ML12038A072
| ML12038A072 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 02/07/2012 |
| From: | Eric Duncan Region 3 Branch 3 |
| To: | Pacilio M Exelon Generation Co, Exelon Nuclear |
| References | |
| IR-11-005 | |
| Download: ML12038A072 (69) | |
See also: IR 05000454/2011005
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION III
2443 WARRENVILLE ROAD, SUITE 210
LISLE, IL 60532-4352
February 7, 2012
Mr. Michael J. Pacilio
Senior Vice President, Exelon Generation Company, LLC
President and Chief Nuclear Office (CNO), Exelon Nuclear
4300 Warrenville Road
Warrenville, IL 60555
SUBJECT: BYRON STATION, UNITS 1 AND 2, NRC INTEGRATED INSPECTION
REPORT 05000454/2011005; 05000455/2011005
Dear Mr. Pacilio:
On December 31, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an
integrated inspection at your Byron Station, Units 1 and 2. The enclosed inspection report
documents the inspection findings which were discussed on January 12, 2012, with
Mr. B. Youman and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel.
Three NRC-identified findings of very low safety significance (Green) were identified during this
inspection.
These findings were determined to involve violations of NRC requirements. Further, a
licensee-identified violation which was determined to be of very low safety significance is
listed in this report. The NRC is treating these violations as non-cited violations (NCVs)
consistent with Section 2.3.2 of the NRC Enforcement Policy.
If you contest these NCVs, you should provide a response within 30 days of the date of this
inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission,
ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional
Administrator, U.S. Nuclear Regulatory Commission - Region III, 2443 Warrenville Road,
Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory
Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Byron
Station.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a
response within 30 days of the date of this inspection report, with the basis for your
disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at
the Byron Station.
M. Pacilio -2-
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response (if any) will be available electronically for public inspection in the
NRC Public Document Room or from the Publicly Available Records (PARS) component of
NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Eric R. Duncan, Chief
Branch 3
Division of Reactor Projects
Docket Nos. 50-454; 50-455
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
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
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
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
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
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;
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 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);
(LSA-II);
- Shipment RWS10-012; DAW Trash; low specific activity (LSA-II);
- Shipment RMS09-094; Rx Vessel Dosimetry; Type A Package; and
- Shipment RMS11-078; Dirty Laundry; low specific activity (LSA-II).
Additionally, the inspectors assessed whether the shipment placarding was consistent
with the information in the shipping documentation.
b. Findings
Introduction: A self-revealed finding of very low safety significance (Green) and an
associated NCV of 10 CFR 71.5, Transportation of Licensed Material, was identified
when licensee personnel failed to comply with 49 CFR 172.203(c) and shipped
packages of radioactive material with transport manifests that did not document all
applicable hazardous substances.
Description: On multiple dates, the licensee shipped containers of radioactive material
to a waste processor with incomplete information on the transport manifest. Specifically,
the transport manifest that accompanied the shipments failed to identify hazardous
materials, including asbestos, lead, and other chemicals that were contained in the
packages. Upon arrival at the waste processors facility, the waste processor identified
the non-conformances in the shipping containers and notified the licensee. Follow-up
actions by the licensee included performing a revised characterization of the shipped
packages. The revised radiological characterization identified negligible impact relative
to the initial radiological assessment and package characterization. This event was
documented in the licensees CAP as:
- IR 1221229; RWS11-006 Contained Un-Manifested Asbestos;
- IR 1173307; RWS10-013 Contained Unapproved Mixed Waste;
- IR 928393; Non-Conforming Metal Shipped to Bear Creek Processing;
- IR 1015646; Non-Conforming Waste Found in Radwaste Shipment; and
- IR 1067394; Non-Conforming Radioactive Waste in Shipment.
38 Enclosure
Immediate corrective actions included providing a corrected copy of the transport
manifest to the waste processor. Additionally, the licensee initiated IR 1285148
to evaluate the human performance issues associated with the shipping
non-conformances. Further, the licensee placed locks on the shipping containers
to control items placed in the packages and to ensure that the manifest accurately
represented the hazards contained in the shipping package.
