative (too high).  The inspectors determined that this finding was of more than minor significance because it was similar to Example 6.c in IMC 0612, Appendix E, "Example of Minor Issues".  Specifically, the effluent monitors with its alarm
set points would have failed to perform its intended function (i.e., trip or isolation function) to prevent an instantaneous effluent release in excess of the applicable TS instantaneous dose rate limits for gases.  In accordance with IMC 0609, Appendix D, 
49 Enclosure  "Public Radiation Safety," the inspectors determined the violation to be of very low safety significance, (Green) because the dose impact to a member of the public from the radiological release was less than the dose values in Appendix I to 10 CFR Part 50 and 10 CFR 20.1301(e).  This violation of TS 5.5.1 is being treated as a NCV consistent with Section 2.3.2 of the NRC Enforcement Policy.  The licensee entered this issue into their CAP as IR 1106461. ATTACHMENT:  SUPPLEMENTAL INFORMATION 
1 Attachment  SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT T. Tulon, Site Vice President Licensee B. Youman, Plant Manager D. Coltman, Operations Manager J. Feimster, Design Engineering Manager D. Damptz, Acting Maintenance Director S. Swanson, Nuclear Oversight Manager R. Gayheart, Training Director B. Barton, Radiation Protection Manager K. Anderson, Acting Radiation Protection Manager A. Creamean, Chemistry Manager D. Gudger, Regulatory Assurance Manager R. Cameron, Licensed Operator Requalification Lead E. Duncan, Chief, Branch 3, Division of Reactor Projects Nuclear Regulatory Commission  LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED 05000454/2011005-001 Opened and Closed NCV Failure to Identify Voided Sections of AF Piping (Section 1R15)    05000455/2011005-001 NCV Failure to Identify Voided Sections of AF Piping (Section 1R15)    05000454/2011005-002 NCV High Energy Line Break Operability Evaluation    (Section 1R15)  05000455/2011005-002 NCV High Energy Line Break Operability Evaluation    (Section 1R15)  05000454/2011005-003 URI Use of TLDs May Not be Consistent with the Methods    Used by the NVLAP Accreditation Process (Section 2RS4)  05000455/2011005-003 URI  Use of TLDs may not be consistent with the methods used    by the NVLAP accreditation process (Section 2RS4)  05000454/2011005-004 NCV Failure to Identify Hazardous Materials on Transportation    Manifest (Section 3RS8)   
2 Attachment  05000455/2011011-00 Closed LER Unit 2 Emergency Diesel Generator Inoperable for Longer Than Allowed by Technical Specifications Due to Inadequate Work Instructions, Revision 0 05000455/2011011-01 LER Unit 2 Emergency Diesel Generator Inoperable for Longer Than Allowed by Technical Specifications
Due to Inadequate Work Instructions, Revision         
3 Attachment  LIST OF DOCUMENTS REVIEWED The following is a list of documents reviewed during the inspection.  Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections of portions of the documents were evaluated as part of the overall inspection effort.  Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report. - IR 1067880; Byron 2010/2011 Winter Readiness Critique, March 30, 2011 Section 1R01:  Adverse Weather Protection (Quarterly) - IR 1186291; 2010/2011 Winter Readiness Critique, March 11, 2011 - IR 1193076; Action Tracking Process Versus Work Control Process, December 2, 2010 - IR 1238947; SX Chemical Feed Lines Need Insulating, July 12, 2011 - IR 1262839; Winter Readiness Work Rescheduled, September 14, 2011 - IR 1265348; Unable to Resolve Parts Required Issue, September 14, 2011 - IR 1265934; Winter Readiness Challenge - No CST Heaters Available, September 21, 2011 - IR 1280434; Switchyard Winter Readiness PM, October 24, 2011 - IR 1280750; Freeze Protection - CWPH Louvers LV48, 142 Stuck Open, October 24, 2011 - IR 1280755; Freeze Protection - Electric Heater 0VV37C Fan Motor, October 24, 2011 - IR 1280755; Freeze Protection: Electric Heater 0VV37C Fan Motor, October 24, 2011 - IR 1280757; 0VH09Y - Damper Stuck Open, October 24, 2011 - IR 1281870; Roof Access Hatch Will Not Remain Closed, October 26, 2011 - IR 1285676; Winter Readiness Walkdown, November 2, 2011 - IR 1286684; 0VT17J LV-82 Has a Louver Broke Preventing Set From Closing, November 5, 2011 - IR 1286686; 0VT11J LV-8 Has a Set of Louvers Not Fully closed, November 5, 2011 - IR 1286687; 0VT16J LV-80 Has a Broken Louver Preventing Set From Closing, November 5, 2011 - IR 1286688; 0VT13J LV-17 Has 2 Sets of Louvers Not Fully Closed, November 5, 2011 - IR 1286689; 0VT18J LV-83 Has Broken Louvers Preventing Set From Closing, November 5, 2011 - IR 1286693; 0VT20J LV-86 Sets of Louvers Not Fully Closed, November 5, 2011 - IR 1286904; 0VT07J LV-4 Has Broken Louvers, November 5, 2011 - IR 1286907; 0VT08J LV-5 Has 2 Sets of Louvers Not Fully Closed, November 5, 2011 - IR 1286908; 0VT10J LV-7 Has One Broken Louver, November 5, 2011 - IR 1286910; 0VT14J LV-18 Has a Set of Louvers Not Fully Closed, November 5, 2011 - IR 1286912; 0VT12J LV-9 Has Broken Louvers and Sets Not Fully Closed, November 5, 2011 - IR 1289988; Freeze Protection Concern, November 13, 2011 - IR 1293508; Winter Readiness System Review Work Removed From 2011,
November 15, 2011 - IR 1297625; 0BOSR XFT-A1, SH Area Heaters Testing Discrepancies, December 3, 2011  - Unit 2 Standing Order; Station Heat Coil Degradation in Unit 2 VA Plenum, Log #11-053 - 0BOSR XFT-A1; Freezing Temperature Equipment Protection SH and Department Support Requirements, Revision 13 - 0BOSR XFT-A3; Freezing Temperature Equipment Protection Plant Ventilation Systems, Revision 8 - 0BOSR XFT-A4; Freezing Temperature Equipment Protection Area Buildings Ventilation Systems and Tanks, Revision 7 - 0BOSR XFT-A5; Freezing Temperature Equipment Protection Non-Protected Area Buildings Ventilation Systems, Revision 6 
4 Attachment  - BOP XFT-1; Cold Weather Operations, Revision 2 - IR 1298335; 0BOSR XFT-A3 Freezing Temperature Protection Discrepancies, December 05, 2011 - Drawing M-62; Diagram of Residual Heat Removal, Revision BD Section 1R04:  Equipment Alignment (Quarterly)      - BAP 300-1A1; At The Controls Area, Revision 52 - BOP RH-E2A; Unit 2 Residual Heat Removal System Train A Electrical Lineup, Revision 4 - BOP RH-M2A; Unit 2 Residual Heat Removal System Train A Valve Lineup, Revision 10 - IR 0332862; 1B AF Pump Air Box Leakage, May 07, 2005 - IR 1289049; Fireproofing on Column Outside 1B AF Pump Room Degraded, November 10, 2011 - IR 1299293; AF005 Flow Control Valve Trim Clearance Low Margin Issue,  November 21, 2011 IR 1304078; Fire Drill Observation - SCBA Voice Amplifiers Not Working, December 17, 2011 - EC 355468; Evaluation of Diesel Driven Auxiliary Feedwater Air Box Gaps, Revision 0 - SPEC. L-2722 Proposed Seal for 2AB-1086 Unit 2; Sheet Numbers 1A, 1, 2, and 3, Revision 1 - BOP AF-M2B; Auxiliary Feedwater Train B Valve Lineup, Revision 4 Section 1R04:  Complete System Walkdown (Semi-Annual)    - IR 1076490; Fire Damper 2VE04Y Access Door Hinge Tack Welds Broken, May 28, 2011 Section 1R05:  Fire Protection (Quarterly) - IR 1075765; Electro-Thermo-Link Separated, June 1, 2010 - IR 1077737; Need CO2 OSS for 2 ICSRs on the T.S. Fire Tamper Surveillance, June 7, 2010 - IR 1072592; 2VD23YA Flexible Conduit Support Clip not Holding Conduit, May 24, 2010 - IR 1072640; Debris in Tray Below Damper 2VD63Y, May 24, 2010 - IR 1073509; Flexible Conduit Loose at Upper, South ETL on Fire Damper, May 26, 2010 - IR 1081618; Difficult to Access Damper, 1VE06Y for Surveillance/Repair, June 17, 2010 - IR 1289049; Fireproofing on Column Outside 1B AF Pump Room Degraded, November 10, 2011 - IR 1250346; Fire Brigade Leader Training Issue, August 12, 2011 - Fire Drill Scenario No. 11-04; Unit 1 Auxiliary Boiler Room Fire, September 16, 2011 - Pre-Fire Plan; Fire Area/Zone - FZ 8.3-1 Southeast, Revision 1 - EC 350613; Evaluation of Fire Damper S-Hook Orientation Impact on Dampers 2VD24&B, VC191Y, and 0VC193Y, Revision 0 - WO 1197473; Tech Spec Fire Damper 18-Month Visual Inspection, December 3, 2009 - WO 1028736; Tech Spec Fire Damper 18-Month Visual Inspection, August 4, 2008 - WO 1124519; Tech Spec Fire Damper 18-Month Visual Inspection, April 14, 2008 - WO 0848826; Tech Spec Fire Damper 18-Month Visual Inspection, December 15, 2006 - 0BMSR 3.10.g.7; TRM Fire Damper 18-Month Visual Inspection, Revision 13 - IR 1304076; Fire Drill Observation - Personnel Walking Through SIM Smoke, December 17, 2011 - RM-AA-101; Records Management Program, Revision 9 - OP-AA-201-003; Fire Drill Performance, Revision 12   
5 Attachment  Corrective Action Documents As a Result of NRC Inspection  IR 1291986; NRC Identified Fire Damper S-Hook Orientation Issue, November 17, 2011 IR 1304063; NRC Identified Issues with S-Hooks Not Resolved, December 17, 2011  - IR 1058790; Bad Fuse Found in 2RD06J Panel, April 20, 2011 Section 1R12:  Maintenance Effectiveness (Quarterly) - IR 1061760; MG Set Motor Smoked on Attempted PM Start, April 26, 2011 - IR 1062164; Motor Cutoff Switch Replaced for 2RD 05E-1B, April 27, 2011 - IR 1065922; Unit 2 Rods Will Not Manually Withdraw, May 5, 2010 - IR 1066455; Unit 2 RD07J Cabinet Capacitor Found Broken, May 6, 2011 - IR 1066490; 2A RD MG Set 1 OVT Timer Failed, May 6, 2011 - IR 1067031; Vibrations Levels on 2B Rod Drive MG Set Remain Unchanged, May 8, 2011 - IR 1290831; 1A RD MG Set Increased Vibrations, November 15, 2011 - BOP RD-5; Control Rod Drive MG Set Up and Paralleling to Operating Control Rod Drive MG Set, Revision 10 - ER-AA-600-1042; On-Line Risk Management, Revision 7 Section 1R13:  Maintenance Risk Assessments and Emergent Work Control (Quarterly) - ER-AA-600-1021; Risk Management Application Methodologies, Revision 4 - PC-AA-1014; Risk Management, Revision 2 - 0BOA ENV-1; Adverse Weather Conditions Unit 0, Rev. 108 - 1BOA ENV-1; Adverse Weather Conditions Unit 0, Rev. 102 - 0BOA ENV-2; Rock River Abnormal Water Level Unit 0, Rev. 100 - IR 1285254; Rock River Level Low, November 2, 2011 - IR 240597; Unplanned LOCAR Entry for 2A Emergency Diesel Generator Due to 2VD024YB Damper Section 1R15:  Operability Evaluations (Quarterly) - IR 240972; Fire Damper "S" Hook Installed Improperly, August 2, 2004 - IR 240985; Need Work Request for Fire Damper Inspections, August 2, 2004 - IR 248940; Fire Damper Issues Identified by NRC, August 31, 2004 - IR 249486; Fire Damper "S" Hook Issue Identified by NRC, September 2, 2004 - IR 297682; NRC Question About Fire Damper S-Hooks, February 4, 2005 - IR 757875; Fire Damper S-Hooks, April 1, 2008 - IR 1285361; Potential Multiple Starts of Diesel Driven AF Pump, November 2, 2011 - IR 1291986; NRC Identified Fire Damper S-Hook Orientation Issue, November 17, 2011 - IR 1292337; Piping Between 2AF006B and 2AF017B Found Not Full, November 18, 2011 - IR 1295958; AF Improvement Suggestion, November 18, 2011 - IR 1295958; AF Improvement Suggestion, November 18, 2011 - IR 1295488; EOC Review of Byron IP 1291986 Fire Damper S-Hooks, November 29, 2011 - Three Mile Island Corrective Action Program Number TI999-0943 linked to ETTS # 25169; One Section of Fire Damper AH-FD-22 Did Not Close During Test, October 1, 1999 - EC 350613; Evaluation of Fire Damper S-Hook Orientation Impact on Dampers 2VD24YB, VC191Y and OVC193Y, August 11, 2004 - EC 350550; Evaluation of Fire Damper S-Hook Orientation Impact, August 31, 2004 - WO 1197473 01; Technical Specification Fire Damper 18 Month Visual Inspection, December 3, 2009 
6 Attachment  - EC 383229; Fill Empty Pipe Between 1AF006A and 1AF017A, Close Drain Valve 1AF018A, and Throttle Open Vent Valve 1AF030A, Revision 0 - EC 383308; OP EVAL 11-003, Small Voids in 2A and 2B SX to AF Suction Piping, Revision 0 - EC 386578; OP Evaluation 11-009 Multiple Starts of Diesel AF Pump, November 8, 2011 - WO 1124519 01; Technical Specification Fire Damper 18 Month Visual Inspection,
April 14, 2008 - WO 848828 01; Technical Specification Fire Damper 18 Month Visual Inspection, December 15, 2006 - BOP AF-3, Filling and Venting the Auxiliary Feedwater System, Revision 4  - M-1FW01147X; Drawing, Byron Unit 1 Support M-1FW01147X, Rev. D - M-1SI06010X; Drawing, Byron Unit 1 M-1SI06010X Sub. E - 13.1.29; Calculation for Mechanical Component Support M-1SI06010X, Rev. D - 13.1.29; Calculation for Mechanical Component Support M-1SI06010X, Rev. E - 13.1.29; Calculation for Mechanical Component Support M-1SI06025V, Rev. F - 13.1.29-BYR97-359; 1SI06010X, 1SI06012X, 1SI06031X, 1SI06075X, 1SI06105X, and 1SI06155X.  Evaluate Subsystem 1SI06 Supports for Additional Loads, Rev. 5 - 14.1.18-1FW01147; Calculation for Mechanical Component Support Number M-1FW01147X, Rev. 0 - IR 1272187; Issues Applicable to Byron from Braidwood Mod/50.59 Inspection, October 4, 2011 - BRW-97-0827-M; Piping Evaluation for Lead Shielding on Subsystem 2SI06, Rev. 0 - RH-2; Large Bore Isometric, Residual Heat Removal System, Rev. 22 - IR 1276280; UFSAR Section 3.6 and Piping Design Specifications are Inconsistent, October 13, 2011 - IR 1276069; 1/2FW01 Piping Calculation Revisions Do Not Meet UFSAR Requirements, October 13, 2011 - IR 1272834; Incorrect Coding of Support Skew on 1FW01 Piping, October 5, 2011 - EMD-064195; Calculation, Addendum E to Piping Stress Report for Subsystem 1SI06, Rev. 5 - IR 1262559; BOP ID: Small Shift Trend in Major Plant Parameters, September 13, 2011 - IR 1265515; U1 RX Power Lowered Below 99.5% for LEFM Troubleshooting, September 16, 2011 - IR 1253439; LEFM Computer Point Is Off Normal Per 1BOSR CX-M1, August 19, 2011 - IR 1263929; LEFM Alarms in IR 1241271 and Card Analysis- OEM Review Results, September 16, 2011 - IR 1241271; LEFM Trouble Alarm - Ramp Back, July 19, 2011 - IR 1241629; LEFM Trouble Alarm Causing Unit 1 Ramp Back Again, July 19, 2011 - IR 1277627; NRC Questions on HELB - Presence of Openings, October 17, 2011 - IR 1279759; Added Scope to Turbine Building HELB Effort, October 21, 2011 - IR 1244251; HELB Discussion with the NRC Residents, July 26, 2011 - IR 1240295; Two New Line Break Locations Identified During HELB Analysis, July 15, 2011 - IR 1238611; Inoperability of ESF Components Due To HELB, July 11, 2011 - IR 1237133; Non-Conservatism in Turbine Building HELB Analysis, July 6, 2011 - IR 1184258; Non-Conservatism in Turbine Building HELB Analysis, March 7, 2011 - IR 1276895; NRC Question - Effect of Turbine Building HELB on Reactor Trip Breakers, October 14, 2011 - IR 1272802; 2B CS Pump Did Not Auto Start During 2B DG Sequence Test, October 5, 2011 Section 1R19:  Post Maintenance Testing (Quarterly) - WO 1476986 02; 2B CS Pump Did Not Auto Start During 2B DG Sequence Test, October 5, 2011 
7 Attachment  - WO 1476986 03; 2B CS Pump Did Not Auto Start During 2B DG Sequence Test, October 5, 2011 - ER-AA-1200; Critical Component Failure Clock, Revision 7 - WO 1324847; 2AF014E IST Disassembly and Inspection, October 5, 2011 - WO 1324407; 2AF014G IST Disassembly and Inspection, October 5, 2011 - WO 1365478; 2AF014H IST Disassembly and Inspection, October 5, 2011 - 2BOSR 7.5.7-2; Unit 2 Train B Auxiliary Feedwater Flow Path Operability Surveillance Following Shutdown, Rev. 6 - IR 1272927; 2B AF Static Pressure Gauge Indication Failed Low, October 5, 2011 - 2BOSR 0.5-2.RH.4-1; Unit 2 ASME Surveillance Requirements for Residual Heat Removal Pump Miniflow Valve 2RH610, Revision 5  Section 1R20:  Refueling and Other Outage Activities - 2BGP 100-1; Plant Heatup, Revision 50 - 2BGP 100-2; Plant Startup, Revision 40 - 2BGP 100-3; Power Ascension, Revision 73 - IR 128875; Error in RCS Leakrate Data in MCR Logs, November 10, 2011 Section 1R22:  Surveillance Testing (Quarterly) - BOP AF-1; Diesel Driven Aux Feedwater Pump Alignment to Standby Condition, Revision 24 - BOP AF-7; Diesel Driven Auxiliary Feedwater Pump 1B Startup on Recirc, Revision 37 - BOP AF-7T1; Diesel Driven Auxiliary Feedwater Pump Operating Log, Revision 21 - BOP AF-8; Diesel Driven Auxiliary Feedwater Pump 1B Shutdown, Revision 22 - WO 1459476 01; 1AF01PB Group B IST Requirements for Diesel Driven AF Pump, October 28, 2011 - 1BOSR 7.5.4-2; Unit 1 Diesel Driven Auxiliary Feedwater Pump Monthly Surveillance, Revision 14 - 2BOSR 8.1.11-2; 2B Diesel Generator Sequencer Test 18 Month, Revision 11 - WO 1337989 01; 2B Diesel Generator Sequencer Test, October 5, 2011 - IR 1281160; 1SI8958B Failed Acceptance Criteria During 1B RH PP IST, October 25, 2011 - IR 1298289; Unit 2 RCS Leakrate Surveillance Needs Improvements, December 05, 2011 - 0BMSR FP-5; Fire Hydrant Yard Loop Annual Flush, Revision 8 - WO 1454082; 1RH01PB Group A IST Requirements for Residual Heat Removal Pump, October 25, 2011 - IR 1281160; 1SI8958B Failed Acceptance Criteria During 1B RH PP IST, October 25, 2011 Corrective Action Documents As a Result of NRC Inspection  - IR 1304054; Surveillance Improvements Needed, December 17, 2011 - AR 1214604; NOS ID B1R17 RP Outage Adverse Trend; 5/11/2011 2RS1:  Radiological Hazard Assessment and Exposure Controls (71124.01) - AR 1243013; RP Response to Fire Alarm Did Not Meet Expectations; 7/22/2011 - AR 1248312; NOS ID Poor Contamination Boundary Controls in FHB; 8/5/2011 - BRP 5800-3; Area Radiation Monitoring System Alert/High Alarm Setpoints; Revision 25 - BRP 5820-14; Process Radiation Monitoring System Alert/High Alarm Setpoints; Revision 42 - RP-AA-460; Controls for High and Locked High Radiation Areas; Revision 20 - RP-AA-460-001; Controls for Very High Radiation Areas; Revision 2 
8 Attachment  - RP-AA-460-003; Access to HRAs/LHRAs in Response to a Potential or Actual Emergency; Revision 1 - RP-AP-460; Access to Reactor In-Core Sump Area; Revision 2 - Work Order 1094446 01; Non Accessible Charcoal Adsober Operability Test; 8/31/2009 2RS3:  In-Plant Airborne Radioactivity Control and Mitigation (71124.03) - Work Order 1149597 01; Perform Recirc Charcoal Halide Test Control Room Ventilation System; 3/16/2010 - National Voluntary Laboratory Accreditation Program; Selected Records; Various Dates 2RS4:  Occupational Dose Assessment (71124.04) - AR 1106461; Non-Conservative Liquid Discharge Alarm Setpoints; 8/26/2010 2RS5:  Radiation Monitoring Instrumentation (71124.05) - AR 1107149; Additional Investigation Required for ODCM/LCO Implementation; 8/29/2010 - AR 1302586; Non-Conservative Setpoints Found for TRM Rad Monitors; 12/14/2011 - AR 1303888; Potential RETS Impact Due to Non-Conservative PRM Setpoints; 12/16/2011 - BRP 5800-3; Area Radiation Monitoring System Alert/High Alarm Setpoints; Revision 25 - BRP 5820-12; Response to Area and Process Radiation Monitor LCOARS or Out of Service Conditions; Revision 28 - BRP 5820-14; Process Radiation Monitoring System Alert/High Alarm Setpoints; Revision 42 - BYR-10-001; Calculation of Liquid Process Radiation Monitor Set Points; 8/30/2010 - RP-BR-951; Set Point Changes for Process Radiation Monitors; ODCM (Effluent) Monitors; Revision 0. - 2009 Byron Station Annual Radioactive Effluent Release Report; April 30, 2010 2RS6:  Radioactive Gaseous and Liquid Effluent Treatment (71124.06) - 2010 Byron Station Annual Radioactive Effluent Release Report; April 29, 2011 - AR 00978684; Effluent Monitor Surveillance Not Performed Per Procedure; dated October 13, 2009 - AR 00996917; Effluent Release Process - Potential Gaps; dated November 22, 2009 - AR 01106461; Non-Conservative Liquid Discharge Alarm Setpoints; dated August 26, 2010 - AR 01107146; Additional Investigation Required for ODCM/LCO Implementation; dated August 29, 2010 - AR 01108146; Treatment of Ar-41 in Gaseous Effluents; dated August 31, 2010 - AR 1247902; 1/2 RE-PR-028 Particulate Filters Could Not Be Located; 8/4/2011 - BCP-400-TWX01; Liquid Radwaste Release from Release Tank OWX01T; Revision 59 - CY-AA-120-400; Closed Cooling Water Chemistry; Revision 13 - CY-AA-120-420; Auxiliary Boiler Chemistry; Revision 10 - CY-AA-130-201; Radiochemistry Quality Control; Revision 1 - CY-AA-170-000; Radioactive Effluent and Environmental Monitoring Programs; Revision 5 - CY-BY-170-301; Offsite Dose Calculation Manual; Revision 6 - CY-BY-170-301; Offsite Dose Calculation Manual; Revision 7 - FASA 1013272; Radioactive Gaseous and Liquid Effluents (RETS); 9/17/2010 - FASA 831375; Radioactive Gaseous and Liquid Effluents (RETS); 3/31/2009 - Gaseous Discharge Permit Number 110411; dated October 13, 2011 - Gaseous Discharge Permit Number 110445; dated October 31, 2011 
9 Attachment  - Liquid Discharge Permit Number 110437; dated October 25, 2011 - RP-BY-900-1PR29J; 1PR29J Process Radiation Monitor Radiological Air Sampling;  Revision 2 - RP-BY-900-2PR29J; 2PR29J Process Radiation Monitor Radiological Air Sampling; Revision 2 - Work Order 1110220 01; Fuel Handling Building Exhaust Charcoal Adsorber Bank Operability Test; 12/21/2009 - Work Order 1236016 01; Perform Calibration of Rad Monitor 1PR28J; 1/18/2011 - Work Order 1249358 01; Perform Surveillance Test of 2PR28J; 4/26/2011 - 2009 Byron Station Annual Radiological Environmental Operating Report; May 2010 2RS7:  Radiological Environmental Monitoring Program (71124.07) - 2010 Byron Station Annual Radiological Environmental Operating Report; May 2011 - 2010 Land Use Census; dated August 30, 2010 - AR 00958298; ODCM Vent Stack Coordinates Inaccurate; dated August 27, 2009 - AR 01034880; REMP Milk Sample - Invalid Result; dated February 24, 2010 - AR 01090911; REMP Groundwater Sample Location No Longer Participating; dated July 15, 2010 - AR 01122156; REMP Sample Results above Detection Limit; dated October 5, 2010 - AR 01129610; Check-In Self-Assessment on the Radiological Environmental Monitoring Program (REMP); Approved June 20, 2011 - AR 01223226; REMP Air Samples - Positive Detects for I-131; dated June 1, 2011 - Environmental, Inc. Sampling Manual, Revision 13 - AR 1015646; Non-Conforming Waste Found in Radwaste Shipment; 1/12/2010 2RS8:  Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation (71124.08) - AR 1067394; Non-Conforming Radioactive Waste in Shipment; 5/10/2010 - AR 1173307; RWS 10-013 Contained Unapproved Mixed Waste; 2/10/2011 - AR 1221229; RWS 11-006 Contained Un-Manifested Asbestos; 5/26/2011 - AR 1231158; RWS 11-001 Manifested for Material Not Present; 6/21/2011 - AR 1233858; NOS ID: Cause of IR Incorrect RW Shipping Paperwork Not Identified; 6/28/2011 - AR 1250262; NOS ID: RP Failed to Address NOS Issues - Finding; 8/11/2011 - AR 1270337; Sea/Land Inventory Not Documented in Accordance with T&RM; 9/30/2011 - AR 1285148; QHPI Request for RP - RWS Manifest; 11/2/2011 - AR 1285591; NRC Identified:  DAW Container Inspections Outside of Procedure Guidance; 11/3/2011 - AR 928393; Non-Conforming Metal Shipped to Bear Creek Processing; 6/5/2009 - Course Code N-RPCTAR; DBIG RAM Shipping/Inspection; Revision 0 - FASA 9866572-03; Radioactive Solid Waste Processing and Radioactive Material Handling, Storage and Transportation; 4/26/2011 - Letter BYRON-2008-0123; Report of Changes, Tests, and Experiments; 12/12/2008 - Letter BYRON-2010-0147; Report of Changes, Tests, and Experiments; 12/13/2010 - Module/LP ID RPTI 8.05; Radioactive Material Shipments; Revision 18 - NOSA-BYR-10-04 (AR 969170); Chemistry, Radwaste, Effluent and Environmental Monitoring Audit Report; 6/2/2010 - NOSA-BYR-11-06 (AR 1130876); Radiation Protection; 8/18/2011 
10 Attachment  - Performance Training and Evaluation; Task 509-004; Provide Radiological Protection Coverage During the Preparation of a Shipment of Radioactive Material; 11/5/2009 - Performance Training and Evaluation; Task 509-010; Perform Surveys on Radioactive Material Transport Vehicles; date not provided - Performance Training and Evaluation; Task 509-013; Receipt Survey of Radioactive Material; - Radiation Protection Technician/Continuing Training; DBIG:  Waste Acceptance Guidelines; Revision 0 - RP-AA-100; Process Control Program for Radioactive Wastes; Revision 7 - RP-AA-600; Radioactive Material/Waste Shipments; Revision 12 - RP-AA-600-1001; Exclusive Use and Emergency Response Information; Revision 6 - RP-AA-600-1003; Radioactive Waste Shipments to Barnwell and Defense Consolidation Facility (DCF); Revision 7 - RP-AA-600-1004; Radioactive Waste Shipments to Energy Solutions' Clive Utah Disposal Site Containerized Waste Facility; Revision 9 - RP-AA-600-1005; Radioactive Material and Non Disposal Site Waste Shipments; Revision 12 - RP-AA-601; Surveying Radioactive Material Shipments; Revision 13 - RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 01/20/2011 - RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 06/02/2011 - RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 10/03/2009 - RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 10/19/2010 - RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 2/17/2010 - RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 8/18/2010 - RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 9/16/2011 - RP-AA-605 Attachment 2; Waste Stream Results Review; DAW; 1/20/2011 - RP-AA-605 Attachment 2; Waste Stream Results Review; DAW; 3/30/2011 - RP-AA-605 Attachment 2; Waste Stream Results Review; DAW; 4/18/2010 - RP-AA-605 Attachment 2; Waste Stream Results Review; Primary Resin; 3/10/2010 - RP-AA-605 Attachment 2; Waste Stream Results Review; Secondary Radwaste Filter; 4/24/2010 - RP-AA-605 Attachment 2; Waste Stream Results Review; Secondary Resin; 3/25/2010 - RP-AA-605; 10 CFR Part 61 Program; Revision 4 - Shipment RMS09-094; Rx Vessel Dosimetry; Type A Package; 11/18/2009 - Shipment RMS11-078; Dirty Laundry; Low Specific Activity (LSA-II); 4/27/2011 - Shipment RWS10-011; Dewatered Bead Resin; Low Specific Activity (LSA-II); 6/29/2010 - Shipment RWS10-012; DAW Trash; Low Specific Activity (LSA-II); 9/1/2010 - Shipment RWS10-013; DAW Trash and TR Pond Sludge; Low Specific Activity (LSA-II); 9/1/2010 - IR 1139610; Potential Non-Conservative Tech Specs for Component Cooling; November 12, 2010 Section 4OA1:  Performance Indicator Verification (71151) - IR 1139728; CC System OLR Impact From IR 1139610; November 12, 2010 - IR 1141591; 2A DG Emergency Stopped Due to Oil Leak; November 17, 2010 - IR 1158910; RH System Issue Resulting in LER - Tracking; January 05, 2011 - IR 1128409; Threshold for SSFF Approaching White Region; June 14, 2011 - IR 1284054; Legacy Issues with Main Steam Tunnel Pressurization Calculation; October 31, 2011 - LS-AA-2080; NRC Safety System Functional Failure - July 2010 to July 2011, Revision 4 - EC 382262; Byron OpEval #10-006 - U-0 CC Pump Potential Non-Conservative Tech Spec 
11 Attachment  - LER 454/2010-001; Technical Specifications Allowed Outage Time Extension Request for Component Cooling System Contained Inaccurate Design Information that Significantly Impacted the Technical Justification, November 12, 2010 - LER 454/2011-001; Potential Loss of Residual Heat Removal System Safety Function in Mode 4 When Aligned for Shutdown Cooling Due to Potential for Flashing or Voiding of Coolant During a Shutdown Loss of Cooling Accident, January 5, 2011 - LER 455/2011-001; Unit 2 Emergency Diesel Generator Inoperable for Longer than Allowed by Technical Specifications Due to Inadequate Work, November 17, 2011 - NEI 99-02 Revision 6; Regulatory Assessment Performance Indicator Guideline, October 2009 - Reactor Oversight Program MSPI Basis Document Revision 3; December 2006 - Monthly Data Elements for NRC Reactor Coolant System (RCS) Specific Activity, October 2010 - September 2011 - PWR High Pressure Safety Injection Function, October 2010 - September 2011 - Residual Heat Removal Function, October 2010 - September 2011 - PWR Auxiliary Feedwater/Emergency Feedwater Function, October 2010 - September 2011 - Cooling Water Support Function, October 2010 - September 2011 - IR 1154673; Unable to Perform Manual Stroke Surveillance of 1SX150A, December 20, 2010 - IR 1152376; Unit 2 CWS MSPI Exelon At-Risk, December 14, 2010 - IR 1263487; CWS2 (SX) MSPI Low Margin, September 15, 2011 - IR 1090691; Unit 1 CWS MSPI At-Risk, July 14, 2010 - Monthly Data Elements for NRC Unplanned Power Changes Per 7000 Critical Hours, June 2010 - October 2011 - IR 1259684; Byron PI in Variance - P.8.1.2 Unplanned Power Changes, September 6, 2011 - IR 1116305; Runback of Byron Station U-1 Due to 1A FW PP Trip, September 22, 2010 - IR 1271650; Difference Between Byron & Braidwood PPC Point Calcs Y2021 & Y2022 Section 4OA2:  Identification and Resolution of Problems (71152) - IR 1282689; Pin Hole Leak in Area 7 on 2RY8028 P-44 - IR 1289655; IR Indicates DG Fire Pump Started in Over Ride for Test CCP,
November 04, 2011 - 2BwOSR 3.8.1.14-2; 2B DG 24 Hour Endurance Run, Revision 5 - WO 1323726; 2B DG 24 Hour Endurance Run 18 Month, September 13, 2011 - Analysis BYR11-036; Turbine Building HELB and Room Heat Up Analyses for MUR PU, Revision 0  - EC 383599; Op Eval 11-005, Turbine Building HELB Analysis Input Errors, Revision 1 - OWA Board Meeting Minutes; Year 2010 Quarter 4, December 28, 2010 - OWA Board Meeting Minutes; Year 2011 Quarter 1, April 5, 2011 - OWA Board Meeting Minutes; Year 2011 Quarter 2, June 30, 2011 - OWA Board Meeting Minutes; Year 2011 Quarter 3, October 14, 2011 - OWA Related IRs; 4Q2010 - 3Q2011 - IR 806396; Both Units SD Systems Degraded for >5 Years, August 12, 2008 - IR 1007239; Review SJAE Strainer Plugging for OWA/OC, December 18, 2009 - IR 1106359; Common Cause - Recommend Venting SD During Stroke Time Surveillance, August 26, 2010 - IR 1118055; 2A Main Feed Pump Recirc Not Modulating Properly, September 26, 2010 - IR 1122751; Missed Fire Watches in the Past, October 06, 2010 - IR 1151298; Unit 1 Tower Overflow, December 12, 2010 - IR 1155725; Caustic Dilution Flow Only Reading 6 GPM, December 24, 2010 - IR 1158940; Multiple Failure of Employee Alarm System, January 1, 2011 - IR 1169182; MMD Support for 2B FW Pump Turning Gear Operation, January 31, 2011 
12 Attachment  - IR 1172246; 0CW278A, Through Wall Crack on Valve Body, February 08, 2011 - IR 1172509; 0CW220 Flow Control Valve Not Repositioning Upon Demand, February 08, 2011 - IR 1194212; Operator Work Around, March 29, 2011 - IR 1194754; RSH CO2 TK Repair(s) Need to Be Expedited, March 30, 2011 - IR 1194754; Missed Closure of ATI, January 09, 2004 - IR 1211839; 2WG046 Drip Pan is Removed Consider Operator Challenge, May 4, 2011 - IR 1212344; Degradation of RSH CO2 Worsens, May 5, 2011 - IR 1216461; 2B CW PP Intake DP 9" Jumped to 2', May 16, 2011  Corrective Action Documents As a Result of NRC Inspection - IR 1276895; NRC Question - Effect of TB HELB on Reactor Trip Breakers, October 14, 2011 - IR 1278980; NRC Question - Maintaining VCT Pressure High for Chemistry, October 18, 2011 - EP-AA-1002; Exelon Nuclear Radiological Emergency Plan Annex for Byron Station; Revisions 26, 27, and 28 Section 1EP4:  Emergency Action Level and Emergency Plan Changes - EP-AA-120-1001; 50.54(q) Program Evaluation and Effectiveness Reviews for Revisions 27 and 28 - EP-AA-120-F-01; EP Document Approval Forms for Revisions 27 and 28   
   
