ML17128A109

Integrated Inspection Report 05000333/2017001

ML17128A109
Person / Time
Site:	FitzPatrick
Issue date:	05/08/2017
From:	Arthur Burritt NRC/RGN-I/DRP/PB5
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
Burritt A
References
IR 2017001
Download: ML17128A109 (32)

See also: IR 05000333/2017001

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION I

2100 RENAISSANCE BLVD., SUITE 100

KING OF PRUSSIA, PA 19406-2713

May 8, 2017

Mr. Bryan C. Hanson

Senior Vice President, Exelon Generation Company, LLC

President and Chief Nuclear Officer, Exelon Nuclear

4300 Winfield Road

Warrenville, IL 60555

SUBJECT: JAMES A. FITZPATRICK NUCLEAR POWER PLANT - INTEGRATED

INSPECTION REPORT 05000333/2017001

Dear Mr. Hanson:

On March 31, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection

at the James A. FitzPatrick Nuclear Power Plant (FitzPatrick). On April 19, 2017, the NRC

inspectors discussed the results of this inspection with Mr. Joseph Pacher, Site Vice President,

and other members of your staff. The results of this inspection are documented in the enclosed

report.

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

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

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

in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Arthur L. Burritt, Chief

Reactor Projects Branch 5

Division of Reactor Projects

Docket No. 50-333

License No. DPR-59

Enclosure:

Inspection Report 05000333/2017001

w/Attachment: Supplementary Information

cc w/encl: Distribution via ListServ

ML17128A109

SUNSI Review Non-Sensitive Publicly Available

Sensitive Non-Publicly Available

OFFICE RI/DRP RI/DRP RI/DRP

NAME BSienel via email MDraxton ABurritt

DATE 5/4/17 5/4/17 5/8/17

1

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket No. 50-333

License No. DPR-59

Report No. 05000333/2017001

Licensee: Exelon Generation Company, LLC

Facility: James A. FitzPatrick Nuclear Power Plant

Location: Scriba, NY

Dates: January 1, 2017, through March 31, 2017

Inspectors: B. Sienel, Senior Resident Inspector

J. Pfingsten, Resident Inspector

G. Stock, Resident Inspector

S. Anderson, Reactor Inspector

E. Burket, Reactor Inspector

R. Rolph, Health Physicist

Approved By: Arthur L. Burritt, Chief

Reactor Projects Branch 5

Division of Reactor Projects

Enclosure

2

TABLE OF CONTENTS

SUMMARY .................................................................................................................................... 3

1. REACTOR SAFETY .............................................................................................................. 4

1R04 Equipment Alignment .................................................................................................. 4

1R05 Fire Protection ............................................................................................................. 5

1R08 Inservice Inspection .................................................................................................... 5

1R11 Licensed Operator Requalification Program and Licensed Operator Performance .... 8

1R12 Maintenance Effectiveness ......................................................................................... 9

1R13 Maintenance Risk Assessments and Emergent Work Control ................................... 9

1R15 Operability Determinations and Functionality Assessments ..................................... 10

1R18 Plant Modifications .................................................................................................... 11

1R19 Post-Maintenance Testing ........................................................................................ 11

1R20 Refueling and Other Outage Activities ...................................................................... 12

1R22 Surveillance Testing.................................................................................................. 13

2. RADIATION SAFETY .......................................................................................................... 14

2RS1 Radiological Hazard Assessment and Exposure Controls ........................................ 14

2RS3 In-Plant Airborne Radioactivity Control and Mitigation .............................................. 15

2RS4 Occupational Dose Assessment ............................................................................... 15

4. OTHER ACTIVITIES ............................................................................................................ 16

4OA1 Performance Indicator Verification ............................................................................ 16

4OA2 Problem Identification and Resolution ...................................................................... 17

4OA3 Follow-Up of Events and Notices of Enforcement Discretion.................................... 19

4OA5 Other Activities .......................................................................................................... 20

4OA6 Meetings, Including Exit ............................................................................................ 21

SUPPLEMENTARY INFORMATION ........................................................................................ A-1

KEY POINTS OF CONTACT .................................................................................................... A-1

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED ..................................... A-1

LIST OF DOCUMENTS REVIEWED ........................................................................................ A-2

LIST OF ACRONYMS ............................................................................................................... A-9

3

SUMMARY

IR 05000333/2017001; 01/01/2017 - 03/31/2017; James A. FitzPatrick Nuclear Power Plant

(FitzPatrick); Routine Integrated Inspection Report.

This report covered a three-month period of inspection by resident inspectors and announced

baseline inspections performed by regional inspectors. The significance of most findings is

indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined

using Inspection Manual Chapter (IMC) 0609, Significance Determination Process, dated

October 28, 2016. Cross-cutting aspects are determined using IMC 0310, Aspects Within

Cross-Cutting Areas, dated December 4, 2014. All violations of NRC requirements are

dispositioned in accordance with the NRCs Enforcement Policy, dated November 1, 2016. The

NRCs program for overseeing the safe operation of commercial nuclear power reactors is

described in NUREG-1649, Reactor Oversight Process, Revision 6.

No findings were identified.

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REPORT DETAILS

Summary of Plant Status

FitzPatrick began the inspection period operating at approximately 57 percent power, the

maximum power achievable due to fuel depletion as the reactor was at the end of this operating

cycle. Due to fuel depletion, power continued to decrease to approximately 54 percent on

January 13, 2017. On January 14, operators shut down the reactor to commence refueling

outage (RFO) 22. Upon completion of refueling and maintenance activities, operators

performed a reactor startup on February 23. The generator was placed online February 25,

2017, ending RFO 22. Operators increased reactor power to approximately 91 percent on

February 27. On February 28, operators reduced power to approximately 54 percent for a

control rod pattern adjustment. Operators increased power to approximately 100 percent on

March 1. Operators reduced power to 89 percent for another rod pattern adjustment on

March 2. Power was restored to 100 percent later that day, where it remained for the rest of the

inspection period.

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R04 Equipment Alignment

Partial System Walkdowns (71111.04 - 4 samples)

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems:

B core spray system while protected for shutdown risk during RFO 22 on

January 18, 2017

A core spray system while protected for shutdown risk during RFO 22 on

January 26, 2017

Residual heat removal (RHR) shutdown cooling during RFO 22 on February 9, 2017

A RHR system during planned maintenance on the B RHR system on

March 7, 2017

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

reactor safety cornerstones at the time they were inspected. The inspectors reviewed

applicable operating procedures, system diagrams, the Updated Final Safety Analysis

Report (UFSAR), technical specifications (TSs), work orders (WOs), condition reports

(CRs), and the impact of ongoing work activities on redundant trains of equipment in

order to identify conditions that could have impacted the systems performance of its

intended safety functions. The inspectors also performed field walkdowns of accessible

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

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

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

were no deficiencies. The inspectors also reviewed whether the licensee had properly

identified equipment issues and entered them into the corrective action program (CAP)

for resolution with the appropriate significance characterization.

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b. Findings

No findings were identified.

1R05 Fire Protection

Resident Inspector Quarterly Walkdowns (71111.05Q - 5 samples)

a. Inspection Scope

The inspectors conducted tours of the areas listed below to assess the material

condition and operational status of fire protection features. The inspectors verified that

the licensee controlled combustible materials and ignition sources in accordance with

administrative procedures. The inspectors verified that fire protection and suppression

equipment was available for use as specified in the area pre-fire plan, and passive fire

barriers were maintained in good material condition. The inspectors also verified that

station personnel implemented compensatory measures for out of service, degraded, or

inoperable fire protection equipment, as applicable, in accordance with procedures.