Analysis: The failure to completely identify all required package contents on a transport
manifest was a performance deficiency. The finding was determined to be more than
minor because it was associated with the Program and Process attribute of the Public
Radiation Safety Cornerstone and adversely affected the cornerstone objective of
ensuring the adequate protection of public health and safety from exposure to
radioactive materials released into the public domain as a result of routine civilian
nuclear reactor operation, in that, providing incorrect information, as part of hazard
communication, could impact the actions of response personnel. The finding involved
an occurrence of the licensees radioactive material transportation program that was
contrary to NRC regulatory requirements. The inspectors determined that the finding
could be evaluated using the SDP in accordance with IMC 0609, Significance
Determination Process, Appendix D, Public Radiation Safety Significance
Determination Process. Using the Public Radiation Safety SDP, the inspectors
determined: (1) radiation limits were not exceeded; (2) there was no breach of a
package during transit; (3) it did not involve a certificate of compliance issue; (4) it was
not a low level burial ground nonconformance; and (5) it did not involve a failure to make
notifications or provide emergency information. As a result, the finding screened as
having very low safety significance (Green).
This finding has a cross-cutting aspect in the Work Control component of the Human
Performance cross-cutting area H.3(b) since the waster shipper failed to coordinate
work activities by incorporating actions to address the impact of the work on different job
activities, and the need for work groups to maintain interfaces with offsite organizations,
and communicate, coordinate, and cooperate with each other during activities in which
interdepartmental coordination is necessary to assure adequate human performance.
Specifically, these events occurred because the radioactive material shipper did not
control the items placed in the waste packages and was not present when the boxes
were loaded.
Enforcement: Title 10 CFR 71.5, Transportation of Licensed Material, requires
licensees to comply with the Department of Transportation (DOT) regulations in
49 CFR Parts 170 through 189 relative to the transportation of licensed material.
Title 49 CFR 172.203, Additional Description Requirements, required, in part,
that hazardous materials be listed on the transport manifest.
Contrary to the above, between May 10, 2010 and May 26, 2011, the licensee failed to
list relevant hazardous materials on the transport manifest for a shipment also containing
DAW. This violation was entered into the licensees CAP as IR 1285148. Because this
violation was of very low safety significance and it was entered into the licensees CAP,
this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC
Enforcement Policy. (NCV 05000454/2011005-04, Failure to Identify Hazardous
Materials on Transportation Manifest)
39 Enclosure
.7 Identification and Resolution of Problems (02.07)
a. Inspection Scope
The inspectors assessed whether problems associated with radioactive waste
processing, handling, storage, and transportation, were being identified by the licensee
at an appropriate threshold, were properly characterized, and were properly addressed
for resolution in the licensee CAP. Additionally, the inspectors evaluated whether the
corrective actions were appropriate for a selected sample of problems documented by
the licensee that involve radioactive waste processing, handling, storage, and
transportation.
The inspectors reviewed results of selected audits performed since the last inspection of
this program and evaluated the adequacy of the licensees corrective actions for issues
identified during those audits.
b. Findings
No findings were identified.
4. OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and
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
.1 Routine Review of Items Entered into the Corrective Action Program
a. Inspection Scope
As part of the various baseline inspection procedures discussed in previous sections of
this report, the inspectors routinely reviewed issues during baseline inspection activities
and plant status reviews to verify that they were being entered into the licensees CAP at
an appropriate threshold, that adequate attention was being given to timely corrective
actions, and that adverse trends were identified and addressed. Attributes reviewed
included: the complete and accurate identification of the problem; that timeliness was
commensurate with the safety significance; that evaluation and disposition of
performance issues, generic implications, common causes, contributing factors, root
causes, extent-of-condition reviews, and previous occurrence reviews were proper and
adequate; and that the classification, prioritization, focus, and timeliness of corrective
actions were commensurate with safety and sufficient to prevent recurrence of the issue.
Minor issues entered into the licensees CAP as a result of the inspectors observations
are included in the attached List of Documents Reviewed.
These routine reviews for the identification and resolution of problems did not constitute
any additional inspection samples. Instead, by procedure they were considered an
integral part of the inspections performed during the quarter and documented in
Section 1 of this report.
b. Findings
No findings were identified.
.2 Daily Corrective Action Program Reviews
a. Inspection Scope
In order to assist with the identification of repetitive equipment failures and specific
human performance issues for follow-up, the inspectors performed a daily screening
of items entered into the licensees CAP. This review was accomplished through
inspection of the stations daily condition report packages.
45 Enclosure
These daily reviews were performed by procedure as part of the inspectors daily plant
status monitoring activities and, as such, did not constitute any separate inspection
samples.
b. Findings
No findings were identified.