   
13 Attachment  LIST OF ACRONYMS USED  ADAMS Agencywide Document Access Management System AF Auxiliary Feedwater ALARA As-Low-As-Is-Reasonably-Achievable ANSI American National Standards Institute ASME American Society of Mechanical Engineers CAP Corrective Action Program CFR Code of Federal Regulations CLB Current Licensing Basis DAW Dry Active Waste DG Emergency Diesel Generator DOT Department of Transportation EAL Emergency Action Level ESF Engineered Safety Feature HELB High Energy Line Break HVAC Heating, Ventilation, and Air Conditioning IMC Inspection Manual Chapter IP Inspection Procedure IR Inspection Report IR Issue Report IST Inservice Testing LER Licensee Event Report LORT Licensed Operator Requalification Training MEER Miscellaneous Electrical Equipment Room MG Motor Generator NEI Nuclear Energy Institute OBE Operating Basis Earthquake ODCM Offsite Dose Calculation Manual OOS Out of Service OpEval Operability Evaluation OSP Outage Safety Plan OWA Operator Workaround psig pound per square inch gauge MSPI Mitigating Systems Performance Index NCV Non-Cited Violation NRC U.S. Nuclear Regulatory Commission NVLAP National Voluntary Laboratory Accreditation Program PI Performance Indicator RCS Reactor Coolant System RFO Refueling Outage RHR Residual Heat Removal RWST Refueling Water Storage Tank SDP Significance Determination Process SH Station Heating SRP Standard Review Plan SSC Structure, System, and Component SX Essential Service Water TLD Thermoluminescent Detector TS Technical Specification 
14 Attachment  UFSAR Updated Final Safety Analysis Report UL Underwriters Laboratory URI Unresolved Item VA Auxiliary Building Ventilation WO Work Order 
M. Pacilio      -2-  In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Sincerely,  /RA/  Eric R. Duncan, Chief Branch 3 Division of Reactor Projects Docket Nos. 50-454; 50-455 License Nos. NPF-37; NPF-66  Enclosure: Inspection Report No. 05000454/2011005 and 05000455/2011005    w/Attachment:  Supplemental Information  cc w/encl: Distribution via ListServ                DOCUMENT NAME:  G:\DRPIII\BYRO\Byron 2011 005.docx  Publicly Available  Non-Publicly Available  Sensitive  Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy OFFICE RIII        NAME EDuncan:dtp    DATE 02/07/12    OFFICIAL RECORD COPY 
Letter to M. Pacilio from E. Duncan dated February 7, 2012.  SUBJECT: BYRON STATION, UNITS 1 AND 2, NRC INTEGRATED INSPECTION REPORT 05000454/2011005; 05000455/2011005 
DISTRIBUTION: Breeda Reilly RidsNrrDorlLpl3-2 Resource RidsNrrPMByron Resource
RidsNrrDirsIrib Resource Cynthia Pederson
Jennifer Uhle Steven Orth Jared Heck Allan Barker Carole Ariano Linda Linn DRPIII DRSIII Patricia Buckley Tammy Tomczak ROPreports.Resource@nrc.gov   