Turbine building, 272 foot elevation, fire zone TB-1 on January 20, 2017

Turbine building, 300 foot elevation and 292 foot elevation, fire zone TB-1 on

January 20, 2017

Relay room, fire area/zone VII/RR-1 on February 27, 2017

Reactor building, 272 foot elevation, fire area/zone IX/RB-1A on February 28, 2017

Reactor building, 300 foot elevation, fire area/zone VIII/RB-1C, IX/RB-1A, X/RB-1B

on March 16, 2017

b. Findings

No findings were identified.

1R08 Inservice Inspection (71111.08G - 1 sample)

a. Inspection Scope

From January 23 to 26, 2017, the inspectors conducted an inspection and review of

inservice examination activities in order to assess the effectiveness of the licensees

program for monitoring degradation of the reactor coolant system boundary, risk-

significant piping and components, and containment systems during FitzPatrick RFO 22.

The sample selection was based on the inspection procedure objectives and risk priority

of those pressure retaining components in these systems where degradation would

result in a significant increase in risk.

Non-Destructive Examination (NDE) and Welding Activities (Section 02.01)

The inspectors observed or reviewed the following NDE activities and completed data

records:

Manual phased array ultrasonic testing (UT), volumetric inspection, American

Society of Mechanical Engineers (ASME) Class 1, 24 inch A RHR dissimilar

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metal weld 24-10-130, and 24 inch B RHR dissimilar metal welds, 24-10-142

and 24-10-144

Visual testing (VT), visual inspection record, ASME International Welding

Engineer (IWE) Examination Category E-A, general visual examination of

exterior containment surfaces from elevations 272-369

VT inspection record and video review, ASME IWE Category E-A, general visual

examination of torus below the water line surfaces

For each evaluation, the inspectors verified NDE activities were performed in

accordance with the 2001 Edition, 2003 Addenda, of the ASME Boiler and Pressure

Vessel (BPV) Code requirements. The inspectors also verified the NDE activities met

the requirements contained in ASME Section XI, Mandatory Appendix VIII,

Article VIII-2000 and the examination personnel were qualified in accordance with ASME

Section XI, Mandatory Appendix VII. The inspectors verified that indications and

defects, if present, were dispositioned in accordance with the ASME Code.

For the general visual examinations, the inspectors ensured that difficult to access areas

or areas made visible by maintenance activities were included within the scope of the

visual examination. Additionally, the inspectors verified the basis for declaring some

containment areas as inaccessible for visual examination by comparing the basis

against previous containment visual examination records.

The inspectors also performed a walk down of the accessible areas of the drywell to

independently assess the condition of the drywell liner.

The inspectors reviewed video of the VT, including VT-3, VT-1, and EVT-1; and results

of several components examined in accordance with the licensees boiling water reactor

vessel and internals project in-vessel visual inspection program. The inspectors verified

the activities were performed in accordance with the licensees augmented inspection

program and associated examination procedure. The inspectors verified indications and

defects, if present, were dispositioned in accordance with the licensees procedures and

NRC requirements.

Re-examination of an Indication Previously Accepted for Service after Analysis

A relevant linear indication was identified in integral attachment weld 24-29-626A pipe

support saddle during the previous outage, RFO 21. An analysis was performed and the

indication was accepted for continued service until the RFO 22 refueling outage.

The inspectors reviewed the NDE summary reports for the VT, magnetic particle testing,

and liquid penetrant testing for the relevant indication to verify the activities were

performed in accordance with the 2001 Edition, 2003 Addenda, of the ASME BPV Code

requirements. The inspectors also reviewed the engineering evaluation to verify the

analysis was consistent with the guidance in ASME Section XI, IWB-3132.3, Acceptance

by Analytical Evaluation.

Modification/Repair/Replacement Consisting of Welding on Pressure Boundary Risk

Significant Systems

The inspectors reviewed the welding activity documentation and associated NDE results

for the repair of the relevant indication previously identified on the ASME Class 1 main

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steam system integral attachment weld 24-29-626A. The inspectors verified that the

welding, NDE, and acceptance were performed in accordance with the 2001 Edition,

2003 Addenda of the ASME BPV Code requirements and the licensees repair and

replacement program. Specifically, the inspectors verified the welding procedure

specification contained the essential, and where applicable, the supplemental essential

variables, in conformance with ASME Section IX, QW-200, and that the weld variables

were within the range qualified by the supporting procedure qualification record as

required by ASME Code Section IX, QW-250.

Identification and Resolution of Problems (IMC 02.05)

The inspectors reviewed a sample of CRs which identified NDE indications, deficiencies,

and other nonconforming conditions since the previous RFO. The inspectors verified

that nonconforming conditions were properly identified, characterized, evaluated,

corrective actions identified and dispositioned, and appropriately entered into the CAP.

b. Findings

Introduction. The inspectors identified an unresolved item (URI) during the inspection

and concluded that additional information was needed to determine if a performance

deficiency existed and if so, whether the issue is more than minor and/or involves a

violation of regulatory requirements. Specifically, the inspectors noted a discrepancy in

the license renewal application for FitzPatrick and subsequent response to an audit

question regarding the existence and inspection of a moisture barrier in the drywell

between the concrete floor and metal liner.

Description. While evaluating drywell containment examination records, the inspectors

reviewed FitzPatrick license renewal documents related to the drywell and identified an

issue for which more information is needed to determine whether there is a performance

deficiency. Specifically, the inspectors noted that NUREG-1905, Safety Evaluation

Report Related to the License Renewal of James A. FitzPatrick Nuclear Power Plant,

(ML081510826) referenced a drywell floor moisture barrier in Section 3.5.2.1.1.

However, during a drywell walkdown, the inspectors noted that no moisture barrier

existed on the drywell floor between the drywell liner and the concrete floor. The

inspectors further noted that Section 3.5.2.2.1.4 of the initial license renewal application

(ML062160494) submitted in July 2006, described a moisture barrier that was to be

inspected as part of the IWE Program and Structures Monitoring Program, and that in

Amendment 9 to the license renewal application (ML071060390), an audit question

discussed the moisture barrier condition.

The inspectors noted that this location in the drywell was visually inspected once per

period in accordance with the licensees Fourth Ten-Year Interval Inservice Inspection

Program, SEP-ISI-007, and that inspection results have not shown significant liner

degradation. Additionally, the licensee performs augmented UT thickness inspections of

the drywell liner interface in accordance with their augmented inspection program.

In response to the inspectors concerns, the licensee entered this issue into the CAP as

CR-JAF-2017-00906 for further evaluation. For the first corrective action (CA 1) in the

CR, the licensee reviewed inspection reports, design requirements, and drawings to

determine whether a moisture barrier previously existed between the containment

drywell liner and containment drywell concrete floor. The licensee concluded on

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February 16, 2017, that the moisture barrier had never existed in that location. The

licensee has a planned corrective action (CA 2) to determine the appropriate actions to

address the apparent discrepancy in information with a due date of May 24, 2017. The

inspectors will review the licensees conclusions and assessment of the issue and

independently determine whether there is a performance deficiency and if so, whether

the issue is more than minor and/or involves a violation of regulatory requirements.

Pending resolution, this issue is an URI. (URI 05000333/2017001-01, Drywell Moisture

Barrier Description in License Renewal Application)

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

(71111.11Q - 2 samples)

.1 Quarterly Review of Licensed Operator Requalification Testing and Training

a. Inspection Scope

The inspectors observed a licensed operator simulator exam on March 22, 2017, which

included an earthquake and unisolable torus leak. The inspectors evaluated operator

performance during the simulated event and verified completion of risk significant

operator actions, including the use of abnormal and emergency operating procedures.