.3 Selected Issue Follow-Up Inspection: Licensee Issue Report on Auxiliary Feedwater
System Crosstie Modification
a. Inspection Scope
The inspectors performed a review of the item below that was identified by an NRC
inspector at a different but similar facility:
- Auxiliary Feedwater System Modification.
This review constituted one in-depth problem identification and resolution sample as
defined in IP 71152-05.
b. Findings
No findings were identified.
.4 Annual Sample: Review of Operator Workarounds
a. Inspection Scope
The inspectors evaluated the licensees implementation of their process used to identify,
document, track, and resolve operational challenges. Inspection activities included, but
were not limited to, a review of the cumulative effects of the operator workarounds
(OWAs) on system availability and the potential for improper operation of the system, for
potential impacts on multiple systems, and on the ability of operators to respond to plant
transients or accidents.
The inspectors performed a review of the cumulative effects of OWAs. The documents
listed in the Attachment were reviewed to accomplish the objectives of the inspection
procedure. The inspectors reviewed both current and historical operational challenge
records to determine whether the licensee was identifying operator challenges at an
appropriate threshold, had entered them into their CAP, and proposed or implemented
appropriate and timely corrective actions which addressed each issue. Reviews were
conducted to determine if any operator challenge could increase the possibility of an
Initiating Event, if the challenge was contrary to training, required a change from
long-standing operational practices, or created the potential for inappropriate
compensatory actions. Additionally, all temporary modifications were reviewed to
identify any potential effect on the functionality of Mitigating Systems, impaired access to
equipment, or required equipment uses for which the equipment was not designed.
Daily plant and equipment status logs, degraded instrument logs, and operator aids or
tools being used to compensate for material deficiencies were also assessed to identify
any potential sources of unidentified operator workarounds.
46 Enclosure
This review constituted one operator workaround annual inspection sample as defined in
IP 71152-05.
b. Findings
No findings were identified.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion (71153)
.1 (Closed) Licensee Event Report 05000455/2011-001, Revision 0 and Revision 1, Unit 2
Emergency Diesel Generator Inoperable for Longer Than Allowed by Technical
Specifications Due to Inadequate Work Instructions
The Licensee Event Report (LER) involved a Unit 2 DG that was unknowingly inoperable
for approximately 6 months due to loose bolting on the upper lubricating oil cooler.
During a routine surveillance on November 17, 2010, a significant oil leak was identified
by the equipment operator. The DG was shut down before damage could occur. The
licensee determined that a bolted flanged connection was misaligned during
reinstallation following maintenance in January of 2010.
NRC Follow-Up inspection 05000455/2011011 determined that the issue was an
apparent violation and a White Finding (EA-11-014). The IR was issued February 11,
2011. On October 4, 2011, an NRC IP 95001 Supplemental IR was issued documenting
the closure of finding 05000455/2011011-01. As the enforcement actions have been
issued, and the Supplemental Inspection has been completed with no significant issues
identified, these LERs are closed.
.2 (Closed) Licensee Event Report 05000455/2011-002, Revision 0, Containment
Pressure Not Within Limits Longer than Allowed By Technical Specifications Due to
Personnel Error
The LER involved a licensee-identified mistaken plugging of a pressure sensor inside of
containment during the previous refueling outage. The plugged was placed during a
routine surveillance on September 28, 2011 and on October 13, 2011, licensee
personnel determined that while the instrument indicated that Unit 2 containment
pressure was within limits, that, in fact containment pressure was above the TS limit. A
containment entry was made, the plug was removed, containment pressure was reduced
and the peak pressure was determined to be approximately 1.91 pounds per square inch
gauge (psig). The TS allowed value was 1.0 psig and the amount of time that the
pressure could be above the limit was 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> with the plant required to be shut down
within the following 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br />. By the time the situation was identified, understood, and
corrected a total time of 95 hours0.0011 days <br />0.0264 hours <br />1.570767e-4 weeks <br />3.61475e-5 months <br /> and 48 minutes had elapsed.
The licensee determined and the inspectors verified that the licensees safety margin
between peak containment pressure and the initial maximum allowed pressure was
10 psig. The technicians error and the delay in correcting the error resulted in 0.91 psig
of the 10 psig margin being used. There was a minor adverse safety consequence due
to the licensee personnels error.
The technicians error identified by the licensee resulted in a minor failure to comply with
TS 3.6.4, Containment Pressure. This LER is closed.