M. Pacilio                                  -2-
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response (if any) will be available electronically for public inspection in the
NRC Public Document Room or from the Publicly Available Records (PARS) component of
NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
                                            Sincerely,
                                            /RA/
                                            Eric R. Duncan, Chief
                                            Branch 3
                                            Division of Reactor Projects
Docket Nos. 50-454; 50-455
License Nos. NPF-37; NPF-66
Enclosure:    Inspection Report No. 05000454/2011005 and 05000455/2011005
                w/Attachment: Supplemental Information
cc w/encl:    Distribution via ListServ
          U. S. NUCLEAR REGULATORY COMMISSION
                          REGION III
Docket Nos:          50-454; 50-455
License Nos:        NPF-37; NPF-66
Report Nos:          05000454/2011005 and 05000455/2011005
Licensee:            Exelon Generation Company, LLC
Facility:            Byron Station, Units 1 and 2
Location:            Byron, IL
Dates:              October 1, 2011, through December 31, 2011
Inspectors:          B. Bartlett, Senior Resident Inspector
                    J. Robbins, Resident Inspector
                    R. Ng, Project Engineer
                    J. Dalzell-Bishop, DRS Emergency Response Specialist
                    J. Cassidy, Senior Health Physicist
                    R. Jickling, Senior Emergency Preparedness Inspector
                    B. Palagi, Senior Operations Engineer
                    J. Nance, Reactor Engineer
                    J. Benjamin, Braidwood Senior Resident Inspector
                    C. Thompson, Resident Inspector, Illinois Emergency
                      Management Agency
Approved by:        E. Duncan, Chief
                    Branch 3
                    Division of Reactor Projects
                                                                    Enclosure
                                        TABLE OF CONTENTS
REPORT DETAILS .................................................................................................................... 4
Summary of Plant Status ........................................................................................................ 4
      1R01    Adverse Weather Protection (71111.01)............................................................ 4
      1R04    Equipment Alignment (71111.04) ...................................................................... 5
      1R05    Fire Protection (71111.05) ................................................................................. 6
      1R11    Licensed Operator Requalification Program (71111.11) .................................... 7
      1R12    Maintenance Effectiveness (71111.12).............................................................. 8
      1R13    Maintenance Risk Assessments and Emergent Work Control (71111.13) ......... 9
      1R15    Operability Evaluations (71111.15) ...................................................................10
      1R19    Post-Maintenance Testing (71111.19) ..............................................................17
      1R20    Outage Activities (71111.20) ............................................................................18
    2.  REACTOR SAFETY ...................................................................................................20
      1EP4    Emergency Action Level and Emergency Plan Changes (71114.04) ................20
      1EP6    Drill Evaluation (71114.06) ...............................................................................21
    3.  RADIATION SAFETY .................................................................................................21
      2RS1 Radiological Hazard Assessment and Exposure Controls (71124.01) ..............21
      2RS3 In-Plant Airborne Radioactivity Control and Mitigation (71124.03) ....................24
      2RS4 Occupational Dose Assessment (71124.04) .....................................................25
      2RS5 Radiation Monitoring Instrumentation (71124.05) .............................................26
      2RS6 Radioactive Gaseous and Liquid Effluent Treatment (71124.06) ......................26
      2RS7 Radiological Environmental Monitoring Program (71124.07) ............................32
      2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,
              and Transportation (71124.08) ...........................................................................34
    4.  OTHER ACTIVITIES ...................................................................................................40
      4OA1 Performance Indicator Verification (71151).......................................................40
      4OA2 Identification and Resolution of Problems (71152)............................................45
      4OA3 Follow-Up of Events and Notices of Enforcement Discretion (71153) ...............47
      4OA6 Management Meetings .....................................................................................48
      4OA7 Licensee-Identified Violations ...........................................................................48
SUPPLEMENTAL INFORMATION............................................................................................. 1
Key Points of Contact ............................................................................................................. 1
List of Items Opened, Closed, and Discussed ........................................................................ 1
List Of Documents Reviewed.................................................................................................. 3
List Of Acronyms Used ..........................................................................................................13
                                                                                                                      Enclosure
                                      SUMMARY OF FINDINGS
Inspection Report (IR) 05000454/2011005, 05000455/2011005; 10/01/2011 - 12/31/2011; Byron
Station, Units 1 & 2; Operability Evaluations and Functional Assessments; Radioactive Solid
Waste Processing and Radioactive Material Handling, Storage, and Transportation
This report covers a 3-month period of inspection by resident inspectors and announced
baseline inspections by regional inspectors. Three Green findings were identified by the
inspectors. The findings were considered Non-Cited Violations (NCVs) of NRC regulations.
The significance of most findings is indicated by their color (Green, White, Yellow, Red) using
Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Assigned
cross-cutting aspects were determined using IMC 0310, Components Within the Cross-Cutting
Areas. Findings for which the SDP does not apply may be Green or be assigned a severity
level after NRC management review. The NRCs program for overseeing the safe operation of
commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,
Revision 4, dated December 2006.
A.      NRC-Identified and Self-Revealed Findings
        Cornerstone: Mitigating Systems
        Green. The inspectors identified a finding of very low safety significance and an
        associated NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action,
        when licensee personnel failed to identify voided piping between Unit 1 valves 1AF006B
        and 1AF017B and Unit 2 valves 2AF006B and 2AF017B of the auxiliary feedwater (AF)
        system. The piping between these valves had been historically voided until they were
        recently re-designed to be filled and maintained filled with water to address an
        NRC-identified Green finding and an associated NCV of 10 CFR Part 50, Appendix B,
        Criterion III, Design Control. The licensee entered this issue into their Corrective
        Action Program (CAP) as IR 1296819, IR 1292337, and IR 1295760. Corrective actions
        included instituting an Operations Standing Order, replacing the Unit 1 AF drain valve,
        and the isolation of the Unit 2 AF drain valve.
        This finding was determined to be more than minor because it was associated with the
        Design Control attribute of the Mitigating Systems Cornerstone and adversely affected
        the cornerstone objective of ensuring the availability, reliability and capability of systems
        that respond to initiating events to prevent undesirable consequences (i.e., core
        damage). The inspectors determined that the finding could be evaluated using the
        SDP in accordance with IMC 0609, Significance Determination Process,
        Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings,
        Table 4a for the Mitigating Systems Cornerstone. Specifically, the inspectors answered
        Yes to Question 1 - Is the finding a design or qualification deficiency confirmed not to
        result in a loss of operability or functionality? Based upon this Phase 1 screening, the
        inspectors concluded that the finding was of very low safety significance (Green). This
        finding had a cross-cutting aspect in the Resources component of the Human
        Performance cross-cutting area [H.2(c)] because the licensee did not have adequate
        procedures to ensure that piping between Unit 1 valves 1AF006B and 1AF017B and
        Unit 2 valves 2AF006B and 2AF017B were maintained filled with water. (Section 1R15)
                                                1                                  Enclosure
Green. The inspectors identified a finding of very low safety significance and an
associated NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures,
and Drawings, when licensee personnel failed to adhere to Operability Determination
Process standards after identifying a non-conservative assumption related to closure
times for hazard barrier dampers separating the Turbine Building from various safety-
related rooms within the Auxiliary Building. In particular, the issues raised by the
inspectors during their review of Operability Evaluation 11-006, Revision 1, resulted in
the station re-evaluating the non-conservative assumptions against aspects of the
current licensing basis (CLB) not previously considered, and substantially revising the
Operability Evaluation. The licensee entered these issues into their CAP as IR 1184258,
IR 1237133, IR 1238611, IR 1240295, IR 1244251, and IR 1276895. In addition to
revising Operability Evaluation 2011-006, corrective actions included an assignment to
reconstitute design basis calculation records and plans to re-design the hazard barrier
dampers.
This finding was determined to be more than minor because it was associated with the
Design Control attribute of the Mitigating Systems cornerstone and adversely affected
the cornerstone objective of ensuring the availability, reliability, and capability of systems
that respond to initiating events to prevent undesirable consequences (i.e., core
damage). The inspectors determined that the finding could be evaluated using the
SDP in accordance with IMC 0609, Significance Determination Process,
Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings,
Table 4a, for the Mitigating Systems cornerstone. Specifically, the inspectors answered
No to all of the Mitigating Systems Cornerstone questions in Table 4a. Based upon
this Phase 1 screening, the inspectors concluded that the finding was of very low safety
significance (Green). This finding had a cross-cutting aspect in the Corrective Action
Program component of the Problem Identification and Resolution cross-cutting area
[P.1(c)] because the licensee failed to thoroughly evaluate the impact on operability of a
non-conforming condition associated with hazard barrier damper closure times.
(Section 1R15)
Cornerstone: Public Radiation Safety
Green. A self-revealed finding of very low safety significance and an associated NCV of
10 CFR 71.5, Transportation of Licensed Material, was identified when licensee
personnel failed to comply with 49 CFR 172.203(c) and shipped packages of radioactive
material with transport manifests that did not document all applicable hazardous
substances. The issue was entered in the licensees CAP as IR 1285148. Immediate
corrective actions included providing a corrected copy of the transport manifest to the
waste processor. Further, the licensee placed locks on the shipping containers to
control items placed in the packages and to ensure that the manifest accurately
represented the hazards contained in the shipping packages.
This finding was determined to be more than minor because it was associated with the
Program and Process attribute of the Public Radiation Safety Cornerstone and adversely
affected the cornerstone objective of ensuring adequate protection of public health and
safety from exposure to radioactive materials released into the public domain as a result
of routine civilian nuclear reactor operation, in that, providing incorrect information, as
part of hazards communications, could impact the actions of response personnel. The
inspectors determined that the finding could be evaluated using the SDP in accordance
with IMC 0609, Significance Determination Process, Appendix D, Public Radiation
                                      2                                    Enclosure
  Safety Significance Determination Process. Using the Public Radiation Safety SDP, the
  inspectors determined: (1) radiation limits were not exceeded; (2) there was no breach
  of a package during transit; (3) this issue did not involve a certificate of compliance;
  (4) this issue was not a low level burial ground nonconformance; and (5) this issue did
  not involve a failure to make notifications or provide emergency information. As a result,
  the finding screened as having very low safety significance (Green). This finding had a
  cross-cutting aspect in the Work Control component of the Human Performance
  cross-cutting area [H.3(b)] since the licensee failed to coordinate work activities by
  incorporating actions to address the impact of the work on different job activities, and the
  need for work groups to maintain interfaces with offsite organizations, and communicate,
  coordinate, and cooperate with each other during activities in which interdepartmental
  coordination was necessary to assure adequate human performance. Specifically, these
  events occurred because the licensee did not control the items placed in the waste
  packages and was not present when the boxes were loaded. (Section 2RS8)
B. Licensee-Identified Violations
  One violation of very low safety significance that was identified by the licensee has been
  reviewed by the inspectors. Corrective actions planned or taken by the licensee have
  been entered into the licensees CAP. This violation and the associated corrective
  action tracking number are listed in Section 4OA7 of this report.
                                          3                                    Enclosure
                                          REPORT DETAILS
Summary of Plant Status
Unit 1 operated at or near full power from the beginning of the inspection period until
November 11, 2011, when power was reduced to 89 percent to perform scheduled turbine
throttle and governor valve testing. The unit was returned to full power the following day and
operated at full power for the remainder of the assessment period.
Unit 2 began the inspection period shut down and in a planned refueling outage. The unit was
restarted and returned to service on October 10, 2011. On November 5, 2011, reactor power
was reduced to 96 percent to perform feedwater heater maintenance. The unit was returned to
full power on November 14, 2011, and operated at full power for the remainder of the inspection
period.
1.      REACTOR SAFETY
        Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity and
        Emergency Preparedness
1R01 Adverse Weather Protection (71111.01)
  .1    Winter Seasonal Readiness Preparations
    a.  Inspection Scope
        The inspectors conducted a review of the licensees preparations for winter conditions to
        verify that the plants design features and implementation of procedures were sufficient
        to protect mitigating systems from the effects of adverse weather. Documentation for
        selected risk-significant systems was reviewed to ensure that these systems would
        remain functional when challenged by inclement weather. During the inspection, the
        inspectors focused on plant specific design features and the licensees procedures used
        to mitigate or respond to adverse weather conditions. Additionally, the inspectors
        reviewed the Updated Final Safety Analysis Report (UFSAR) and performance
        requirements for systems selected for inspection, and verified that operator actions were
        appropriate as specified by plant specific procedures. Cold weather protection, such as
        heat tracing and area heaters, was verified to be in operation where applicable. The
        inspectors also reviewed Corrective Action Program (CAP) items to verify that the
        licensee was identifying adverse weather issues at an appropriate threshold and
        entering them into their CAP in accordance with station corrective action procedures.
        Specific documents reviewed during this inspection are listed in the Attachment. The
        inspectors reviews focused specifically on the following plant systems due to their risk
        significance or susceptibility to cold weather issues:
        *      Station Heating System (SH);
        *      Auxiliary Building Heating, Ventilation, and Air-Conditioning (HVAC) [VA]; and
        *      Refueling Water Storage Tanks (RWSTs).
        This inspection constituted one winter seasonal readiness preparation sample as
        defined in Inspection Procedure (IP) 71111.01-05.
                                                4                                Enclosure
  b. Findings
      No findings were identified.
1R04 Equipment Alignment (71111.04)
.1  Quarterly Partial System Walkdowns
  a. Inspection Scope
      The inspectors performed partial system walkdowns of the following risk-significant
      systems:
      *      Unit 2 Train A Residual Heat Removal System Following Restoration to its
              Standby Line-Up;
      *      Unit 2 Train B Essential Service Water (SX) with the Unit 2 Train A SX
              Out-of-Service (OOS);
      *      Unit 2 Train B Auxiliary Feedwater (AF) with the Unit 2 Train A AF OOS; and
      *      Unit 1 Train A AF with the Unit 1 Train B AF OOS.
      The inspectors selected these systems based on their risk significance relative to the
      Reactor Safety Cornerstones at the time they were inspected. The inspectors attempted
      to identify any discrepancies that could impact the function of the system, and, therefore,
      potentially increase risk. The inspectors reviewed applicable operating procedures,
      system diagrams, UFSAR, Technical Specification (TS) requirements, outstanding work
      orders (WOs), condition reports, and the impact of ongoing work activities on redundant
      trains of equipment in order to identify conditions that could have rendered the systems
      incapable of performing their intended functions. The inspectors also walked down
      accessible portions of the systems to verify system components and support equipment
      were aligned correctly and operable. The inspectors examined the material condition of
      the components and observed operating parameters of equipment to verify that there
      were no obvious deficiencies. The inspectors also verified that the licensee had properly
      identified and resolved equipment alignment problems that could cause initiating events
      or impact the capability of mitigating systems or barriers and entered them into the CAP
      with the appropriate significance characterization. Documents reviewed are listed in the
      Attachment.
      These activities constituted four partial system walkdown samples as defined in
      IP 71111.04-05.
  b. Findings
      No findings were identified.
                                            5                                  Enclosure
1R05 Fire Protection (71111.05)
.1  Routine Resident Inspector Tours (71111.05Q)
  a. Inspection Scope
      The inspectors conducted fire protection walkdowns which were focused on availability,
      accessibility, and the condition of firefighting equipment in the following risk-significant
      plant areas:
      *      Unit 1 426 Turbine Building (Fire Zone 8.5-1);
      *      Unit 1 426 Turbine Building (Fire Zone 8.5-1);
      *      Unit 1 Train B Auxiliary Feedwater Pump Room (Fire Zone 11.4A-1); and
      *      Unit 2 Train B Auxiliary Feedwater Pump Room (Fire Zone 11.4A-2 ).
      The inspectors reviewed areas to assess if the licensee had implemented a fire
      protection program that adequately controlled combustibles and ignition sources within
      the plant, effectively maintained fire detection and suppression capability, maintained
      passive fire protection features in good material condition, and implemented adequate
      compensatory measures for out-of-service, degraded or inoperable fire protection
      equipment, systems, or features in accordance with the licensees fire plan. The
      inspectors selected fire areas based on their overall contribution to internal fire risk as
      documented in the plants Individual Plant Examination of External Events with later
      additional insights, their potential to impact equipment which could initiate or mitigate a
      plant transient, or their impact on the plants ability to respond to a security event. Using
      the documents listed in the Attachment, the inspectors verified that fire hoses and
      extinguishers were in their designated locations and available for immediate use; that
      fire detectors and sprinklers were unobstructed; that transient material loading was
      within the analyzed limits; and fire doors, dampers, and penetration seals appeared to
      be in satisfactory condition. The inspectors also verified that minor issues identified
      during the inspection were entered into the licensees CAP. Documents reviewed are
      listed in the Attachment.
      These activities constituted four quarterly fire protection inspection samples as defined in
      IP 71111.05-05.
  b. Findings
      No findings were identified.
  .2  Annual Fire Protection Drill Observation (71111.05A)
  a. Inspection Scope
      On November 11, 2011, and December 17, 2011, the inspectors observed a fire brigade
      activation Fire Drill in the Unit 1 Auxiliary Boiler Room, 401' Elevation (Fire Zone 8.3-1
      SE). Based on this observation, the inspectors evaluated the readiness of the plant fire
      brigade to fight fires. The inspectors verified that the licensee staff identified
      deficiencies; openly discussed them in a self-critical manner at the drill debrief, and took
      appropriate corrective actions. Specific attributes evaluated were:
                                              6                                  Enclosure
      *      proper wearing of turnout gear and self-contained breathing apparatus;
      *      proper use and layout of fire hoses;
      *      employment of appropriate fire fighting techniques;
      *      sufficient firefighting equipment brought to the scene;
      *      effectiveness of fire brigade leader communications, command, and control;
      *      search for victims and propagation of the fire into other plant areas;
      *      smoke removal operations;
      *      utilization of pre-planned strategies;
      *      adherence to the pre-planned drill scenario; and
      *      drill objectives.
      Documents reviewed are listed in the Attachment to this report.
      These activities constituted one annual fire protection inspection sample as defined in
      IP 71111.05-05.
  b. Findings
      No findings were identified.
1R11 Licensed Operator Requalification Program (71111.11)
.1  Annual Operating Test Results (71111.11B)
  a. Inspection Scope
      The inspectors reviewed the overall pass/fail results of the Annual Operating Test,
      administered by the licensee from October 18, 2011 through December 8, 2011,
      required by 10 CFR 55.59(a). The results were compared to the thresholds established
      in IMC 0609, Appendix I, Licensed Operator Requalification Significance Determination
      Process (SDP)," to assess the overall adequacy of the licensees Licensed Operator
      Requalification Program (LORT) to meet the requirements of 10 CFR 55.59.
      This inspection constitutes one biennial and one annual licensed operator requalification
      inspection sample as defined in IP 71111.11B and IP71111.11A.
  b. Findings
      No findings were identified.
.2  Resident Inspector Quarterly Review (71111.11Q)
  a. Inspection Scope
      On November 16, 2011, the inspectors observed a crew of licensed operators in the
      plants simulator during licensed operator requalification examinations to verify that
      operator performance was adequate, evaluators were identifying and documenting crew
      performance problems and training was being conducted in accordance with licensee
      procedures. The inspectors evaluated the following areas:
                                              7                                  Enclosure
      *      licensed operator performance;
      *      crews clarity and formality of communications;
      *      ability to take timely actions in the conservative direction;
      *      prioritization, interpretation, and verification of annunciator alarms;
      *      correct use and implementation of abnormal and emergency procedures;
      *      control board manipulations;
      *      oversight and direction from supervisors; and
      *      ability to identify and implement appropriate TS actions and emergency plan
              actions and notifications.
      The crews performance in these areas was compared to pre-established operator action
      expectations and successful critical task completion requirements. Documents reviewed
      are listed in the Attachment.
      In addition, the inspectors observed licensed operator performance in the actual plant
      and the main control room during this calendar quarter.
      This inspection constituted one quarterly licensed operator requalification program
      sample as defined in IP 71111.11.
  b. Findings
      No findings were identified.
1R12 Maintenance Effectiveness (71111.12)
.1  Routine Quarterly Evaluations (71111.12Q)
  a. Inspection Scope
      The inspectors evaluated degraded performance issues involving the following
      risk-significant systems:
      *      Unit 1 Rod Drive Motor Generator (MG) Set High Vibrations; and
      *      High Energy Line Break (HELB) Dampers.
      The inspectors reviewed events including those in which ineffective equipment
      maintenance had resulted in valid or invalid automatic actuations of engineered
      safeguards systems and independently verified the licensee's actions to address
      system performance or condition problems in terms of the following:
      *      implementing appropriate work practices;
      *      identifying and addressing common cause failures;
      *      scoping of systems in accordance with 10 CFR 50.65(b) of the Maintenance Rule;
      *      characterizing system reliability issues for performance;
      *      charging unavailability for performance;
      *      trending key parameters for condition monitoring;
      *      ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and
      *      verifying appropriate performance criteria for structures, systems, and
              components (SSCs)/functions classified as (a)(2) or appropriate and adequate
              goals and corrective actions for systems classified as (a)(1).
                                                8                                  Enclosure
      The inspectors assessed performance issues with respect to the reliability, availability,
      and condition monitoring of the system. In addition, the inspectors verified maintenance
      effectiveness issues were entered into the CAP with the appropriate significance
      characterization. Documents reviewed are listed in the Attachment.
      This inspection constituted two quarterly maintenance effectiveness sample as defined
      in IP 71111.12-05.
  b. Findings
      No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)
.1  Maintenance Risk Assessments and Emergent Work Control
  a. Inspection Scope
      The inspectors reviewed the licensee's evaluation and management of plant risk for the
      maintenance and emergent work activities affecting risk-significant and safety-related
      equipment listed below to verify that the appropriate risk assessments were performed
      prior to removing equipment for work:
      *        Shutdown Safety Associated with Cavity Drain;
      *        Unit Common B Fire Pump OOS With SX as its Backup While One Train of SX
              was OOS;
      *        Review of Planned Risk Significant Activities During Elevated Winds and Low
              River Level; and
      *        Unit 2 Train B Auxiliary Feedwater Pump OOS.
      These activities were selected based on their potential risk significance relative to the
      Reactor Safety Cornerstones. As applicable for each activity, the inspectors verified that
      risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate
      and complete. When emergent work was performed, the inspectors verified that the
      plant risk was promptly reassessed and managed. The inspectors reviewed the scope
      of maintenance work, discussed the results of the assessment with the licensee's
      probabilistic risk analyst or shift technical advisor, and verified plant conditions were
      consistent with the risk assessment. The inspectors also reviewed TS requirements and
      walked down portions of redundant safety systems, when applicable, to verify risk
      analysis assumptions were valid and applicable requirements were met.
      These maintenance risk assessments and emergent work control activities constituted
      four samples as defined in IP 71111.13-05.
  b. Findings
      No findings were identified.
                                              9                                  Enclosure
1R15 Operability Evaluations (71111.15)
.1    Operability Evaluations
  a.  Inspection Scope
        The inspectors reviewed the following issues:
        *      Unit 1 Embedment Plate 1SI06025V Due to Questions Regarding Supporting
              Analysis/Calculations;
        *      Unit 1 Seismic Support 1FW01147X Due to Questions Regarding Impact to HELB
              Analysis;
        *      Unit 1 and Unit 2 Train B AF Pumps Due to Questions Regarding Multiple Starts;
        *      Unit 1 Leading Edge Flow Monitor Due to Identified Anomaly in Trended Data;
        *      Unit 1 and Unit 2 Train B AF Pumps Due to Potential Pipe Voids in Cross-Tie
              Piping; and
        *      Unit 1 Engineered Safety Features Switchgear Rooms Division 11 and 12 Due to
              Questions Regarding 1VX20Y and 1VX17Y Fire Damper S Hooks Preventing
              Closure of Dampers
        The inspectors selected these potential operability issues based on the risk significance
        of the associated components and systems. The inspectors evaluated the technical
        adequacy of the evaluations to ensure that TS operability was properly justified and the
        subject component or system remained available such that no unrecognized increase in
        risk occurred. The inspectors compared the operability and design criteria in the
        appropriate sections of the TS and UFSAR to the licensees evaluations to determine
        whether the components or systems were operable. Where compensatory measures
        were required to maintain operability, the inspectors determined whether the measures
        in place would function as intended and were properly controlled. The inspectors
        determined, where appropriate, compliance with bounding limitations associated with the
        evaluations. Additionally, the inspectors reviewed a sample of corrective action
        documents to verify that the licensee was identifying and correcting any deficiencies
        associated with operability evaluations. Documents reviewed are listed in the
        Attachment.
        This operability inspection constituted six samples as defined in IP 71111.15-05.
  b.  Findings
    .1) Failure to Identify Auxiliary Feedwater Pump Suction Voids
        Introduction: The inspectors identified a finding of very low safety significance (Green)
        and an associated NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective
        Action, when licensee personnel failed to identify voided piping between Unit 1 valves
        1AF006B and 1AF017B and Unit 2 valves 2AF006B and 2AF017B of the auxiliary
        feedwater system. The piping between these valves had been historically voided until
        they were recently re-designed to be filled and maintained filled with water to address an
        NRC-identified Green finding and an associated NCV of 10 CFR Part 50, Appendix B,
        Criterion III, Design Control (NCV 05000454/2011004-04; 05000455/-2011004-04,
        Design of Auxiliary Feedwater System Included Voids in Safety-Related Alternate
        Suction Flow Paths).
                                              10                                  Enclosure
Description: On November 16, 2011, the inspectors notified licensee staff that there
appeared to be no visible water in tygon tubing attached to vent valves between Unit 1
valves 1AF006B and 1AF017B and Unit 2 valves 2AF006B and 2AF017B. Visible water
in tygon tubing attached to these vent valves was being used as an indication that the
piping between these valves was filled with water. The inspectors could not determine
whether there was water within the tygon tubing because the inside of the tubing was
coated with a brown and black substance suspected to be mold. The inspectors
concluded that without visible water in the tygon tubing, the space between these valves
could be voided, contrary to plant design requirements. The piping between Unit 1
valves 1AF006B and 1AF017B and Unit 2 valves 2AF006B and 2AF017B had been
historically voided, but were recently re-designed and filled with water to address an
NRC-identified Green finding and associated NCV of 10 CFR Part 50, Appendix B,
Criterion III, Design Control (NCV 05000454/2011004-04; 05000455/-2011004-04,
Design of Auxiliary Feedwater System Included Voids in Safety-Related Alternate
Suction Flow Paths). The basis for this Green finding and associated NCV was that the
licensee had not performed design reviews, calculations, or suitable tests that
demonstrated the voided piping between Unit 1 valves 1AF006B and 1AF017B and
Unit 2 valves 2AF006B and 2AF017B would not adversely impact the ability of the AF
system to perform its design function. This piping was downstream of the safety-related
essential service water (SX) supply for the diesel-driven AF pumps. The inspectors did
observe standing water in the tygon tubing between Unit 1 valves 1AF006A and
1AF017A and Unit 2 valves 2AF006A and 2AF017A associated with the Unit 1 and
Unit 2 motor-driven AF pumps.
On November 17, 2011, the inspectors reviewed the Inspection Reports (IRs) generated
the previous day and did not identify any that documented the issue discussed above.
The inspectors re-inspected the tygon tubing between Unit 1 valves 1AF006B and
1AF017B and Unit 2 valves 2AF006B and 2AF017B and could not determine whether
there was water in the tygon tubing. Licensee management was subsequently notified of
the inspectors observations. The licensee performed a system walkdown and
confirmed that there was no visible water level in the tygon tubing between Unit 1 valves
1AF006B and 1AF017B. The section of piping between the valves was subsequently
filled with water and verified full through ultrasonic testing.
On November 18, 2011, the inspectors re-inspected the tygon tubing between Unit 1
valves 1AF006B and 1AF017B and Unit 2 valves 2AF006B and 2AF017B and could not
determine whether there was water in the tygon tubing. The inspectors notified licensee
management and questioned the licensees actions to address the inspectors previous
questions and concerns. The licensee performed a walkdown of the system and
confirmed the inspectors concern that the tygon tube was again empty, which indicated
that the section of piping between Unit 1 valves AF006B and AF017B was likely voided.
The licensee entered this issue into their CAP. The section of piping between the valves
was again re-filled and verified full.
On November 29, 2011, the inspectors performed field walkdowns and identified, again,
that the tygon tubing attached to the vent line between Unit 2 valves 2AF006B and
2AF017B did not have a visible water level. The inspectors notified licensee
management and concluded that the licensee did not have adequate measures in place
to monitor or ensure the sections of piping between Unit 1 valves 1AF006B and
1AF017B and Unit 2 valves 2AF006B and 2AF017B were maintained full of water. The
licensee performed a walkdown of the system, confirmed the inspectors concerns, and
                                        11                                Enclosure
filled the voided sections of piping as before. In addition, the Operations department
instituted an Operations Standing Order that required a verification that the tygon tubing
was filled with water multiple times a shift. The licensee entered this issue into their
CAP as IR 1296819, IR 1292337, and IR 1295760. Corrective actions included
instituting the Operations Standing Order, replacing the Unit 1 AF drain valve, and
isolating the Unit 2 AF drain valve.
Analysis: The inspectors determined that the failure to identify voided sections of AF
piping prior to and following the inspectors observations and interactions with licensee
management was a performance deficiency.
This finding was determined to be more than minor because it was associated with the
Design Control attribute of the Mitigating Systems Cornerstone and adversely affected
the cornerstone objective of ensuring the availability, reliability and capability of systems
that respond to initiating events to prevent undesirable consequences (i.e., core
damage). Specifically, the unverified configuration might have rendered the Unit 1 and
Unit 2 diesel-driven AF pumps inoperable.
The inspectors determined that the finding could be evaluated using the SDP in
accordance with IMC 0609, Significance Determination Process, Attachment 0609.04,
Phase 1 - Initial Screening and Characterization of Findings, Table 4a for the Mitigating
Systems Cornerstone. Specifically, the inspectors answered Yes to Question 1 - Is
the finding a design or qualification deficiency confirmed not to result in a loss of
operability or functionality? This conclusion was reached after conservatively assuming
that both sections of piping for Unit 1 and Unit 2 were completely voided and after
reviewing tests performed by the licensee in response to the previously documented
design control Green finding and associated NCV. These tests demonstrated that under
the existing plant conditions, and even if the piping between Unit 1 valves 1AF006B and
1AF017B and Unit 2 valves 2AF006B and 2AF017B was completely voided, that the
diesel-driven AF pumps were not inoperable. However, these tests were not of sufficient
scope to demonstrate that under all possible plant conditions that the diesel-driven AF
pumps would have remained operable. Therefore, although the existing void did not
render the diesel-driven AF pumps inoperable, there remained the possibility that under
some conditions the unverified configuration discussed above could have rendered the
diesel-driven AF pumps inoperable. Based upon this Phase 1 screening, the inspectors
concluded that the finding was of very low safety significance (Green).
This finding had a cross-cutting aspect in the Resources component of the Human
Performance cross-cutting area [H.2(c)] because the licensee did not ensure that
procedures were adequate to ensure nuclear safety. In particular, licensee procedures
did not ensure that the sections of piping between Unit 1 valves 1AF006B and 1AF017B
and Unit 2 valves 2AF006B and 2AF017B were maintained filled with water as required
to support nuclear safety.
Enforcement: 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires,
in part, that measures shall be established to assure that conditions adverse to quality,
such as failures, malfunctions, deficiencies, deviations, defective material and
equipment, and non-conformances are promptly identified and corrected.
Contrary to the above, licensee personnel failed to identify non-conforming conditions
associated with the stations safety-related diesel-driven AF systems. Specifically, the
                                      12                                  Enclosure
    space between Unit 1 valves 1AF006B and 1AF017B and Unit 2 valves 2AF006B and
    2AF017B had been re-designed to be full of water and was identified by the inspectors
    prior to November 16, 2011; November 17, 2011; November 18, 2011; and
    November 29, 2011 to be voided.
    Corrective actions included filling the voided piping sections, replacing the Unit 1 drain
    valve, isolating the Unit 2 drain valve, and monitoring tygon tubing water level on a more
    frequent basis. Because this violation was of very low safety significance and was
    entered into the licensees CAP as IR 1296819, IR 1292337, and IR 1295760, this
    violation is being treated as a NCV consistent with Section 2.3.2 of the NRC
    Enforcement Policy. (NCV 05000454/2011005-01; 05000455/2011005-01, Failure to
    Identify Voided Sections of AF Piping)
.2) Operability Evaluation Not Performed in Accordance with Station Standards
    Introduction: The inspectors identified a finding of very low safety significance (Green)
    and an associated NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions,
    Procedures, and Drawings, when licensee personnel failed to adhere to numerous
    Operability Determination Process standards after identifying a non-conservative
    assumption related to closure times for hazard barrier dampers separating the Turbine
    Building from various safety-related rooms within the Auxiliary Building.
    Description: On July 6, 2011, the licensee identified non-conservative assumptions in
    the actuation time for fusible links used in hazard barrier dampers for the Engineered
    Safety Feature (ESF) Rooms, Non-ESF Switchgear Rooms, Miscellaneous Electrical
    Equipment Rooms (MEERs) and Emergency Diesel Generator (DG) Rooms. These
    dampers protected these rooms from the effects of a Turbine Building fire or HELB
    event. The applicable calculations of record assumed that these dampers shut within
    about 5 seconds of reaching a temperature of 165 degrees fahrenheit (°F). These
    dampers utilized a fusible link which was required to meet Underwriters Laboratories
    (UL) specifications (Heat Responsive Links for Fire Protection Service: UL 33). This
    specification provided a formula for calculating an acceptable fusible link response time
    as a function of temperature. Using the UL formula, licensee personnel calculated that
    the expected thermal link response times were up to 100 seconds for the ESF
    Switchgear Room dampers and 200 seconds for the MEER and Non-ESF Switchgear
    dampers based on projected HELB temperatures outside of these rooms. Therefore, the
    station calculations of record assumed that these dampers would isolate the affected
    rooms from a Turbine Building HELB much sooner than UL specifications. The licensee
    evaluated this non-conservative condition in Operability Evaluation 11-006, Revision 1,
    concluded that there was reasonable assurance that the equipment affected in the
    identified rooms would remain operable during a licensing basis HELB event. This
    conclusion was reached after the licensee had completed and approved Operability
    Evaluation 11-006 in accordance with OP-AA-108-115, Operability Evaluation
    Standard, Revision 9.
    The inspectors reviewed Operability Evaluation 11-006, Revision 1, and identified a
    number of examples in which the evaluation did not meet the standards in OP-AA-108-
    115. Specifically, OP-AA-108-115, Operability Evaluation Standard, Revision 9
    included the following requirements:
                                            13                                Enclosure
OP-AA-108-115, Operability Evaluation Standard, Revision 9
Section 4.4.2
The OpEval [Operability Evaluation] should contain sufficient detail for a knowledgeable
individual to independently reach the same conclusions as the Preparer (i.e., the OpEval
must be able to stand alone).
1.      The Preparer should examine the CLB [Current Licensing Basis] requirements or
        commitments, including the TSs and UFSAR, to establish the conditions and
        performance requirements to be met for determining operability, as necessary.
        The scope of an OpEval needs to be sufficient to address the capability of the
        SSC to perform its specified safety functions.
        The OpEval should address the following, as applicable . . . Determine the extent
        of condition for all similarly affected SSCs.
The inspectors identified the following examples that did not meet this standard:
*      Operability Evaluation 11-006, Revision 1, did not evaluate the non-conforming
        condition against the CLB single failure criterion. This single failure criterion was
        discussed in NRC Standard Review Plan (SRP) Section 3.6.1, Branch Technical
        Position (BTP) ASB 3-1, Section B.3.b(2). Branch Technical Position ASB 3-1,
        Section B.3.b(2) discussed how a single active component failure should be
        assumed in systems used to mitigate the consequences of a postulated piping
        failure to shut down the reactor. After the inspectors discussed this requirement
        with the licensee, licensee personnel determined that the dampers needed to be
        considered for single failure during a HELB event. This CLB single failure
        criterion was readily available when the licensee examined the CLB requirements
        for this issue during the development of Operability Evaluation 11-006. The
        licensee entered this issue into their CAP as IR 1244251.
*      Operability Evaluation 11-006, Revision 1, did not adequately consider a pipe
        crack in accordance with the CLB. The CLB requirements for a pipe crack
        included an assumed lower allowable stress threshold than for a broken or
        severed pipe. Specifically, Operability Evaluation 11-006, Revision 1, did not
        address leakage cracks in accordance with Section III of the American Society of
        Mechanical Engineers (ASME) Code for Class 2 and Class 3 piping as
        referenced in Section 3.6.2.1.2.1.1, "Fluid System Piping Not in the Containment
        Penetration Area," of the UFSAR. In particular, Section d of Section 3.6.2.1.2.1.1
        stated, in part, "[L]eakage cracks in high energy ASME Section III Class 2 and 3
        piping and seismically analyzed and supported ANSI [American Nuclear
        Standards Institute] B31.1 piping are postulated at locations where the stresses
        under the loadings resulting from normal and upset plant conditions and an OBE
        [Operating Basis Earthquake] event as calculated by equations (9) and (10) in
        Paragraph NC-3652 of ASME Section III exceed 0.4 (1.2 multiplied times Sh +
        Sa). The licensee entered this issue into their CAP as IR 1240295.
*      Operability Evaluation 11-006, Revision 1, did not address the extent of condition
        review for all similarly affected SSCs. The inspectors identified a number of
        safety-related rooms that utilized the same (or similar) style dampers in which the
                                          14                                Enclosure
        non-conforming condition applied that were not evaluated. Those rooms
        included the Unit 1 and Unit 2 Lower Cable Spreading Room Non-Segregated
        Bus Duct areas; an electrical cable chase located above the B Emergency
        Diesel Generator; the station Emergency Diesel Generator Diesel Oil Storage
        Tank Rooms; and the Control Room Ventilation Makeup System, which could be
        aligned to take makeup air from the Turbine Building. The licensee entered this
        issue into their CAP as IR 1279759 and IR 12776277.
*      Operability Evaluation 11-006, Revision 1, as associated with MEER 12 and
        MEER 22, did not identify a potential common mode failure after the inspectors
        determined that the licensee had not adequately considered single failure.
        These rooms contained both trains of Unit 1 and Unit 2 reactor trip and reactor
        trip bypass breakers, respectively. The event of concern was a Turbine Building
        HELB combined with the failure of either the MEER 12 or MEER 22 hazard
        barrier dampers to shut, which would expose both trains of reactor trip breakers
        to a harsh steam environment. This equipment was not environmentally qualified
        in accordance with 10 CFR 50.49. The licensee entered this issue into their CAP
        as IR 1276895.
*      The inspectors were not able to reach the same conclusions as the
        Preparer when reviewing Operability Evaluation 11-006, Revision 1, since
        Operability Evaluation 11-006, Revision 1, lacked the necessary detail regarding
        assumptions and limitations for the inspectors to determine if the evaluation was
        consistent with station design. The inspectors concluded that Operability
        Evaluation 11-006, Revision 1, did not meet the licensees stand alone
        requirement in OP-AA-108-115.
On November 17, 2011, the licensee completed a substantial revision to Operability
Evaluation 11-006, Revision 1, that addressed the issues previously identified by the
inspectors.
In addition to the issues described above, the inspectors identified that the stations
applicable HELB calculations of records had not considered the licensing basis single
failure. The inspectors determined that this historic issue contributed to the licensees
misunderstanding of their CLB.
The licensee entered these issues into the their CAP as IR 1184258, IR 1237133,
IR 1238611, IR 1240295, IR 1244251, and IR 1276895. Corrective actions include two
revisions of Operability Evaluation 11-006, an assignment to reconstitute the applicable
design basis calculation records, and plans to re-design the hazard barrier dampers to
provide additional margin.
Analysis: The inspectors determined that the failure to meet the station Operability
Determination process standards outlined in OP-AA-108-115, Operability Evaluation
Standard, Revision 9, during the evaluation of a non-conforming condition was a
performance deficiency.
This performance deficiency was determined to be more than minor because it was
similar to the not minor if aspect of Example 3j in IMC 0612, Appendix E, Example of
Minor Issues, since the errors in Operability Evaluation 11-006, Revision 1, resulted in a
condition in which there was a reasonable doubt on the operability of the systems and
                                        15                                Enclosure
components that were the subject of the evaluation and dissimilar from the minor
because aspect of this example since the impact of the errors on Operability
Determination 11-006, Revision 1, was not minimal. In addition, the performance
deficiency was determined to be more than minor because it was associated with the
Design Control attribute of the Mitigating Systems Cornerstone and adversely affected
the cornerstone objective of ensuring the availability, reliability, and capability of systems
that respond to initiating events to prevent undesirable consequences (i.e., core
damage).
The inspectors determined that the finding could be evaluated using the SDP in
accordance with IMC 0609, Significance Determination Process, Attachment 0609.04,
Phase 1 - Initial Screening and Characterization of Findings, Table 4a, for the
Mitigating Systems Cornerstone. Specifically, the inspectors answered No to all of the
Mitigating Systems Cornerstone questions in Table 4a. As a result, the finding screened
as having very low safety significance (Green).
This finding has a cross-cutting aspect in the CAP component of the Problem
Identification and Resolution cross-cutting area [P.1(c)] since the licensee failed to
thoroughly evaluate the impact on operability of a non-conforming condition associated
with hazard barrier closure times.
Enforcement: 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures,
and Drawings, requires, in part, that activities affecting quality shall be prescribed
by documented instructions, procedures, or drawings, of a type appropriate to the
circumstance and shall be accomplished in accordance with these instructions,
procedures of drawings.
Contrary to the above, the inspectors identified examples during the development of
Operability Evaluation 11-006, Revision 1, in which licensee personnel failed to adhere
to quality procedure OP-AA-108-115, Operability Determinations (CM-1), Revision 9.
In particular, OP-AA-108-115, Revision 9, stated in part:
The OpEval should contain sufficient detail for a knowledgeable individual to
independently reach the same conclusions as the Preparer (i.e., the OpEval must
be able to stand alone).
The Preparer should examine the CLB [Current Licensing Basis] requirements or
commitments, including the TSs and UFSAR, to establish the conditions and
performance requirements to be met for determining operability, as necessary.
The scope of an OpEval needs to be sufficient to address the capability of the SSC
to perform its specified safety functions.
The OpEval should address the following, as applicable . . . Determine the extent of
condition for all similarly affected SSCs.
Contrary to this requirement:
*    On July 15, 2011, the licensee did not adequately examine the applicable CLB
    requirements or commitments to establish the performance requirements to be met
                                      16                                    Enclosure
            for determining operability in the case of single failure, common mode, and leakage
            crack assumptions.
      *    On July 15, 2011, the licensees OpEval did not adequately address the extent of
            condition for all similarly affected SSCs.
      *    On July 15, 2011, the OpEval did not contain sufficient detail for a knowledgeable
            individual to independently reach the same conclusions as the Preparer.
      Because this violation was of very low safety significance and it was entered into the
      licensees corrective actions program, this violation is being treated as a NCV, consistent
      with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000454/2011005-02;
      05000455/2011005-02, Operability Evaluation Not Performed in Accordance with
      Station Standards)
1R19 Post-Maintenance Testing (71111.19)
.1  Post-Maintenance Testing
  a. Inspection Scope
      The inspectors reviewed the following post maintenance testing activities to verify that
      procedures and test activities were adequate to ensure system operability and functional
      capability:
      *        Unit 2 AF Check Valves 2AF014E, 2AF014G, and 2AF014H Following
              Disassembly and Inspection;
      *        Unit 2 Reactor Coolant Pump Motor - 2D Following Refuel Maintenance and
              Inspection;
      *        Unit 2 Charging Valve Stroke Time and Position Indication Test 2CV8804A
              Following Circuit Modification;
      *        Unit 2 Solid State Protection System Following Unit 2 Refueling Outage
              Preventive Maintenance;
      *        Unit 2 Train B Containment Spray Following Replacement of Timer Relay;
      *        Unit 1 Train A Rod Drive Motor-Generator Following Bearing Replacement; and
      *        Surveillance 2BOSR 0.5-2.RH.4-1 Following Maintenance on Valve 2RH610
      These activities were selected based upon the structure, system, or component's ability
      to impact risk. The inspectors evaluated these activities for the following (as applicable):
      the effect of testing on the plant had been adequately addressed; testing was adequate
      for the maintenance performed; acceptance criteria were clear and demonstrated
      operational readiness; test instrumentation was appropriate; tests were performed as
      written in accordance with properly reviewed and approved procedures; equipment was
      returned to its operational status following testing (temporary modifications or jumpers
      required for test performance were properly removed after test completion); and test
      documentation was properly evaluated. The inspectors evaluated the activities against
      TSs, the UFSAR, 10 CFR Part 50 requirements, licensee procedures, and various
      NRC generic communications to ensure that the test results adequately ensured that the
      equipment met the licensing basis and design requirements. In addition, the inspectors
      reviewed corrective action documents associated with post maintenance tests to
      determine whether the licensee was identifying problems and entering them in the CAP
                                                17                                Enclosure
    and that the problems were being corrected commensurate with their importance to
    safety. Documents reviewed are listed in the Attachment.
    This inspection constituted seven post maintenance testing samples as defined in
    IP 71111.19-05.
  a. Findings
    No findings were identified.
1R20 Outage Activities (71111.20)
.1  Refueling Outage Activities
  a. Inspection Scope
    The inspectors reviewed the Outage Safety Plan (OSP) and contingency plans for the
    Unit 2 refueling outage (RFO) B2R16, conducted September 18 through October 10,
    2011, to confirm that the licensee had appropriately considered risk, industry experience,
    and previous site-specific problems in developing and implementing a plan that assured