The inspectors assessed the clarity and effectiveness of communications,

implementation of actions in response to alarms and degrading plant conditions, and the

oversight and direction provided by the control room supervisor. The inspectors verified

the accuracy and timeliness of the emergency classification made by the shift manager

and the TS action statements entered by the crew. Additionally, the inspectors assessed

the ability of the crew and training staff to identify and document crew performance

problems.

b. Findings

No findings were identified.

.2 Quarterly Review of Licensed Operator Performance in the Main Control Room

a. Inspection Scope

On January 14, 2017, the inspectors observed control room operators during the reactor

shutdown for RFO 22. Portions of the reactor shutdown including crew briefs; control

rod insertion; removal of the main generator from service; and main turbine, nuclear

instrumentation, and rod worth minimizer testing were observed. The inspectors

observed crew performance to verify that procedure use, crew communications, and

coordination of activities between work groups met established expectations and

standards.

b. Findings

No findings were identified.

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1R12 Maintenance Effectiveness (71111.12Q - 2 samples)

a. Inspection Scope

The inspectors reviewed the samples listed below to assess the effectiveness of

maintenance activities on structure, system, and component performance and reliability.

The inspectors reviewed system health reports, CAP documents, maintenance WOs,

and maintenance rule basis documents to ensure that the licensee was identifying and

properly evaluating performance problems within the scope of the maintenance rule. For

each sample selected, the inspectors verified that the structure, system, or component

was properly scoped into the maintenance rule in accordance with Title 10 of the Code

of Federal Regulations (10 CFR) 50.65 and verified that the (a)(2) performance criteria

established by licensee staff was reasonable. As applicable, for structures, systems,

and components classified as (a)(1), the inspectors assessed the adequacy of goals and

corrective actions to return these structures, systems, and components to (a)(2).

Additionally, the inspectors ensured that licensee staff was identifying and addressing

common cause failures that occurred within and across maintenance rule system

boundaries.

Main steam isolation valve (MSIV) local leak-rate test results during RFO 22

Residual heat removal service water (RHRSW) keep full service water supply line silt

buildup on January 25, 2017

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - 5 samples)

a. Inspection Scope

The inspectors reviewed station evaluation and management of plant risk for the

maintenance and emergent work activities listed below to verify that the licensee

performed the appropriate risk assessments prior to removing equipment for work. The

inspectors selected these activities based on potential risk significance relative to the

reactor safety cornerstones. As applicable for each activity, the inspectors verified that

licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and

that the assessments were accurate and complete. When the licensee performed

emergent work, the inspectors verified that operations personnel promptly assessed and

managed plant risk. The inspectors reviewed the scope of maintenance work and

discussed the results of the assessment with the stations probabilistic risk analyst to

verify plant conditions were consistent with the risk assessment. The inspectors also

reviewed the TS requirements and inspected portions of redundant safety systems,

when applicable, to verify risk analysis assumptions were valid, and applicable

requirements were met.

66UC-22H, east crescent area unit cooler isolation following identification of

increased erosion on January 3, 2017

Shutdown risk assessment for risk window 2/3 during RFO 22 on January 18, 2017

10

Outage risk assessment during operation with a potential for draining the reactor

vessel (OPDRV) window on January 23, 2017

Outage risk during emergent welding activities (OPDRV) on February 1, 2017

Planned maintenance on the A low pressure coolant injection inverter the week of

March 20, 2017

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments (71111.15 - 5 samples)

a. Inspection Scope

The inspectors reviewed operability determinations for the following degraded or non-

conforming conditions based on the risk significance of the associated components and

systems:

CR-JAF-2017-0575 concerning operability of the B source range monitor on

January 26, 2017

CR-JAF-2017-0610 regarding operability of 10AOV68B after failing to fully stroke for

surveillance testing on January 26, 2017

EC 69512 concerning RHR strainer functionality during the RFO 22 performance of

ST-9CB with a temporary repair installed (before the temporary modification

installation) on February 1, 2017

CR-JAF-2017-0848 regarding core cell 38-39 operability with a loose alignment pin

and modified fuel support casting on February 7, 2017

CR-JAF-2017-0812 concerning RHR strainer operability with temporary modification

installed for operating cycle 23 on February 14, 2017

The inspectors evaluated the technical adequacy of the operability determinations to

assess whether 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

TSs and UFSAR to the licensees evaluations to determine whether the components or

systems were operable. The inspectors confirmed, where appropriate, compliance with

bounding limitations associated with the evaluations. Where compensatory measures

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

in place would function as intended and were properly controlled by the licensee.

b. Findings

No findings were identified.

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1R18 Plant Modifications (71111.18 - 3 samples)

.1 Temporary Modifications

a. Inspection Scope

The inspectors reviewed the temporary modifications listed below to determine whether

the modifications affected the safety functions of systems that are important to safety.

The inspectors reviewed 10 CFR 50.59 documentation and post-modification testing

results, and conducted field walkdowns of the modifications to verify that the temporary

modifications did not degrade the design bases, licensing bases, and performance

capability of the affected systems.

Engineering change (EC) 66088, provide isolation between RHRSW and secondary

containment for work on 10MOV-89B on January 31, 2017

EC 69507, temporary RHR suction strainer shells on February 7, 2017

b. Findings

No findings were identified.

.2 Permanent Modifications

a. Inspection Scope

The inspectors evaluated a permanent modification to replace 10MOV-89B, RHR heat

exchanger B service water outlet isolation valve, implemented by EC 67365, 10 MOV-

89A/B replacement. The inspectors verified that the design bases, licensing bases, and

performance capability of the affected system were not degraded by the modification. In

addition, the inspectors reviewed modification documents associated with the upgrade

and design change. The inspectors also reviewed the successfully completed

surveillance test conducted to verify system operability following the valve replacement.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing (71111.19 - 8 samples)

a. Inspection Scope

The inspectors reviewed the post-maintenance tests for the maintenance activities listed

below to verify that procedures and test activities adequately tested the safety functions

that may have been affected by the maintenance activity, that the acceptance criteria in

the procedure were consistent with the information in the applicable licensing basis

and/or design basis documents, and that the test results were properly reviewed and

accepted and problems were appropriately documented. The inspectors also walked

down the affected job site, observed the pre-job brief and post-job critique where

possible, confirmed work site cleanliness was maintained, and witnessed the test or

reviewed test data to verify quality control hold points were performed and checked, and

that results adequately demonstrated restoration of the affected safety functions.

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WO 341278, B standby liquid control relief valve replacement on January 21, 2017

WO 52473778, C main steam line isolation valve, 29AOV-80C, actuator

replacement on January 27, 2017

WO 453213, Hydraulic control unit (HCU) 26-23 directional control valve

replacement on January 31, 2017

WO 403664, C safety relief valve replacement on February 9, 2017

WO 396857, fuel cell 38-39 fuel support casting modification on February 9, 2017

WO 52607951, inspections and post-maintenance tests for multiple completed

maintenance activities during ST-39H, reactor pressure vessel system leakage test

and control rod drive Class 2 piping inservice test, on February 22, 2017

WO 457224,A reactor water recirculation pump motor generator voltage regulator

replacement on February 27, 2017

WO 466553, A RHR suction strainer temporary modification installation on

February 10, 2017

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities (71111.20 - 1 sample)

a. Inspection Scope

The inspectors reviewed the stations work schedule and outage risk plan for FitzPatrick

RFO 22, conducted January 14 through February 25, 2017. The inspectors reviewed

the licensees development and implementation of outage plans and schedules to verify

that risk, industry experience, previous site-specific problems, and defense-in-depth

were considered. During the outage, the inspectors observed portions of the shutdown

and cooldown processes and monitored controls associated with the following outage

activities:

Configuration management, including maintenance of defense-in-depth,

commensurate with the outage plan for the key safety functions and compliance with

the applicable TSs when taking equipment out of service

Implementation of clearance activities and confirmation that tags were properly hung

and that equipment was appropriately configured to safely support the associated

work or testing

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

instruments to provide accurate indication and instrument error accounting

Status and configuration of electrical systems and switchyard activities to ensure that

TSs were met

Monitoring of decay heat removal operations

Impact of outage work on the ability of the operators to operate the spent fuel pool

cooling system

Reactor water inventory controls, including flow paths, configurations, alternative

means for inventory additions, and controls to prevent inventory loss

Activities that could affect reactivity

Maintenance of secondary containment as required by TSs

Refueling activities, including fuel handling and 100 percent core verification

Fatigue management

13

Tracking of startup prerequisites, walkdown of the drywell (primary containment) to

verify that debris had not been left which could block the emergency core cooling

system suction strainers, and startup and ascension to full power operation

Identification and resolution of problems related to RFO activities

b. Findings

No findings were identified.