47 Enclosure
4OA6 Management Meetings
.1 Exit Meeting Summary
On January 12, 2012, the inspectors presented the inspection results to Mr. B. Youman,
and other members of the licensee staff. The licensee acknowledged the issues
presented. The inspectors confirmed that none of the potential report input discussed
was considered proprietary.
.2 Interim Exit Meetings
Interim exits were conducted for:
- The results of an Operator Licensing inspection with the Lead Operations Training
staff instructor, Mr. M. McCue, via telephone on December 8, 2011.
- The results of an annual review of Emergency Action Level and Emergency Plan
changes with the Emergency Preparedness Coordinator, Mr. R. Kartheiser, via
telephone on December 7, 2011.
- The results of Occupational and Public Radiation Safety programs inspections
with the Site Vice President, Mr. T. Tulon, on November 10, 2011 and with the
Acting Plant Manager, E. Hernandez, on December 28, 2011.
The licensee acknowledged the issues presented. The inspectors confirmed that none
of the potential report input discussed was considered proprietary. Proprietary material
received during the inspection was returned to the licensee.
4OA7 Licensee-Identified Violations
The following violation of very low safety significance was identified by the licensee. The
violation met the criteria of Section VI of the NRC Enforcement Policy for being
dispositioned as a Non-Cited Violation.
.1 Effluent Monitors Alarms Setpoints Incorrectly Established
Technical Specification 5.5.1 states that the ODCM shall contain the methodology and
parameters used in the calculation of offsite doses resulting from radioactive gaseous
and liquid effluents, and in the calculation of gaseous and liquid monitoring alarm and
trip setpoints.
Contrary to the above, on August 26, 2010, the licensee identified a potential for
non-conservative alarm setpoints for effluent monitors. Subsequently, the licensee
calculated new setpoints for these monitors using the methodology prescribed in the
ODCM and determined that the previous alarm setpoints were incorrectly established
and were non-conservative (too high). The inspectors determined that this finding was
of more than minor significance because it was similar to Example 6.c in IMC 0612,
Appendix E, Example of Minor Issues. Specifically, the effluent monitors with its alarm
set points would have failed to perform its intended function (i.e., trip or isolation
function) to prevent an instantaneous effluent release in excess of the applicable TS
instantaneous dose rate limits for gases. In accordance with IMC 0609, Appendix D,
48 Enclosure
Public Radiation Safety, the inspectors determined the violation to be of very low safety
significance, (Green) because the dose impact to a member of the public from the
radiological release was less than the dose values in Appendix I to 10 CFR Part 50 and
10 CFR 20.1301(e). This violation of TS 5.5.1 is being treated as a NCV consistent with
Section 2.3.2 of the NRC Enforcement Policy. The licensee entered this issue into their
CAP as IR 1106461.
ATTACHMENT: SUPPLEMENTAL INFORMATION
49 Enclosure
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
T. Tulon, Site Vice President
B. Youman, Plant Manager
D. Coltman, Operations Manager
J. Feimster, Design Engineering Manager
D. Damptz, Acting Maintenance Director
S. Swanson, Nuclear Oversight Manager
R. Gayheart, Training Director
B. Barton, Radiation Protection Manager
K. Anderson, Acting Radiation Protection Manager
A. Creamean, Chemistry Manager
D. Gudger, Regulatory Assurance Manager
R. Cameron, Licensed Operator Requalification Lead
Nuclear Regulatory Commission
E. Duncan, Chief, Branch 3, Division of Reactor Projects
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
05000454/2011005-001 NCV Failure to Identify Voided Sections of AF Piping
(Section 1R15)05000455/2011005-001 NCV Failure to Identify Voided Sections of AF Piping
(Section 1R15)05000454/2011005-002 NCV High Energy Line Break Operability Evaluation
(Section 1R15)05000455/2011005-002 NCV High Energy Line Break Operability Evaluation
(Section 1R15)05000454/2011005-003 URI Use of TLDs May Not be Consistent with the Methods
Used by the NVLAP Accreditation Process (Section 2RS4)05000455/2011005-003 URI Use of TLDs may not be consistent with the methods used
by the NVLAP accreditation process (Section 2RS4)05000454/2011005-004 NCV Failure to Identify Hazardous Materials on Transportation
Manifest (Section 3RS8)
1 Attachment
Closed
05000455/2011011-00 LER Unit 2 Emergency Diesel Generator Inoperable for
Longer Than Allowed by Technical Specifications
Due to Inadequate Work Instructions, Revision 0
05000455/2011011-01 LER Unit 2 Emergency Diesel Generator Inoperable for
Longer Than Allowed by Technical Specifications
Due to Inadequate Work Instructions, Revision
2 Attachment
LIST OF DOCUMENTS REVIEWED
The following is a list of documents reviewed during the inspection. Inclusion on this list does
not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that
selected sections of portions of the documents were evaluated as part of the overall inspection
effort. Inclusion of a document on this list does not imply NRC acceptance of the document or
any part of it, unless this is stated in the body of the inspection report.