    maintenance of defense-in-depth. During the RFO, the inspectors observed portions of
    the shutdown and cooldown processes and monitored licensee controls over the outage
    activities listed below. Documents reviewed during the inspection are listed in the
    Attachment to this report.
    *        Licensee configuration management, including maintenance of defense-in-depth
              commensurate with the OSP for key safety functions and compliance with the
              applicable TS when taking equipment out of service.
    *        Implementation of clearance activities and confirmation that tags were properly
              hung and equipment appropriately configured to safely support the work or
              testing.
    *        Installation and configuration of reactor coolant pressure, level, and temperature
              instruments to provide accurate indication, accounting for instrument error.
    *        Controls over the status and configuration of electrical systems to ensure that
              TS and OSP requirements were met, and controls over switchyard activities.
    *        Monitoring of decay heat removal processes, systems, and components.
    *        Controls to ensure that outage work was not impacting the ability of the operators
              to operate the spent fuel pool cooling system.
    *        Reactor water inventory controls including flow paths, configurations, and
              alternative means for inventory addition, and controls to prevent inventory loss.
    *        Controls over activities that could affect reactivity.
    *        Maintenance of secondary containment as required by TS.
    *        Licensee fatigue management, as required by 10 CFR 26, Subpart I.
    *        Refueling activities, including fuel handling and sipping to detect fuel assembly
              leakage.
    *        Startup and ascension to full power operation, tracking of startup prerequisites,
              walkdown of the drywell (primary containment) to verify that debris had not been
              left which could block emergency core cooling system suction strainers, and
              reactor physics testing.
    *        Licensee identification and resolution of problems related to RFO activities.
                                              18                                Enclosure
      This inspection constituted one RFO sample as defined in IP 71111.20-05.
  b. Findings
      No findings were identified.
1R22 Surveillance Testing (71111.22)
.1  Surveillance Testing
  a. Inspection Scope
      The inspectors reviewed the test results for the following activities to determine whether
      risk significant systems and equipment were capable of performing their intended safety
      function and to verify testing was conducted in accordance with applicable procedural
      and TS requirements:
      *      Unit 2 Train B Diesel Generator Sequence Test;
      *      Unit 1 Train B AF Pump ASME Surveillance;
      *      Unit 1 Train B AF Valve Strokes for 1AF013E-H;
      *      Unit 1 Train B Residual Heat Removal (RHR) Check Valve 1SI8958B;
      *      Unit 2 Reactor Coolant System (RCS) Water Inventory Balance Surveillance
              (Leak Detection); and
      *      0BMSR FP-5, Fire Hydrant Yard Loop Annual Flush
      The inspectors observed in-plant activities and reviewed procedures and associated
      records to determine the following:
      *      did preconditioning occur;
      *      were the effects of the testing adequately addressed by control room personnel or
              engineers prior to the commencement of the testing;
      *      were acceptance criteria clearly stated, demonstrated operational readiness, and
              consistent with the system design basis;
      *      plant equipment calibration was correct, accurate, and properly documented;
      *      as left setpoints were within required ranges; and the calibration frequency were
              in accordance with TSs, the USAR, procedures, and applicable commitments;
      *      measuring and test equipment calibration was current;
      *      test equipment was used within the required range and accuracy; applicable
              prerequisites described in the test procedures were satisfied;
      *      test frequencies met TS requirements to demonstrate operability and reliability;
              tests were performed in accordance with the test procedures and other applicable
              procedures; jumpers and lifted leads were controlled and restored where used;
      *      test data and results were accurate, complete, within limits, and valid;
      *      test equipment was removed after testing;
      *      where applicable for inservice testing (IST) activities, testing was performed in
              accordance with the applicable version of Section XI of the ASME code, and
              reference values were consistent with the system design basis;
      *      where applicable, test results not meeting acceptance criteria were addressed
              with an adequate operability evaluation or the system or component was declared
              inoperable;
                                              19                                  Enclosure
      *      where applicable for safety-related instrument control surveillance tests, reference
            setting data were accurately incorporated in the test procedure;
      *      where applicable, actual conditions encountering high resistance electrical
            contacts were such that the intended safety function could still be accomplished;
      *      prior procedure changes had not provided an opportunity to identify problems
            encountered during the performance of the surveillance or calibration test;
      *      equipment was returned to a position or status required to support the
            performance of its safety functions; and
      *      all problems identified during the testing were appropriately documented and
            dispositioned in the CAP.
      Documents reviewed are listed in the Attachment.
      This inspection constituted four routine surveillance testing samples, one IST sample,
      and one RCS Leak Detection sample, as defined in IP 71111.22, Sections -02 and -05.
  b. Findings
      No findings were identified.
2.    REACTOR SAFETY
      Cornerstone: Emergency Preparedness
1EP4 Emergency Action Level and Emergency Plan Changes (71114.04)
  .1  Emergency Action Level and Emergency Plan Changes
  a. Inspection Scope
      Since the last NRC inspection of this program area, Emergency Action Levels (EALs)
      and Emergency Plan Revisions 27 and 28 were implemented based on the licensees
      determination, in accordance with 10 CFR 50.54(q), that the changes resulted in no
      decrease in effectiveness of the Plan, and that the revised Plan as changed continued to
      meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. The
      inspectors conducted a sampling review of the Emergency Plan changes and a review of
      the EAL changes to evaluate for potential decreases in effectiveness of the Plan.
      However, these reviews do not constitute formal NRC approval of the changes.
      Therefore, these changes remain subject to future NRC inspection in their entirety.
      This EAL and Emergency Plan changes inspection constituted one sample as defined in
      IP 71114.04-05.
  b. Findings
      No findings were identified.
                                            20                                Enclosure
1EP6 Drill Evaluation (71114.06)
  .1  Emergency Preparedness Drill Observation
  a. Inspection Scope
      The inspectors evaluated the conduct of a routine licensee emergency drill on
      November 15, 2011, to identify any weaknesses and deficiencies in classification,
      notification, and protective action recommendation development activities. The
      inspectors observed emergency response operations in the Simulator Control Room
      and Technical Support Center to determine whether the event classification,
      notifications, and protective action recommendations were performed in accordance
      with procedures. The inspectors also attended the licensee drill critique to compare
      any inspector-observed weakness with those identified by the licensee staff in order to
      evaluate the critique and to verify whether the licensee staff was properly identifying
      weaknesses and entering them into the CAP. As part of the inspection, the inspectors
      reviewed the drill package and other documents listed in the Attachment.
      This emergency preparedness drill inspection constituted one sample as defined in
      IP 71114.06-05.
  b. Findings
      No findings were identified.
3.    RADIATION SAFETY
2RS1 Radiological Hazard Assessment and Exposure Controls (71124.01)
      The inspection activities supplement those documented in Inspection
      Report 05000454/2011002; 05000455/2011002 and constitute one
      complete sample as defined in IP 71124.01-05.
  .1  Inspection Planning (02.01)
  a. Inspection Scope
      The inspectors reviewed licensee performance indicators for the occupational exposure
      cornerstone for follow-up. The inspectors reviewed the results of radiation protection
      program audits (e.g., licensee quality assurance audits or other independent audits).
      The inspectors reviewed reports of operational occurrences related to occupational
      radiation safety since the last inspection. The inspectors reviewed the results of the
      audit and operational report reviews to gain insights into overall licensee performance.
  b. Findings
      No findings were identified.
                                            21                                Enclosure
.2  Instructions to Workers (02.03)
a. Inspection Scope
    The inspectors reviewed selected occurrences where a workers electronic personal
    dosimeter noticeably malfunctioned or alarmed. The inspectors evaluated whether
    workers responded appropriately to the off-normal condition. The inspectors assessed
    whether the issue was included in the CAP and dose evaluations were conducted as
    appropriate.
b. Findings
    No findings were identified.
.3  Radiological Hazards Control and Work Coverage (02.05)
a. Inspection Scope
    The inspectors examined the licensees physical and programmatic controls for highly
    activated or contaminated materials (nonfuel) stored within spent fuel and other storage
    pools. The inspectors assessed whether appropriate controls (i.e., administrative and
    physical controls) were in place to preclude inadvertent removal of these materials from
    the pool.
    The inspectors examined the posting and physical controls for selected high radiation
    areas and very high radiation areas to verify conformance with the occupational radiation
    performance indicator.
b. Findings
    No findings were identified.
.4  Risk-Significant High Radiation Area and Very High Radiation Area Controls (02.06)
a. Inspection Scope
    The inspectors discussed with the radiation protection manager the controls and
    procedures for high-risk high radiation areas and very high radiation areas. The
    inspectors discussed methods employed by the licensee to provide stricter control of
    very high radiation area access as specified in 10 CFR 20.1602, Control of Access to
    Very High Radiation Areas, and Regulatory Guide 8.38, Control of Access to High and
    Very High Radiation Areas of Nuclear Plants. The inspectors assessed whether any
    changes to licensee procedures substantially reduced the effectiveness and level of
    worker protection.
    The inspectors discussed the controls in place for special areas that have the potential
    to become very high radiation areas during certain plant operations with health physics
    supervisors (or equivalent positions having backshift health physics oversight authority).
    The inspectors assessed whether these plant operations required communication
    beforehand with the health physics group, so as to allow corresponding timely actions to
                                          22                                Enclosure
    properly post, control, and monitor the radiation hazards including re-access
    authorization.
    The inspectors evaluated licensee controls for very high radiation areas and areas with
    the potential to become very high radiation areas to ensure that an individual was not
    able to gain unauthorized access to the very high radiation area.
b. Findings
    No findings were identified.
.5  Radiation Worker Performance (02.07)
a. Inspection Scope
    The inspectors reviewed radiological problem reports since the last inspection that found
    the cause of the event to be human performance errors. The inspectors evaluated
    whether there was an observable pattern traceable to a similar cause. The inspectors
    assessed whether this perspective matched the corrective action approach taken by the
    licensee to resolve the reported problems. The inspectors discussed with the radiation
    protection manager any problems with the corrective actions planned or taken.
b. Findings
    No findings were identified.
.6  Radiation Protection Technician Proficiency (02.08)
a. Inspection Scope
    The inspectors reviewed radiological problem reports since the last inspection that found
    the cause of the event to be radiation protection technician error. The inspectors
    evaluated whether there was an observable pattern traceable to a similar cause. The
    inspectors assessed whether this perspective matched the corrective action approach
    taken by the licensee to resolve the reported problems.
b. Findings
    No findings were identified.
.7  Problem Identification and Resolution (02.09)
a. Inspection Scope
    The inspectors evaluated whether problems associated with radiation monitoring and
    exposure control were being identified by the licensee at an appropriate threshold and
    were properly addressed for resolution in the licensees CAP. The inspectors assessed
    the appropriateness of the corrective actions for a selected sample of problems
    documented by the licensee that involved radiation monitoring and exposure controls.
    The inspectors assessed the licensees process for applying operating experience to
    their plant.
                                          23                                Enclosure
  b. Findings
    No findings were identified.
2RS3 In-Plant Airborne Radioactivity Control and Mitigation (71124.03)
    The inspection activities supplement those documented in Inspection
    Report 05000454/2011002; 05000455/2011002 and constitute one
    complete sample as defined in IP 71124.03-05.
.1  Engineering Controls (02.02)
  a. Inspection Scope
    The inspectors reviewed the licensees use of permanent and temporary ventilation to
    determine whether the licensee used ventilation systems as part of its engineering
    controls (in-lieu of respiratory protection devices) to control airborne radioactivity. The
    inspectors reviewed procedural guidance for use of installed plant systems, such as
    containment purge, spent fuel pool ventilation, and auxiliary building ventilation, and
    assessed whether the systems were used, to the extent practicable, during high-risk
    activities (e.g., using containment purge during cavity flood-up).
    The inspectors selected installed ventilation systems used to mitigate the potential for
    airborne radioactivity, and evaluated whether the ventilation airflow capacity, flow path
    (including the alignment of the suction and discharges), and filter/charcoal unit
    efficiencies, as appropriate, were consistent with maintaining concentrations of airborne
    radioactivity in work areas below the concentrations of an airborne area to the extent
    practicable.
    The inspectors selected temporary ventilation system setups (high efficiency particulate
    air/charcoal negative pressure units, down draft tables, tents, metal Kelly buildings, and
    other enclosures) used to support work in contaminated areas. The inspectors
    assessed whether the use of these systems was consistent with licensee procedural
    guidance and the As-Low-As-Reasonably-Achievable (ALARA) concept.
    The inspectors reviewed airborne monitoring protocols by selecting installed systems
    used to monitor and warn of changing airborne concentrations in the plant and
    evaluating whether the alarms and setpoints were sufficient to prompt licensee/worker
    action to ensure that doses were maintained within the limits of 10 CFR Part 20 and the
    ALARA concept.
    The inspectors assessed whether the licensee had established trigger points (e.g., the
    Electric Power Research Institutes Alpha Monitoring Guidelines for Operating Nuclear
    Power Stations) for evaluating levels of airborne beta-emitting (e.g., plutonium-241) and
    alpha-emitting radionuclides.
  b. Findings
    No findings were identified.
                                              24                                Enclosure
.2  Use of Respiratory Protection Devices (02.03)
  a. Inspection Scope
    For those situations where it was impractical to employ engineering controls to minimize
    airborne radioactivity, the inspectors assessed whether the licensee provided respiratory
    protective devices such that occupational doses were ALARA. The inspectors selected
    work activities where respiratory protection devices were used to limit the intake of
    radioactive materials, and assessed whether the licensee performed an evaluation
    concluding that further engineering controls were not practical and that the use of
    respirators was ALARA. The inspectors also evaluated whether the licensee had
    established means (such as routine bioassay) to determine if the level of protection
    (protection factor) provided by the respiratory protection devices during use was at least
    as good as that assumed in the licensees work controls and dose assessment.
  b. Findings
    No findings were identified.
2RS4 Occupational Dose Assessment (71124.04)
    The inspection activities supplement those documented in Inspection
    Report 05000454/2011002; 05000455/2011002 and constitute one
    complete sample as defined in IP 71124.04-05.
.1  External Dosimetry (02.02)
  a. Inspection Scope
    The inspectors evaluated whether the licensees dosimetry vendor was National
    Voluntary Laboratory Accreditation Program (NVLAP) accredited and if the approved
    irradiation test categories for each type of personnel dosimeter used were consistent
    with the types and energies of the radiation present and the way the dosimeter was
    being used (e.g., to measure deep dose equivalent, shallow dose equivalent, or lens
    dose equivalent).
  b. Findings
    Introduction: The inspectors identified that the licensees use of dosimeters (TLDs)
    may not be consistent with the methods used by the NVLAP accreditation process.
    As a result, the inspectors identified an Unresolved Item (URI) for the apparent
    non-compliance with 10 CFR 20.1501(c)(2) because the accreditation process for the
    types of radiation included in the NVLAP program may not approximate the types of
    radiation for which the individual wearing the dosimeter is monitored.
    Discussion: The licensee used a vendor to supply and process dosimeters used to
    measure radiation exposure for the monitored workers. This vendor was NVLAP
    accredited for beta, gamma, neutron, mixture of beta/gamma, and mixture
    neutron/gamma radiations. However, the licensee used the dosimeters when workers
    may be exposed to beta, gamma, and neutron radiations within the same monitoring
                                            25                                Enclosure
    period. The inspectors determined that this mixture of three radiation types may not be
    aligned with the accreditation process.
    The issue was categorized as a URI pending NRC evaluation of this practice and
    determination whether a single TLD can accurately measure occupational dose to three
    types of radiation (URI 05000454/2011005-03; 05000455/2011005-03; Use of TLDs May
    Not be Consistent with the Methods Used by the NVLAP Accreditation Process)
2RS5 Radiation Monitoring Instrumentation (71124.05)
    The inspection activities supplement those documented in Inspection
    Report 05000454/2011002; 05000455/2011002 and constitute one
    complete sample as defined in IP 71124.05-05.
.1  Inspection Planning (02.01)
  a. Inspection Scope
    The inspectors reviewed the area radiation monitor alarm setpoint values and setpoint
    bases as provided in the TSs and the Final Safety Analysis Report.
    The inspectors reviewed effluent monitor alarm setpoint bases and the calculation
    methods provided in the Offsite Dose Calculation Manual (ODCM).
  b. Findings
    No findings were identified.
2RS6 Radioactive Gaseous and Liquid Effluent Treatment (71124.06)
    This inspection constituted one complete sample as defined in IP 71124.06-05.
.1  Inspection Planning and Program Reviews (02.01)
    Event Report and Effluent Report Reviews
  a. Inspection Scope
    The inspectors reviewed the radiological effluent release reports issued since the last
    inspection to determine if the reports were submitted as required by the ODCMl/TSs.
    The inspectors reviewed anomalous results, unexpected trends, or abnormal releases
    identified by the licensee for further inspection to determine if they were evaluated, were
    entered in the CAP, and were adequately resolved.
    The inspectors identified radioactive effluent monitor operability issues reported by the
    licensee in effluent release reports and reviewed these issues during the onsite
    inspection, as warranted, and determined if the issues were entered into the CAP and
    adequately resolved.
  b. Findings
    No findings were identified.
                                              26                                Enclosure
  Offsite Dose Calculation Manual and Final Safety Analysis Report Review
c. Inspection Scope
  The inspectors reviewed Final Safety Analysis Report descriptions of the radioactive
  effluent monitoring systems, treatment systems, and effluent flow paths so they could be
  evaluated during inspection walkdowns.
  The inspectors reviewed changes to the ODCM made by the licensee since the last
  inspection against the guidance in NUREG-1301, NUREG-0133, and Regulatory
  Guides 1.109, 1.21 and 4.1. When differences were identified, the inspectors reviewed
  the technical basis or evaluations of the change during the onsite inspection to
  determine whether they were technically justified and maintain effluent releases ALARA.
  The inspectors reviewed licensee documentation to determine if the licensee had
  identified any non-radioactive systems that had become contaminated as disclosed
  either through an event report or the ODCM since the last inspection. This review
  provided an intelligent sample list for the onsite inspection of any 10 CFR 50.59
  evaluations and allowed a determination if any newly contaminated systems had an
  unmonitored effluent discharge path to the environment, whether any required ODCM
  revisions were made to incorporate these new pathways and whether the associated
  effluents were reported in accordance with Regulatory Guide 1.21.
d. Findings
  No findings were identified.
  Groundwater Protection Initiative Program
e. Inspection Scope
  The inspectors reviewed reported groundwater monitoring results and changes to the
  licensees written program for identifying and controlling contaminated spills/leaks to
  groundwater.
f. Findings
  No findings were identified.
  Procedures, Special Reports, and Other Documents
g. Inspection Scope
  The inspectors reviewed Licensee Event Reports, event reports and/or special reports
  related to the effluent program issued since the previous inspection to identify any
  additional focus areas for the inspection based on the scope/breadth of problems
  described in these reports.
  The inspectors reviewed effluent program implementing procedures, particularly those
  associated with effluent sampling, effluent monitor setpoint determinations, and dose
  calculations.
                                          27                                Enclosure
    The inspectors reviewed copies of licensee and third party (independent) evaluation
    reports of the effluent monitoring program since the last inspection to gather insights into
    the licensees program and aid in selecting areas for inspection review (smart sampling).
h. Findings
    No findings were identified.
.2  Walkdowns and Observations (02.02)
a. Inspection Scope
    The inspectors walked down selected components of the gaseous and liquid discharge
    systems to evaluate whether equipment configuration and flow paths aligned with the
    documents reviewed in 02.01 above and to assess equipment material condition.
    Special attention was made to identify potential unmonitored release points (such as
    open roof vents in boiling water reactor turbine decks, temporary structures butted
    against turbine, auxiliary or containment buildings), building alterations which could
    impact airborne or liquid effluent controls, and ventilation system leakage that
    communicated directly with the environment.
    For equipment or areas associated with the systems selected for review that were not
    readily accessible due to radiological conditions, the inspectors reviewed the licensee's
    material condition surveillance records, as applicable.
    The inspectors walked down filtered-ventilation systems to assess for conditions such as
    degraded high-efficiency particulate air/charcoal banks, improper alignment, or system
    installation issues that would impact the performance or the effluent monitoring capability
    of the effluent system.
    As available, the inspectors observed selected portions of the routine processing and
    discharge of radioactive gaseous effluent (including sample collection and analysis) to
    evaluate whether appropriate treatment equipment was used and the processing
    activities aligned with discharge permits.
    The inspectors determined if the licensee had made significant changes to their
    effluent release points (e.g., changes subject to a 10 CFR 50.59 review or requiring
    NRC approval of alternate discharge points).
    As available, the inspectors observed selected portions of the routine processing and
    discharge of liquid waste (including sample collection and analysis) to determine if
    appropriate effluent treatment equipment was being used and whether radioactive liquid
    waste was being processed and discharged in accordance with procedure requirements
    and aligned with discharge permits.
b. Findings
    No findings were identified.
                                          28                                  Enclosure
.3  Sampling and Analyses (02.03)
a. Inspection Scope
    The inspectors selected effluent sampling activities, consistent with smart sampling, and
    assessed whether adequate controls had been implemented to ensure representative
    samples were obtained (e.g., provisions for sample line flushing, vessel recirculation,
    composite samplers, etc.)
    The inspectors selected effluent discharges made with inoperable (declared out-of-
    service) effluent radiation monitors to assess whether controls were in place to ensure
    compensatory sampling was performed consistent with the radiological effluent
    TSs/ODCM and that those controls were adequate to prevent the release of
    unmonitored liquid and gaseous effluents.
    The inspectors determined whether the facility was routinely relying on the use of
    compensatory sampling in lieu of adequate system maintenance, based on the
    frequency of compensatory sampling since the last inspection.
    The inspectors reviewed the results of the inter-laboratory comparison program to
    evaluate the quality of the radioactive effluent sample analyses and assessed whether
    the inter-laboratory comparison program included hard-to-detect isotopes as
    appropriate.
b. Findings
    No findings were identified.
.4  Instrumentation and Equipment (02.04)
    Effluent Flow Measuring Instruments
a. Inspection Scope
    The inspectors reviewed the methodology the licensee used to determine the effluent
    stack and vent flow rates to determine if the flow rates were consistent with radiological
    effluent TSs/ODCM or Final Safety Analysis Report values, and that differences between
    assumed and actual stack and vent flow rates did not affect the results of the projected
    public doses.
b. Findings
    No findings were identified.
    Air Cleaning Systems
c. Inspection Scope
    The inspectors assessed whether surveillance test results since the previous
    inspection for TS required ventilation effluent discharge systems (high-efficiency
    particulate air and charcoal filtration), such as the Standby Gas Treatment System
    and the Containment/Auxiliary Building Ventilation System, met TS acceptance criteria.
                                            29                              Enclosure
d. Findings
    No findings were identified.
.5  Dose Calculations (02.05)
a. Inspection Scope
    The inspectors reviewed all significant changes in reported dose values compared to the
    previous radiological effluent release report (e.g., a factor of 5, or increases that
    approach Appendix I criteria) to evaluate the factors which may have resulted in the
    change.
    The inspectors reviewed radioactive liquid and gaseous waste discharge permits to
    assess whether the projected doses to members of the public were accurate and based
    on representative samples of the discharge path.
    The inspectors evaluated the methods used to determine the isotopes that were
    included in the source term to ensure all applicable radionuclides were included within
    detectability standards. The review included the current Part 61 analyses to ensure
    hard-to-detect radionuclides were included in the source term.
    The inspectors reviewed changes in the licensees offsite dose calculations since the
    last inspection to evaluate whether changes were consistent with the ODCM and
    Regulatory Guide 1.109. The inspectors reviewed meteorological dispersion and
    deposition factors used in the ODCM and effluent dose calculations to evaluate whether
    appropriate factors were being used for public dose calculations.
    The inspectors reviewed the latest Land Use Census to assess whether changes (e.g.,
    significant increases or decreases to population in the plant environs, changes in critical
    exposure pathways, the location of nearest member of the public or critical receptor,
    etc.) had been factored into the dose calculations.
    For the releases reviewed above, the inspectors evaluated whether the calculated doses
    (monthly, quarterly, and annual dose) were within the 10 CFR Part 50, Appendix I, and
    TS dose criteria.
    The inspectors reviewed, as available, records of any abnormal gaseous or liquid tank
    discharges (e.g., discharges resulting from misaligned valves, valve leak-by, etc) to
    ensure the abnormal discharge was monitored by the discharge point effluent monitor.
    Discharges made with inoperable effluent radiation monitors, or unmonitored leakages
    were reviewed to ensure that an evaluation was made of the discharge to satisfy
    10 CFR 20.1501 so as to account for the source term and projected doses to the public.
b. Findings
    No findings were identified.
                                          30                                    Enclosure
.6  Groundwater Protection Initiative Implementation (02.06)
a. Inspection Scope
    The inspectors reviewed monitoring results of the Groundwater Protection Initiative to
    determine if the licensee had implemented its program as intended and to identify any
    anomalous results. For anomalous results or missed samples, the inspectors assessed
    whether the licensee had identified and addressed deficiencies through its CAP.
    The inspectors reviewed identified leakage or spill events and entries made into
    10 CFR 50.75 (g) records. The inspectors reviewed evaluations of leaks or spills
    and reviewed any remediation actions taken for effectiveness. The inspectors
    reviewed onsite contamination events involving contamination of ground water and
    assessed whether the source of the leak or spill was identified and mitigated.
    For unmonitored spills, leaks, or unexpected liquid or gaseous discharges, the
    inspectors assessed whether an evaluation was performed to determine the type and
    amount of radioactive material that was discharged by:
    *  Assessing whether sufficient radiological surveys were performed to evaluate the
        extent of the contamination and the radiological source term and assessing whether
        a survey/evaluation had been performed to include consideration of hard-to-detect
        radionuclides.
    *  Determining whether the licensee completed offsite notifications, as provided in its
        Groundwater Protection Initiative implementing procedures.
    The inspectors reviewed the evaluation of discharges from onsite surface water bodies
    that contained or potentially contained radioactivity, and the potential for ground water
    leakage from these onsite surface water bodies. The inspectors assessed whether the
    licensee was properly accounting for discharges from these surface water bodies as part
    of their effluent release reports.
    The inspectors assessed whether on-site ground water sample results and a description
    of any significant on-site leaks/spills into ground water for each calendar year were
    documented in the Annual Radiological Environmental Operating Report for the
    radiological environmental monitoring program or the Annual Radiological Effluent
    Release Report for the Radiological Effluent TSs.
    For significant, new effluent discharge points (such as significant or continuing leakage
    to ground water that continued to impact the environment if not remediated), the
    inspectors evaluated whether the ODCM was updated to include the new release point.
b. Findings
    No findings were identified.
                                            31                                Enclosure
.7  Problem Identification and Resolution (02.07)
  a. Inspection Scope
    Inspectors assessed whether problems associated with the effluent monitoring and
    control program were being identified by the licensee at an appropriate threshold and
    were properly addressed for resolution in the licensee CAP. In addition, the inspectors
    evaluated the appropriateness of the corrective actions for a selected sample of
    problems documented by the licensee involving radiation monitoring and exposure
    controls.
  b. Findings
    No findings were identified.
2RS7 Radiological Environmental Monitoring Program (71124.07)
    This inspection constituted one complete sample as defined in IP 71124.07-05.
.1  Inspection Planning (02.01)
  a. Inspection Scope
    The inspectors reviewed the annual radiological environmental operating reports and the
    results of any licensee assessments since the last inspection to assess whether the
    radiological environmental monitoring program was implemented in accordance with the
    TSs and ODCM. This review included reported changes to the ODCM with respect to
    environmental monitoring, commitments in terms of sampling locations, monitoring and
    measurement frequencies, land use census, inter-laboratory comparison program, and
    analysis of data.
    The inspectors reviewed the ODCM to identify locations of environmental monitoring
    stations.
    The inspectors reviewed the Final Safety Analysis Report for information regarding the
    environmental monitoring program and meteorological monitoring instrumentation.
    The inspectors reviewed quality assurance audit results of the program to assist in
    choosing inspection smart samples and audits and technical evaluations performed on
    the vendor laboratory program.
    The inspectors reviewed the annual effluent release report and the 10 CFR Part 61,
    Licensing Requirements for Land Disposal of Radioactive Waste, report, to determine
    if the licensee was sampling, as appropriate, for the predominant and dose-causing
    radionuclides likely to be released in effluents.
  b. Findings
    No findings were identified.
                                            32                              Enclosure
.2  Site Inspection (02.02)
a. Inspection Scope
    The inspectors walked down select air sampling stations and thermoluminescent
    dosimeter monitoring stations to determine whether they were located as described in
    the ODCM and to determine the equipment material condition. Consistent with smart
    sampling, the air sampling stations were selected based on the locations with the
    highest X/Q, D/Q wind sectors, and thermoluminescent dosimeters were selected based
    on the most risk-significant locations (e.g., those that have the highest potential for
    public dose impact).
    For the air samplers and thermoluminescent dosimeters selected, the inspectors
    reviewed the calibration and maintenance records to evaluate whether they
    demonstrated adequate operability of these components. Additionally, the review
    included the calibration and maintenance records of select composite water samplers.
    The inspectors assessed whether the licensee had initiated sampling of other
    appropriate media upon loss of a required sampling station.
    The inspectors observed the collection and preparation of environmental samples from
    different environmental media (e.g., ground and surface water, milk, vegetation,
    sediment, and soil) as available to determine if environmental sampling was
    representative of the release pathways as specified in the ODCM and if sampling
    techniques were in accordance with procedures.
    Based on direct observation and review of records, the inspectors assessed whether
    the meteorological instruments were operable, calibrated, and maintained in
    accordance with guidance contained in the Final Safety Analysis Report; NRC
    Regulatory Guide 1.23, Meteorological Monitoring Programs for Nuclear Power Plants;
    and licensee procedures. The inspectors assessed whether the meteorological data
    readout and recording instruments in the control room and, if applicable, at the tower
    were operable.
    The inspectors evaluated whether missed and/or anomalous environmental samples
    were identified and reported in the annual environmental monitoring report. The
    inspectors selected events that involved a missed sample, inoperable sampler, lost
    thermoluminescent dosimeter, or anomalous measurement to determine if the licensee
    had identified the cause and had implemented corrective actions. The inspectors
    reviewed the licensees assessment of any positive sample results (i.e., licensed
    radioactive material detected above the lower limits of detection) and reviewed the
    associated radioactive effluent release data that was the source of the released material.
    The inspectors selected structures, systems, or components that involved or could
    reasonably involve licensed material for which there was a credible mechanism for
    licensed material to reach ground water, and assessed whether the licensee had
    implemented a sampling and monitoring program sufficient to detect leakage of these
    structures, systems, or components to ground water.
                                          33                                  Enclosure
    The inspectors evaluated whether records, as required by 10 CFR 50.75(g), of leaks,
    spills, and remediation since the previous inspection were retained in a retrievable
    manner.
    The inspectors reviewed any significant changes made by the licensee to the ODCM as
    the result of changes to the land census, long-term meteorological conditions (3-year
    average), or modifications to the sampler stations since the last inspection. The
    inspectors reviewed technical justifications for any changed sampling locations to
    evaluate whether the licensee performed the reviews required to ensure that the
    changes did not affect the ability to monitor the impact of radioactive effluent releases on
    the environment.
    The inspectors assessed whether the appropriate detection sensitivities with respect to
    TSs/ODCM were used for counting samples (i.e., the samples met the TSs/ODCM
    required lower limits of detection). The inspectors reviewed quality control charts for
    maintaining radiation measurement instrument status and actions taken for degrading
    detector performance. The licensee used a vendor laboratory to analyze the radiological
    environmental monitoring program samples so the inspectors reviewed the results of the
    vendors quality control program, including the interlaboratory comparison, to assess the
    adequacy of the vendors program.
    The inspectors reviewed the results of the licensees interlaboratory comparison
    program to evaluate the adequacy of environmental sample analyses performed by the
    licensee. The inspectors assessed whether the interlaboratory comparison test included
    the media/nuclide mix appropriate for the facility. If applicable, the inspectors reviewed
    the licensees determination of any bias to the data and the overall effect on the
    radiological environmental monitoring program.
  b. Findings
    No findings were identified.
.3  Identification and Resolution of Problems (02.03)
  a. Inspection Scope
    The inspectors assessed whether problems associated with the radiological
    environmental monitoring program were being identified by the licensee at an
    appropriate threshold and were properly addressed for resolution in the licensees CAP.
    Additionally, the inspectors assessed the appropriateness of the corrective actions for a
    selected sample of problems documented by the licensee that involved the radiological
    environmental monitoring program.
  b. Findings
    No findings were identified.
2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and
    Transportation (71124.08)
    This inspection constituted one complete sample as defined in IP 71124.08-05.
                                            34                                  Enclosure
.1  Inspection Planning (02.01)
a. Inspection Scope
    The inspectors reviewed the solid radioactive waste system description in the Final
    Safety Analysis Report, the process control program, and the recent radiological effluent
    release report for information on the types, amounts, and processing of radioactive
    waste disposed.
    The inspectors reviewed the scope of any quality assurance audits in this area since the
    last inspection to gain insights into the licensees performance and inform the smart
    sampling inspection planning.
b. Findings
    No findings were identified.
.2  Radioactive Material Storage (02.02)
a. Inspection Scope
    The inspectors selected areas where containers of radioactive waste were stored, and
    evaluated whether the containers were labeled in accordance with 10 CFR 20.1904,
    Labeling Containers, or controlled in accordance with 10 CFR 20.1905, Exemptions to
    Labeling Requirements, as appropriate.
    The inspectors assessed whether the radioactive material storage areas were controlled
    and posted in accordance with the requirements of 10 CFR Part 20, Standards for
    Protection against Radiation. For materials stored or used in controlled or unrestricted
    areas, the inspectors evaluated whether they were secured against unauthorized
    removal and controlled in accordance with 10 CFR 20.1801, Security of Stored
    Material, and 10 CFR 20.1802, Control of Material Not in Storage, as appropriate.
    The inspectors evaluated whether the licensee established a process for monitoring the
    impact of long term storage (e.g., buildup of any gases produced by waste
    decomposition, chemical reactions, container deformation, loss of container integrity, or
    re-release of free-flowing water) that was sufficient to identify potential unmonitored,
    unplanned releases or nonconformance with waste disposal requirements.
    The inspectors selected containers of stored radioactive material, and inspected the
    containers for signs of swelling, leakage, and deformation.
b. Findings
    No findings were identified.
.3  Radioactive Waste System Walkdown (02.03)
a. Inspection Scope
    The inspectors walked down accessible portions of select radioactive waste processing
    systems to assess whether the current system configuration and operation agreed with
                                            35                                  Enclosure
    the descriptions in the Final Safety Analysis Report, ODCM, and process control
    program.
    The inspectors reviewed administrative and/or physical controls (i.e., drainage and
    isolation of the system from other systems) to assess whether the equipment which was
    not in service or abandoned in place would contribute to an unmonitored release path
    and/or affect operating systems or be a source of unnecessary personnel exposure.
    The inspectors assessed whether the licensee reviewed the safety significance of
    systems and equipment abandoned in place in accordance with 10 CFR 50.59,
    Changes, Tests, and Experiments.
    The inspectors reviewed the adequacy of changes made to the radioactive waste
    processing systems since the last inspection. The inspectors evaluated whether
    changes from what was described in the Final Safety Analysis Report were reviewed
    and documented in accordance with 10 CFR 50.59, as appropriate and to assess the
    impact on radiation doses to members of the public.
    The inspectors selected processes for transferring radioactive waste resin and/or sludge
    discharges into shipping/disposal containers and assessed whether the waste stream
    mixing, sampling procedures, and methodology for waste concentration averaging were
    consistent with the process control program, and provided representative samples of the
    waste product for the purposes of waste classification as described in 10 CFR 61.55,
    Waste Classification.
    For those systems that provided tank recirculation, the inspectors evaluated whether the
    tank recirculation procedures provided sufficient mixing.
    The inspectors assessed whether the licensees process control program correctly
    described the current methods and procedures for dewatering and waste stabilization
    (e.g., removal of freestanding liquid).
b. Findings
    No findings were identified.
.4  Waste Characterization and Classification (02.04)
a. Inspection Scope
    The inspectors selected the following radioactive waste streams for review:
    *        Primary Resin;
    *        Secondary Resin;
    *        Secondary Radwaste Filter; and
    *        Dry Active Waste (DAW).
    For the waste streams listed above, the inspectors assessed whether the licensees
    radiochemical sample analysis results (i.e., 10 CFR Part 61" analysis) were sufficient to
    support radioactive waste characterization as required by 10 CFR Part 61, Licensing
    Requirements for Land Disposal of Radioactive Waste. The inspectors evaluated
    whether the licensees use of scaling factors and calculations to account for difficult-to-
                                            36                              Enclosure
    measure radionuclides was technically sound and based on current 10 CFR Part 61
    analyses for the selected radioactive waste streams.
    The inspectors evaluated whether changes to plant operational parameters were taken
    into account to: (1) maintain the validity of the waste stream composition data between
    the annual or biennial sample analysis update; and (2) assure that waste shipments
    continued to meet the requirements of 10 CFR Part 61 for the waste streams selected
    above.
    The inspectors evaluated whether the licensee had established and maintained an
    adequate quality assurance program to ensure compliance with the waste classification
    and characterization requirements of 10 CFR 61.55 and 10 CFR 61.56, Waste
    Characteristics.
b. Findings
    No findings were identified.
.5  Shipment Preparation (02.05)
a. Inspection Scope
    The inspectors observed shipment packaging, surveying, labeling, marking, placarding,
    vehicle checks, emergency instructions, disposal manifest, shipping papers provided to
    the driver, and licensee verification of shipment readiness. The inspectors assessed
    whether the requirements of applicable transport cask certificates of compliance had
    been met. The inspectors evaluated whether the receiving licensee was authorized to
    receive the shipment packages. The inspectors evaluated whether the licensees
    procedures for cask loading and closure were consistent with the vendors current
    approved procedures.
    The inspectors observed radiation workers during the conduct of radioactive waste
    processing and radioactive material shipment preparation and receipt activities. The
    inspectors assessed whether the shippers were knowledgeable of the shipping
    regulations and whether shipping personnel demonstrated adequate skills to accomplish
    the package preparation requirements for public transport with respect to the licensees
    response to NRC Bulletin 79-19, Packaging of Low-Level Radioactive Waste for
    Transport and Burial, dated August 10, 1979; and Title 49 CFR Part 172, Hazardous
    Materials Table, Special Provisions, Hazardous Materials Communication, Emergency
    Response Information, Training Requirements, and Security Plans, Subpart H,
    Training.
    Due to limited opportunities for direct observation, the inspectors reviewed the technical
    instructions presented to workers during routine training. The inspectors assessed
    whether the licensees training program provided training to personnel responsible for
    the conduct of radioactive waste processing and radioactive material shipment
    preparation activities.
b. Findings
    No findings were identified.
                                          37                                Enclosure
.6  Shipping Records (02.06)
a. Inspection Scope
    The inspectors evaluated whether the shipping documents indicated the proper shipper
    name; emergency response information and a 24-hour contact telephone number;
    accurate curie content and volume of material; and appropriate waste classification,
    transport index, and UN number for the following radioactive shipments:
    *      Shipment RWS10-011; Dewatered Bead Resin; low specific activity (LSA-II);
    *      Shipment RWS10-013; DAW Trash and TR Pond Sludge; low specific activity
            (LSA-II);
    *      Shipment RWS10-012; DAW Trash; low specific activity (LSA-II);
    *      Shipment RMS09-094; Rx Vessel Dosimetry; Type A Package; and
    *      Shipment RMS11-078; Dirty Laundry; low specific activity (LSA-II).
    Additionally, the inspectors assessed whether the shipment placarding was consistent
    with the information in the shipping documentation.
b. Findings
    Introduction: A self-revealed finding of very low safety significance (Green) and an
    associated NCV of 10 CFR 71.5, Transportation of Licensed Material, was identified
    when licensee personnel failed to comply with 49 CFR 172.203(c) and shipped
    packages of radioactive material with transport manifests that did not document all
    applicable hazardous substances.
    Description: On multiple dates, the licensee shipped containers of radioactive material
    to a waste processor with incomplete information on the transport manifest. Specifically,
    the transport manifest that accompanied the shipments failed to identify hazardous
    materials, including asbestos, lead, and other chemicals that were contained in the
    packages. Upon arrival at the waste processors facility, the waste processor identified
    the non-conformances in the shipping containers and notified the licensee. Follow-up
    actions by the licensee included performing a revised characterization of the shipped
    packages. The revised radiological characterization identified negligible impact relative
    to the initial radiological assessment and package characterization. This event was
    documented in the licensees CAP as:
    *      IR 1221229; RWS 11-006 Contained Un-Manifested Asbestos;
    *      IR 1173307; RWS 10-013 Contained Unapproved Mixed Waste;
    *      IR 928393; Non-Conforming Metal Shipped to Bear Creek Processing;
    *      IR 1015646; Non-Conforming Waste Found in Radwaste Shipment; and
    *      IR 1067394; Non-Conforming Radioactive Waste in Shipment.
                                          38                                Enclosure
Immediate corrective actions included providing a corrected copy of the transport
manifest to the waste processor. Additionally, the licensee initiated IR 1285148
to evaluate the human performance issues associated with the shipping
non-conformances. Further, the licensee placed locks on the shipping containers
to control items placed in the packages and to ensure that the manifest accurately
represented the hazards contained in the shipping package.
Analysis: The failure to completely identify all required package contents on a transport
manifest was a performance deficiency. The finding was determined to be more than
minor because it was associated with the Program and Process attribute of the Public
Radiation Safety Cornerstone and adversely affected the cornerstone objective of
ensuring the adequate protection of public health and safety from exposure to
radioactive materials released into the public domain as a result of routine civilian
nuclear reactor operation, in that, providing incorrect information, as part of hazard
communication, could impact the actions of response personnel. The finding involved
an occurrence of the licensees radioactive material transportation program that was
contrary to NRC regulatory requirements. The inspectors determined that the finding
could be evaluated using the SDP in accordance with IMC 0609, Significance
Determination Process, Appendix D, Public Radiation Safety Significance
Determination Process. Using the Public Radiation Safety SDP, the inspectors
determined: (1) radiation limits were not exceeded; (2) there was no breach of a
package during transit; (3) it did not involve a certificate of compliance issue; (4) it was
not a low level burial ground nonconformance; and (5) it did not involve a failure to make
notifications or provide emergency information. As a result, the finding screened as
having very low safety significance (Green).
This finding has a cross-cutting aspect in the Work Control component of the Human
Performance cross-cutting area [H.3(b)] since the waster shipper failed to coordinate
work activities by incorporating actions to address the impact of the work on different job
activities, and the need for work groups to maintain interfaces with offsite organizations,
and communicate, coordinate, and cooperate with each other during activities in which
interdepartmental coordination is necessary to assure adequate human performance.
Specifically, these events occurred because the radioactive material shipper did not
control the items placed in the waste packages and was not present when the boxes
were loaded.
Enforcement: Title 10 CFR 71.5, Transportation of Licensed Material, requires
licensees to comply with the Department of Transportation (DOT) regulations in
49 CFR Parts 170 through 189 relative to the transportation of licensed material.
Title 49 CFR 172.203, Additional Description Requirements, required, in part,
that hazardous materials be listed on the transport manifest.
Contrary to the above, between May 10, 2010 and May 26, 2011, the licensee failed to
list relevant hazardous materials on the transport manifest for a shipment also containing
DAW. This violation was entered into the licensees CAP as IR 1285148. Because this
violation was of very low safety significance and it was entered into the licensees CAP,
this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC
Enforcement Policy. (NCV 05000454/2011005-04, Failure to Identify Hazardous
Materials on Transportation Manifest)
                                        39                                  Enclosure
  .7  Identification and Resolution of Problems (02.07)
  a. Inspection Scope
      The inspectors assessed whether problems associated with radioactive waste
      processing, handling, storage, and transportation, were being identified by the licensee
      at an appropriate threshold, were properly characterized, and were properly addressed
      for resolution in the licensee CAP. Additionally, the inspectors evaluated whether the
      corrective actions were appropriate for a selected sample of problems documented by
      the licensee that involve radioactive waste processing, handling, storage, and
      transportation.
      The inspectors reviewed results of selected audits performed since the last inspection of
      this program and evaluated the adequacy of the licensees corrective actions for issues
      identified during those audits.
  b. Findings
      No findings were identified.
4.    OTHER ACTIVITIES
      Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and
      Emergency Preparedness
4OA1 Performance Indicator Verification (71151)
.1  Reactor Coolant System Leakage
  a. Inspection Scope
      The inspectors sampled licensee submittals for the Unit 1 and Unit 2 RCS Leakage
      Performance Indicator (PI) for the period from the third quarter 2010 through the second
      quarter 2011. To determine the accuracy of the PI data reported during those periods,
      PI definitions and guidance contained in Nuclear Energy Institute (NEI) 99-02,
      Regulatory Assessment Performance Indicator Guideline, Revision 6, dated
      October 2009, was used. The inspectors reviewed the licensees operator logs,
      RCS leakage tracking data, issue reports, event reports and NRC Integrated Inspection
      Reports for the period of June 2010 through June 2011 to validate the accuracy of the