1R22 Surveillance Testing (71111.22 - 8 samples)

a. Inspection Scope

The inspectors observed performance of surveillance tests and/or reviewed test data of

selected risk-significant structures, systems, and components to assess whether test

results satisfied TSs, the UFSAR, and licensee procedure requirements. The inspectors

verified that test acceptance criteria were clear, tests demonstrated operational

readiness and were consistent with design documentation, test instrumentation had

current calibrations and the range and accuracy for the application, tests were performed

as written, and applicable test prerequisites were satisfied.

Upon test completion, the inspectors considered whether the test results supported that

equipment was capable of performing the required safety functions. The inspectors

reviewed the following surveillance tests:

ST-9BB, Emergency diesel generator B and D full load test and emergency service

water pump operability test, on January 11, 2017

ST-1B, MSIV fast closure test (inservice test (IST)), on January 14, 2017

ST-39B-X7B, Type C leak test main steam line B MSIVs (IST), (inboard MSIV,

29AOV-80B), on January 17, 2017 (PCIV)

ST-39B-X7B, Type C leak test main steam line B MSIVs (IST), (outboard MSIV,

29AOV-86B), on January 17, 2017 (PCIV)

ST-6M, Standby liquid control recirculation injection test (IST), on January 21, 2017

ST-9CB, Emergency diesel generator B and D load sequencing test and 4KV

emergency power system voltage relays instrument functional test, on February 2,

2017

ST-2HB, Low pressure coolant injection initiation logic system B and reactor

pressure vessel low pressure permissive logic systems A and B functional test, on

February 3, 2017

ST-29F, RPT/ARI logic functional and simulated automatic actuation test, on

February 7, 2017

b. Findings

No findings were identified.

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2. RADIATION SAFETY

Cornerstone: Occupational and Public Radiation Safety

2RS1 Radiological Hazard Assessment and Exposure Controls (71124.01 - 4 samples)

a. Inspection Scope

The inspectors reviewed the licensees performance in assessing and controlling

radiological hazards in the workplace. The inspectors used the requirements contained

in 10 CFR Part 20, TSs, applicable regulatory guides (RGs), and the procedures

required by TSs as criteria for determining compliance.

Radiological Hazard Assessment (1 sample)

The inspectors conducted independent radiation measurements during walkdowns of the

facility and reviewed the radiological survey program, air sampling and analysis,

continuous air monitor use, recent plant radiation surveys for radiological work activities,

and any changes to plant operations since the last inspection to verify survey adequacy

of any new radiological hazards for onsite workers or members of the public.

Instructions to Workers (1 sample)

The inspectors reviewed high radiation area work permit controls and use, and observed

containers of radioactive materials and assessed whether the containers were labeled

and controlled in accordance with requirements.

The inspectors reviewed several occurrences where a workers electronic personal

dosimeter alarmed. The inspectors reviewed the licensees evaluation of the incidents,

documentation in the CAP, and whether compensatory dose evaluations were

conducted when appropriate. The inspectors verified follow-up investigations of actual

radiological conditions for unexpected radiological hazards were performed.

Radiological Hazards Control and Work Coverage (1 sample)

The inspectors evaluated in-plant radiological conditions and performed independent

radiation measurements during facility walkdowns and observation of radiological work

activities. The inspectors assessed whether posted surveys; radiation work permits;

worker radiological briefings and radiation protection job coverage; the use of continuous

air monitoring, air sampling, and engineering controls; and dosimetry monitoring were

consistent with the present conditions. The inspectors examined the control of highly

activated or contaminated materials stored within the spent fuel pool and the posting and

physical controls for selected high radiation areas, locked high radiation areas, and very

high radiation areas to verify conformance with the occupational performance indicator.

15

Radiation Worker Performance and Radiation Protection Technician Proficiency (1

sample)

The inspectors evaluated radiation worker performance with respect to radiation

protection work requirements. The inspectors evaluated radiation protection technicians

in performance of radiation surveys and in providing radiological job coverage.

b. Findings

No findings were identified.

2RS3 In-Plant Airborne Radioactivity Control and Mitigation (71124.03 - 1 sample)

a. Inspection Scope

The inspectors reviewed the control of in-plant airborne radioactivity and the use of

respiratory protection devices in these areas. The inspectors used the requirements in

10 CFR Part 20, RG 8.15, RG 8.25, NUREG/CR-0041, TSs, and procedures required by

TSs as criteria for determining compliance.

Inspection Planning

The inspectors reviewed the UFSAR to identify ventilation and radiation monitoring

systems associated with airborne radioactivity controls and respiratory protection

equipment staged for emergency use. The inspectors also reviewed respiratory

protection program procedures and current performance indicators for unintended

internal exposure incidents.

Engineering Controls (1 sample)

The inspectors reviewed operability and use of both permanent and temporary

ventilation systems, and the adequacy of airborne radioactivity radiation monitoring in

the plant based on location, sensitivity, and alarm setpoints.

b. Findings

No findings were identified.

2RS4 Occupational Dose Assessment (71124.04 - 1 sample)

a. Inspection Scope

The inspectors reviewed the monitoring, assessment, and reporting of occupational

dose. The inspectors used the requirements in 10 CFR Part 20, RGs, TSs, and

procedures required by TSs as criteria for determining compliance.

Inspection Planning

The inspectors reviewed radiation protection program audits, National Voluntary

Laboratory Accreditation Program dosimetry testing reports, and procedures associated

with dosimetry operations.

16

Source Term Characterization (1 sample)

The inspectors reviewed the plant radiation characterization (including gamma, beta,

alpha, and neutron) being monitored. The inspectors verified the use of scaling factors

to account for hard-to-detect radionuclides in internal dose assessments.

b. Findings

No findings were identified.

4. OTHER ACTIVITIES

4OA1 Performance Indicator Verification (71151)

.1 Unplanned Power Changes (1 sample)

a. Inspection Scope

The inspectors reviewed the licensees submittals for the Unplanned Power Changes

performance indicator for the period of January 1, 2016, through December 31, 2016.

To determine the accuracy of the performance indicator data reported during those

periods, inspectors used definitions and guidance contained in Nuclear Energy Institute

(NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline,

Revision 7. The inspectors reviewed the licensees operator narrative logs, maintenance

planning schedules, CRs, event reports, and NRC integrated inspection reports to

validate the accuracy of the submittals.

b. Findings

No findings were identified.