Section 1R01: Adverse Weather Protection (Quarterly)
- IR 1067880; Byron 2010/2011 Winter Readiness Critique, March 30, 2011
- IR 1186291; 2010/2011 Winter Readiness Critique, March 11, 2011
- IR 1193076; Action Tracking Process Versus Work Control Process, December 2, 2010
- IR 1238947; SX Chemical Feed Lines Need Insulating, July 12, 2011
- IR 1262839; Winter Readiness Work Rescheduled, September 14, 2011
- IR 1265348; Unable to Resolve Parts Required Issue, September 14, 2011
- IR 1265934; Winter Readiness Challenge - No CST Heaters Available, September 21, 2011
- IR 1280434; Switchyard Winter Readiness PM, October 24, 2011
- IR 1280750; Freeze Protection - CWPH Louvers LV48, 142 Stuck Open, October 24, 2011
- IR 1280755; Freeze Protection - Electric Heater 0VV37C Fan Motor, October 24, 2011
- IR 1280755; Freeze Protection: Electric Heater 0VV37C Fan Motor, October 24, 2011
- IR 1280757; 0VH09Y - Damper Stuck Open, October 24, 2011
- IR 1281870; Roof Access Hatch Will Not Remain Closed, October 26, 2011
- IR 1285676; Winter Readiness Walkdown, November 2, 2011
- IR 1286684; 0VT17J LV-82 Has a Louver Broke Preventing Set From Closing,
November 5, 2011
- IR 1286686; 0VT11J LV-8 Has a Set of Louvers Not Fully closed, November 5, 2011
- IR 1286687; 0VT16J LV-80 Has a Broken Louver Preventing Set From Closing,
November 5, 2011
- IR 1286688; 0VT13J LV-17 Has 2 Sets of Louvers Not Fully Closed, November 5, 2011
- IR 1286689; 0VT18J LV-83 Has Broken Louvers Preventing Set From Closing,
November 5, 2011
- IR 1286693; 0VT20J LV-86 Sets of Louvers Not Fully Closed, November 5, 2011
- IR 1286904; 0VT07J LV-4 Has Broken Louvers, November 5, 2011
- IR 1286907; 0VT08J LV-5 Has 2 Sets of Louvers Not Fully Closed, November 5, 2011
- IR 1286908; 0VT10J LV-7 Has One Broken Louver, November 5, 2011
- IR 1286910; 0VT14J LV-18 Has a Set of Louvers Not Fully Closed, November 5, 2011
- IR 1286912; 0VT12J LV-9 Has Broken Louvers and Sets Not Fully Closed, November 5, 2011
- IR 1289988; Freeze Protection Concern, November 13, 2011
- IR 1293508; Winter Readiness System Review Work Removed From 2011,
November 15, 2011
- IR 1297625; 0BOSR XFT-A1, SH Area Heaters Testing Discrepancies, December 3, 2011
- Unit 2 Standing Order; Station Heat Coil Degradation in Unit 2 VA Plenum, Log #11-053
- 0BOSR XFT-A1; Freezing Temperature Equipment Protection SH and Department Support
Requirements, Revision 13
- 0BOSR XFT-A3; Freezing Temperature Equipment Protection Plant Ventilation Systems,
Revision 8
- 0BOSR XFT-A4; Freezing Temperature Equipment Protection Area Buildings Ventilation
Systems and Tanks, Revision 7
- 0BOSR XFT-A5; Freezing Temperature Equipment Protection Non-Protected Area Buildings
Ventilation Systems, Revision 6
3 Attachment
- BOP XFT-1; Cold Weather Operations, Revision 2
- IR 1298335; 0BOSR XFT-A3 Freezing Temperature Protection Discrepancies,
December 05, 2011
Section 1R04: Equipment Alignment (Quarterly)
- Drawing M-62; Diagram of Residual Heat Removal, Revision BD
- BAP 300-1A1; At The Controls Area, Revision 52
- BOP RH-E2A; Unit 2 Residual Heat Removal System Train A Electrical Lineup, Revision 4