      submittals. The inspectors also reviewed the licensees issue report database to
      determine if any problems had been identified with the PI data collected or transmitted
      for this indicator. Documents reviewed are listed in the Attachment.
      This inspection constituted two RCS leakage samples as defined in IP 71151-05.
  b. Findings
      No findings were identified.
                                            40                                Enclosure
.2  Unplanned Transients Per 7000 Critical Hours
a. Inspection Scope
    The inspectors sampled licensee submittals for the Unplanned Transients per 7000
    Critical Hours performance indicator for Unit 1 and Unit 2 for the period from the second
    quarter of 2010 through the 3rd quarter of 2011. To determine the accuracy of the PI
    data reported during those periods, PI definitions and guidance contained in NEI 99-02,
    Regulatory Assessment Performance Indicator Guideline, Revision 6, dated
    October 2009, was used. The inspectors reviewed the licensees operator narrative
    logs, issue reports, maintenance rule records, event reports and NRC Integrated
    Inspection Reports for the period of April 2010 through September 2011 to validate the
    accuracy of the submittals. The inspectors also reviewed the licensees issue report
    database to determine if any problems had been identified with the PI data collected or
    transmitted for this indicator. Documents reviewed are listed in the Attachment.
    This inspection constituted two unplanned transients per 7000 critical hours samples as
    defined in IP 71151-05.
b. Findings
    No findings were identified.
.3  Safety System Functional Failures
a. Inspection Scope
    The inspectors sampled licensee submittals for the Safety System Functional Failures
    performance indicator for Unit 1 and Unit 2 for the period from the second quarter of
    2010 through the third quarter of 2011. To determine the accuracy of the PI data
    reported during those periods, PI definitions and guidance contained in NEI 99-02,
    Regulatory Assessment Performance Indicator Guideline, Revision 6, dated
    October 2009, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and
    50.73" definitions and guidance, were used. The inspectors reviewed the licensees
    operator narrative logs, operability assessments, maintenance rule records,
    maintenance work orders, issue reports, event reports and NRC Integrated Inspection
    Reports for the period of June 2010 through September 2011 to validate the accuracy of
    the submittals. The inspectors also reviewed the licensees issue report database to
    determine if any problems had been identified with the PI data collected or transmitted
    for this indicator. Documents reviewed are listed in the Attachment.
    This inspection constituted two safety system functional failures samples as defined in
    IP 71151-05.
b. Findings
    No findings were identified.
                                          41                                Enclosure
.4  Reactor Coolant System Specific Activity
a. Inspection Scope
    The inspectors sampled licensee submittals for the RCS specific activity PI for Unit 1
    and Unit 2 for the period from the 4th quarter of 2010 through the 3rd quarter of 2011.
    The inspectors used PI definitions and guidance contained in NEI 99-02, Regulatory
    Assessment Performance Indicator Guideline, Revision 6, dated October 2009 to
    determine the accuracy of the PI data reported during those periods. The inspectors
    reviewed the licensees reactor coolant system chemistry samples, TS requirements,
    issue reports, event reports, and NRC Integrated Inspection Reports for the period of the
    4th quarter 2010 through the 3rd quarter of 2011 to validate the accuracy of the
    submittals. The inspectors also reviewed the licensees issue report database to
    determine if any problems had been identified with the PI data collected or transmitted
    for this indicator. In addition to record reviews, the inspectors observed a chemistry
    technician obtain and analyze a reactor coolant system sample. Documents reviewed
    are listed in the Attachment.
    This inspection constituted two RCS specific activity samples as defined in IP 71151-05.
b. Findings
    No findings were identified.
.5  Mitigating Systems Performance Index - Heat Removal System
a. Inspection Scope
    The inspectors sampled licensee submittals for the Mitigating Systems Performance
    Index (MSPI) - Heat Removal System performance indicator for Unit 1 and Unit 2 for the
    period from the fourth quarter of 2010 through the third quarter of 2011. To determine
    the accuracy of the PI data reported during those periods, PI definitions and guidance
    contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline,
    Revision 6, dated October 2009, was used. The inspectors reviewed the licensees
    operator narrative logs, issue reports, event reports, MSPI derivation reports, and NRC
    Integrated IRs for the period of October 2010 through September 2011 to validate the
    accuracy of the submittals. The inspectors reviewed the MSPI component risk
    coefficient to determine if it had changed by more than 25 percent in value since the
    previous inspection, and if so, that the change was in accordance with applicable NEI
    guidance. The inspectors also reviewed the licensees issue report database to
    determine if any problems had been identified with the PI data collected or transmitted
    for this indicator. Documents reviewed are listed in the Attachment.
    This inspection constituted two MSPI heat removal system samples as defined in
    IP 71151-05.
b. Findings
    No findings were identified.
                                            42                                Enclosure
.6  Mitigating Systems Performance Index - Cooling Water Systems
a. Inspection Scope
    The inspectors sampled licensee submittals for the MSPI - Cooling Water Systems
    performance indicator for Unit 1 and Unit 2 for the period from the fourth quarter of 2010
    through the third quarter of 2011. To determine the accuracy of the PI data reported
    during those periods, PI definitions and guidance contained in NEI 99-02, Regulatory
    Assessment Performance Indicator Guideline, Revision 6, dated October 2009, was
    used. The inspectors reviewed the licensees operator narrative logs, issue reports,
    MSPI derivation reports, event reports and NRC Integrated Inspection Reports for the
    period of October 2010 through September 2011 to validate the accuracy of the
    submittals. The inspectors reviewed the MSPI component risk coefficient to determine if
    it had changed by more than 25 percent in value since the previous inspection, and if so,
    whether the change was in accordance with applicable NEI guidance. The inspectors
    also reviewed the licensees issue report database to determine if any problems had
    been identified with the PI data collected or transmitted for this indicator. Documents
    reviewed are listed in the Attachment.
    This inspection constituted two MSPI cooling water system samples as defined in
    IP 71151-05.
b. Findings
    No findings were identified.
.7  Mitigating Systems Performance Index - High Pressure Injection Systems
a. Inspection Scope
    The inspectors sampled licensee submittals for the MSPI - High Pressure Injection
    Systems performance indicator for Unit 1 and Unit 2 for the period from the fourth
    quarter of 2010 through the third quarter of 2011. To determine the accuracy of the PI
    data reported during those periods, PI definitions and guidance contained in NEI 99-02,
    Regulatory Assessment Performance Indicator Guideline, Revision 6, dated
    October 2009, were used. The inspectors reviewed the licensees operator narrative
    logs, issue reports, MSPI derivation reports, event reports and NRC Integrated
    Inspection Reports for the period of October 2010 through September of 2011 to validate
    the accuracy of the submittals. The inspectors reviewed the MSPI component risk
    coefficient to determine if it had changed by more than 25 percent in value since the
    previous inspection, and if so, that the change was in accordance with applicable
    NEI guidance. The inspectors also reviewed the licensees issue report database to
    determine if any problems had been identified with the PI data collected or transmitted
    for this indicator. Documents reviewed are listed in the Attachment.
    This inspection constituted two MSPI high pressure injection system samples as defined
    in IP 71151-05.
b. Findings
    No findings were identified.
                                          43                                  Enclosure
.8  Occupational Exposure Control Effectiveness
a. Inspection Scope
    The inspectors sampled licensee submittals for the occupational radiological
    occurrences PI for the period from the fourth quarter of 2010 through the 3rd quarter
    of 2011. To determine the accuracy of the PI data reported during these periods, the
    inspectors used PI definitions and guidance contained in NEI 99-02, Regulatory
    Assessment Performance Indicator Guideline, Revision 6, dated October 2009. The
    inspectors reviewed the licensees assessment of the PI for occupational radiation safety
    to determine if indicator-related data was adequately assessed and reported. To assess
    the adequacy of the licensees PI data collection and analyses, the inspectors discussed
    with radiation protection staff, the scope, and breadth of its data review and the results of
    those reviews. The inspectors independently reviewed electronic personal dosimetry
    dose rate and accumulated dose alarms and dose reports and the dose assignments for
    any intakes that occurred during the time period reviewed to determine if there were
    potentially unrecognized occurrences. The inspectors also conducted walkdowns of
    numerous locked high and very high radiation area entrances to determine the adequacy
    of the controls in place for these areas. Documents reviewed are listed in the
    Attachment.
    This inspection constituted one occupational exposure control effectiveness sample as
    defined in IP 71151-05.
b. Findings
    No findings were identified.
.9  Radiological Effluent Technical Specification/Offsite Dose Calculation Manual
    Radiological Effluent Occurrences
a. Inspection Scope
    The inspectors sampled licensee submittals for the radiological effluent TS/ODCM
    radiological effluent occurrences PI for the period from the fourth quarter of 2010 through
    the third quarter of 2011. To determine the accuracy of the PI data reported during
    these periods, the inspectors used PI definitions and guidance contained in NEI 99-02,
    Regulatory Assessment Performance Indicator Guideline, Revision 6, dated
    October 2009. The inspectors reviewed the licensees issue report database and
    selected individual reports generated since this indicator was last reviewed to identify
    any potential occurrences such as unmonitored, uncontrolled, or improperly calculated
    effluent releases that may have impacted offsite dose. The inspectors reviewed
    gaseous effluent summary data and the results of associated offsite dose calculations
    for selected dates between the fourth quarter of 2010 through the third quarter of 2011 to
    determine if indicator results were accurately reported. The inspectors also reviewed the
    licensees methods for quantifying gaseous and liquid effluents and determining effluent
    dose. Documents reviewed are listed in the Attachment.
                                            44                                Enclosure
      This inspection constituted one Radiological Effluent TS/ODCM radiological effluent
      occurrences sample as defined in IP 71151 05.
  b. Findings
      No findings were identified.
4OA2 Identification and Resolution of Problems (71152)
      Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency
      Preparedness, Public Radiation Safety, Occupational Radiation Safety, and
      Physical Protection
.1  Routine Review of Items Entered into the Corrective Action Program
  a. Inspection Scope
      As part of the various baseline inspection procedures discussed in previous sections of
      this report, the inspectors routinely reviewed issues during baseline inspection activities
      and plant status reviews to verify that they were being entered into the licensees CAP at
      an appropriate threshold, that adequate attention was being given to timely corrective
      actions, and that adverse trends were identified and addressed. Attributes reviewed
      included: the complete and accurate identification of the problem; that timeliness was
      commensurate with the safety significance; that evaluation and disposition of
      performance issues, generic implications, common causes, contributing factors, root
      causes, extent-of-condition reviews, and previous occurrence reviews were proper and
      adequate; and that the classification, prioritization, focus, and timeliness of corrective
      actions were commensurate with safety and sufficient to prevent recurrence of the issue.
      Minor issues entered into the licensees CAP as a result of the inspectors observations
      are included in the attached List of Documents Reviewed.
      These routine reviews for the identification and resolution of problems did not constitute
      any additional inspection samples. Instead, by procedure they were considered an
      integral part of the inspections performed during the quarter and documented in
      Section 1 of this report.
  b. Findings
      No findings were identified.
.2  Daily Corrective Action Program Reviews
  a. Inspection Scope
      In order to assist with the identification of repetitive equipment failures and specific
      human performance issues for follow-up, the inspectors performed a daily screening
      of items entered into the licensees CAP. This review was accomplished through
      inspection of the stations daily condition report packages.
                                              45                                  Enclosure
    These daily reviews were performed by procedure as part of the inspectors daily plant
    status monitoring activities and, as such, did not constitute any separate inspection
    samples.
  b. Findings
    No findings were identified.
.3  Selected Issue Follow-Up Inspection: Licensee Issue Report on Auxiliary Feedwater
    System Crosstie Modification
  a. Inspection Scope
    The inspectors performed a review of the item below that was identified by an NRC
    inspector at a different but similar facility:
    *    Auxiliary Feedwater System Modification.
    This review constituted one in-depth problem identification and resolution sample as
    defined in IP 71152-05.
  b. Findings
    No findings were identified.
.4  Annual Sample: Review of Operator Workarounds
  a. Inspection Scope
    The inspectors evaluated the licensees implementation of their process used to identify,
    document, track, and resolve operational challenges. Inspection activities included, but
    were not limited to, a review of the cumulative effects of the operator workarounds
    (OWAs) on system availability and the potential for improper operation of the system, for
    potential impacts on multiple systems, and on the ability of operators to respond to plant
    transients or accidents.
    The inspectors performed a review of the cumulative effects of OWAs. The documents
    listed in the Attachment were reviewed to accomplish the objectives of the inspection
    procedure. The inspectors reviewed both current and historical operational challenge
    records to determine whether the licensee was identifying operator challenges at an
    appropriate threshold, had entered them into their CAP, and proposed or implemented
    appropriate and timely corrective actions which addressed each issue. Reviews were
    conducted to determine if any operator challenge could increase the possibility of an
    Initiating Event, if the challenge was contrary to training, required a change from
    long-standing operational practices, or created the potential for inappropriate
    compensatory actions. Additionally, all temporary modifications were reviewed to
    identify any potential effect on the functionality of Mitigating Systems, impaired access to
    equipment, or required equipment uses for which the equipment was not designed.
    Daily plant and equipment status logs, degraded instrument logs, and operator aids or
    tools being used to compensate for material deficiencies were also assessed to identify
    any potential sources of unidentified operator workarounds.
                                            46                                  Enclosure
      This review constituted one operator workaround annual inspection sample as defined in
      IP 71152-05.
  b. Findings
      No findings were identified.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion (71153)
.1  (Closed) Licensee Event Report 05000455/2011-001, Revision 0 and Revision 1, Unit 2
      Emergency Diesel Generator Inoperable for Longer Than Allowed by Technical
      Specifications Due to Inadequate Work Instructions
      The Licensee Event Report (LER) involved a Unit 2 DG that was unknowingly inoperable
      for approximately 6 months due to loose bolting on the upper lubricating oil cooler.
      During a routine surveillance on November 17, 2010, a significant oil leak was identified
      by the equipment operator. The DG was shut down before damage could occur. The
      licensee determined that a bolted flanged connection was misaligned during
      reinstallation following maintenance in January of 2010.
      NRC Follow-Up inspection 05000455/2011011 determined that the issue was an
      apparent violation and a White Finding (EA-11-014). The IR was issued February 11,
      2011. On October 4, 2011, an NRC IP 95001 Supplemental IR was issued documenting
      the closure of finding 05000455/2011011-01. As the enforcement actions have been
      issued, and the Supplemental Inspection has been completed with no significant issues
      identified, these LERs are closed.
.2  (Closed) Licensee Event Report 05000455/2011-002, Revision 0, Containment
      Pressure Not Within Limits Longer than Allowed By Technical Specifications Due to
      Personnel Error
      The LER involved a licensee-identified mistaken plugging of a pressure sensor inside of
      containment during the previous refueling outage. The plugged was placed during a
      routine surveillance on September 28, 2011 and on October 13, 2011, licensee
      personnel determined that while the instrument indicated that Unit 2 containment
      pressure was within limits, that, in fact containment pressure was above the TS limit. A
      containment entry was made, the plug was removed, containment pressure was reduced
      and the peak pressure was determined to be approximately 1.91 pounds per square inch
      gauge (psig). The TS allowed value was 1.0 psig and the amount of time that the
      pressure could be above the limit was 1 hour with the plant required to be shut down
      within the following 42 hours. By the time the situation was identified, understood, and
      corrected a total time of 95 hours and 48 minutes had elapsed.
      The licensee determined and the inspectors verified that the licensees safety margin
      between peak containment pressure and the initial maximum allowed pressure was
      10 psig. The technicians error and the delay in correcting the error resulted in 0.91 psig
      of the 10 psig margin being used. There was a minor adverse safety consequence due
      to the licensee personnels error.
      The technicians error identified by the licensee resulted in a minor failure to comply with
      TS 3.6.4, Containment Pressure. This LER is closed.
                                              47                                Enclosure
4OA6 Management Meetings
.1  Exit Meeting Summary
      On January 12, 2012, the inspectors presented the inspection results to Mr. B. Youman,
      and other members of the licensee staff. The licensee acknowledged the issues
      presented. The inspectors confirmed that none of the potential report input discussed
      was considered proprietary.
.2  Interim Exit Meetings
      Interim exits were conducted for:
    *        The results of an Operator Licensing inspection with the Lead Operations Training
              staff instructor, Mr. M. McCue, via telephone on December 8, 2011.
    *        The results of an annual review of Emergency Action Level and Emergency Plan
              changes with the Emergency Preparedness Coordinator, Mr. R. Kartheiser, via
              telephone on December 7, 2011.
    *        The results of Occupational and Public Radiation Safety programs inspections
              with the Site Vice President, Mr. T. Tulon, on November 10, 2011 and with the
              Acting Plant Manager, E. Hernandez, on December 28, 2011.
      The licensee acknowledged the issues presented. The inspectors confirmed that none
      of the potential report input discussed was considered proprietary. Proprietary material
      received during the inspection was returned to the licensee.
4OA7 Licensee-Identified Violations
      The following violation of very low safety significance was identified by the licensee. The
      violation met the criteria of Section VI of the NRC Enforcement Policy for being
      dispositioned as a Non-Cited Violation.
  .1  Effluent Monitors Alarms Setpoints Incorrectly Established
      Technical Specification 5.5.1 states that the ODCM shall contain the methodology and
      parameters used in the calculation of offsite doses resulting from radioactive gaseous
      and liquid effluents, and in the calculation of gaseous and liquid monitoring alarm and
      trip setpoints.
      Contrary to the above, on August 26, 2010, the licensee identified a potential for
      non-conservative alarm setpoints for effluent monitors. Subsequently, the licensee
      calculated new setpoints for these monitors using the methodology prescribed in the
      ODCM and determined that the previous alarm setpoints were incorrectly established
      and were non-conservative (too high). The inspectors determined that this finding was
      of more than minor significance because it was similar to Example 6.c in IMC 0612,
      Appendix E, Example of Minor Issues. Specifically, the effluent monitors with its alarm
      set points would have failed to perform its intended function (i.e., trip or isolation
      function) to prevent an instantaneous effluent release in excess of the applicable TS
      instantaneous dose rate limits for gases. In accordance with IMC 0609, Appendix D,
                                            48                                    Enclosure
Public Radiation Safety, the inspectors determined the violation to be of very low safety
significance, (Green) because the dose impact to a member of the public from the
radiological release was less than the dose values in Appendix I to 10 CFR Part 50 and
10 CFR 20.1301(e). This violation of TS 5.5.1 is being treated as a NCV consistent with
Section 2.3.2 of the NRC Enforcement Policy. The licensee entered this issue into their
CAP as IR 1106461.
ATTACHMENT: SUPPLEMENTAL INFORMATION
                                      49                                Enclosure
                              SUPPLEMENTAL INFORMATION
                                  KEY POINTS OF CONTACT
Licensee
T. Tulon, Site Vice President
B. Youman, Plant Manager
D. Coltman, Operations Manager
J. Feimster, Design Engineering Manager
D. Damptz, Acting Maintenance Director
S. Swanson, Nuclear Oversight Manager
R. Gayheart, Training Director
B. Barton, Radiation Protection Manager
K. Anderson, Acting Radiation Protection Manager
A. Creamean, Chemistry Manager
D. Gudger, Regulatory Assurance Manager
R. Cameron, Licensed Operator Requalification Lead
Nuclear Regulatory Commission
E. Duncan, Chief, Branch 3, Division of Reactor Projects
                    LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
05000454/2011005-001        NCV    Failure to Identify Voided Sections of AF Piping
                                    (Section 1R15)
05000455/2011005-001        NCV    Failure to Identify Voided Sections of AF Piping
                                    (Section 1R15)
05000454/2011005-002          NCV    High Energy Line Break Operability Evaluation
                                    (Section 1R15)
05000455/2011005-002          NCV    High Energy Line Break Operability Evaluation
                                    (Section 1R15)
05000454/2011005-003          URI    Use of TLDs May Not be Consistent with the Methods
                                    Used by the NVLAP Accreditation Process (Section 2RS4)
05000455/2011005-003          URI    Use of TLDs may not be consistent with the methods used
                                    by the NVLAP accreditation process (Section 2RS4)
05000454/2011005-004          NCV    Failure to Identify Hazardous Materials on Transportation
                                    Manifest (Section 3RS8)
                                            1                                Attachment
Closed
05000455/2011011-00 LER Unit 2 Emergency Diesel Generator Inoperable for
                        Longer Than Allowed by Technical Specifications
                        Due to Inadequate Work Instructions, Revision 0
05000455/2011011-01 LER Unit 2 Emergency Diesel Generator Inoperable for
                        Longer Than Allowed by Technical Specifications
                        Due to Inadequate Work Instructions, Revision
                        2                              Attachment
                                  LIST OF DOCUMENTS REVIEWED
The following is a list of documents reviewed during the inspection. Inclusion on this list does
not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that
selected sections of portions of the documents were evaluated as part of the overall inspection
effort. Inclusion of a document on this list does not imply NRC acceptance of the document or
any part of it, unless this is stated in the body of the inspection report.
Section 1R01: Adverse Weather Protection (Quarterly)
- IR 1067880; Byron 2010/2011 Winter Readiness Critique, March 30, 2011
- IR 1186291; 2010/2011 Winter Readiness Critique, March 11, 2011
- IR 1193076; Action Tracking Process Versus Work Control Process, December 2, 2010
- IR 1238947; SX Chemical Feed Lines Need Insulating, July 12, 2011
- IR 1262839; Winter Readiness Work Rescheduled, September 14, 2011
- IR 1265348; Unable to Resolve Parts Required Issue, September 14, 2011
- IR 1265934; Winter Readiness Challenge - No CST Heaters Available, September 21, 2011
- IR 1280434; Switchyard Winter Readiness PM, October 24, 2011
- IR 1280750; Freeze Protection - CWPH Louvers LV48, 142 Stuck Open, October 24, 2011
- IR 1280755; Freeze Protection - Electric Heater 0VV37C Fan Motor, October 24, 2011
- IR 1280755; Freeze Protection: Electric Heater 0VV37C Fan Motor, October 24, 2011
- IR 1280757; 0VH09Y - Damper Stuck Open, October 24, 2011
- IR 1281870; Roof Access Hatch Will Not Remain Closed, October 26, 2011
- IR 1285676; Winter Readiness Walkdown, November 2, 2011
- IR 1286684; 0VT17J LV-82 Has a Louver Broke Preventing Set From Closing,
  November 5, 2011
- IR 1286686; 0VT11J LV-8 Has a Set of Louvers Not Fully closed, November 5, 2011
- IR 1286687; 0VT16J LV-80 Has a Broken Louver Preventing Set From Closing,
  November 5, 2011
- IR 1286688; 0VT13J LV-17 Has 2 Sets of Louvers Not Fully Closed, November 5, 2011
- IR 1286689; 0VT18J LV-83 Has Broken Louvers Preventing Set From Closing,
  November 5, 2011
- IR 1286693; 0VT20J LV-86 Sets of Louvers Not Fully Closed, November 5, 2011
- IR 1286904; 0VT07J LV-4 Has Broken Louvers, November 5, 2011
- IR 1286907; 0VT08J LV-5 Has 2 Sets of Louvers Not Fully Closed, November 5, 2011
- IR 1286908; 0VT10J LV-7 Has One Broken Louver, November 5, 2011
- IR 1286910; 0VT14J LV-18 Has a Set of Louvers Not Fully Closed, November 5, 2011
- IR 1286912; 0VT12J LV-9 Has Broken Louvers and Sets Not Fully Closed, November 5, 2011
- IR 1289988; Freeze Protection Concern, November 13, 2011
- IR 1293508; Winter Readiness System Review Work Removed From 2011,
  November 15, 2011
- IR 1297625; 0BOSR XFT-A1, SH Area Heaters Testing Discrepancies, December 3, 2011
- Unit 2 Standing Order; Station Heat Coil Degradation in Unit 2 VA Plenum, Log #11-053
- 0BOSR XFT-A1; Freezing Temperature Equipment Protection SH and Department Support
  Requirements, Revision 13
- 0BOSR XFT-A3; Freezing Temperature Equipment Protection Plant Ventilation Systems,
  Revision 8
- 0BOSR XFT-A4; Freezing Temperature Equipment Protection Area Buildings Ventilation
  Systems and Tanks, Revision 7
- 0BOSR XFT-A5; Freezing Temperature Equipment Protection Non-Protected Area Buildings
  Ventilation Systems, Revision 6
                                                3                              Attachment
- BOP XFT-1; Cold Weather Operations, Revision 2
- IR 1298335; 0BOSR XFT-A3 Freezing Temperature Protection Discrepancies,
  December 05, 2011
Section 1R04: Equipment Alignment (Quarterly)
- Drawing M-62; Diagram of Residual Heat Removal, Revision BD
- BAP 300-1A1; At The Controls Area, Revision 52
- BOP RH-E2A; Unit 2 Residual Heat Removal System Train A Electrical Lineup, Revision 4
- BOP RH-M2A; Unit 2 Residual Heat Removal System Train A Valve Lineup, Revision 10
- IR 0332862; 1B AF Pump Air Box Leakage, May 07, 2005
- IR 1289049; Fireproofing on Column Outside 1B AF Pump Room Degraded,
  November 10, 2011
- IR 1299293; AF005 Flow Control Valve Trim Clearance Low Margin Issue,
  November 21, 2011
  IR 1304078; Fire Drill Observation - SCBA Voice Amplifiers Not Working, December 17, 2011
- EC 355468; Evaluation of Diesel Driven Auxiliary Feedwater Air Box Gaps, Revision 0
- SPEC. L-2722 Proposed Seal for 2AB-1086 Unit 2; Sheet Numbers 1A, 1, 2, and 3, Revision 1
Section 1R04: Complete System Walkdown (Semi-Annual)
- BOP AF-M2B; Auxiliary Feedwater Train B Valve Lineup, Revision 4
Section 1R05: Fire Protection (Quarterly)
- IR 1076490; Fire Damper 2VE04Y Access Door Hinge Tack Welds Broken, May 28, 2011
- IR 1075765; Electro-Thermo-Link Separated, June 1, 2010
- IR 1077737; Need CO2 OSS for 2 ICSRs on the T.S. Fire Tamper Surveillance, June 7, 2010
- IR 1072592; 2VD23YA Flexible Conduit Support Clip not Holding Conduit, May 24, 2010
- IR 1072640; Debris in Tray Below Damper 2VD63Y, May 24, 2010
- IR 1073509; Flexible Conduit Loose at Upper, South ETL on Fire Damper, May 26, 2010
- IR 1081618; Difficult to Access Damper, 1VE06Y for Surveillance/Repair, June 17, 2010
- IR 1289049; Fireproofing on Column Outside 1B AF Pump Room Degraded,
  November 10, 2011
- IR 1250346; Fire Brigade Leader Training Issue, August 12, 2011
- Fire Drill Scenario No. 11-04; Unit 1 Auxiliary Boiler Room Fire, September 16, 2011
- Pre-Fire Plan; Fire Area/Zone - FZ 8.3-1 Southeast, Revision 1
- EC 350613; Evaluation of Fire Damper S-Hook Orientation Impact on Dampers 2VD24&B,
  VC191Y, and 0VC193Y, Revision 0
- WO 1197473; Tech Spec Fire Damper 18-Month Visual Inspection, December 3, 2009
- WO 1028736; Tech Spec Fire Damper 18-Month Visual Inspection, August 4, 2008
- WO 1124519; Tech Spec Fire Damper 18-Month Visual Inspection, April 14, 2008
- WO 0848826; Tech Spec Fire Damper 18-Month Visual Inspection, December 15, 2006
- 0BMSR 3.10.g.7; TRM Fire Damper 18-Month Visual Inspection, Revision 13
- IR 1304076; Fire Drill Observation - Personnel Walking Through SIM Smoke,
  December 17, 2011
- RM-AA-101; Records Management Program, Revision 9
- OP-AA-201-003; Fire Drill Performance, Revision 12
                                              4                              Attachment
Corrective Action Documents As a Result of NRC Inspection
IR 1291986; NRC Identified Fire Damper S-Hook Orientation Issue, November 17, 2011
IR 1304063; NRC Identified Issues with S-Hooks Not Resolved, December 17, 2011
Section 1R12: Maintenance Effectiveness (Quarterly)
- IR 1058790; Bad Fuse Found in 2RD06J Panel, April 20, 2011
- IR 1061760; MG Set Motor Smoked on Attempted PM Start, April 26, 2011
- IR 1062164; Motor Cutoff Switch Replaced for 2RD 05E-1B, April 27, 2011
- IR 1065922; Unit 2 Rods Will Not Manually Withdraw, May 5, 2010
- IR 1066455; Unit 2 RD07J Cabinet Capacitor Found Broken, May 6, 2011
- IR 1066490; 2A RD MG Set 1 OVT Timer Failed, May 6, 2011
- IR 1067031; Vibrations Levels on 2B Rod Drive MG Set Remain Unchanged, May 8, 2011
- IR 1290831; 1A RD MG Set Increased Vibrations, November 15, 2011
- BOP RD-5; Control Rod Drive MG Set Up and Paralleling to Operating Control Rod Drive MG
  Set, Revision 10
Section 1R13: Maintenance Risk Assessments and Emergent Work Control (Quarterly)
- ER-AA-600-1042; On-Line Risk Management, Revision 7
- ER-AA-600-1021; Risk Management Application Methodologies, Revision 4
- PC-AA-1014; Risk Management, Revision 2
- 0BOA ENV-1; Adverse Weather Conditions Unit 0, Rev. 108
- 1BOA ENV-1; Adverse Weather Conditions Unit 0, Rev. 102
- 0BOA ENV-2; Rock River Abnormal Water Level Unit 0, Rev. 100
- IR 1285254; Rock River Level Low, November 2, 2011
Section 1R15: Operability Evaluations (Quarterly)
- IR 240597; Unplanned LOCAR Entry for 2A Emergency Diesel Generator Due to 2VD024YB
  Damper
- IR 240972; Fire Damper S Hook Installed Improperly, August 2, 2004
- IR 240985; Need Work Request for Fire Damper Inspections, August 2, 2004
- IR 248940; Fire Damper Issues Identified by NRC, August 31, 2004
- IR 249486; Fire Damper S Hook Issue Identified by NRC, September 2, 2004
- IR 297682; NRC Question About Fire Damper S-Hooks, February 4, 2005
- IR 757875; Fire Damper S-Hooks, April 1, 2008
- IR 1285361; Potential Multiple Starts of Diesel Driven AF Pump, November 2, 2011
- IR 1291986; NRC Identified Fire Damper S-Hook Orientation Issue, November 17, 2011
- IR 1292337; Piping Between 2AF006B and 2AF017B Found Not Full, November 18, 2011
- IR 1295958; AF Improvement Suggestion, November 18, 2011
- IR 1295958; AF Improvement Suggestion, November 18, 2011
- IR 1295488; EOC Review of Byron IP 1291986 Fire Damper S-Hooks, November 29, 2011
- Three Mile Island Corrective Action Program Number TI999-0943 linked to ETTS # 25169;
  One Section of Fire Damper AH-FD-22 Did Not Close During Test, October 1, 1999
- EC 350613; Evaluation of Fire Damper S-Hook Orientation Impact on Dampers 2VD24YB,
  VC191Y and OVC193Y, August 11, 2004
- EC 350550; Evaluation of Fire Damper S-Hook Orientation Impact, August 31, 2004
- WO 1197473 01; Technical Specification Fire Damper 18 Month Visual Inspection,
  December 3, 2009
                                              5                            Attachment
- EC 383229; Fill Empty Pipe Between 1AF006A and 1AF017A, Close Drain Valve 1AF018A,
  and Throttle Open Vent Valve 1AF030A, Revision 0
- EC 383308; OP EVAL 11-003, Small Voids in 2A and 2B SX to AF Suction Piping, Revision 0
- EC 386578; OP Evaluation 11-009 Multiple Starts of Diesel AF Pump, November 8, 2011
- WO 1124519 01; Technical Specification Fire Damper 18 Month Visual Inspection,
  April 14, 2008
- WO 848828 01; Technical Specification Fire Damper 18 Month Visual Inspection,
  December 15, 2006
- BOP AF-3, Filling and Venting the Auxiliary Feedwater System, Revision 4
- M-1FW01147X; Drawing, Byron Unit 1 Support M-1FW01147X, Rev. D
- M-1SI06010X; Drawing, Byron Unit 1 M-1SI06010X Sub. E
- 13.1.29; Calculation for Mechanical Component Support M-1SI06010X, Rev. D
- 13.1.29; Calculation for Mechanical Component Support M-1SI06010X, Rev. E
- 13.1.29; Calculation for Mechanical Component Support M-1SI06025V, Rev. F
- 13.1.29-BYR97-359; 1SI06010X, 1SI06012X, 1SI06031X, 1SI06075X, 1SI06105X, and
  1SI06155X. Evaluate Subsystem 1SI06 Supports for Additional Loads, Rev. 5
- 14.1.18-1FW01147; Calculation for Mechanical Component Support Number M-1FW01147X,
  Rev. 0
- IR 1272187; Issues Applicable to Byron from Braidwood Mod/50.59 Inspection,
  October 4, 2011
- BRW-97-0827-M; Piping Evaluation for Lead Shielding on Subsystem 2SI06, Rev. 0
- RH-2; Large Bore Isometric, Residual Heat Removal System, Rev. 22
- IR 1276280; UFSAR Section 3.6 and Piping Design Specifications are Inconsistent,
  October 13, 2011
- IR 1276069; 1/2FW01 Piping Calculation Revisions Do Not Meet UFSAR Requirements,
  October 13, 2011
- IR 1272834; Incorrect Coding of Support Skew on 1FW01 Piping, October 5, 2011
- EMD-064195; Calculation, Addendum E to Piping Stress Report for Subsystem 1SI06, Rev. 5
- IR 1262559; BOP ID: Small Shift Trend in Major Plant Parameters, September 13, 2011
- IR 1265515; U1 RX Power Lowered Below 99.5% for LEFM Troubleshooting,
  September 16, 2011
- IR 1253439; LEFM Computer Point Is Off Normal Per 1BOSR CX-M1, August 19, 2011
- IR 1263929; LEFM Alarms in IR 1241271 and Card Analysis- OEM Review Results,
  September 16, 2011
- IR 1241271; LEFM Trouble Alarm - Ramp Back, July 19, 2011
- IR 1241629; LEFM Trouble Alarm Causing Unit 1 Ramp Back Again, July 19, 2011
- IR 1277627; NRC Questions on HELB - Presence of Openings, October 17, 2011
- IR 1279759; Added Scope to Turbine Building HELB Effort, October 21, 2011
- IR 1244251; HELB Discussion with the NRC Residents, July 26, 2011
- IR 1240295; Two New Line Break Locations Identified During HELB Analysis, July 15, 2011
- IR 1238611; Inoperability of ESF Components Due To HELB, July 11, 2011
- IR 1237133; Non-Conservatism in Turbine Building HELB Analysis, July 6, 2011
- IR 1184258; Non-Conservatism in Turbine Building HELB Analysis, March 7, 2011
- IR 1276895; NRC Question - Effect of Turbine Building HELB on Reactor Trip Breakers,
  October 14, 2011
Section 1R19: Post Maintenance Testing (Quarterly)
- IR 1272802; 2B CS Pump Did Not Auto Start During 2B DG Sequence Test, October 5, 2011
- WO 1476986 02; 2B CS Pump Did Not Auto Start During 2B DG Sequence Test,
  October 5, 2011
                                            6                            Attachment
- WO 1476986 03; 2B CS Pump Did Not Auto Start During 2B DG Sequence Test,
  October 5, 2011
- ER-AA-1200; Critical Component Failure Clock, Revision 7
- WO 1324847; 2AF014E IST Disassembly and Inspection, October 5, 2011
- WO 1324407; 2AF014G IST Disassembly and Inspection, October 5, 2011
- WO 1365478; 2AF014H IST Disassembly and Inspection, October 5, 2011
- 2BOSR 7.5.7-2; Unit 2 Train B Auxiliary Feedwater Flow Path Operability Surveillance
  Following Shutdown, Rev. 6
- IR 1272927; 2B AF Static Pressure Gauge Indication Failed Low, October 5, 2011
- 2BOSR 0.5-2.RH.4-1; Unit 2 ASME Surveillance Requirements for Residual Heat Removal
  Pump Miniflow Valve 2RH610, Revision 5
Section 1R20: Refueling and Other Outage Activities
- 2BGP 100-1; Plant Heatup, Revision 50
- 2BGP 100-2; Plant Startup, Revision 40
- 2BGP 100-3; Power Ascension, Revision 73
Section 1R22: Surveillance Testing (Quarterly)
- IR 128875; Error in RCS Leakrate Data in MCR Logs, November 10, 2011
- BOP AF-1; Diesel Driven Aux Feedwater Pump Alignment to Standby Condition, Revision 24
- BOP AF-7; Diesel Driven Auxiliary Feedwater Pump 1B Startup on Recirc, Revision 37
- BOP AF-7T1; Diesel Driven Auxiliary Feedwater Pump Operating Log, Revision 21
- BOP AF-8; Diesel Driven Auxiliary Feedwater Pump 1B Shutdown, Revision 22
- WO 1459476 01; 1AF01PB Group B IST Requirements for Diesel Driven AF Pump,
  October 28, 2011
- 1BOSR 7.5.4-2; Unit 1 Diesel Driven Auxiliary Feedwater Pump Monthly Surveillance,
  Revision 14
- 2BOSR 8.1.11-2; 2B Diesel Generator Sequencer Test 18 Month, Revision 11
- WO 1337989 01; 2B Diesel Generator Sequencer Test, October 5, 2011
- IR 1281160; 1SI8958B Failed Acceptance Criteria During 1B RH PP IST, October 25, 2011
- IR 1298289; Unit 2 RCS Leakrate Surveillance Needs Improvements, December 05, 2011
- 0BMSR FP-5; Fire Hydrant Yard Loop Annual Flush, Revision 8
- WO 1454082; 1RH01PB Group A IST Requirements for Residual Heat Removal Pump,
  October 25, 2011
- IR 1281160; 1SI8958B Failed Acceptance Criteria During 1B RH PP IST, October 25, 2011
Corrective Action Documents As a Result of NRC Inspection
- IR 1304054; Surveillance Improvements Needed, December 17, 2011
2RS1: Radiological Hazard Assessment and Exposure Controls (71124.01)
- AR 1214604; NOS ID B1R17 RP Outage Adverse Trend; 5/11/2011
- AR 1243013; RP Response to Fire Alarm Did Not Meet Expectations; 7/22/2011
- AR 1248312; NOS ID Poor Contamination Boundary Controls in FHB; 8/5/2011
- BRP 5800-3; Area Radiation Monitoring System Alert/High Alarm Setpoints; Revision 25
- BRP 5820-14; Process Radiation Monitoring System Alert/High Alarm Setpoints; Revision 42
- RP-AA-460; Controls for High and Locked High Radiation Areas; Revision 20
- RP-AA-460-001; Controls for Very High Radiation Areas; Revision 2
                                            7                              Attachment
- RP-AA-460-003; Access to HRAs/LHRAs in Response to a Potential or Actual Emergency;
  Revision 1
- RP-AP-460; Access to Reactor In-Core Sump Area; Revision 2
2RS3: In-Plant Airborne Radioactivity Control and Mitigation (71124.03)
- Work Order 1094446 01; Non Accessible Charcoal Adsober Operability Test; 8/31/2009
- Work Order 1149597 01; Perform Recirc Charcoal Halide Test Control Room Ventilation
  System; 3/16/2010
2RS4: Occupational Dose Assessment (71124.04)
- National Voluntary Laboratory Accreditation Program; Selected Records; Various Dates
2RS5: Radiation Monitoring Instrumentation (71124.05)
- AR 1106461; Non-Conservative Liquid Discharge Alarm Setpoints; 8/26/2010
- AR 1107149; Additional Investigation Required for ODCM/LCO Implementation; 8/29/2010
- AR 1302586; Non-Conservative Setpoints Found for TRM Rad Monitors; 12/14/2011
- AR 1303888; Potential RETS Impact Due to Non-Conservative PRM Setpoints; 12/16/2011
- BRP 5800-3; Area Radiation Monitoring System Alert/High Alarm Setpoints; Revision 25
- BRP 5820-12; Response to Area and Process Radiation Monitor LCOARS or Out of Service
  Conditions; Revision 28
- BRP 5820-14; Process Radiation Monitoring System Alert/High Alarm Setpoints; Revision 42
- BYR-10-001; Calculation of Liquid Process Radiation Monitor Set Points; 8/30/2010
- RP-BR-951; Set Point Changes for Process Radiation Monitors; ODCM (Effluent) Monitors;
  Revision 0.
2RS6: Radioactive Gaseous and Liquid Effluent Treatment (71124.06)
- 2009 Byron Station Annual Radioactive Effluent Release Report; April 30, 2010
- 2010 Byron Station Annual Radioactive Effluent Release Report; April 29, 2011
- AR 00978684; Effluent Monitor Surveillance Not Performed Per Procedure; dated October 13,
  2009
- AR 00996917; Effluent Release Process - Potential Gaps; dated November 22, 2009
- AR 01106461; Non-Conservative Liquid Discharge Alarm Setpoints; dated August 26, 2010
- AR 01107146; Additional Investigation Required for ODCM/LCO Implementation; dated
  August 29, 2010
- AR 01108146; Treatment of Ar-41 in Gaseous Effluents; dated August 31, 2010
- AR 1247902; 1/2 RE-PR-028 Particulate Filters Could Not Be Located; 8/4/2011
- BCP-400-TWX01; Liquid Radwaste Release from Release Tank OWX01T; Revision 59
- CY-AA-120-400; Closed Cooling Water Chemistry; Revision 13
- CY-AA-120-420; Auxiliary Boiler Chemistry; Revision 10
- CY-AA-130-201; Radiochemistry Quality Control; Revision 1
- CY-AA-170-000; Radioactive Effluent and Environmental Monitoring Programs; Revision 5
- CY-BY-170-301; Offsite Dose Calculation Manual; Revision 6
- CY-BY-170-301; Offsite Dose Calculation Manual; Revision 7
- FASA 1013272; Radioactive Gaseous and Liquid Effluents (RETS); 9/17/2010
- FASA 831375; Radioactive Gaseous and Liquid Effluents (RETS); 3/31/2009
- Gaseous Discharge Permit Number 110411; dated October 13, 2011
- Gaseous Discharge Permit Number 110445; dated October 31, 2011
                                            8                              Attachment
- Liquid Discharge Permit Number 110437; dated October 25, 2011
- RP-BY-900-1PR29J; 1PR29J Process Radiation Monitor Radiological Air Sampling;
  Revision 2
- RP-BY-900-2PR29J; 2PR29J Process Radiation Monitor Radiological Air Sampling;
  Revision 2
- Work Order 1110220 01; Fuel Handling Building Exhaust Charcoal Adsorber Bank Operability
  Test; 12/21/2009
- Work Order 1236016 01; Perform Calibration of Rad Monitor 1PR28J; 1/18/2011
- Work Order 1249358 01; Perform Surveillance Test of 2PR28J; 4/26/2011
2RS7: Radiological Environmental Monitoring Program (71124.07)
- 2009 Byron Station Annual Radiological Environmental Operating Report; May 2010
- 2010 Byron Station Annual Radiological Environmental Operating Report; May 2011
- 2010 Land Use Census; dated August 30, 2010
- AR 00958298; ODCM Vent Stack Coordinates Inaccurate; dated August 27, 2009
- AR 01034880; REMP Milk Sample - Invalid Result; dated February 24, 2010
- AR 01090911; REMP Groundwater Sample Location No Longer Participating; dated July 15,
  2010
- AR 01122156; REMP Sample Results above Detection Limit; dated October 5, 2010
- AR 01129610; Check-In Self-Assessment on the Radiological Environmental Monitoring
  Program (REMP); Approved June 20, 2011
- AR 01223226; REMP Air Samples - Positive Detects for I-131; dated June 1, 2011
- Environmental, Inc. Sampling Manual, Revision 13
2RS8: Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,
and Transportation (71124.08)
- AR 1015646; Non-Conforming Waste Found in Radwaste Shipment; 1/12/2010
- AR 1067394; Non-Conforming Radioactive Waste in Shipment; 5/10/2010
- AR 1173307; RWS 10-013 Contained Unapproved Mixed Waste; 2/10/2011
- AR 1221229; RWS 11-006 Contained Un-Manifested Asbestos; 5/26/2011
- AR 1231158; RWS 11-001 Manifested for Material Not Present; 6/21/2011
- AR 1233858; NOS ID: Cause of IR Incorrect RW Shipping Paperwork Not Identified;
  6/28/2011
- AR 1250262; NOS ID: RP Failed to Address NOS Issues - Finding; 8/11/2011
- AR 1270337; Sea/Land Inventory Not Documented in Accordance with T&RM; 9/30/2011
- AR 1285148; QHPI Request for RP - RWS Manifest; 11/2/2011
- AR 1285591; NRC Identified: DAW Container Inspections Outside of Procedure Guidance;
  11/3/2011
- AR 928393; Non-Conforming Metal Shipped to Bear Creek Processing; 6/5/2009
- Course Code N-RPCTAR; DBIG RAM Shipping/Inspection; Revision 0
- FASA 9866572-03; Radioactive Solid Waste Processing and Radioactive Material Handling,
  Storage and Transportation; 4/26/2011
- Letter BYRON-2008-0123; Report of Changes, Tests, and Experiments; 12/12/2008
- Letter BYRON-2010-0147; Report of Changes, Tests, and Experiments; 12/13/2010
- Module/LP ID RPTI 8.05; Radioactive Material Shipments; Revision 18
- NOSA-BYR-10-04 (AR 969170); Chemistry, Radwaste, Effluent and Environmental Monitoring
  Audit Report; 6/2/2010
- NOSA-BYR-11-06 (AR 1130876); Radiation Protection; 8/18/2011
                                          9                              Attachment
- Performance Training and Evaluation; Task 509-004; Provide Radiological Protection
  Coverage During the Preparation of a Shipment of Radioactive Material; 11/5/2009
- Performance Training and Evaluation; Task 509-010; Perform Surveys on Radioactive
  Material Transport Vehicles; date not provided
- Performance Training and Evaluation; Task 509-013; Receipt Survey of Radioactive Material;
- Radiation Protection Technician/Continuing Training; DBIG: Waste Acceptance Guidelines;
  Revision 0
- RP-AA-100; Process Control Program for Radioactive Wastes; Revision 7
- RP-AA-600; Radioactive Material/Waste Shipments; Revision 12
- RP-AA-600-1001; Exclusive Use and Emergency Response Information; Revision 6
- RP-AA-600-1003; Radioactive Waste Shipments to Barnwell and Defense Consolidation
  Facility (DCF); Revision 7
- RP-AA-600-1004; Radioactive Waste Shipments to Energy Solutions Clive Utah Disposal Site
  Containerized Waste Facility; Revision 9
- RP-AA-600-1005; Radioactive Material and Non Disposal Site Waste Shipments; Revision 12
- RP-AA-601; Surveying Radioactive Material Shipments; Revision 13
- RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 01/20/2011
- RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 06/02/2011
- RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 10/03/2009
- RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 10/19/2010
- RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 2/17/2010
- RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 8/18/2010
- RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 9/16/2011
- RP-AA-605 Attachment 2; Waste Stream Results Review; DAW; 1/20/2011
- RP-AA-605 Attachment 2; Waste Stream Results Review; DAW; 3/30/2011
- RP-AA-605 Attachment 2; Waste Stream Results Review; DAW; 4/18/2010
- RP-AA-605 Attachment 2; Waste Stream Results Review; Primary Resin; 3/10/2010
- RP-AA-605 Attachment 2; Waste Stream Results Review; Secondary Radwaste Filter;
  4/24/2010
- RP-AA-605 Attachment 2; Waste Stream Results Review; Secondary Resin; 3/25/2010
- RP-AA-605; 10 CFR Part 61 Program; Revision 4
- Shipment RMS09-094; Rx Vessel Dosimetry; Type A Package; 11/18/2009
- Shipment RMS11-078; Dirty Laundry; Low Specific Activity (LSA-II); 4/27/2011
- Shipment RWS10-011; Dewatered Bead Resin; Low Specific Activity (LSA-II); 6/29/2010
- Shipment RWS10-012; DAW Trash; Low Specific Activity (LSA-II); 9/1/2010
- Shipment RWS10-013; DAW Trash and TR Pond Sludge; Low Specific Activity (LSA-II);
  9/1/2010
Section 4OA1: Performance Indicator Verification (71151)
- IR 1139610; Potential Non-Conservative Tech Specs for Component Cooling;
  November 12, 2010
- IR 1139728; CC System OLR Impact From IR 1139610; November 12, 2010
- IR 1141591; 2A DG Emergency Stopped Due to Oil Leak; November 17, 2010
- IR 1158910; RH System Issue Resulting in LER - Tracking; January 05, 2011
- IR 1128409; Threshold for SSFF Approaching White Region; June 14, 2011
- IR 1284054; Legacy Issues with Main Steam Tunnel Pressurization Calculation;
  October 31, 2011
- LS-AA-2080; NRC Safety System Functional Failure - July 2010 to July 2011, Revision 4
- EC 382262; Byron OpEval #10-006 - U-0 CC Pump Potential Non-Conservative Tech Spec
                                            10                            Attachment
- LER 454/2010-001; Technical Specifications Allowed Outage Time Extension Request for
  Component Cooling System Contained Inaccurate Design Information that Significantly
  Impacted the Technical Justification, November 12, 2010
- LER 454/2011-001; Potential Loss of Residual Heat Removal System Safety Function in Mode
  4 When Aligned for Shutdown Cooling Due to Potential for Flashing or Voiding of Coolant
  During a Shutdown Loss of Cooling Accident, January 5, 2011
- LER 455/2011-001; Unit 2 Emergency Diesel Generator Inoperable for Longer than Allowed
  by Technical Specifications Due to Inadequate Work, November 17, 2011
- NEI 99-02 Revision 6; Regulatory Assessment Performance Indicator Guideline, October 2009
- Reactor Oversight Program MSPI Basis Document Revision 3; December 2006
- Monthly Data Elements for NRC Reactor Coolant System (RCS) Specific Activity, October
  2010 - September 2011
- PWR High Pressure Safety Injection Function, October 2010 - September 2011
- Residual Heat Removal Function, October 2010 - September 2011
- PWR Auxiliary Feedwater/Emergency Feedwater Function, October 2010 - September 2011
- Cooling Water Support Function, October 2010 - September 2011
- IR 1154673; Unable to Perform Manual Stroke Surveillance of 1SX150A, December 20, 2010
- IR 1152376; Unit 2 CWS MSPI Exelon At-Risk, December 14, 2010
- IR 1263487; CWS2 (SX) MSPI Low Margin, September 15, 2011
- IR 1090691; Unit 1 CWS MSPI At-Risk, July 14, 2010
- Monthly Data Elements for NRC Unplanned Power Changes Per 7000 Critical Hours, June
  2010 - October 2011
- IR 1259684; Byron PI in Variance - P.8.1.2 Unplanned Power Changes, September 6, 2011
- IR 1116305; Runback of Byron Station U-1 Due to 1A FW PP Trip, September 22, 2010
Section 4OA2: Identification and Resolution of Problems (71152)
- IR 1271650; Difference Between Byron & Braidwood PPC Point Calcs Y2021 & Y2022
- IR 1282689; Pin Hole Leak in Area 7 on 2RY8028 P-44
- IR 1289655; IR Indicates DG Fire Pump Started in Over Ride for Test CCP,
  November 04, 2011
- 2BwOSR 3.8.1.14-2; 2B DG 24 Hour Endurance Run, Revision 5
- WO 1323726; 2B DG 24 Hour Endurance Run 18 Month, September 13, 2011
- Analysis BYR11-036; Turbine Building HELB and Room Heat Up Analyses for MUR PU,
  Revision 0
- EC 383599; Op Eval 11-005, Turbine Building HELB Analysis Input Errors, Revision 1
- OWA Board Meeting Minutes; Year 2010 Quarter 4, December 28, 2010
- OWA Board Meeting Minutes; Year 2011 Quarter 1, April 5, 2011
- OWA Board Meeting Minutes; Year 2011 Quarter 2, June 30, 2011
- OWA Board Meeting Minutes; Year 2011 Quarter 3, October 14, 2011
- OWA Related IRs; 4Q2010 - 3Q2011
- IR 806396; Both Units SD Systems Degraded for >5 Years, August 12, 2008
- IR 1007239; Review SJAE Strainer Plugging for OWA/OC, December 18, 2009
- IR 1106359; Common Cause - Recommend Venting SD During Stroke Time Surveillance,
  August 26, 2010
- IR 1118055; 2A Main Feed Pump Recirc Not Modulating Properly, September 26, 2010
- IR 1122751; Missed Fire Watches in the Past, October 06, 2010
- IR 1151298; Unit 1 Tower Overflow, December 12, 2010
- IR 1155725; Caustic Dilution Flow Only Reading 6 GPM, December 24, 2010
- IR 1158940; Multiple Failure of Employee Alarm System, January 1, 2011
- IR 1169182; MMD Support for 2B FW Pump Turning Gear Operation, January 31, 2011
                                            11                              Attachment
- IR 1172246; 0CW278A, Through Wall Crack on Valve Body, February 08, 2011
- IR 1172509; 0CW220 Flow Control Valve Not Repositioning Upon Demand,
  February 08, 2011
- IR 1194212; Operator Work Around, March 29, 2011
- IR 1194754; RSH CO2 TK Repair(s) Need to Be Expedited, March 30, 2011
- IR 1194754; Missed Closure of ATI, January 09, 2004
- IR 1211839; 2WG046 Drip Pan is Removed Consider Operator Challenge, May 4, 2011
- IR 1212344; Degradation of RSH CO2 Worsens, May 5, 2011
- IR 1216461; 2B CW PP Intake DP 9 Jumped to 2, May 16, 2011
Corrective Action Documents As a Result of NRC Inspection
- IR 1276895; NRC Question - Effect of TB HELB on Reactor Trip Breakers, October 14, 2011
- IR 1278980; NRC Question - Maintaining VCT Pressure High for Chemistry, October 18, 2011
Section 1EP4: Emergency Action Level and Emergency Plan Changes
- EP-AA-1002; Exelon Nuclear Radiological Emergency Plan Annex for Byron Station;
  Revisions 26, 27, and 28
- EP-AA-120-1001; 50.54(q) Program Evaluation and Effectiveness Reviews for Revisions 27
  and 28
- EP-AA-120-F-01; EP Document Approval Forms for Revisions 27 and 28
                                          12                            Attachment
                          LIST OF ACRONYMS USED
ADAMS  Agencywide Document Access Management System
AF    Auxiliary Feedwater
ALARA  As-Low-As-Is-Reasonably-Achievable
ANSI  American National Standards Institute
ASME  American Society of Mechanical Engineers
CAP    Corrective Action Program
CFR    Code of Federal Regulations
CLB    Current Licensing Basis
DAW    Dry Active Waste
DG    Emergency Diesel Generator
DOT    Department of Transportation
EAL    Emergency Action Level
ESF    Engineered Safety Feature
HELB  High Energy Line Break
HVAC  Heating, Ventilation, and Air Conditioning
IMC    Inspection Manual Chapter
IP    Inspection Procedure
IR    Inspection Report
IR    Issue Report
IST    Inservice Testing
LER    Licensee Event Report
LORT  Licensed Operator Requalification Training
MEER  Miscellaneous Electrical Equipment Room
MG    Motor Generator
NEI    Nuclear Energy Institute
OBE    Operating Basis Earthquake
ODCM  Offsite Dose Calculation Manual
OOS    Out of Service
OpEval Operability Evaluation
OSP    Outage Safety Plan
OWA    Operator Workaround
psig  pound per square inch gauge
MSPI  Mitigating Systems Performance Index
NCV    Non-Cited Violation
NRC    U.S. Nuclear Regulatory Commission
NVLAP  National Voluntary Laboratory Accreditation Program
PI    Performance Indicator
RCS    Reactor Coolant System
RFO    Refueling Outage
RHR    Residual Heat Removal
RWST  Refueling Water Storage Tank
SDP    Significance Determination Process
SH    Station Heating
SRP    Standard Review Plan
SSC    Structure, System, and Component
SX    Essential Service Water
TLD    Thermoluminescent Detector
TS    Technical Specification
                                      13                  Attachment
UFSAR Updated Final Safety Analysis Report
UL    Underwriters Laboratory
URI  Unresolved Item
VA    Auxiliary Building Ventilation
WO    Work Order
                                    14    Attachment
M. Pacilio                                                                            -2-
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its
enclosure will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of NRC's document system
(ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the
Public Electronic Reading Room).
                                                                          Sincerely,
                                                                          /RA/
                                                                          Eric R. Duncan, Chief
                                                                          Branch 3
                                                                          Division of Reactor Projects
Docket Nos. 50-454; 50-455
License Nos. NPF-37; NPF-66
Enclosure:                Inspection Report No. 05000454/2011005 and 05000455/2011005
                            w/Attachment: Supplemental Information
cc w/encl:                Distribution via ListServ
DOCUMENT NAME: G:\DRPIII\BYRO\Byron 2011 005.docx
    Publicly Available                          Non-Publicly Available                    Sensitive                Non-Sensitive
To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy
OFFICE              RIII
NAME                EDuncan:dtp
DATE                02/07/12
                                                          OFFICIAL RECORD COPY
Letter to M. Pacilio from E. Duncan dated February 7, 2012.
SUBJECT:      BYRON STATION, UNITS 1 AND 2, NRC INTEGRATED INSPECTION
              REPORT 05000454/2011005; 05000455/2011005
DISTRIBUTION:
Breeda Reilly
RidsNrrDorlLpl3-2 Resource
RidsNrrPMByron Resource
RidsNrrDirsIrib Resource
Cynthia Pederson
Jennifer Uhle
Steven Orth
Jared Heck
Allan Barker
Carole Ariano
Linda Linn
DRPIII
DRSIII
Patricia Buckley
Tammy Tomczak
ROPreports.Resource@nrc.gov
}}
}}