.2 Safety System Functional Failures (1 sample)

a. Inspection Scope

The inspectors reviewed the licensees submittals for the safety system functional

failures performance indicator for the period of January 1, 2016, through December 31,

2016. To determine the accuracy of the performance indicator data reported during

those periods, inspectors used definitions and guidance contained in NEI Document 99-

02, Revision 7; and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 10

CFR 50.73." The inspectors reviewed the licensees operator narrative logs, operability

assessments, CRs, event reports and NRC integrated inspection reports to validate the

accuracy of the submittals.

b. Findings

No findings were identified.

17

4OA2 Problem Identification and Resolution (71152 - 2 samples)

.1 Routine Review of Problem Identification and Resolution Activities

a. Inspection Scope

As required by Inspection Procedure 71152, Problem Identification and Resolution, the

inspectors routinely reviewed issues during baseline inspection activities and plant

status reviews to verify the licensee entered issues into the CAP at an appropriate

threshold, gave adequate attention to timely corrective actions, and identified and

addressed adverse trends. 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 CAP and periodically attended CR

screening meetings. The inspectors also confirmed, on a sampling basis, that, as

applicable, for identified defects and non-conformances, the licensee performed an

evaluation in accordance with 10 CFR Part 21.

b. Findings

No findings were identified.

.2 Annual Sample: Control Rod Unexpected Insertion to the Full in Position

a. Inspection Scope

The inspectors performed an in-depth review of the licensee's evaluation and corrective

actions associated with CR-JAF-2016-01483 for the unexpected insertion of control rod

18-35 to the full in position. The CR documented that on April 24, 2016, while

performing control rod operability testing for fully withdrawn control rods, control rod 18-

35 drifted in from position 48 to 00. Operators entered Abnormal Operating Procedure

27 for a control rod drift and lowered power, ultimately to approximately 60 percent.

Maintenance replaced all four directional control valves (DCVs) with new valves and

finger filters on HCU 18-35. Following replacement of the DCVs, control rod 18-35 was

stroke timed per surveillance test ST-20N and inserted to position 46 and withdrawn to

position 48 (full out) with no abnormalities.

The inspectors assessed the licensees problem identification threshold, problem

analysis, extent of condition reviews, compensatory actions, and the prioritization and

timeliness of corrective actions to determine whether the licensee was appropriately

identifying, characterizing, and correcting problems associated with this issue and

whether the planned or completed corrective actions were appropriate. The inspectors

compared the actions taken to the requirements of the licensee's CAP and 10 CFR Part

50, Appendix B, Criterion XVI, Corrective Action. In addition, the inspectors reviewed

documentation associated with this issue, including the apparent cause evaluation and

DCV replacement schedules, and interviewed engineering personnel to assess the

effectiveness of the implemented corrective actions to resolve the issue.

b. Findings and Observations

No findings were identified.

18

The inspectors determined that the licensee took appropriate actions to identify the

direct and apparent causes of the issue. The direct cause of the issue was that HCU 18-

35 DCVs failed to fully close when de-energized. The apparent cause was determined

to be the use of a performance-based preventive maintenance (PM) strategy vice a time-

based PM replacement for the DCVs. This resulted in a condition that allowed a latent

equipment issue (age-related degradation) to exist that would have been replaced under

a time-based PM strategy, resulting in the direct cause of the HCU 18-35 DCVs failing to

fully close when de-energized. The licensee replaced all four DCVs with new valves and

finger filters on HCU 18-35 and stroked control rod 18-35 in a timely manner.

The licensee also performed an extent of condition review for the other control rods in

which the HCU contained DCVs that are greater than 20 years old. The licensee

initiated a corrective action to replace all DCVs greater than 20 years old by RFO 23.

During RFO 22, the licensee replaced 149 DCVs. There are approximately 244 DCVs

that will need to be replaced by the end of RFO 23.

The inspectors determined the licensees overall response to the issue was

commensurate with its safety significance, was timely, and the corrective actions taken

and planned were reasonable. Although there was an industry recommendation to

switch to a time-based program for DCV replacement, there was not a reasonable

timeframe to replace the DCVs that were older than 20 years before this failure

occurred. Therefore, there was no performance deficiency since the failure was not

reasonably foreseeable and preventable.

.3 Annual Sample: Deferred Corrective Action Recovery

a. Inspection Scope

The inspectors performed a review of the licensee's processes used to recover

corrective action items, including deferred corrective maintenance and permanent

modifications, following the decision not to permanently shut down FitzPatrick in January

2017. In addition to confirming the adequacy of the processes used, this inspection was

performed to identify any risk significant systems significantly affected by deferrals to

help inform future NRC inspections.

The inspectors reviewed documentation associated with this issue and interviewed

performance improvement, maintenance, work planning, and engineering personnel to

assess the effectiveness of the implemented processes.

b. Findings and Observations

No findings were identified.

The inspectors determined that the licensee took appropriate actions to recover

corrective action items following the decision not to permanently shut down FitzPatrick.

After Entergy announced the plan to decommission the plant, various corrective actions,

maintenance activities and surveillances were reviewed to determine whether they

should continue to be performed or should be deferred or rescheduled until after the

permanent shutdown date and ultimately not performed. The licensee had determined

the list of systems which would be required during various phases of decommissioning

to base their scheduling decisions on. Approximately twenty adverse condition

19

corrective actions were approved for extension past the permanent shutdown date.

Following the decision to continue plant operation, these items were reassessed for

scheduling. Approximately half of the items have been completed to date. The

inspectors determined the remaining items were appropriately scheduled commensurate

with their safety significance.

Surveillances and PM tasks were not cancelled or extended past their late dates. The

licensee is working to reestablish more ideal PM scheduling to get back into their

performance indicator target without the use of deep grace (close to late date) periods

for completion.

Permanent modifications were captured in the CAP if required to correct an adverse

condition. System improvement modifications remained listed in the system health

reports, so no process was required to recover them.

The inspectors reviewed the current list of corrective maintenance and key system

health work orders. No risk significant systems were adversely affected by deferrals.

The inspectors determined the licensees process to recover corrective action items

following the decision not to decommission the plant was appropriate.

4OA3 Follow-Up of Events and Notices of Enforcement Discretion (71153 - 1 sample)

(Closed) Licensee Event Report (LER) 05000333/2016-003-00: Simultaneous Opening

of Secondary Containment Airlock Doors

On June 7, 2016, personnel inside and outside the secondary containment

simultaneously opened both doors to the north reactor building, 272 foot elevation,

secondary containment airlock. TS Surveillance Requirement (SR) 3.6.4.1.3 requires

that one secondary containment access door in each access opening is closed at all

times. Both parties were aware of this requirement, and both withdrew and closed their

respective doors within a period of approximately two seconds. However, during the

period that both doors were simultaneously open, TS SR 3.6.4.1.3 was not satisfied, and

therefore, secondary containment was inoperable per TS Limiting Condition for

Operation 3.6.4.1. The limiting condition for operation action statement requires that

secondary containment be restored to operable status within four hours. This condition

was met once one of the secondary containment access doors was closed. However,

because secondary containment is a single train system, this occurrence was reportable

under 10 CFR 50.72 as a condition that at the time of discovery would have prevented

the fulfillment of the secondary containment safety function, even though the condition

existed for less than the TS allowed outage time.

The inspectors noted that the subject secondary containment access is equipped with

three sets of green and red position indication lights, one set on each entrance to the

airlock and the third set inside the airlock. All the green lights are energized if both

airlock doors are closed. However, if either door is opened, the green lights extinguish

and all the red lights are energized. This scheme functions adequately to alert an

individual preparing to enter an airlock that another individual is already in the process of

entering from the other side. However, in the event that both doors are operated

simultaneously, the indications for both individuals are as expected for a single door

being opened, and neither recognizes a problem exists until they are positioned to see

the other open door (at which point, it is too late). Therefore, the inspectors determined

20

that this event was not due to a human performance deficiency. Given that secondary

containment differential pressure remained within specification, along with the short

duration of the event, the inspectors determined that secondary containment had

remained capable of performing its design function throughout the event. Additionally,

the issue was reported in a timely manner in accordance with the requirements of

10 CFR 50.72, so it did not constitute a traditional enforcement issue. Because the

failure to comply with TS SR 3.6.4.1.3 was corrected within the allowed outage time, no

violation of regulatory requirements occurred. Cameras and monitors have since been

installed on each side of the secondary containment airlock in question, enabling

individuals to verify that the opposing door will not be simultaneously opened. This LER

is closed.