Latest revision as of 08:44, 12 November 2019

IR 05000454-11-005, IR 05000455-11-005; 10/01/2011 - 12/31/2011; Byron Station, Units 1 & 2; Operability Evaluations and Functional Assessments; Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportati
ML12038A072
Person / Time
Site: Byron  Constellation icon.png
Issue date: 02/07/2012
From: Eric Duncan
Region 3 Branch 3
To: Pacilio M
Exelon Generation Co, Exelon Nuclear
References
IR-11-005
Download: ML12038A072 (69)
v • d • e


See also: IR 05000454/2011005

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE ROAD, SUITE 210

LISLE, IL 60532-4352

February 7, 2012

Mr. Michael J. Pacilio

Senior Vice President, Exelon Generation Company, LLC

President and Chief Nuclear Office (CNO), Exelon Nuclear

4300 Warrenville Road

Warrenville, IL 60555

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

REPORT 05000454/2011005; 05000455/2011005

Dear Mr. Pacilio:

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

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

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

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

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

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

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

personnel.

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

inspection.

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

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

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

consistent with Section 2.3.2 of the NRC Enforcement Policy.

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

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

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

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

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

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

Station.

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

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

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

the Byron Station.

M. Pacilio -2-

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

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

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

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

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

Sincerely,

/RA/

Eric R. Duncan, Chief

Branch 3

Division of Reactor Projects

Docket Nos. 50-454; 50-455

License Nos. NPF-37; NPF-66

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

w/Attachment: Supplemental Information

cc w/encl: Distribution via ListServ

U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket Nos: 50-454; 50-455

License Nos: NPF-37; NPF-66

Report Nos: 05000454/2011005 and 05000455/2011005

Licensee: Exelon Generation Company, LLC

Facility: Byron Station, Units 1 and 2

Location: Byron, IL

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

Inspectors: B. Bartlett, Senior Resident Inspector

J. Robbins, Resident Inspector

R. Ng, Project Engineer

J. Dalzell-Bishop, DRS Emergency Response Specialist

J. Cassidy, Senior Health Physicist

R. Jickling, Senior Emergency Preparedness Inspector

B. Palagi, Senior Operations Engineer

J. Nance, Reactor Engineer

J. Benjamin, Braidwood Senior Resident Inspector

C. Thompson, Resident Inspector, Illinois Emergency

Management Agency

Approved by: E. Duncan, Chief

Branch 3

Division of Reactor Projects

Enclosure

TABLE OF CONTENTS

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Enclosure

SUMMARY OF FINDINGS

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

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

Waste Processing and Radioactive Material Handling, Storage, and Transportation

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

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

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

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

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

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

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

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

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

Revision 4, dated December 2006.

A. NRC-Identified and Self-Revealed Findings

Cornerstone: Mitigating Systems

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

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

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

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

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

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

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

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

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

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

and the isolation of the Unit 2 AF drain valve.

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

Design Control attribute of the Mitigating Systems Cornerstone and adversely affected

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

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

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

SDP in accordance with IMC 0609, Significance Determination Process,

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

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

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

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

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

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

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

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

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

1 Enclosure

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

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

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

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

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

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

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

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

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

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

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

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

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

dampers.

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

Design Control attribute of the Mitigating Systems cornerstone and adversely affected

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

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

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

SDP in accordance with IMC 0609, Significance Determination Process,

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

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

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

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

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

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

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

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

(Section 1R15)

Cornerstone: Public Radiation Safety

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

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

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

material with transport manifests that did not document all applicable hazardous

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

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

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

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

represented the hazards contained in the shipping packages.

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

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

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

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

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

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

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

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

2 Enclosure

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

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

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

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

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

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

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

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

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

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

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

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

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

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

B. Licensee-Identified Violations

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

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

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

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

3 Enclosure

REPORT DETAILS

Summary of Plant Status

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

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

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

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

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

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

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

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

period.

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity and

Emergency Preparedness

1R01 Adverse Weather Protection (71111.01)

.1 Winter Seasonal Readiness Preparations

a. Inspection Scope

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

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

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

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

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

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

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

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

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

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

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

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

licensee was identifying adverse weather issues at an appropriate threshold and

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

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

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

significance or susceptibility to cold weather issues:

  • Station Heating System (SH);
  • Auxiliary Building Heating, Ventilation, and Air-Conditioning (HVAC) [VA]; and
  • Refueling Water Storage Tanks (RWSTs).

This inspection constituted one winter seasonal readiness preparation sample as

defined in Inspection Procedure (IP) 71111.01-05.

4 Enclosure

b. Findings

No findings were identified.

1R04 Equipment Alignment (71111.04)

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

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

systems:

Standby Line-Up;

Out-of-Service (OOS);

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

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

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

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

potentially increase risk. The inspectors reviewed applicable operating procedures,

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

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

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

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

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

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

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

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

identified and resolved equipment alignment problems that could cause initiating events

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

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

Attachment.

These activities constituted four partial system walkdown samples as defined in

IP 71111.04-05.

b. Findings

No findings were identified.

5 Enclosure

1R05 Fire Protection (71111.05)

.1 Routine Resident Inspector Tours (71111.05Q)

a. Inspection Scope

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

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

plant areas:

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

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

protection program that adequately controlled combustibles and ignition sources within

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

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

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

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

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

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

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

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

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

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

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

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

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

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

listed in the Attachment.

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

IP 71111.05-05.

b. Findings

No findings were identified.

.2 Annual Fire Protection Drill Observation (71111.05A)

a. Inspection Scope

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

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

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

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

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

appropriate corrective actions. Specific attributes evaluated were:

6 Enclosure

  • proper wearing of turnout gear and self-contained breathing apparatus;
  • proper use and layout of fire hoses;
  • employment of appropriate fire fighting techniques;
  • sufficient firefighting equipment brought to the scene;
  • effectiveness of fire brigade leader communications, command, and control;
  • search for victims and propagation of the fire into other plant areas;
  • smoke removal operations;
  • utilization of pre-planned strategies;
  • adherence to the pre-planned drill scenario; and
  • drill objectives.

Documents reviewed are listed in the Attachment to this report.

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

IP 71111.05-05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program (71111.11)

.1 Annual Operating Test Results (71111.11B)

a. Inspection Scope

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

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

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

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

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

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

This inspection constitutes one biennial and one annual licensed operator requalification

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

b. Findings

No findings were identified.

.2 Resident Inspector Quarterly Review (71111.11Q)

a. Inspection Scope

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

plants simulator during licensed operator requalification examinations to verify that

operator performance was adequate, evaluators were identifying and documenting crew

performance problems and training was being conducted in accordance with licensee

procedures. The inspectors evaluated the following areas:

7 Enclosure

  • licensed operator performance;
  • crews clarity and formality of communications;
  • ability to take timely actions in the conservative direction;
  • prioritization, interpretation, and verification of annunciator alarms;
  • correct use and implementation of abnormal and emergency procedures;
  • control board manipulations;
  • oversight and direction from supervisors; and
  • ability to identify and implement appropriate TS actions and emergency plan

actions and notifications.

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

expectations and successful critical task completion requirements. Documents reviewed

are listed in the Attachment.

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

and the main control room during this calendar quarter.

This inspection constituted one quarterly licensed operator requalification program

sample as defined in IP 71111.11.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness (71111.12)

.1 Routine Quarterly Evaluations (71111.12Q)

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following

risk-significant systems:

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

The inspectors reviewed events including those in which ineffective equipment

maintenance had resulted in valid or invalid automatic actuations of engineered

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

system performance or condition problems in terms of the following:

  • implementing appropriate work practices;
  • identifying and addressing common cause failures;
  • scoping of systems in accordance with 10 CFR 50.65(b) of the Maintenance Rule;
  • characterizing system reliability issues for performance;
  • charging unavailability for performance;
  • trending key parameters for condition monitoring;
  • verifying appropriate performance criteria for structures, systems, and

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

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

8 Enclosure

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

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

effectiveness issues were entered into the CAP with the appropriate significance

characterization. Documents reviewed are listed in the Attachment.

This inspection constituted two quarterly maintenance effectiveness sample as defined

in IP 71111.12-05.

b. Findings

No findings were identified.

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

.1 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

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

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

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

prior to removing equipment for work:

  • Shutdown Safety Associated with Cavity Drain;
  • Unit Common B Fire Pump OOS With SX as its Backup While One Train of SX

was OOS;

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

River Level; and

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

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

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

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

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

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

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

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

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

analysis assumptions were valid and applicable requirements were met.

These maintenance risk assessments and emergent work control activities constituted

four samples as defined in IP 71111.13-05.

b. Findings

No findings were identified.

9 Enclosure

1R15 Operability Evaluations (71111.15)

.1 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following issues:

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

Analysis/Calculations;

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

Analysis;

  • Unit 1 and Unit 2 Train B AF Pumps Due to Questions Regarding Multiple Starts;
  • Unit 1 Leading Edge Flow Monitor Due to Identified Anomaly in Trended Data;
  • Unit 1 and Unit 2 Train B AF Pumps Due to Potential Pipe Voids in Cross-Tie

Piping; and

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

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

Closure of Dampers

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

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

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

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

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

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

whether the components or systems were operable. Where compensatory measures

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

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

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

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

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

associated with operability evaluations. Documents reviewed are listed in the

Attachment.

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

b. Findings

.1) Failure to Identify Auxiliary Feedwater Pump Suction Voids

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

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

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

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

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

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

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

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

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

Suction Flow Paths).

10 Enclosure

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Unit 2 motor-driven AF pumps.

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

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

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

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

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

the inspectors observations. The licensee performed a system walkdown and

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

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

filled with water and verified full through ultrasonic testing.

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

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

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

management and questioned the licensees actions to address the inspectors previous

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

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

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

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

was again re-filled and verified full.

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

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

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

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

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

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

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

11 Enclosure

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

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

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

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

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

isolating the Unit 2 AF drain valve.

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

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

management was a performance deficiency.

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

Design Control attribute of the Mitigating Systems Cornerstone and adversely affected

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

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

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

Unit 2 diesel-driven AF pumps inoperable.

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

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

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

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

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

operability or functionality? This conclusion was reached after conservatively assuming

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

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

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

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

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

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

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

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

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

some conditions the unverified configuration discussed above could have rendered the

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

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

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

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

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

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

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

to support nuclear safety.

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

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

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

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

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

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

12 Enclosure

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

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

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

November 29, 2011 to be voided.

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

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

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

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

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

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

Identify Voided Sections of AF Piping)

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

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

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

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

Operability Determination Process standards after identifying a non-conservative

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

conclusion was reached after the licensee had completed and approved Operability

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

Standard, Revision 9.

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

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

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

included the following requirements:

13 Enclosure

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

Section 4.4.2

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

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

must be able to stand alone).

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

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

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

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

SSC to perform its specified safety functions.

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

of condition for all similarly affected SSCs.

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

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

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

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

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

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

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

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

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

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

criterion was readily available when the licensee examined the CLB requirements

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

licensee entered this issue into their CAP as IR 1244251.

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

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

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

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

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

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

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

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

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

piping and seismically analyzed and supported ANSI [American Nuclear

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

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

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

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

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

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

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

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

14 Enclosure

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

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

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

Diesel Generator; the station Emergency Diesel Generator Diesel Oil Storage

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

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

issue into their CAP as IR 1279759 and IR 12776277.

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

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

determined that the licensee had not adequately considered single failure.

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

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

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

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

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

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

as IR 1276895.

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

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

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

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

consistent with station design. The inspectors concluded that Operability

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

requirement in OP-AA-108-115.

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

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

inspectors.

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

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

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

misunderstanding of their CLB.

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

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

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

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

provide additional margin.

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

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

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

performance deficiency.

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

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

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

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

15 Enclosure

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

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

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

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

Design Control attribute of the Mitigating Systems Cornerstone and adversely affected

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

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

damage).

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

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

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

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

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

as having very low safety significance (Green).

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

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

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

with hazard barrier closure times.

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

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

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

circumstance and shall be accomplished in accordance with these instructions,

procedures of drawings.

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

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

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

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

The OpEval should contain sufficient detail for a knowledgeable individual to

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

be able to stand alone).

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

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

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

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

to perform its specified safety functions.

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

condition for all similarly affected SSCs.

Contrary to this requirement:

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

requirements or commitments to establish the performance requirements to be met

16 Enclosure

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

crack assumptions.

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

condition for all similarly affected SSCs.

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

individual to independently reach the same conclusions as the Preparer.

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

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

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

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

Station Standards)

1R19 Post-Maintenance Testing (71111.19)

.1 Post-Maintenance Testing

a. Inspection Scope

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

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

capability:

Disassembly and Inspection;

Inspection;

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

Following Circuit Modification;

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

Preventive Maintenance;

  • Unit 1 Train A Rod Drive Motor-Generator Following Bearing Replacement; and
  • Surveillance 2BOSR 0.5-2.RH.4-1 Following Maintenance on Valve 2RH610

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

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

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

for the maintenance performed; acceptance criteria were clear and demonstrated

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

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

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

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

documentation was properly evaluated. The inspectors evaluated the activities against

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

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

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

reviewed corrective action documents associated with post maintenance tests to

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

17 Enclosure

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

safety. Documents reviewed are listed in the Attachment.

This inspection constituted seven post maintenance testing samples as defined in

IP 71111.19-05.

a. Findings

No findings were identified.

1R20 Outage Activities (71111.20)

.1 Refueling Outage Activities

a. Inspection Scope

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

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

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

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

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

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

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

Attachment to this report.

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

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

applicable TS when taking equipment out of service.

  • Implementation of clearance activities and confirmation that tags were properly

hung and equipment appropriately configured to safely support the work or

testing.

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

instruments to provide accurate indication, accounting for instrument error.

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

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

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

to operate the spent fuel pool cooling system.

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

  • Controls over activities that could affect reactivity.
  • Licensee fatigue management, as required by 10 CFR 26, Subpart I.
  • Refueling activities, including fuel handling and sipping to detect fuel assembly

leakage.

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

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

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

reactor physics testing.

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

18 Enclosure

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

b. Findings

No findings were identified.

1R22 Surveillance Testing (71111.22)

.1 Surveillance Testing

a. Inspection Scope

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

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

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

and TS requirements:

  • Unit 2 Train B Diesel Generator Sequence Test;
  • Unit 1 Train B AF Pump ASME Surveillance;
  • Unit 1 Train B AF Valve Strokes for 1AF013E-H;

(Leak Detection); and

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

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

records to determine the following:

  • did preconditioning occur;
  • were the effects of the testing adequately addressed by control room personnel or

engineers prior to the commencement of the testing;

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

consistent with the system design basis;

  • plant equipment calibration was correct, accurate, and properly documented;
  • as left setpoints were within required ranges; and the calibration frequency were

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

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

prerequisites described in the test procedures were satisfied;

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

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

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

  • test data and results were accurate, complete, within limits, and valid;
  • test equipment was removed after testing;
  • where applicable for inservice testing (IST) activities, testing was performed in

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

reference values were consistent with the system design basis;

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

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

inoperable;

19 Enclosure

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

setting data were accurately incorporated in the test procedure;

  • where applicable, actual conditions encountering high resistance electrical

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

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

encountered during the performance of the surveillance or calibration test;

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

performance of its safety functions; and

  • all problems identified during the testing were appropriately documented and

dispositioned in the CAP.

Documents reviewed are listed in the Attachment.

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

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

b. Findings

No findings were identified.

2. REACTOR SAFETY

Cornerstone: Emergency Preparedness

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

.1 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

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

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

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

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

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

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

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

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

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

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

IP 71114.04-05.

b. Findings

No findings were identified.

20 Enclosure

1EP6 Drill Evaluation (71114.06)

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

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

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

notification, and protective action recommendation development activities. The

inspectors observed emergency response operations in the Simulator Control Room

and Technical Support Center to determine whether the event classification,

notifications, and protective action recommendations were performed in accordance

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

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

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

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

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

This emergency preparedness drill inspection constituted one sample as defined in

IP 71114.06-05.

b. Findings

No findings were identified.

3. RADIATION SAFETY

2RS1 Radiological Hazard Assessment and Exposure Controls (71124.01)

The inspection activities supplement those documented in Inspection

Report 05000454/2011002; 05000455/2011002 and constitute one

complete sample as defined in IP 71124.01-05.

.1 Inspection Planning (02.01)

a. Inspection Scope

The inspectors reviewed licensee performance indicators for the occupational exposure

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

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

The inspectors reviewed reports of operational occurrences related to occupational

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

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

b. Findings

No findings were identified.

21 Enclosure

.2 Instructions to Workers (02.03)

a. Inspection Scope

The inspectors reviewed selected occurrences where a workers electronic personal

dosimeter noticeably malfunctioned or alarmed. The inspectors evaluated whether

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

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

appropriate.

b. Findings

No findings were identified.

.3 Radiological Hazards Control and Work Coverage (02.05)

a. Inspection Scope

The inspectors examined the licensees physical and programmatic controls for highly

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

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

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

the pool.

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

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

performance indicator.

b. Findings

No findings were identified.

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

a. Inspection Scope

The inspectors discussed with the radiation protection manager the controls and

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

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

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

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

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

changes to licensee procedures substantially reduced the effectiveness and level of

worker protection.

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

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

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

The inspectors assessed whether these plant operations required communication

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

22 Enclosure

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

authorization.

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

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

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

b. Findings

No findings were identified.

.5 Radiation Worker Performance (02.07)

a. Inspection Scope

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

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

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

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

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

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

b. Findings

No findings were identified.

.6 Radiation Protection Technician Proficiency (02.08)

a. Inspection Scope

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

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

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

inspectors assessed whether this perspective matched the corrective action approach

taken by the licensee to resolve the reported problems.

b. Findings

No findings were identified.

.7 Problem Identification and Resolution (02.09)

a. Inspection Scope

The inspectors evaluated whether problems associated with radiation monitoring and

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

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

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

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

The inspectors assessed the licensees process for applying operating experience to

their plant.

23 Enclosure

b. Findings

No findings were identified.

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

The inspection activities supplement those documented in Inspection

Report 05000454/2011002; 05000455/2011002 and constitute one

complete sample as defined in IP 71124.03-05.

.1 Engineering Controls (02.02)

a. Inspection Scope

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

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

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

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

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

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

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

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

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

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

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

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

practicable.

The inspectors selected temporary ventilation system setups (high efficiency particulate

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

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

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

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

The inspectors reviewed airborne monitoring protocols by selecting installed systems

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

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

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

ALARA concept.

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

Electric Power Research Institutes Alpha Monitoring Guidelines for Operating Nuclear

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

alpha-emitting radionuclides.

b. Findings

No findings were identified.

24 Enclosure

.2 Use of Respiratory Protection Devices (02.03)

a. Inspection Scope

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

airborne radioactivity, the inspectors assessed whether the licensee provided respiratory

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

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

radioactive materials, and assessed whether the licensee performed an evaluation

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

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

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

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

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

b. Findings

No findings were identified.

2RS4 Occupational Dose Assessment (71124.04)

The inspection activities supplement those documented in Inspection

Report 05000454/2011002; 05000455/2011002 and constitute one

complete sample as defined in IP 71124.04-05.

.1 External Dosimetry (02.02)

a. Inspection Scope

The inspectors evaluated whether the licensees dosimetry vendor was National

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

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

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

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

dose equivalent).

b. Findings

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

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

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

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

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

radiation for which the individual wearing the dosimeter is monitored.

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

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

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

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

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

25 Enclosure

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

aligned with the accreditation process.

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

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

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

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

2RS5 Radiation Monitoring Instrumentation (71124.05)

The inspection activities supplement those documented in Inspection

Report 05000454/2011002; 05000455/2011002 and constitute one

complete sample as defined in IP 71124.05-05.

.1 Inspection Planning (02.01)

a. Inspection Scope

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

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

The inspectors reviewed effluent monitor alarm setpoint bases and the calculation

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

b. Findings

No findings were identified.

2RS6 Radioactive Gaseous and Liquid Effluent Treatment (71124.06)

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

.1 Inspection Planning and Program Reviews (02.01)

Event Report and Effluent Report Reviews

a. Inspection Scope

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

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

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

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

entered in the CAP, and were adequately resolved.

The inspectors identified radioactive effluent monitor operability issues reported by the

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

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

adequately resolved.

b. Findings

No findings were identified.

26 Enclosure

Offsite Dose Calculation Manual and Final Safety Analysis Report Review

c. Inspection Scope

The inspectors reviewed Final Safety Analysis Report descriptions of the radioactive

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

evaluated during inspection walkdowns.

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

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

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

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

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

The inspectors reviewed licensee documentation to determine if the licensee had

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

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

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

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

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

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

effluents were reported in accordance with Regulatory Guide 1.21.

d. Findings

No findings were identified.

Groundwater Protection Initiative Program

e. Inspection Scope

The inspectors reviewed reported groundwater monitoring results and changes to the

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

groundwater.

f. Findings

No findings were identified.

Procedures, Special Reports, and Other Documents

g. Inspection Scope

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

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

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

described in these reports.

The inspectors reviewed effluent program implementing procedures, particularly those

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

calculations.

27 Enclosure

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

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

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

h. Findings

No findings were identified.

.2 Walkdowns and Observations (02.02)

a. Inspection Scope

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

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

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

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

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

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

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

communicated directly with the environment.

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

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

material condition surveillance records, as applicable.

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

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

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

of the effluent system.

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

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

evaluate whether appropriate treatment equipment was used and the processing

activities aligned with discharge permits.

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

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

NRC approval of alternate discharge points).

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

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

appropriate effluent treatment equipment was being used and whether radioactive liquid

waste was being processed and discharged in accordance with procedure requirements

and aligned with discharge permits.

b. Findings

No findings were identified.

28 Enclosure

.3 Sampling and Analyses (02.03)

a. Inspection Scope

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

assessed whether adequate controls had been implemented to ensure representative

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

composite samplers, etc.)

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

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

compensatory sampling was performed consistent with the radiological effluent

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

unmonitored liquid and gaseous effluents.

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

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

frequency of compensatory sampling since the last inspection.

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

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

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

appropriate.

b. Findings

No findings were identified.

.4 Instrumentation and Equipment (02.04)

Effluent Flow Measuring Instruments

a. Inspection Scope

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

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

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

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

public doses.

b. Findings

No findings were identified.

Air Cleaning Systems

c. Inspection Scope

The inspectors assessed whether surveillance test results since the previous

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

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

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

29 Enclosure

d. Findings

No findings were identified.

.5 Dose Calculations (02.05)

a. Inspection Scope

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

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

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

change.

The inspectors reviewed radioactive liquid and gaseous waste discharge permits to

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

on representative samples of the discharge path.

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

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

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

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

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

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

Regulatory Guide 1.109. The inspectors reviewed meteorological dispersion and

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

appropriate factors were being used for public dose calculations.

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

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

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

etc.) had been factored into the dose calculations.

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

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

TS dose criteria.

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

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

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

Discharges made with inoperable effluent radiation monitors, or unmonitored leakages

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

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

b. Findings

No findings were identified.

30 Enclosure

.6 Groundwater Protection Initiative Implementation (02.06)

a. Inspection Scope

The inspectors reviewed monitoring results of the Groundwater Protection Initiative to

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

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

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

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

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

and reviewed any remediation actions taken for effectiveness. The inspectors

reviewed onsite contamination events involving contamination of ground water and

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

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

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

amount of radioactive material that was discharged by:

  • Assessing whether sufficient radiological surveys were performed to evaluate the

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

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

radionuclides.

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

Groundwater Protection Initiative implementing procedures.

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

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

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

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

of their effluent release reports.

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

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

documented in the Annual Radiological Environmental Operating Report for the

radiological environmental monitoring program or the Annual Radiological Effluent

Release Report for the Radiological Effluent TSs.

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

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

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

b. Findings

No findings were identified.

31 Enclosure

.7 Problem Identification and Resolution (02.07)

a. Inspection Scope

Inspectors assessed whether problems associated with the effluent monitoring and

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

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

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

problems documented by the licensee involving radiation monitoring and exposure

controls.

b. Findings

No findings were identified.

2RS7 Radiological Environmental Monitoring Program (71124.07)

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

.1 Inspection Planning (02.01)

a. Inspection Scope

The inspectors reviewed the annual radiological environmental operating reports and the

results of any licensee assessments since the last inspection to assess whether the

radiological environmental monitoring program was implemented in accordance with the

TSs and ODCM. This review included reported changes to the ODCM with respect to

environmental monitoring, commitments in terms of sampling locations, monitoring and

measurement frequencies, land use census, inter-laboratory comparison program, and

analysis of data.

The inspectors reviewed the ODCM to identify locations of environmental monitoring

stations.

The inspectors reviewed the Final Safety Analysis Report for information regarding the

environmental monitoring program and meteorological monitoring instrumentation.

The inspectors reviewed quality assurance audit results of the program to assist in

choosing inspection smart samples and audits and technical evaluations performed on

the vendor laboratory program.

The inspectors reviewed the annual effluent release report and the 10 CFR Part 61,

Licensing Requirements for Land Disposal of Radioactive Waste, report, to determine

if the licensee was sampling, as appropriate, for the predominant and dose-causing

radionuclides likely to be released in effluents.

b. Findings

No findings were identified.

32 Enclosure

.2 Site Inspection (02.02)

a. Inspection Scope

The inspectors walked down select air sampling stations and thermoluminescent

dosimeter monitoring stations to determine whether they were located as described in

the ODCM and to determine the equipment material condition. Consistent with smart

sampling, the air sampling stations were selected based on the locations with the

highest X/Q, D/Q wind sectors, and thermoluminescent dosimeters were selected based

on the most risk-significant locations (e.g., those that have the highest potential for

public dose impact).