4OA5 Other Activities

Temporary Instruction (TI) 2515/192, Inspection of the Licensees Interim Measures

Associated with the Open Phase Condition Design Vulnerabilities in Electric Power

Systems

a. Inspection Scope

The objective of this performance-based TI is to verify implementation of interim

compensatory measures associated with an open phase condition (OPC) design

vulnerability in electric power system for operating reactors. The inspectors conducted

an inspection to determine if FitzPatrick had implemented the following interim

compensatory measures. These compensatory measures are to remain in place until

permanent automatic detection and protection schemes are installed and declared

operable for OPC design vulnerability. The inspectors verified the following:

FitzPatrick had identified and discussed with plant staff the lessons learned from the

OPC events at the U.S. operating plants including the Byron Station OPC event and

its consequences. This includes conducting operator training for promptly

diagnosing, recognizing consequences, and responding to an OPC event.

FitzPatrick had updated plant operating procedures to help operators promptly

diagnose and respond to OPC events on offsite power sources credited for safe

shutdown of the plant.

FitzPatrick had established and continues to implement periodic walkdown activities

to inspect switchyard equipment such as insulators, disconnect switches, and

transmission line and transformer connections associated with the offsite power

circuits to detect a visible OPC.

FitzPatrick had ensured that routine maintenance and testing activities on switchyard

components have been implemented and maintained. As part of the maintenance

and testing activities, FitzPatrick assessed and managed plant risk in accordance

with 10 CFR 50.65(a)(4) requirements.

21

b. Findings and Observations

No findings of significance were identified. The inspectors verified the criteria were met.

Information gained from this TI have been provided to the program office for further

review.

4OA6 Meetings, Including Exit

On April 19, 2017, the inspectors presented the inspection results to Mr. Joseph Pacher,

Site Vice President, and other members of the FitzPatrick staff. The inspectors verified

that no proprietary information was retained by the inspectors or documented in this

report.

ATTACHMENT: SUPPLEMENTARY INFORMATION

A-1

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

B. Sullivan, Site Vice President

T. Peter, General Manager, Plant Operations

C. Adner, Director, Manager Operations and Regulatory and Performance Improvement

D. Bittinger, Manager, Design and Programs Engineering

W. Drews, Manager, Regulatory Assurance

K. Habayeb, Supervisor, Engineering

R. Heath, Manager, Radiation Protection

J. Jones, Manager, Emergency Planning

D. Poulin, Director, Engineering

T. Redfearn, Manager, Security

M. Reno, Manager, Training

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened

05000333/2017001-01 URI Drywell Moisture Barrier Description in License

Renewal Application (Section 1R08)

Closed

05000333/2016-003-00 LER Concurrent Opening of Reactor Building Airlock

Doors (Section 4OA3)

05000333/TI 2515/192 TI Inspection of the Licensees Interim

Compensatory Measures Associated with the

Open Phase Condition Design Vulnerabilities in

Electric Power Systems (Section 4OA5)

Attachment

A-2

LIST OF DOCUMENTS REVIEWED

Section 1R04: Equipment Alignment

Procedures

AOP-19A, Loss of Switchgear L16, Revision 5

ODSO-4, Shift Turnover and Log Keeping, Revision 118

OP-13, RHR System, Revision 98

OP-13D, RHR - Shutdown Cooling, Revision 30

OP-14, Core Spray System, Revision 37

Condition Report

CR-JAF-2017-0396

Drawings

FM-20A, Flow Diagram RHR System 10, Revision 72

FM-20B, Flow Diagram RHR System 10, Revision 62

FM-23A, Flow Diagram Core Spray System 14, Revision 49

Section 1R05: Fire Protection

Procedures

JAF-RPT-04-00478, JAF Fire Hazards Analysis, Revision 2

JAF-RPT-04-00478, JAF Fire Hazards Analysis, Revision 2

PFP-PWR12, Relay Room Elevation 286 Fire Area VII/Fire Zone RR-1, Revision 5

PFP-PWR20, Reactor Building - East / Elevation 272 Fire Area/Zone IX/RB-1A, Revision 5

PFP-PWR21, Reactor Building - West / Elevation 272 Fire Area/Zone X/RB-1B, Revision 5

PFP-PWR24, Reactor Building - East, Elevation 300 Fire Area/Fire Zone - 8/RB-1C, 9RB-1A,

Revision 5

PFP-PWR25, Reactor Building - West, Elevation 300 Fire Area/Fire Zone - X/RB-1B,

Revision 3

PFP-PWR45, Turbine Building, Elevation 272, Fire Area/Zone IE/TB-1, Revision 06

PFP-PWR46, Turbine Building, Elevation 272, Fire Area/Zone IE/TB-1, OR-2, Revision 04

PFP-PWR48, Turbine Building, Elevation 300, Fire Area/Zone IE/TB-1, Revision 04

Drawings

FPSSK-2, Fire Area/Zone Arrangement Plan El 272-0, Revision 3

FPSSK-3, Fire Area/Zone Arrangement Plan El 300-0, Revision 3

Section 1R08: Inservice Inspection

Procedures

CEP-NDE-0505, Ultrasonic Thickness Examination, Revision 4

CEP-NDE-0901, VT-1 Examination, Revision 4

PQR 015, Manual Gas Tungsten Arc Welding (GTAW), Revision 1

PQR 024, Manual Gas Tungsten and Shielded Metal Arc Welding (GTAW and SMAW),

Revision 1

PRO-ISI-IVVI-0001-GFIT1, Procedure for In-Vessel Visual Inspection (IVVI) of the James A.

Fitzpatrick BWR 4 RPV Internals, Revision 2

SEP-ISI-007, ASME Section XI Fourth 10-Year Interval Inservice Inspection Program Plan,

Revision 7

SI-UT-130, Procedure for the Phased Array Ultrasonic Examination of Dissimilar Metal Welds,

Revision 3

A-3

WPS-CS-1/1-A, Welding Procedure Specification, Revision 0

WPS-CS-1/1-B, Welding Procedure Specification, Revision 0

Condition Reports

CR-JAF-2014-04909 CR-JAF-2014-06304 CR-JAF-2014-06884

CR-JAF-2014-07232 CR-JAF-2015-01099 CR-JAF-2015-03000

CR-JAF-2017-00480 CR-JAF-2017-00667 CR-JAF-2017-00706

CR-JAF-2017-00812 CR-JAF-2017-00822 CR-JAF-2017-00906

CR-JAF-2017-00910

Work Order 0039397101, Repair Linear Flaw in ISI Weld 24-29-626A, January 26, 2017

NDE Summary Reports

3036-NTHBIR, Closure Head Vent Nozzle IR, January 22, 2017

ISI-VT-16-012, IWE General Exam RB 272-300, January 23, 2017

ISI-VT-16-013, IWE General Exam RB 300-326, January 23, 2017

ISI-VT-17-017, VT-3 Pressure Retaining Bolting, January 26, 2017

ISI-VT-17-023, VT-3 Torus Supports, January 23, 2017

[[::JAF-RHR-130|JAF-RHR-130]], FitzPatrick DMW RHR 24-10-130, January 29, 2017

[[::JAF-RHR-142|JAF-RHR-142]], FitzPatrick DMW RHR 24-10-142, January 30, 2017

[[::JAF-RHR-144|JAF-RHR-144]], FitzPatrick DMW RHR 24-10-144, January 30, 2017

Miscellaneous

J.A. FitzPatrick RO21 Final Report, Fall 2014, Inservice Inspection - FAC, Volume 1