For the air samplers and thermoluminescent dosimeters selected, the inspectors

reviewed the calibration and maintenance records to evaluate whether they

demonstrated adequate operability of these components. Additionally, the review

included the calibration and maintenance records of select composite water samplers.

The inspectors assessed whether the licensee had initiated sampling of other

appropriate media upon loss of a required sampling station.

The inspectors observed the collection and preparation of environmental samples from

different environmental media (e.g., ground and surface water, milk, vegetation,

sediment, and soil) as available to determine if environmental sampling was

representative of the release pathways as specified in the ODCM and if sampling

techniques were in accordance with procedures.

Based on direct observation and review of records, the inspectors assessed whether

the meteorological instruments were operable, calibrated, and maintained in

accordance with guidance contained in the Final Safety Analysis Report; NRC

Regulatory Guide 1.23, Meteorological Monitoring Programs for Nuclear Power Plants;

and licensee procedures. The inspectors assessed whether the meteorological data

readout and recording instruments in the control room and, if applicable, at the tower

were operable.

The inspectors evaluated whether missed and/or anomalous environmental samples

were identified and reported in the annual environmental monitoring report. The

inspectors selected events that involved a missed sample, inoperable sampler, lost

thermoluminescent dosimeter, or anomalous measurement to determine if the licensee

had identified the cause and had implemented corrective actions. The inspectors

reviewed the licensees assessment of any positive sample results (i.e., licensed

radioactive material detected above the lower limits of detection) and reviewed the

associated radioactive effluent release data that was the source of the released material.

The inspectors selected structures, systems, or components that involved or could

reasonably involve licensed material for which there was a credible mechanism for

licensed material to reach ground water, and assessed whether the licensee had

implemented a sampling and monitoring program sufficient to detect leakage of these

structures, systems, or components to ground water.

33 Enclosure

The inspectors evaluated whether records, as required by 10 CFR 50.75(g), of leaks,

spills, and remediation since the previous inspection were retained in a retrievable

manner.

The inspectors reviewed any significant changes made by the licensee to the ODCM as

the result of changes to the land census, long-term meteorological conditions (3-year

average), or modifications to the sampler stations since the last inspection. The

inspectors reviewed technical justifications for any changed sampling locations to

evaluate whether the licensee performed the reviews required to ensure that the

changes did not affect the ability to monitor the impact of radioactive effluent releases on

the environment.

The inspectors assessed whether the appropriate detection sensitivities with respect to

TSs/ODCM were used for counting samples (i.e., the samples met the TSs/ODCM

required lower limits of detection). The inspectors reviewed quality control charts for

maintaining radiation measurement instrument status and actions taken for degrading

detector performance. The licensee used a vendor laboratory to analyze the radiological

environmental monitoring program samples so the inspectors reviewed the results of the

vendors quality control program, including the interlaboratory comparison, to assess the

adequacy of the vendors program.

The inspectors reviewed the results of the licensees interlaboratory comparison

program to evaluate the adequacy of environmental sample analyses performed by the

licensee. The inspectors assessed whether the interlaboratory comparison test included

the media/nuclide mix appropriate for the facility. If applicable, the inspectors reviewed

the licensees determination of any bias to the data and the overall effect on the

radiological environmental monitoring program.

b. Findings

No findings were identified.

.3 Identification and Resolution of Problems (02.03)

a. Inspection Scope

The inspectors assessed whether problems associated with the radiological

environmental monitoring program were being identified by the licensee at an

appropriate threshold and were properly addressed for resolution in the licensees CAP.

Additionally, the inspectors assessed the appropriateness of the corrective actions for a

selected sample of problems documented by the licensee that involved the radiological

environmental monitoring program.

b. Findings

No findings were identified.

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

Transportation (71124.08)

This inspection constituted one complete sample as defined in IP 71124.08-05.

34 Enclosure

.1 Inspection Planning (02.01)

a. Inspection Scope

The inspectors reviewed the solid radioactive waste system description in the Final

Safety Analysis Report, the process control program, and the recent radiological effluent

release report for information on the types, amounts, and processing of radioactive

waste disposed.

The inspectors reviewed the scope of any quality assurance audits in this area since the

last inspection to gain insights into the licensees performance and inform the smart

sampling inspection planning.

b. Findings

No findings were identified.

.2 Radioactive Material Storage (02.02)

a. Inspection Scope

The inspectors selected areas where containers of radioactive waste were stored, and

evaluated whether the containers were labeled in accordance with 10 CFR 20.1904,

Labeling Containers, or controlled in accordance with 10 CFR 20.1905, Exemptions to

Labeling Requirements, as appropriate.

The inspectors assessed whether the radioactive material storage areas were controlled

and posted in accordance with the requirements of 10 CFR Part 20, Standards for

Protection against Radiation. For materials stored or used in controlled or unrestricted

areas, the inspectors evaluated whether they were secured against unauthorized

removal and controlled in accordance with 10 CFR 20.1801, Security of Stored

Material, and 10 CFR 20.1802, Control of Material Not in Storage, as appropriate.

The inspectors evaluated whether the licensee established a process for monitoring the

impact of long term storage (e.g., buildup of any gases produced by waste

decomposition, chemical reactions, container deformation, loss of container integrity, or

re-release of free-flowing water) that was sufficient to identify potential unmonitored,

unplanned releases or nonconformance with waste disposal requirements.

The inspectors selected containers of stored radioactive material, and inspected the

containers for signs of swelling, leakage, and deformation.

b. Findings

No findings were identified.

.3 Radioactive Waste System Walkdown (02.03)

a. Inspection Scope

The inspectors walked down accessible portions of select radioactive waste processing

systems to assess whether the current system configuration and operation agreed with

35 Enclosure

the descriptions in the Final Safety Analysis Report, ODCM, and process control

program.

The inspectors reviewed administrative and/or physical controls (i.e., drainage and

isolation of the system from other systems) to assess whether the equipment which was

not in service or abandoned in place would contribute to an unmonitored release path

and/or affect operating systems or be a source of unnecessary personnel exposure.

The inspectors assessed whether the licensee reviewed the safety significance of

systems and equipment abandoned in place in accordance with 10 CFR 50.59,

Changes, Tests, and Experiments.

The inspectors reviewed the adequacy of changes made to the radioactive waste

processing systems since the last inspection. The inspectors evaluated whether

changes from what was described in the Final Safety Analysis Report were reviewed

and documented in accordance with 10 CFR 50.59, as appropriate and to assess the

impact on radiation doses to members of the public.

The inspectors selected processes for transferring radioactive waste resin and/or sludge

discharges into shipping/disposal containers and assessed whether the waste stream

mixing, sampling procedures, and methodology for waste concentration averaging were

consistent with the process control program, and provided representative samples of the

waste product for the purposes of waste classification as described in 10 CFR 61.55,

Waste Classification.

For those systems that provided tank recirculation, the inspectors evaluated whether the

tank recirculation procedures provided sufficient mixing.

The inspectors assessed whether the licensees process control program correctly

described the current methods and procedures for dewatering and waste stabilization

(e.g., removal of freestanding liquid).

b. Findings

No findings were identified.

.4 Waste Characterization and Classification (02.04)

a. Inspection Scope

The inspectors selected the following radioactive waste streams for review:

  • Primary Resin;
  • Secondary Resin;
  • Secondary Radwaste Filter; and
  • Dry Active Waste (DAW).

For the waste streams listed above, the inspectors assessed whether the licensees

radiochemical sample analysis results (i.e., 10 CFR Part 61" analysis) were sufficient to

support radioactive waste characterization as required by 10 CFR Part 61, Licensing

Requirements for Land Disposal of Radioactive Waste. The inspectors evaluated

whether the licensees use of scaling factors and calculations to account for difficult-to-

36 Enclosure

measure radionuclides was technically sound and based on current 10 CFR Part 61

analyses for the selected radioactive waste streams.

The inspectors evaluated whether changes to plant operational parameters were taken

into account to: (1) maintain the validity of the waste stream composition data between

the annual or biennial sample analysis update; and (2) assure that waste shipments

continued to meet the requirements of 10 CFR Part 61 for the waste streams selected

above.

The inspectors evaluated whether the licensee had established and maintained an

adequate quality assurance program to ensure compliance with the waste classification

and characterization requirements of 10 CFR 61.55 and 10 CFR 61.56, Waste

Characteristics.

b. Findings

No findings were identified.

.5 Shipment Preparation (02.05)

a. Inspection Scope

The inspectors observed shipment packaging, surveying, labeling, marking, placarding,

vehicle checks, emergency instructions, disposal manifest, shipping papers provided to

the driver, and licensee verification of shipment readiness. The inspectors assessed

whether the requirements of applicable transport cask certificates of compliance had

been met. The inspectors evaluated whether the receiving licensee was authorized to

receive the shipment packages. The inspectors evaluated whether the licensees

procedures for cask loading and closure were consistent with the vendors current

approved procedures.

The inspectors observed radiation workers during the conduct of radioactive waste

processing and radioactive material shipment preparation and receipt activities. The

inspectors assessed whether the shippers were knowledgeable of the shipping

regulations and whether shipping personnel demonstrated adequate skills to accomplish

the package preparation requirements for public transport with respect to the licensees

response to NRC Bulletin 79-19, Packaging of Low-Level Radioactive Waste for

Transport and Burial, dated August 10, 1979; and Title 49 CFR Part 172, Hazardous

Materials Table, Special Provisions, Hazardous Materials Communication, Emergency

Response Information, Training Requirements, and Security Plans, Subpart H,

Training.

Due to limited opportunities for direct observation, the inspectors reviewed the technical

instructions presented to workers during routine training. The inspectors assessed

whether the licensees training program provided training to personnel responsible for

the conduct of radioactive waste processing and radioactive material shipment

preparation activities.

b. Findings

No findings were identified.

37 Enclosure

.6 Shipping Records (02.06)

a. Inspection Scope

The inspectors evaluated whether the shipping documents indicated the proper shipper

name; emergency response information and a 24-hour contact telephone number;

accurate curie content and volume of material; and appropriate waste classification,

transport index, and UN number for the following radioactive shipments:

  • Shipment RWS10-011; Dewatered Bead Resin; low specific activity (LSA-II);
  • Shipment RWS10-013; DAW Trash and TR Pond Sludge; low specific activity

(LSA-II);

  • Shipment RWS10-012; DAW Trash; low specific activity (LSA-II);
  • Shipment RMS09-094; Rx Vessel Dosimetry; Type A Package; and
  • Shipment RMS11-078; Dirty Laundry; low specific activity (LSA-II).

Additionally, the inspectors assessed whether the shipment placarding was consistent

with the information in the shipping documentation.

b. Findings

Introduction: A self-revealed finding of very low safety significance (Green) and an

associated NCV of 10 CFR 71.5, Transportation of Licensed Material, was identified

when licensee personnel failed to comply with 49 CFR 172.203(c) and shipped

packages of radioactive material with transport manifests that did not document all

applicable hazardous substances.

Description: On multiple dates, the licensee shipped containers of radioactive material

to a waste processor with incomplete information on the transport manifest. Specifically,

the transport manifest that accompanied the shipments failed to identify hazardous

materials, including asbestos, lead, and other chemicals that were contained in the

packages. Upon arrival at the waste processors facility, the waste processor identified

the non-conformances in the shipping containers and notified the licensee. Follow-up

actions by the licensee included performing a revised characterization of the shipped

packages. The revised radiological characterization identified negligible impact relative

to the initial radiological assessment and package characterization. This event was

documented in the licensees CAP as:

  • IR 928393; Non-Conforming Metal Shipped to Bear Creek Processing;
  • IR 1015646; Non-Conforming Waste Found in Radwaste Shipment; and
  • IR 1067394; Non-Conforming Radioactive Waste in Shipment.

38 Enclosure

Immediate corrective actions included providing a corrected copy of the transport

manifest to the waste processor. Additionally, the licensee initiated IR 1285148

to evaluate the human performance issues associated with the shipping

non-conformances. Further, the licensee placed locks on the shipping containers

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

represented the hazards contained in the shipping package.

Analysis: The failure to completely identify all required package contents on a transport

manifest was a performance deficiency. The finding was determined to be more than

minor because it was associated with the Program and Process attribute of the Public

Radiation Safety Cornerstone and adversely affected the cornerstone objective of

ensuring the adequate protection of public health and safety from exposure to

radioactive materials released into the public domain as a result of routine civilian

nuclear reactor operation, in that, providing incorrect information, as part of hazard

communication, could impact the actions of response personnel. The finding involved

an occurrence of the licensees radioactive material transportation program that was

contrary to NRC regulatory requirements. The inspectors determined that the finding

could be evaluated using the SDP in accordance with IMC 0609, Significance

Determination Process, Appendix D, Public Radiation Safety Significance

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

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

package during transit; (3) it did not involve a certificate of compliance issue; (4) it was

not a low level burial ground nonconformance; and (5) it did not involve a failure to make

notifications or provide emergency information. As a result, the finding screened as

having very low safety significance (Green).

This finding has a cross-cutting aspect in the Work Control component of the Human

Performance cross-cutting area H.3(b) since the waster shipper failed to coordinate

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

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

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

interdepartmental coordination is necessary to assure adequate human performance.

Specifically, these events occurred because the radioactive material shipper did not

control the items placed in the waste packages and was not present when the boxes

were loaded.

Enforcement: Title 10 CFR 71.5, Transportation of Licensed Material, requires

licensees to comply with the Department of Transportation (DOT) regulations in

49 CFR Parts 170 through 189 relative to the transportation of licensed material.

Title 49 CFR 172.203, Additional Description Requirements, required, in part,

that hazardous materials be listed on the transport manifest.

Contrary to the above, between May 10, 2010 and May 26, 2011, the licensee failed to

list relevant hazardous materials on the transport manifest for a shipment also containing

DAW. This violation was entered into the licensees CAP as IR 1285148. Because this

violation was of very low safety significance and it was entered into the licensees CAP,

this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC

Enforcement Policy. (NCV 05000454/2011005-04, Failure to Identify Hazardous

Materials on Transportation Manifest)

39 Enclosure

.7 Identification and Resolution of Problems (02.07)

a. Inspection Scope

The inspectors assessed whether problems associated with radioactive waste

processing, handling, storage, and transportation, were being identified by the licensee

at an appropriate threshold, were properly characterized, and were properly addressed

for resolution in the licensee CAP. Additionally, the inspectors evaluated whether the

corrective actions were appropriate for a selected sample of problems documented by

the licensee that involve radioactive waste processing, handling, storage, and

transportation.

The inspectors reviewed results of selected audits performed since the last inspection of

this program and evaluated the adequacy of the licensees corrective actions for issues

identified during those audits.

b. Findings

No findings were identified.

4. OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and

Emergency Preparedness

4OA1 Performance Indicator Verification (71151)

.1 Reactor Coolant System Leakage

a. Inspection Scope

The inspectors sampled licensee submittals for the Unit 1 and Unit 2 RCS Leakage

Performance Indicator (PI) for the period from the third quarter 2010 through the second

quarter 2011. To determine the accuracy of the PI data reported during those periods,

PI definitions and guidance contained in Nuclear Energy Institute (NEI) 99-02,

Regulatory Assessment Performance Indicator Guideline, Revision 6, dated

October 2009, was used. The inspectors reviewed the licensees operator logs,

RCS leakage tracking data, issue reports, event reports and NRC Integrated Inspection

Reports for the period of June 2010 through June 2011 to validate the accuracy of the

submittals. The inspectors also reviewed the licensees issue report database to

determine if any problems had been identified with the PI data collected or transmitted

for this indicator. Documents reviewed are listed in the Attachment.

This inspection constituted two RCS leakage samples as defined in IP 71151-05.

b. Findings

No findings were identified.

40 Enclosure

.2 Unplanned Transients Per 7000 Critical Hours

a. Inspection Scope

The inspectors sampled licensee submittals for the Unplanned Transients per 7000

Critical Hours performance indicator for Unit 1 and Unit 2 for the period from the second

quarter of 2010 through the 3rd quarter of 2011. To determine the accuracy of the PI

data reported during those periods, PI definitions and guidance contained in NEI 99-02,

Regulatory Assessment Performance Indicator Guideline, Revision 6, dated

October 2009, was used. The inspectors reviewed the licensees operator narrative

logs, issue reports, maintenance rule records, event reports and NRC Integrated

Inspection Reports for the period of April 2010 through September 2011 to validate the

accuracy of the submittals. The inspectors also reviewed the licensees issue report

database to determine if any problems had been identified with the PI data collected or

transmitted for this indicator. Documents reviewed are listed in the Attachment.

This inspection constituted two unplanned transients per 7000 critical hours samples as

defined in IP 71151-05.

b. Findings

No findings were identified.

.3 Safety System Functional Failures

a. Inspection Scope

The inspectors sampled licensee submittals for the Safety System Functional Failures

performance indicator for Unit 1 and Unit 2 for the period from the second quarter of

2010 through the third quarter of 2011. To determine the accuracy of the PI data

reported during those periods, PI definitions and guidance contained in NEI 99-02,

Regulatory Assessment Performance Indicator Guideline, Revision 6, dated

October 2009, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and

50.73" definitions and guidance, were used. The inspectors reviewed the licensees

operator narrative logs, operability assessments, maintenance rule records,

maintenance work orders, issue reports, event reports and NRC Integrated Inspection

Reports for the period of June 2010 through September 2011 to validate the accuracy of

the submittals. The inspectors also reviewed the licensees issue report database to

determine if any problems had been identified with the PI data collected or transmitted

for this indicator. Documents reviewed are listed in the Attachment.

This inspection constituted two safety system functional failures samples as defined in

IP 71151-05.

b. Findings

No findings were identified.

41 Enclosure

.4 Reactor Coolant System Specific Activity

a. Inspection Scope

The inspectors sampled licensee submittals for the RCS specific activity PI for Unit 1

and Unit 2 for the period from the 4th quarter of 2010 through the 3rd quarter of 2011.

The inspectors used PI definitions and guidance contained in NEI 99-02, Regulatory

Assessment Performance Indicator Guideline, Revision 6, dated October 2009 to

determine the accuracy of the PI data reported during those periods. The inspectors

reviewed the licensees reactor coolant system chemistry samples, TS requirements,

issue reports, event reports, and NRC Integrated Inspection Reports for the period of the

4th quarter 2010 through the 3rd quarter of 2011 to validate the accuracy of the

submittals. The inspectors also reviewed the licensees issue report database to

determine if any problems had been identified with the PI data collected or transmitted

for this indicator. In addition to record reviews, the inspectors observed a chemistry

technician obtain and analyze a reactor coolant system sample. Documents reviewed

are listed in the Attachment.

This inspection constituted two RCS specific activity samples as defined in IP 71151-05.

b. Findings

No findings were identified.

.5 Mitigating Systems Performance Index - Heat Removal System

a. Inspection Scope

The inspectors sampled licensee submittals for the Mitigating Systems Performance

Index (MSPI) - Heat Removal System performance indicator for Unit 1 and Unit 2 for the

period from the fourth quarter of 2010 through the third quarter of 2011. To determine

the accuracy of the PI data reported during those periods, PI definitions and guidance

contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline,

Revision 6, dated October 2009, was used. The inspectors reviewed the licensees

operator narrative logs, issue reports, event reports, MSPI derivation reports, and NRC

Integrated IRs for the period of October 2010 through September 2011 to validate the

accuracy of the submittals. The inspectors reviewed the MSPI component risk

coefficient to determine if it had changed by more than 25 percent in value since the

previous inspection, and if so, that the change was in accordance with applicable NEI

guidance. The inspectors also reviewed the licensees issue report database to

determine if any problems had been identified with the PI data collected or transmitted

for this indicator. Documents reviewed are listed in the Attachment.

This inspection constituted two MSPI heat removal system samples as defined in

IP 71151-05.

b. Findings

No findings were identified.

42 Enclosure

.6 Mitigating Systems Performance Index - Cooling Water Systems

a. Inspection Scope

The inspectors sampled licensee submittals for the MSPI - Cooling Water Systems

performance indicator for Unit 1 and Unit 2 for the period from the fourth quarter of 2010

through the third quarter of 2011. To determine the accuracy of the PI data reported

during those periods, PI definitions and guidance contained in NEI 99-02, Regulatory

Assessment Performance Indicator Guideline, Revision 6, dated October 2009, was

used. The inspectors reviewed the licensees operator narrative logs, issue reports,

MSPI derivation reports, event reports and NRC Integrated Inspection Reports for the

period of October 2010 through September 2011 to validate the accuracy of the

submittals. The inspectors reviewed the MSPI component risk coefficient to determine if

it had changed by more than 25 percent in value since the previous inspection, and if so,

whether the change was in accordance with applicable NEI guidance. The inspectors

also reviewed the licensees issue report database to determine if any problems had

been identified with the PI data collected or transmitted for this indicator. Documents

reviewed are listed in the Attachment.

This inspection constituted two MSPI cooling water system samples as defined in

IP 71151-05.

b. Findings

No findings were identified.

.7 Mitigating Systems Performance Index - High Pressure Injection Systems

a. Inspection Scope

The inspectors sampled licensee submittals for the MSPI - High Pressure Injection

Systems performance indicator for Unit 1 and Unit 2 for the period from the fourth

quarter of 2010 through the third quarter of 2011. To determine the accuracy of the PI

data reported during those periods, PI definitions and guidance contained in NEI 99-02,

Regulatory Assessment Performance Indicator Guideline, Revision 6, dated

October 2009, were used. The inspectors reviewed the licensees operator narrative

logs, issue reports, MSPI derivation reports, event reports and NRC Integrated

Inspection Reports for the period of October 2010 through September of 2011 to validate

the accuracy of the submittals. The inspectors reviewed the MSPI component risk

coefficient to determine if it had changed by more than 25 percent in value since the

previous inspection, and if so, that the change was in accordance with applicable

NEI guidance. The inspectors also reviewed the licensees issue report database to

determine if any problems had been identified with the PI data collected or transmitted

for this indicator. Documents reviewed are listed in the Attachment.

This inspection constituted two MSPI high pressure injection system samples as defined

in IP 71151-05.

b. Findings

No findings were identified.

43 Enclosure

.8 Occupational Exposure Control Effectiveness

a. Inspection Scope

The inspectors sampled licensee submittals for the occupational radiological

occurrences PI for the period from the fourth quarter of 2010 through the 3rd quarter

of 2011. To determine the accuracy of the PI data reported during these periods, the

inspectors used PI definitions and guidance contained in NEI 99-02, Regulatory

Assessment Performance Indicator Guideline, Revision 6, dated October 2009. The

inspectors reviewed the licensees assessment of the PI for occupational radiation safety

to determine if indicator-related data was adequately assessed and reported. To assess

the adequacy of the licensees PI data collection and analyses, the inspectors discussed

with radiation protection staff, the scope, and breadth of its data review and the results of

those reviews. The inspectors independently reviewed electronic personal dosimetry

dose rate and accumulated dose alarms and dose reports and the dose assignments for

any intakes that occurred during the time period reviewed to determine if there were

potentially unrecognized occurrences. The inspectors also conducted walkdowns of

numerous locked high and very high radiation area entrances to determine the adequacy

of the controls in place for these areas. Documents reviewed are listed in the

Attachment.

This inspection constituted one occupational exposure control effectiveness sample as

defined in IP 71151-05.

b. Findings

No findings were identified.

.9 Radiological Effluent Technical Specification/Offsite Dose Calculation Manual

Radiological Effluent Occurrences

a. Inspection Scope

The inspectors sampled licensee submittals for the radiological effluent TS/ODCM

radiological effluent occurrences PI for the period from the fourth quarter of 2010 through

the third quarter of 2011. To determine the accuracy of the PI data reported during

these periods, the inspectors used PI definitions and guidance contained in NEI 99-02,

Regulatory Assessment Performance Indicator Guideline, Revision 6, dated

October 2009. The inspectors reviewed the licensees issue report database and

selected individual reports generated since this indicator was last reviewed to identify

any potential occurrences such as unmonitored, uncontrolled, or improperly calculated

effluent releases that may have impacted offsite dose. The inspectors reviewed

gaseous effluent summary data and the results of associated offsite dose calculations

for selected dates between the fourth quarter of 2010 through the third quarter of 2011 to

determine if indicator results were accurately reported. The inspectors also reviewed the

licensees methods for quantifying gaseous and liquid effluents and determining effluent

dose. Documents reviewed are listed in the Attachment.

44 Enclosure

This inspection constituted one Radiological Effluent TS/ODCM radiological effluent

occurrences sample as defined in IP 71151 05.

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems (71152)

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency

Preparedness, Public Radiation Safety, Occupational Radiation Safety, and

Physical Protection

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

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of

this report, the inspectors routinely reviewed issues during baseline inspection activities

and plant status reviews to verify that they were being entered into the licensees CAP at

an appropriate threshold, that adequate attention was being given to timely corrective

actions, and that adverse trends were identified and addressed. Attributes reviewed

included: the complete and accurate identification of the problem; that timeliness was

commensurate with the safety significance; that evaluation and disposition of

performance issues, generic implications, common causes, contributing factors, root

causes, extent-of-condition reviews, and previous occurrence reviews were proper and

adequate; and that the classification, prioritization, focus, and timeliness of corrective

actions were commensurate with safety and sufficient to prevent recurrence of the issue.

Minor issues entered into the licensees CAP as a result of the inspectors observations

are included in the attached List of Documents Reviewed.

These routine reviews for the identification and resolution of problems did not constitute

any additional inspection samples. Instead, by procedure they were considered an

integral part of the inspections performed during the quarter and documented in

Section 1 of this report.

b. Findings

No findings were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

In order to assist with the identification of repetitive equipment failures and specific

human performance issues for follow-up, the inspectors performed a daily screening

of items entered into the licensees CAP. This review was accomplished through

inspection of the stations daily condition report packages.

45 Enclosure

These daily reviews were performed by procedure as part of the inspectors daily plant

status monitoring activities and, as such, did not constitute any separate inspection

samples.

b. Findings

No findings were identified.

.3 Selected Issue Follow-Up Inspection: Licensee Issue Report on Auxiliary Feedwater

System Crosstie Modification

a. Inspection Scope

The inspectors performed a review of the item below that was identified by an NRC

inspector at a different but similar facility:

This review constituted one in-depth problem identification and resolution sample as

defined in IP 71152-05.

b. Findings

No findings were identified.

.4 Annual Sample: Review of Operator Workarounds

a. Inspection Scope

The inspectors evaluated the licensees implementation of their process used to identify,

document, track, and resolve operational challenges. Inspection activities included, but

were not limited to, a review of the cumulative effects of the operator workarounds

(OWAs) on system availability and the potential for improper operation of the system, for

potential impacts on multiple systems, and on the ability of operators to respond to plant

transients or accidents.

The inspectors performed a review of the cumulative effects of OWAs. The documents

listed in the Attachment were reviewed to accomplish the objectives of the inspection

procedure. The inspectors reviewed both current and historical operational challenge

records to determine whether the licensee was identifying operator challenges at an

appropriate threshold, had entered them into their CAP, and proposed or implemented

appropriate and timely corrective actions which addressed each issue. Reviews were

conducted to determine if any operator challenge could increase the possibility of an

Initiating Event, if the challenge was contrary to training, required a change from

long-standing operational practices, or created the potential for inappropriate

compensatory actions. Additionally, all temporary modifications were reviewed to

identify any potential effect on the functionality of Mitigating Systems, impaired access to

equipment, or required equipment uses for which the equipment was not designed.

Daily plant and equipment status logs, degraded instrument logs, and operator aids or

tools being used to compensate for material deficiencies were also assessed to identify

any potential sources of unidentified operator workarounds.

46 Enclosure

This review constituted one operator workaround annual inspection sample as defined in

IP 71152-05.

b. Findings

No findings were identified.

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

.1 (Closed) Licensee Event Report 05000455/2011-001, Revision 0 and Revision 1, Unit 2

Emergency Diesel Generator Inoperable for Longer Than Allowed by Technical

Specifications Due to Inadequate Work Instructions

The Licensee Event Report (LER) involved a Unit 2 DG that was unknowingly inoperable

for approximately 6 months due to loose bolting on the upper lubricating oil cooler.

During a routine surveillance on November 17, 2010, a significant oil leak was identified

by the equipment operator. The DG was shut down before damage could occur. The

licensee determined that a bolted flanged connection was misaligned during

reinstallation following maintenance in January of 2010.

NRC Follow-Up inspection 05000455/2011011 determined that the issue was an

apparent violation and a White Finding (EA-11-014). The IR was issued February 11,

2011. On October 4, 2011, an NRC IP 95001 Supplemental IR was issued documenting

the closure of finding 05000455/2011011-01. As the enforcement actions have been

issued, and the Supplemental Inspection has been completed with no significant issues

identified, these LERs are closed.

.2 (Closed) Licensee Event Report 05000455/2011-002, Revision 0, Containment

Pressure Not Within Limits Longer than Allowed By Technical Specifications Due to

Personnel Error

The LER involved a licensee-identified mistaken plugging of a pressure sensor inside of

containment during the previous refueling outage. The plugged was placed during a

routine surveillance on September 28, 2011 and on October 13, 2011, licensee

personnel determined that while the instrument indicated that Unit 2 containment

pressure was within limits, that, in fact containment pressure was above the TS limit. A

containment entry was made, the plug was removed, containment pressure was reduced

and the peak pressure was determined to be approximately 1.91 pounds per square inch

gauge (psig). The TS allowed value was 1.0 psig and the amount of time that the

pressure could be above the limit was 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> with the plant required to be shut down

within the following 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br />. By the time the situation was identified, understood, and

corrected a total time of 95 hours0.0011 days <br />0.0264 hours <br />1.570767e-4 weeks <br />3.61475e-5 months <br /> and 48 minutes had elapsed.

The licensee determined and the inspectors verified that the licensees safety margin

between peak containment pressure and the initial maximum allowed pressure was

10 psig. The technicians error and the delay in correcting the error resulted in 0.91 psig

of the 10 psig margin being used. There was a minor adverse safety consequence due

to the licensee personnels error.

The technicians error identified by the licensee resulted in a minor failure to comply with

TS 3.6.4, Containment Pressure. This LER is closed.

47 Enclosure

4OA6 Management Meetings

.1 Exit Meeting Summary

On January 12, 2012, the inspectors presented the inspection results to Mr. B. Youman,

and other members of the licensee staff. The licensee acknowledged the issues

presented. The inspectors confirmed that none of the potential report input discussed

was considered proprietary.

.2 Interim Exit Meetings

Interim exits were conducted for:

  • The results of an Operator Licensing inspection with the Lead Operations Training

staff instructor, Mr. M. McCue, via telephone on December 8, 2011.

  • The results of an annual review of Emergency Action Level and Emergency Plan

changes with the Emergency Preparedness Coordinator, Mr. R. Kartheiser, via

telephone on December 7, 2011.

with the Site Vice President, Mr. T. Tulon, on November 10, 2011 and with the

Acting Plant Manager, E. Hernandez, on December 28, 2011.

The licensee acknowledged the issues presented. The inspectors confirmed that none

of the potential report input discussed was considered proprietary. Proprietary material

received during the inspection was returned to the licensee.

4OA7 Licensee-Identified Violations

The following violation of very low safety significance was identified by the licensee. The

violation met the criteria of Section VI of the NRC Enforcement Policy for being

dispositioned as a Non-Cited Violation.

.1 Effluent Monitors Alarms Setpoints Incorrectly Established

Technical Specification 5.5.1 states that the ODCM shall contain the methodology and

parameters used in the calculation of offsite doses resulting from radioactive gaseous

and liquid effluents, and in the calculation of gaseous and liquid monitoring alarm and

trip setpoints.

Contrary to the above, on August 26, 2010, the licensee identified a potential for

non-conservative alarm setpoints for effluent monitors. Subsequently, the licensee

calculated new setpoints for these monitors using the methodology prescribed in the

ODCM and determined that the previous alarm setpoints were incorrectly established

and were non-conservative (too high). The inspectors determined that this finding was

of more than minor significance because it was similar to Example 6.c in IMC 0612,

Appendix E, Example of Minor Issues. Specifically, the effluent monitors with its alarm

set points would have failed to perform its intended function (i.e., trip or isolation

function) to prevent an instantaneous effluent release in excess of the applicable TS

instantaneous dose rate limits for gases. In accordance with IMC 0609, Appendix D,

48 Enclosure

Public Radiation Safety, the inspectors determined the violation to be of very low safety

significance, (Green) because the dose impact to a member of the public from the

radiological release was less than the dose values in Appendix I to 10 CFR Part 50 and

10 CFR 20.1301(e). This violation of TS 5.5.1 is being treated as a NCV consistent with

Section 2.3.2 of the NRC Enforcement Policy. The licensee entered this issue into their

CAP as IR 1106461.

ATTACHMENT: SUPPLEMENTAL INFORMATION

49 Enclosure

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

T. Tulon, Site Vice President

B. Youman, Plant Manager

D. Coltman, Operations Manager

J. Feimster, Design Engineering Manager

D. Damptz, Acting Maintenance Director

S. Swanson, Nuclear Oversight Manager

R. Gayheart, Training Director

B. Barton, Radiation Protection Manager

K. Anderson, Acting Radiation Protection Manager

A. Creamean, Chemistry Manager

D. Gudger, Regulatory Assurance Manager

R. Cameron, Licensed Operator Requalification Lead

Nuclear Regulatory Commission

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

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000454/2011005-001 NCV Failure to Identify Voided Sections of AF Piping

(Section 1R15)05000455/2011005-001 NCV Failure to Identify Voided Sections of AF Piping

(Section 1R15)05000454/2011005-002 NCV High Energy Line Break Operability Evaluation

(Section 1R15)05000455/2011005-002 NCV High Energy Line Break Operability Evaluation

(Section 1R15)05000454/2011005-003 URI Use of TLDs May Not be Consistent with the Methods

Used by the NVLAP Accreditation Process (Section 2RS4)05000455/2011005-003 URI Use of TLDs may not be consistent with the methods used

by the NVLAP accreditation process (Section 2RS4)05000454/2011005-004 NCV Failure to Identify Hazardous Materials on Transportation

Manifest (Section 3RS8)

1 Attachment

Closed

05000455/2011011-00 LER Unit 2 Emergency Diesel Generator Inoperable for

Longer Than Allowed by Technical Specifications

Due to Inadequate Work Instructions, Revision 0

05000455/2011011-01 LER Unit 2 Emergency Diesel Generator Inoperable for

Longer Than Allowed by Technical Specifications

Due to Inadequate Work Instructions, Revision

2 Attachment

LIST OF DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection. Inclusion on this list does

not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that

selected sections of portions of the documents were evaluated as part of the overall inspection

effort. Inclusion of a document on this list does not imply NRC acceptance of the document or

any part of it, unless this is stated in the body of the inspection report.