LO-JAFLO-2016-00035, Pre-NRC ISI Snapshot Assessment, December 5, 2016

OE-NOE-2015-00096-CA-12, NRC Information Notice 2015-04, Fatigue in Branch Connection

Welds, Revision 0

OE-NOE-2016-00145 CA#00012, NRC-RIS-2016-07 Containment Shell or Liner Moisture

Barrier Inspection, Revision 0

WPQ-EN-0229-08536, Welding Performance Qualification, December 22, 2016

Section 1R11: Licensed Operator Requalification Program

Procedures

OP-65, Startup and Shutdown Procedure, Revision 121

ST-5C, IRM-APRM Instrument Range Overlap Check, completed January 14, 2017

Section 1R12: Maintenance Effectiveness

Procedures

EN-DC-205, Maintenance Rule Monitoring, Revision 6

EN-DC-206, Maintenance Rule (a)(1) Process, Revision 3

Condition Reports

CR-JAF-2014-4381 CR-JAF-2015-3924* CR-JAF-2016-0263*

CR-JAF-2016-0324* CR-JAF-2016-0610 CR-JAF-2016-1671*

CR-JAF-2016-2356 CR-JAF-2016-2411* CR-JAF-2016-3831*

CR-JAF-2016-4815* CR-JAF-2017-0309* CR-JAF-2017-0310*

CR-JAF-2017-0501* CR-JAF-2017-0768 CR-JAF-2017-0886*

CR-JAF-2017-0920* CR-JAF-2017-0942 CR-JAF-2017-1108*

CR-JAF-2017-2033

• Maintenance Rule Functional Failure Evaluations also reviewed for Condition Reports

A-4

Work Orders

451680

466890

Miscellaneous

JAF-RPT-MST-02480, Maintenance Rule Basis Document System 029 Main Steam, Revision 9

JAF-RPT-MULTI-02294, Maintenance Rule Basis Document for Service Water Systems

including System 10 (RHRSW), 46 (Normal SW), and 46-ESW (Emergency SW),

Revision 12

Maintenance Rule (a)(1) Action Plan for System 29, February 6, 2017

System Health Report for Main Steam System 3Q-2016

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

Procedures

AP-10.09, Outage Risk Assessment, Revision 35

AP-10.10, On-Line Risk Assessment, Revision 9

EN-WM-104, On-Line Risk Assessment, Revision 12

ODSO-4, Shift Turnover and Log Keeping, Revision 118

OP-43C, LPCI Independent Power Supply System, Revision 23

Condition Reports (* NRC Identified)

CR-JAF-2017-0465*

CR-JAF-2016-4882

Miscellaneous

R22 Revision 1 Risk Assessment Based on Schedule, December 29, 2016

Section 1R15: Operability Determinations and Functionality Assessments

Procedures

EN-NE-G-0032, BWR Primary System Loose Parts Analysis Considerations, Revision 1

ST-39J, Leak Testing of RHR and Core Spray Testable Check Valves (IST), Revision 18

Condition Reports

CR-JAF-2012-6414 CR-JAF-2014-5302 CR-JAF-2017-0610

CR-JAF-2017-0812 CR-JAF-2017-0848 CR-JAF-2017-0851

CR-JAF-2017-0997

Work Orders

00396857

52606738

Drawing

FM-20A, Flow Diagram RHR System 10, Revision 47

Miscellaneous

ALION-CAL-SI-9389-002, Design Pressure for Strainer Clamshell Cover Modules, Revision 2

EC 69400

EC 69507, Temporary RHR suction strainer shells

EC 69558, Enlarge alignment slot on fuel support casting for cell location 38-39 to allow for FSC

assembly in proper orientation over guide pin in core plate

A-5

EC 69571

[[::JAF-194295-RP01|JAF-194295-RP01]], RHR Strainer Module Repair Report, Revision 0

Section 1R18: Plant Modifications

Procedures

EN-DC-117, Post Modification Testing and Special Instructions, Revision 8

ST-2XB, RHR Service Water Loop B Quarterly Operability Test (IST), Revision 13

ST-41D, Remote Valve Position Indication Verification Online (IST), Revision 20

Condition Report (* NRC identified)

2017-2018*

Work Order 00327815

Drawings

FM-20B, Flow Diagram Residual Heat Removal System 10, Revision 72

FP-37E, Service Water Piping Reactor Building Sh-5, Revision 22

FP-37F, Service Water Piping Reactor Building Sh-6, Revision 13

Miscellaneous

EC 66231, Provide Isolation between RHRSW and Secondary Containment for Work on

10MOV-89A

EC 66088, Provide Isolation between RHRSW and Secondary Containment for Work on

10MOV-89B

Engineering Change 67365, 10MOV-89A/B Replacement, Revision 0

Section 1R19: Post-Maintenance Testing

Procedures

EN-WM-107, Post Maintenance Testing, Revision 5

ESP-68.001, Leak Rate Test of Automatic Depressurization System (ADS) Pneumatic Supply

Check Valves, Revision 5

IMP-02-184.8, Recirculating MG Set Voltage Regulator Tuning**, completed 2/27/17

MP-003.11, HCU Directional Control Valves 03SOV-120 through 123, Revision 18

RAP-7.3.39, Channel-Control Blade Interference Monitoring, completed 2/9/17

ST-2AL, RHR Loop A Quarterly Operability Test (IST), Revision 36

ST-2AM, RHR Loop B Quarterly Operability Test (IST), completed 2/22/17

ST-6HB, Standby Liquid Control B Side Quarterly Operability Test (IST), completed 1/21/17

ST-20N, Control Rod Exercise/Timing/Stall Flow Test, completed 2/4/17

ST-22A, ADS Simulated Automatic Actuation Test, Revision 24

ST-22K, Manual Safety Relief Valve Operation System Test (IST), Revision 5

ST-39B, Type B and C LLRT of Containment Penetrations (IST), Revision 36

ST-39B-X7C, Type C Leak Test Main Steam Line C MSIVs (IST), Revision 15

ST-39H, RPV System Leakage Test and Control Rod Drive Class 2 Piping Inservice Test

(ISI)**, Revision 34

ST-43G, Remote Shutdown Panel 25ASP-5 Component Operation and Isolation Verification,

Revision 6

Condition Reports

CR-JAF-2017-0409 CR-JAF-2017-1501 CR-JAF-2017-1549 CR-JAF-2017-1670

CR-JAF-2017-1676 CR-JAF-2017-1678 CR-JAF-2017-1684 CR-JAF-2017-1686

A-6

CR-JAF-2017-1689 CR-JAF-2017-1694

Work Orders

00341278 00396857 00403664 00453213 00456762 00457224

00465534 00466391 00466553 52607951

Section 1R20: Refueling and Other Outage Activities

Procedures

EN-OM-123, Fatigue Management Program, Revision 13

ESP-65.001, Drywell Inspection, Revision 4

ODSO-4, Shift Turnover and Log Keeping, Revision 118

OP-9, Main Turbine, Revision 58

OP-11A, Main Generator, Transformers and Isolated Bus Phase Cooling, Revision 52

OP-13D, RHR-Shutdown Cooling, Revision 29

OP-21, Emergency Service Water (ESW), Revision 38

OP-30A, Refueling Water Level Control, Revision 18

OP-65, Startup and Shutdown Procedure, Revision 121

OSP-66.001, Management of Refueling Activities, Revision 8

RAP-7.4.01, Control Rod Scram Time Evaluation**, Revision 28

ST-2AN, RHR Loop A Monthly Operability Test, Revision 16

ST-2AO, RHR Loop B Monthly Operability Test, Revision 16

ST-24J, RCIC [Reactor Core Isolation Cooling] Flow Rate and Inservice Test (IST), Revision 45