Section 1R01: Adverse Weather Protection (Quarterly)

- IR 1067880; Byron 2010/2011 Winter Readiness Critique, March 30, 2011

- IR 1186291; 2010/2011 Winter Readiness Critique, March 11, 2011

- IR 1193076; Action Tracking Process Versus Work Control Process, December 2, 2010

- IR 1238947; SX Chemical Feed Lines Need Insulating, July 12, 2011

- IR 1262839; Winter Readiness Work Rescheduled, September 14, 2011

- IR 1265348; Unable to Resolve Parts Required Issue, September 14, 2011

- IR 1265934; Winter Readiness Challenge - No CST Heaters Available, September 21, 2011

- IR 1280434; Switchyard Winter Readiness PM, October 24, 2011

- IR 1280750; Freeze Protection - CWPH Louvers LV48, 142 Stuck Open, October 24, 2011

- IR 1280755; Freeze Protection - Electric Heater 0VV37C Fan Motor, October 24, 2011

- IR 1280755; Freeze Protection: Electric Heater 0VV37C Fan Motor, October 24, 2011

- IR 1280757; 0VH09Y - Damper Stuck Open, October 24, 2011

- IR 1281870; Roof Access Hatch Will Not Remain Closed, October 26, 2011

- IR 1285676; Winter Readiness Walkdown, November 2, 2011

- IR 1286684; 0VT17J LV-82 Has a Louver Broke Preventing Set From Closing,

November 5, 2011

- IR 1286686; 0VT11J LV-8 Has a Set of Louvers Not Fully closed, November 5, 2011

- IR 1286687; 0VT16J LV-80 Has a Broken Louver Preventing Set From Closing,

November 5, 2011

- IR 1286688; 0VT13J LV-17 Has 2 Sets of Louvers Not Fully Closed, November 5, 2011

- IR 1286689; 0VT18J LV-83 Has Broken Louvers Preventing Set From Closing,

November 5, 2011

- IR 1286693; 0VT20J LV-86 Sets of Louvers Not Fully Closed, November 5, 2011

- IR 1286904; 0VT07J LV-4 Has Broken Louvers, November 5, 2011

- IR 1286907; 0VT08J LV-5 Has 2 Sets of Louvers Not Fully Closed, November 5, 2011

- IR 1286908; 0VT10J LV-7 Has One Broken Louver, November 5, 2011

- IR 1286910; 0VT14J LV-18 Has a Set of Louvers Not Fully Closed, November 5, 2011

- IR 1286912; 0VT12J LV-9 Has Broken Louvers and Sets Not Fully Closed, November 5, 2011

- IR 1289988; Freeze Protection Concern, November 13, 2011

- IR 1293508; Winter Readiness System Review Work Removed From 2011,

November 15, 2011

- IR 1297625; 0BOSR XFT-A1, SH Area Heaters Testing Discrepancies, December 3, 2011

- Unit 2 Standing Order; Station Heat Coil Degradation in Unit 2 VA Plenum, Log #11-053

- 0BOSR XFT-A1; Freezing Temperature Equipment Protection SH and Department Support

Requirements, Revision 13

- 0BOSR XFT-A3; Freezing Temperature Equipment Protection Plant Ventilation Systems,

Revision 8

- 0BOSR XFT-A4; Freezing Temperature Equipment Protection Area Buildings Ventilation

Systems and Tanks, Revision 7

- 0BOSR XFT-A5; Freezing Temperature Equipment Protection Non-Protected Area Buildings

Ventilation Systems, Revision 6

3 Attachment

- BOP XFT-1; Cold Weather Operations, Revision 2

- IR 1298335; 0BOSR XFT-A3 Freezing Temperature Protection Discrepancies,

December 05, 2011

Section 1R04: Equipment Alignment (Quarterly)

- Drawing M-62; Diagram of Residual Heat Removal, Revision BD

- BAP 300-1A1; At The Controls Area, Revision 52

- BOP RH-E2A; Unit 2 Residual Heat Removal System Train A Electrical Lineup, Revision 4

- BOP RH-M2A; Unit 2 Residual Heat Removal System Train A Valve Lineup, Revision 10

- IR 0332862; 1B AF Pump Air Box Leakage, May 07, 2005

- IR 1289049; Fireproofing on Column Outside 1B AF Pump Room Degraded,

November 10, 2011

- IR 1299293; AF005 Flow Control Valve Trim Clearance Low Margin Issue,

November 21, 2011

IR 1304078; Fire Drill Observation - SCBA Voice Amplifiers Not Working, December 17, 2011

- EC 355468; Evaluation of Diesel Driven Auxiliary Feedwater Air Box Gaps, Revision 0

- SPEC. L-2722 Proposed Seal for 2AB-1086 Unit 2; Sheet Numbers 1A, 1, 2, and 3, Revision 1

Section 1R04: Complete System Walkdown (Semi-Annual)

- BOP AF-M2B; Auxiliary Feedwater Train B Valve Lineup, Revision 4

Section 1R05: Fire Protection (Quarterly)

- IR 1076490; Fire Damper 2VE04Y Access Door Hinge Tack Welds Broken, May 28, 2011

- IR 1075765; Electro-Thermo-Link Separated, June 1, 2010

- IR 1077737; Need CO2 OSS for 2 ICSRs on the T.S. Fire Tamper Surveillance, June 7, 2010

- IR 1072592; 2VD23YA Flexible Conduit Support Clip not Holding Conduit, May 24, 2010

- IR 1072640; Debris in Tray Below Damper 2VD63Y, May 24, 2010

- IR 1073509; Flexible Conduit Loose at Upper, South ETL on Fire Damper, May 26, 2010

- IR 1081618; Difficult to Access Damper, 1VE06Y for Surveillance/Repair, June 17, 2010

- IR 1289049; Fireproofing on Column Outside 1B AF Pump Room Degraded,

November 10, 2011

- IR 1250346; Fire Brigade Leader Training Issue, August 12, 2011

- Fire Drill Scenario No. 11-04; Unit 1 Auxiliary Boiler Room Fire, September 16, 2011

- Pre-Fire Plan; Fire Area/Zone - FZ 8.3-1 Southeast, Revision 1

- EC 350613; Evaluation of Fire Damper S-Hook Orientation Impact on Dampers 2VD24&B,

VC191Y, and 0VC193Y, Revision 0

- WO 1197473; Tech Spec Fire Damper 18-Month Visual Inspection, December 3, 2009

- WO 1028736; Tech Spec Fire Damper 18-Month Visual Inspection, August 4, 2008

- WO 1124519; Tech Spec Fire Damper 18-Month Visual Inspection, April 14, 2008

- WO 0848826; Tech Spec Fire Damper 18-Month Visual Inspection, December 15, 2006

- 0BMSR 3.10.g.7; TRM Fire Damper 18-Month Visual Inspection, Revision 13

- IR 1304076; Fire Drill Observation - Personnel Walking Through SIM Smoke,

December 17, 2011

- RM-AA-101; Records Management Program, Revision 9

- OP-AA-201-003; Fire Drill Performance, Revision 12

4 Attachment

Corrective Action Documents As a Result of NRC Inspection

IR 1291986; NRC Identified Fire Damper S-Hook Orientation Issue, November 17, 2011

IR 1304063; NRC Identified Issues with S-Hooks Not Resolved, December 17, 2011

Section 1R12: Maintenance Effectiveness (Quarterly)

- IR 1058790; Bad Fuse Found in 2RD06J Panel, April 20, 2011

- IR 1061760; MG Set Motor Smoked on Attempted PM Start, April 26, 2011

- IR 1062164; Motor Cutoff Switch Replaced for 2RD 05E-1B, April 27, 2011

- IR 1065922; Unit 2 Rods Will Not Manually Withdraw, May 5, 2010

- IR 1066455; Unit 2 RD07J Cabinet Capacitor Found Broken, May 6, 2011

- IR 1066490; 2A RD MG Set 1 OVT Timer Failed, May 6, 2011

- IR 1067031; Vibrations Levels on 2B Rod Drive MG Set Remain Unchanged, May 8, 2011

- IR 1290831; 1A RD MG Set Increased Vibrations, November 15, 2011

- BOP RD-5; Control Rod Drive MG Set Up and Paralleling to Operating Control Rod Drive MG

Set, Revision 10

Section 1R13: Maintenance Risk Assessments and Emergent Work Control (Quarterly)

- ER-AA-600-1042; On-Line Risk Management, Revision 7

- ER-AA-600-1021; Risk Management Application Methodologies, Revision 4

- PC-AA-1014; Risk Management, Revision 2

- 0BOA ENV-1; Adverse Weather Conditions Unit 0, Rev. 108

- 1BOA ENV-1; Adverse Weather Conditions Unit 0, Rev. 102

- 0BOA ENV-2; Rock River Abnormal Water Level Unit 0, Rev. 100

- IR 1285254; Rock River Level Low, November 2, 2011

Section 1R15: Operability Evaluations (Quarterly)

- IR 240597; Unplanned LOCAR Entry for 2A Emergency Diesel Generator Due to 2VD024YB

Damper

- IR 240972; Fire Damper S Hook Installed Improperly, August 2, 2004

- IR 240985; Need Work Request for Fire Damper Inspections, August 2, 2004

- IR 248940; Fire Damper Issues Identified by NRC, August 31, 2004

- IR 249486; Fire Damper S Hook Issue Identified by NRC, September 2, 2004

- IR 297682; NRC Question About Fire Damper S-Hooks, February 4, 2005

- IR 757875; Fire Damper S-Hooks, April 1, 2008

- IR 1285361; Potential Multiple Starts of Diesel Driven AF Pump, November 2, 2011

- IR 1291986; NRC Identified Fire Damper S-Hook Orientation Issue, November 17, 2011

- IR 1292337; Piping Between 2AF006B and 2AF017B Found Not Full, November 18, 2011

- IR 1295958; AF Improvement Suggestion, November 18, 2011

- IR 1295958; AF Improvement Suggestion, November 18, 2011

- IR 1295488; EOC Review of Byron IP 1291986 Fire Damper S-Hooks, November 29, 2011

- Three Mile Island Corrective Action Program Number TI999-0943 linked to ETTS # 25169;

One Section of Fire Damper AH-FD-22 Did Not Close During Test, October 1, 1999

- EC 350613; Evaluation of Fire Damper S-Hook Orientation Impact on Dampers 2VD24YB,

VC191Y and OVC193Y, August 11, 2004

- EC 350550; Evaluation of Fire Damper S-Hook Orientation Impact, August 31, 2004

- WO 1197473 01; Technical Specification Fire Damper 18 Month Visual Inspection,

December 3, 2009

5 Attachment

- EC 383229; Fill Empty Pipe Between 1AF006A and 1AF017A, Close Drain Valve 1AF018A,

and Throttle Open Vent Valve 1AF030A, Revision 0

- EC 383308; OP EVAL 11-003, Small Voids in 2A and 2B SX to AF Suction Piping, Revision 0

- EC 386578; OP Evaluation 11-009 Multiple Starts of Diesel AF Pump, November 8, 2011

- WO 1124519 01; Technical Specification Fire Damper 18 Month Visual Inspection,

April 14, 2008

- WO 848828 01; Technical Specification Fire Damper 18 Month Visual Inspection,

December 15, 2006

- BOP AF-3, Filling and Venting the Auxiliary Feedwater System, Revision 4

- M-1FW01147X; Drawing, Byron Unit 1 Support M-1FW01147X, Rev. D

- M-1SI06010X; Drawing, Byron Unit 1 M-1SI06010X Sub. E

- 13.1.29; Calculation for Mechanical Component Support M-1SI06010X, Rev. D

- 13.1.29; Calculation for Mechanical Component Support M-1SI06010X, Rev. E

- 13.1.29; Calculation for Mechanical Component Support M-1SI06025V, Rev. F

- 13.1.29-BYR97-359; 1SI06010X, 1SI06012X, 1SI06031X, 1SI06075X, 1SI06105X, and

1SI06155X. Evaluate Subsystem 1SI06 Supports for Additional Loads, Rev. 5

- 14.1.18-1FW01147; Calculation for Mechanical Component Support Number M-1FW01147X,

Rev. 0

- IR 1272187; Issues Applicable to Byron from Braidwood Mod/50.59 Inspection,

October 4, 2011

- BRW-97-0827-M; Piping Evaluation for Lead Shielding on Subsystem 2SI06, Rev. 0

- RH-2; Large Bore Isometric, Residual Heat Removal System, Rev. 22

- IR 1276280; UFSAR Section 3.6 and Piping Design Specifications are Inconsistent,

October 13, 2011

- IR 1276069; 1/2FW01 Piping Calculation Revisions Do Not Meet UFSAR Requirements,

October 13, 2011

- IR 1272834; Incorrect Coding of Support Skew on 1FW01 Piping, October 5, 2011

- EMD-064195; Calculation, Addendum E to Piping Stress Report for Subsystem 1SI06, Rev. 5

- IR 1262559; BOP ID: Small Shift Trend in Major Plant Parameters, September 13, 2011

- IR 1265515; U1 RX Power Lowered Below 99.5% for LEFM Troubleshooting,

September 16, 2011

- IR 1253439; LEFM Computer Point Is Off Normal Per 1BOSR CX-M1, August 19, 2011

- IR 1263929; LEFM Alarms in IR 1241271 and Card Analysis- OEM Review Results,

September 16, 2011

- IR 1241271; LEFM Trouble Alarm - Ramp Back, July 19, 2011

- IR 1241629; LEFM Trouble Alarm Causing Unit 1 Ramp Back Again, July 19, 2011

- IR 1277627; NRC Questions on HELB - Presence of Openings, October 17, 2011

- IR 1279759; Added Scope to Turbine Building HELB Effort, October 21, 2011

- IR 1244251; HELB Discussion with the NRC Residents, July 26, 2011

- IR 1240295; Two New Line Break Locations Identified During HELB Analysis, July 15, 2011

- IR 1238611; Inoperability of ESF Components Due To HELB, July 11, 2011

- IR 1237133; Non-Conservatism in Turbine Building HELB Analysis, July 6, 2011

- IR 1184258; Non-Conservatism in Turbine Building HELB Analysis, March 7, 2011

- IR 1276895; NRC Question - Effect of Turbine Building HELB on Reactor Trip Breakers,

October 14, 2011

Section 1R19: Post Maintenance Testing (Quarterly)

- IR 1272802; 2B CS Pump Did Not Auto Start During 2B DG Sequence Test, October 5, 2011

- WO 1476986 02; 2B CS Pump Did Not Auto Start During 2B DG Sequence Test,

October 5, 2011

6 Attachment

- WO 1476986 03; 2B CS Pump Did Not Auto Start During 2B DG Sequence Test,

October 5, 2011

- ER-AA-1200; Critical Component Failure Clock, Revision 7

- WO 1324847; 2AF014E IST Disassembly and Inspection, October 5, 2011

- WO 1324407; 2AF014G IST Disassembly and Inspection, October 5, 2011

- WO 1365478; 2AF014H IST Disassembly and Inspection, October 5, 2011

- 2BOSR 7.5.7-2; Unit 2 Train B Auxiliary Feedwater Flow Path Operability Surveillance

Following Shutdown, Rev. 6

- IR 1272927; 2B AF Static Pressure Gauge Indication Failed Low, October 5, 2011

- 2BOSR 0.5-2.RH.4-1; Unit 2 ASME Surveillance Requirements for Residual Heat Removal

Pump Miniflow Valve 2RH610, Revision 5

Section 1R20: Refueling and Other Outage Activities

- 2BGP 100-1; Plant Heatup, Revision 50

- 2BGP 100-2; Plant Startup, Revision 40

- 2BGP 100-3; Power Ascension, Revision 73

Section 1R22: Surveillance Testing (Quarterly)

- IR 128875; Error in RCS Leakrate Data in MCR Logs, November 10, 2011

- BOP AF-1; Diesel Driven Aux Feedwater Pump Alignment to Standby Condition, Revision 24

- BOP AF-7; Diesel Driven Auxiliary Feedwater Pump 1B Startup on Recirc, Revision 37

- BOP AF-7T1; Diesel Driven Auxiliary Feedwater Pump Operating Log, Revision 21

- BOP AF-8; Diesel Driven Auxiliary Feedwater Pump 1B Shutdown, Revision 22

- WO 1459476 01; 1AF01PB Group B IST Requirements for Diesel Driven AF Pump,

October 28, 2011

- 1BOSR 7.5.4-2; Unit 1 Diesel Driven Auxiliary Feedwater Pump Monthly Surveillance,

Revision 14

- 2BOSR 8.1.11-2; 2B Diesel Generator Sequencer Test 18 Month, Revision 11

- WO 1337989 01; 2B Diesel Generator Sequencer Test, October 5, 2011

- IR 1281160; 1SI8958B Failed Acceptance Criteria During 1B RH PP IST, October 25, 2011

- IR 1298289; Unit 2 RCS Leakrate Surveillance Needs Improvements, December 05, 2011

- 0BMSR FP-5; Fire Hydrant Yard Loop Annual Flush, Revision 8

- WO 1454082; 1RH01PB Group A IST Requirements for Residual Heat Removal Pump,

October 25, 2011

- IR 1281160; 1SI8958B Failed Acceptance Criteria During 1B RH PP IST, October 25, 2011

Corrective Action Documents As a Result of NRC Inspection

- IR 1304054; Surveillance Improvements Needed, December 17, 2011

2RS1: Radiological Hazard Assessment and Exposure Controls (71124.01)

- AR 1214604; NOS ID B1R17 RP Outage Adverse Trend; 5/11/2011

- AR 1243013; RP Response to Fire Alarm Did Not Meet Expectations; 7/22/2011

- AR 1248312; NOS ID Poor Contamination Boundary Controls in FHB; 8/5/2011

- BRP 5800-3; Area Radiation Monitoring System Alert/High Alarm Setpoints; Revision 25

- BRP 5820-14; Process Radiation Monitoring System Alert/High Alarm Setpoints; Revision 42

- RP-AA-460; Controls for High and Locked High Radiation Areas; Revision 20

- RP-AA-460-001; Controls for Very High Radiation Areas; Revision 2

7 Attachment

- RP-AA-460-003; Access to HRAs/LHRAs in Response to a Potential or Actual Emergency;

Revision 1

- RP-AP-460; Access to Reactor In-Core Sump Area; Revision 2

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

- Work Order 1094446 01; Non Accessible Charcoal Adsober Operability Test; 8/31/2009

- Work Order 1149597 01; Perform Recirc Charcoal Halide Test Control Room Ventilation

System; 3/16/2010

2RS4: Occupational Dose Assessment (71124.04)

- National Voluntary Laboratory Accreditation Program; Selected Records; Various Dates

2RS5: Radiation Monitoring Instrumentation (71124.05)

- AR 1106461; Non-Conservative Liquid Discharge Alarm Setpoints; 8/26/2010

- AR 1107149; Additional Investigation Required for ODCM/LCO Implementation; 8/29/2010

- AR 1302586; Non-Conservative Setpoints Found for TRM Rad Monitors; 12/14/2011

- AR 1303888; Potential RETS Impact Due to Non-Conservative PRM Setpoints; 12/16/2011

- BRP 5800-3; Area Radiation Monitoring System Alert/High Alarm Setpoints; Revision 25

- BRP 5820-12; Response to Area and Process Radiation Monitor LCOARS or Out of Service

Conditions; Revision 28

- BRP 5820-14; Process Radiation Monitoring System Alert/High Alarm Setpoints; Revision 42

- BYR-10-001; Calculation of Liquid Process Radiation Monitor Set Points; 8/30/2010

- RP-BR-951; Set Point Changes for Process Radiation Monitors; ODCM (Effluent) Monitors;

Revision 0.

2RS6: Radioactive Gaseous and Liquid Effluent Treatment (71124.06)

- 2009 Byron Station Annual Radioactive Effluent Release Report; April 30, 2010

- 2010 Byron Station Annual Radioactive Effluent Release Report; April 29, 2011

- AR 00978684; Effluent Monitor Surveillance Not Performed Per Procedure; dated October 13,

2009

- AR 00996917; Effluent Release Process - Potential Gaps; dated November 22, 2009

- AR 01106461; Non-Conservative Liquid Discharge Alarm Setpoints; dated August 26, 2010

- AR 01107146; Additional Investigation Required for ODCM/LCO Implementation; dated

August 29, 2010

- AR 01108146; Treatment of Ar-41 in Gaseous Effluents; dated August 31, 2010

- AR 1247902; 1/2 RE-PR-028 Particulate Filters Could Not Be Located; 8/4/2011

- BCP-400-TWX01; Liquid Radwaste Release from Release Tank OWX01T; Revision 59

- CY-AA-120-400; Closed Cooling Water Chemistry; Revision 13

- CY-AA-120-420; Auxiliary Boiler Chemistry; Revision 10

- CY-AA-130-201; Radiochemistry Quality Control; Revision 1

- CY-AA-170-000; Radioactive Effluent and Environmental Monitoring Programs; Revision 5

- CY-BY-170-301; Offsite Dose Calculation Manual; Revision 6

- CY-BY-170-301; Offsite Dose Calculation Manual; Revision 7

- FASA 1013272; Radioactive Gaseous and Liquid Effluents (RETS); 9/17/2010

- FASA 831375; Radioactive Gaseous and Liquid Effluents (RETS); 3/31/2009

- Gaseous Discharge Permit Number 110411; dated October 13, 2011

- Gaseous Discharge Permit Number 110445; dated October 31, 2011

8 Attachment

- Liquid Discharge Permit Number 110437; dated October 25, 2011

- RP-BY-900-1PR29J; 1PR29J Process Radiation Monitor Radiological Air Sampling;

Revision 2

- RP-BY-900-2PR29J; 2PR29J Process Radiation Monitor Radiological Air Sampling;

Revision 2

- Work Order 1110220 01; Fuel Handling Building Exhaust Charcoal Adsorber Bank Operability

Test; 12/21/2009

- Work Order 1236016 01; Perform Calibration of Rad Monitor 1PR28J; 1/18/2011

- Work Order 1249358 01; Perform Surveillance Test of 2PR28J; 4/26/2011

2RS7: Radiological Environmental Monitoring Program (71124.07)

- 2009 Byron Station Annual Radiological Environmental Operating Report; May 2010

- 2010 Byron Station Annual Radiological Environmental Operating Report; May 2011

- 2010 Land Use Census; dated August 30, 2010

- AR 00958298; ODCM Vent Stack Coordinates Inaccurate; dated August 27, 2009

- AR 01034880; REMP Milk Sample - Invalid Result; dated February 24, 2010

- AR 01090911; REMP Groundwater Sample Location No Longer Participating; dated July 15,

2010

- AR 01122156; REMP Sample Results above Detection Limit; dated October 5, 2010

- AR 01129610; Check-In Self-Assessment on the Radiological Environmental Monitoring

Program (REMP); Approved June 20, 2011

- AR 01223226; REMP Air Samples - Positive Detects for I-131; dated June 1, 2011

- Environmental, Inc. Sampling Manual, Revision 13

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

and Transportation (71124.08)

- AR 1015646; Non-Conforming Waste Found in Radwaste Shipment; 1/12/2010

- AR 1067394; Non-Conforming Radioactive Waste in Shipment; 5/10/2010

- AR 1173307; RWS10-013 Contained Unapproved Mixed Waste; 2/10/2011

- AR 1221229; RWS11-006 Contained Un-Manifested Asbestos; 5/26/2011

- AR 1231158; RWS11-001 Manifested for Material Not Present; 6/21/2011

- AR 1233858; NOS ID: Cause of IR Incorrect RW Shipping Paperwork Not Identified;

6/28/2011

- AR 1250262; NOS ID: RP Failed to Address NOS Issues - Finding; 8/11/2011

- AR 1270337; Sea/Land Inventory Not Documented in Accordance with T&RM; 9/30/2011

- AR 1285148; QHPI Request for RP - RWS Manifest; 11/2/2011

- AR 1285591; NRC Identified: DAW Container Inspections Outside of Procedure Guidance;

11/3/2011

- AR 928393928393 Non-Conforming Metal Shipped to Bear Creek Processing; 6/5/2009

- Course Code N-RPCTAR; DBIG RAM Shipping/Inspection; Revision 0

- FASA 9866572-03; Radioactive Solid Waste Processing and Radioactive Material Handling,

Storage and Transportation; 4/26/2011

- Letter BYRON-2008-0123; Report of Changes, Tests, and Experiments; 12/12/2008

- Letter BYRON-2010-0147; Report of Changes, Tests, and Experiments; 12/13/2010

- Module/LP ID RPTI 8.05; Radioactive Material Shipments; Revision 18

- NOSA-BYR-10-04 (AR 969170969170; Chemistry, Radwaste, Effluent and Environmental Monitoring

Audit Report; 6/2/2010

- NOSA-BYR-11-06 (AR 1130876); Radiation Protection; 8/18/2011

9 Attachment

- Performance Training and Evaluation; Task 509-004; Provide Radiological Protection

Coverage During the Preparation of a Shipment of Radioactive Material; 11/5/2009

- Performance Training and Evaluation; Task 509-010; Perform Surveys on Radioactive

Material Transport Vehicles; date not provided

- Performance Training and Evaluation; Task 509-013; Receipt Survey of Radioactive Material;

- Radiation Protection Technician/Continuing Training; DBIG: Waste Acceptance Guidelines;

Revision 0

- RP-AA-100; Process Control Program for Radioactive Wastes; Revision 7

- RP-AA-600; Radioactive Material/Waste Shipments; Revision 12

- RP-AA-600-1001; Exclusive Use and Emergency Response Information; Revision 6

- RP-AA-600-1003; Radioactive Waste Shipments to Barnwell and Defense Consolidation

Facility (DCF); Revision 7

- RP-AA-600-1004; Radioactive Waste Shipments to Energy Solutions Clive Utah Disposal Site

Containerized Waste Facility; Revision 9

- RP-AA-600-1005; Radioactive Material and Non Disposal Site Waste Shipments; Revision 12

- RP-AA-601; Surveying Radioactive Material Shipments; Revision 13

- RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 01/20/2011

- RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 06/02/2011

- RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 10/03/2009

- RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 10/19/2010

- RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 2/17/2010

- RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 8/18/2010

- RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 9/16/2011

- RP-AA-605 Attachment 2; Waste Stream Results Review; DAW; 1/20/2011

- RP-AA-605 Attachment 2; Waste Stream Results Review; DAW; 3/30/2011

- RP-AA-605 Attachment 2; Waste Stream Results Review; DAW; 4/18/2010

- RP-AA-605 Attachment 2; Waste Stream Results Review; Primary Resin; 3/10/2010

- RP-AA-605 Attachment 2; Waste Stream Results Review; Secondary Radwaste Filter;

4/24/2010

- RP-AA-605 Attachment 2; Waste Stream Results Review; Secondary Resin; 3/25/2010

- RP-AA-605; 10 CFR Part 61 Program; Revision 4

- Shipment RMS09-094; Rx Vessel Dosimetry; Type A Package; 11/18/2009

- Shipment RMS11-078; Dirty Laundry; Low Specific Activity (LSA-II); 4/27/2011

- Shipment RWS10-011; Dewatered Bead Resin; Low Specific Activity (LSA-II); 6/29/2010

- Shipment RWS10-012; DAW Trash; Low Specific Activity (LSA-II); 9/1/2010

- Shipment RWS10-013; DAW Trash and TR Pond Sludge; Low Specific Activity (LSA-II);

9/1/2010

Section 4OA1: Performance Indicator Verification (71151)

- IR 1139610; Potential Non-Conservative Tech Specs for Component Cooling;

November 12, 2010

- IR 1139728; CC System OLR Impact From IR 1139610; November 12, 2010

- IR 1141591; 2A DG Emergency Stopped Due to Oil Leak; November 17, 2010

- IR 1158910; RH System Issue Resulting in LER - Tracking; January 05, 2011

- IR 1128409; Threshold for SSFF Approaching White Region; June 14, 2011

- IR 1284054; Legacy Issues with Main Steam Tunnel Pressurization Calculation;

October 31, 2011

- LS-AA-2080; NRC Safety System Functional Failure - July 2010 to July 2011, Revision 4

- EC 382262; Byron OpEval #10-006 - U-0 CC Pump Potential Non-Conservative Tech Spec

10 Attachment

- LER 454/2010-001; Technical Specifications Allowed Outage Time Extension Request for

Component Cooling System Contained Inaccurate Design Information that Significantly

Impacted the Technical Justification, November 12, 2010

- LER 454/2011-001; Potential Loss of Residual Heat Removal System Safety Function in Mode

4 When Aligned for Shutdown Cooling Due to Potential for Flashing or Voiding of Coolant

During a Shutdown Loss of Cooling Accident, January 5, 2011

- LER 455/2011-001; Unit 2 Emergency Diesel Generator Inoperable for Longer than Allowed

by Technical Specifications Due to Inadequate Work, November 17, 2011

- NEI 99-02 Revision 6; Regulatory Assessment Performance Indicator Guideline, October 2009

- Reactor Oversight Program MSPI Basis Document Revision 3; December 2006

- Monthly Data Elements for NRC Reactor Coolant System (RCS) Specific Activity, October

2010 - September 2011

- PWR High Pressure Safety Injection Function, October 2010 - September 2011

- Residual Heat Removal Function, October 2010 - September 2011

- PWR Auxiliary Feedwater/Emergency Feedwater Function, October 2010 - September 2011

- Cooling Water Support Function, October 2010 - September 2011

- IR 1154673; Unable to Perform Manual Stroke Surveillance of 1SX150A, December 20, 2010

- IR 1152376; Unit 2 CWS MSPI Exelon At-Risk, December 14, 2010

- IR 1263487; CWS2 (SX) MSPI Low Margin, September 15, 2011

- IR 1090691; Unit 1 CWS MSPI At-Risk, July 14, 2010

- Monthly Data Elements for NRC Unplanned Power Changes Per 7000 Critical Hours, June

2010 - October 2011

- IR 1259684; Byron PI in Variance - P.8.1.2 Unplanned Power Changes, September 6, 2011

- IR 1116305; Runback of Byron Station U-1 Due to 1A FW PP Trip, September 22, 2010

Section 4OA2: Identification and Resolution of Problems (71152)

- IR 1271650; Difference Between Byron & Braidwood PPC Point Calcs Y2021 & Y2022

- IR 1282689; Pin Hole Leak in Area 7 on 2RY8028 P-44

- IR 1289655; IR Indicates DG Fire Pump Started in Over Ride for Test CCP,

November 04, 2011

- 2BwOSR 3.8.1.14-2; 2B DG 24 Hour Endurance Run, Revision 5

- WO 1323726; 2B DG 24 Hour Endurance Run 18 Month, September 13, 2011

- Analysis BYR11-036; Turbine Building HELB and Room Heat Up Analyses for MUR PU,

Revision 0

- EC 383599; Op Eval 11-005, Turbine Building HELB Analysis Input Errors, Revision 1

- OWA Board Meeting Minutes; Year 2010 Quarter 4, December 28, 2010

- OWA Board Meeting Minutes; Year 2011 Quarter 1, April 5, 2011

- OWA Board Meeting Minutes; Year 2011 Quarter 2, June 30, 2011

- OWA Board Meeting Minutes; Year 2011 Quarter 3, October 14, 2011

- OWA Related IRs; 4Q2010 - 3Q2011

- IR 806396; Both Units SD Systems Degraded for >5 Years, August 12, 2008

- IR 1007239; Review SJAE Strainer Plugging for OWA/OC, December 18, 2009

- IR 1106359; Common Cause - Recommend Venting SD During Stroke Time Surveillance,

August 26, 2010

- IR 1118055; 2A Main Feed Pump Recirc Not Modulating Properly, September 26, 2010

- IR 1122751; Missed Fire Watches in the Past, October 06, 2010

- IR 1151298; Unit 1 Tower Overflow, December 12, 2010

- IR 1155725; Caustic Dilution Flow Only Reading 6 GPM, December 24, 2010

- IR 1158940; Multiple Failure of Employee Alarm System, January 1, 2011

- IR 1169182; MMD Support for 2B FW Pump Turning Gear Operation, January 31, 2011

11 Attachment

- IR 1172246; 0CW278A, Through Wall Crack on Valve Body, February 08, 2011

- IR 1172509; 0CW220 Flow Control Valve Not Repositioning Upon Demand,

February 08, 2011

- IR 1194212; Operator Work Around, March 29, 2011

- IR 1194754; RSH CO2 TK Repair(s) Need to Be Expedited, March 30, 2011

- IR 1194754; Missed Closure of ATI, January 09, 2004

- IR 1211839; 2WG046 Drip Pan is Removed Consider Operator Challenge, May 4, 2011

- IR 1212344; Degradation of RSH CO2 Worsens, May 5, 2011

- IR 1216461; 2B CW PP Intake DP 9 Jumped to 2, May 16, 2011

Corrective Action Documents As a Result of NRC Inspection

- IR 1276895; NRC Question - Effect of TB HELB on Reactor Trip Breakers, October 14, 2011

- IR 1278980; NRC Question - Maintaining VCT Pressure High for Chemistry, October 18, 2011

Section 1EP4: Emergency Action Level and Emergency Plan Changes

- EP-AA-1002; Exelon Nuclear Radiological Emergency Plan Annex for Byron Station;

Revisions 26, 27, and 28

- EP-AA-120-1001; 50.54(q) Program Evaluation and Effectiveness Reviews for Revisions 27

and 28

- EP-AA-120-F-01; EP Document Approval Forms for Revisions 27 and 28

12 Attachment

LIST OF ACRONYMS USED

ADAMS Agencywide Document Access Management System

AF Auxiliary Feedwater

ALARA As-Low-As-Is-Reasonably-Achievable

ANSI American National Standards Institute

ASME American Society of Mechanical Engineers

CAP Corrective Action Program

CFR Code of Federal Regulations

CLB Current Licensing Basis

DAW Dry Active Waste

DG Emergency Diesel Generator

DOT Department of Transportation

EAL Emergency Action Level

ESF Engineered Safety Feature

HELB High Energy Line Break

HVAC Heating, Ventilation, and Air Conditioning

IMC Inspection Manual Chapter

IP Inspection Procedure

IR Inspection Report

IR Issue Report

IST Inservice Testing

LER Licensee Event Report

LORT Licensed Operator Requalification Training

MEER Miscellaneous Electrical Equipment Room

MG Motor Generator

NEI Nuclear Energy Institute

OBE Operating Basis Earthquake

ODCM Offsite Dose Calculation Manual

OOS Out of Service

OpEval Operability Evaluation

OSP Outage Safety Plan

OWA Operator Workaround

psig pound per square inch gauge

MSPI Mitigating Systems Performance Index

NCV Non-Cited Violation

NRC U.S. Nuclear Regulatory Commission

NVLAP National Voluntary Laboratory Accreditation Program

PI Performance Indicator

RCS Reactor Coolant System

RFO Refueling Outage

RHR Residual Heat Removal

RWST Refueling Water Storage Tank

SDP Significance Determination Process

SH Station Heating

SRP Standard Review Plan

SSC Structure, System, and Component

SX Essential Service Water

TLD Thermoluminescent Detector

TS Technical Specification

13 Attachment

UFSAR Updated Final Safety Analysis Report

UL Underwriters Laboratory

URI Unresolved Item

VA Auxiliary Building Ventilation

WO Work Order 14 Attachment

M. Pacilio -2-

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

enclosure will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Records (PARS) component of NRC's document system

(ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the

Public Electronic Reading Room).

Sincerely,

/RA/

Eric R. Duncan, Chief

Branch 3

Division of Reactor Projects

Docket Nos. 50-454; 50-455

License Nos. NPF-37; NPF-66

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

w/Attachment: Supplemental Information

cc w/encl: Distribution via ListServ

DOCUMENT NAME: G:\DRPIII\BYRO\Byron 2011 005.docx

Publicly Available Non-Publicly Available Sensitive Non-Sensitive

To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy

OFFICE RIII

NAME EDuncan:dtp

DATE 02/07/12

OFFICIAL RECORD COPY

Letter to M. Pacilio from E. Duncan dated February 7, 2012.

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

REPORT 05000454/2011005; 05000455/2011005

DISTRIBUTION:

Breeda Reilly

RidsNrrDorlLpl3-2 Resource

RidsNrrPMByron Resource

RidsNrrDirsIrib Resource

Cynthia Pederson

Jennifer Uhle

Steven Orth

Jared Heck

Allan Barker

Carole Ariano

Linda Linn

DRPIII

DRSIII

Patricia Buckley

Tammy Tomczak

ROPreports.Resource@nrc.gov

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