ST-26J, Heatup and Cooldown Temperature Checks, Revision 24

TOP-416, Transferring from A RFP to B RFP While On the Low Flow Control Valve, Revision 0

Condition Reports

CR-JAF-2017-0706 CR-JAF-2017-0738 CR-JAF-2017-0812

CR-JAF-2017-0848 CR-JAF-2017-1142 CR-JAF-2017-1146

Miscellaneous

System Window Closeout Checklist for 11SLC (1R22-0071), January 22, 2017

System Window Closeout Checklist for B RHR (R22-0022), February 2, 2017

Section 1R22: Surveillance Testing

Procedures

CEP-APJ-001, Primary Containment Leakage Rate Testing (10CFR50 Appendix J) Program

Plan, Revision 3

MST-011.11, Standby Liquid Control Explosive Valves (IST), Revision 14

OP-25, Control Rod Drive Hydraulic System, Revision 88

OP-22, Diesel Generator Emergency Power, Revision 61

ST-1B, MSIV Fast Closure Test (IST), Revision 26

ST-6M, Standby Liquid Control Recirculation, Injection Test (IST, ISI), Revision 8

ST-6N, Reverse Closure Test of SLC Injection Line Check Valves (IST), Revision 0

ST-9BB, EDG B and D Full Load Test and ESW Pump Operability Test, Revision 15

ST-9CB, EDG B and D Load Sequencing Test and 4KV Emergency Power System Voltage

Relays Instrument Functional Test**, Revision 3

ST-29F, RPT/ARI Logic Functional and Simulated Automatic Actuation Test, Revision 17

ST-39B, Type B and C LLRT of Containment Penetrations (IST), Revision 36

ST-39B-X7B, Type C Leak Test Main Steam Line B MSIVs (IST), Revision 14

ST-43H, Circuit Breaker 10614 Remote Shutdown Operation and Isolation Verification,

Revision 11

A-7

Condition Reports

CR-JAF-2017-0310

CR-JAF-2017-0425

CR-JAF-2017-1292

Work Orders

52698422

52733249

Drawing

FM-21A, Flow Diagram Standby Liquid Control System 11, Revision 37

Miscellaneous

Updated FSAR Section 4.6, Main Steam Isolation Valves

Updated FSAR Section 8.6, Emergency AC Power System

Section 2RS1: Radiological Hazard Assessment and Exposure Controls

Procedures

EN-RP-100, Radiation Worker Expectations, Revision 11

EN-RP-101, Access Control for Radiologically Controlled Areas, Revision 12

EN-RP-102, Radiological Control, Revision 5

EN-RP-105, Radiological Work Permits, Revision 16

EN-RP-106-01, Radiological Survey Guidelines, Revision 3

EN-RP-108, Radiation Protection Posting, Revision 18

EN-RP-121, Radioactive Material Control, Revision 13

EN-RP-141-01, Job Coverage Using Remote Monitoring Technology, Revision 6

EN-RP-152, Conduct of Radiation Protection, Revision 1

Condition Reports

CR-JAF-2016-00607 CR-JAF-2016-00650 CR-JAF-2016-04668

CR-JAF-2016-05190 CR-JAF-2017-00627 CR-JAF-2017-00637

RWPs and ALARA Plans

RWP ALARA Plan

20170514 17-0514

20170609 17-0609

20170701 17-0701

20170944 17-0944

Surveys

[[::JAF-1701-0325|JAF-1701-0325]] [[::JAF-1701-0376|JAF-1701-0376]] [[::JAF-1701-0397|JAF-1701-0397]]

JAF-1701-0455 [[::JAF-1701-0495|JAF-1701-0495]] [[::JAF-1701-0520|JAF-1701-0520]]

JAF-1701-0532 [[::JAF-1701-0568|JAF-1701-0568]] [[::JAF-1701-0577|JAF-1701-0577]]

JAF-1701-0582 [[::JAF-1701-0601|JAF-1701-0601]] [[::JAF-1701-0740|JAF-1701-0740]]

JAF-1701-0757 [[::JAF-1701-0639|JAF-1701-0639]] [[::JAF-1701-0659|JAF-1701-0659]]

JAF-1701-0667 [[::JAF-1701-0698|JAF-1701-0698]] [[::JAF-1701-0720|JAF-1701-0720]]

JAF-1701-0721 [[::JAF-1701-0722|JAF-1701-0722]] [[::JAF-1701-0723|JAF-1701-0723]]

JAF-1701-0724 [[::JAF-1701-0725|JAF-1701-0725]] [[::JAF-1701-0726|JAF-1701-0726]]

JAF-1701-0732 [[::JAF-1701-0733|JAF-1701-0733]] [[::JAF-1701-0735|JAF-1701-0735]]

JAF-1701-0736 [[::JAF-1701-0737|JAF-1701-0737]] [[::JAF-1701-0744|JAF-1701-0744]]

JAF-1701-0752 [[::JAF-1701-0778|JAF-1701-0778]] [[::JAF-1701-0789|JAF-1701-0789]]

A-8

[[::JAF-1701-0798|JAF-1701-0798]]

Miscellaneous

Air Sample 17106, 17111, 17137, 17139, 17142, 17147, 17150, 17182

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

Procedure

EN-RP-131, Air Sampling, Revision 15

Section 4OA2: Problem Identification and Resolution

Procedure

EN-LI-118, Cause Evaluation Process, Revision 22

Condition Reports

CR-JAF-2010-08458

CR-JAF-2016-01483

Section 4OA3: Follow-up of Events and Notices of Enforcement Discretion

Condition Reports

CR-JAF-2015-4146

CR-JAF-2016-1996

Section 4OA5: Other Activities

Procedures

AOP-72, 115 KV Grid Loss, Instability, or Degradation, Revision 11

OP-44A, 115 KV System, Revision 22

Condition Reports

CR-HQN-2012-0847

CR-JAF-2012-1016

CR-JAF-2005-5180

Work Orders

00456356

52692025

52693298

Miscellaneous

EC 48543, Provide Open Phase Detection and Protection for 115KV Switchyard - Parent EC,

Revision 0

LER 050005333-2005-006-00, Inoperable 115 KV Line in Excess of Technical Specification

Allowed Out of Service Time

A-9

LIST OF ACRONYMS

10 CFR Title 10 of the Code of Federal Regulations

ASME American Society of Mechanical Engineers

BPV boiler and pressure vessel

CAP corrective action program

CR condition report

DCV directional control valve

EC engineering change

HCU hydraulic control unit

IMC Inspection Manual Chapter

IST inservice test

IWE International Welding Engineer

LER licensee event report

MSIV main steam isolation valve

NDE non-destructive examination

NEI Nuclear Energy Institute

NRC Nuclear Regulatory Commission

OPC open phase condition

OPDRV operation with a potential for draining the reactor vessel

PM preventive maintenance

RFO refuel outage

RG regulatory guide

RHR residual heat removal

RHRSW residual heat removal service water

RPV reactor pressure vessel

SR surveillance requirement

TI temporary instruction

TS technical specification

UFSAR Updated Final Safety Analysis Report

URI unresolved item

UT ultrasonic testing

VT visual testing

WO work order