- BOP RH-M2A; Unit 2 Residual Heat Removal System Train A Valve Lineup, Revision 10
- IR 0332862; 1B AF Pump Air Box Leakage, May 07, 2005
- IR 1289049; Fireproofing on Column Outside 1B AF Pump Room Degraded,
November 10, 2011
- IR 1299293; AF005 Flow Control Valve Trim Clearance Low Margin Issue,
November 21, 2011
IR 1304078; Fire Drill Observation - SCBA Voice Amplifiers Not Working, December 17, 2011
- EC 355468; Evaluation of Diesel Driven Auxiliary Feedwater Air Box Gaps, Revision 0
- SPEC. L-2722 Proposed Seal for 2AB-1086 Unit 2; Sheet Numbers 1A, 1, 2, and 3, Revision 1
Section 1R04: Complete System Walkdown (Semi-Annual)
- BOP AF-M2B; Auxiliary Feedwater Train B Valve Lineup, Revision 4
Section 1R05: Fire Protection (Quarterly)
- IR 1076490; Fire Damper 2VE04Y Access Door Hinge Tack Welds Broken, May 28, 2011
- IR 1075765; Electro-Thermo-Link Separated, June 1, 2010
- IR 1077737; Need CO2 OSS for 2 ICSRs on the T.S. Fire Tamper Surveillance, June 7, 2010
- IR 1072592; 2VD23YA Flexible Conduit Support Clip not Holding Conduit, May 24, 2010
- IR 1072640; Debris in Tray Below Damper 2VD63Y, May 24, 2010
- IR 1073509; Flexible Conduit Loose at Upper, South ETL on Fire Damper, May 26, 2010
- IR 1081618; Difficult to Access Damper, 1VE06Y for Surveillance/Repair, June 17, 2010
- IR 1289049; Fireproofing on Column Outside 1B AF Pump Room Degraded,
November 10, 2011
- IR 1250346; Fire Brigade Leader Training Issue, August 12, 2011
- Fire Drill Scenario No. 11-04; Unit 1 Auxiliary Boiler Room Fire, September 16, 2011
- Pre-Fire Plan; Fire Area/Zone - FZ 8.3-1 Southeast, Revision 1
- EC 350613; Evaluation of Fire Damper S-Hook Orientation Impact on Dampers 2VD24&B,
VC191Y, and 0VC193Y, Revision 0
- WO 1197473; Tech Spec Fire Damper 18-Month Visual Inspection, December 3, 2009
- WO 1028736; Tech Spec Fire Damper 18-Month Visual Inspection, August 4, 2008
- WO 1124519; Tech Spec Fire Damper 18-Month Visual Inspection, April 14, 2008
- WO 0848826; Tech Spec Fire Damper 18-Month Visual Inspection, December 15, 2006
- 0BMSR 3.10.g.7; TRM Fire Damper 18-Month Visual Inspection, Revision 13
- IR 1304076; Fire Drill Observation - Personnel Walking Through SIM Smoke,
December 17, 2011
- RM-AA-101; Records Management Program, Revision 9
- OP-AA-201-003; Fire Drill Performance, Revision 12
4 Attachment
Corrective Action Documents As a Result of NRC Inspection
IR 1291986; NRC Identified Fire Damper S-Hook Orientation Issue, November 17, 2011
IR 1304063; NRC Identified Issues with S-Hooks Not Resolved, December 17, 2011
Section 1R12: Maintenance Effectiveness (Quarterly)
- IR 1058790; Bad Fuse Found in 2RD06J Panel, April 20, 2011
- IR 1061760; MG Set Motor Smoked on Attempted PM Start, April 26, 2011
- IR 1062164; Motor Cutoff Switch Replaced for 2RD 05E-1B, April 27, 2011
- IR 1065922; Unit 2 Rods Will Not Manually Withdraw, May 5, 2010
- IR 1066455; Unit 2 RD07J Cabinet Capacitor Found Broken, May 6, 2011
- IR 1066490; 2A RD MG Set 1 OVT Timer Failed, May 6, 2011
- IR 1067031; Vibrations Levels on 2B Rod Drive MG Set Remain Unchanged, May 8, 2011
- IR 1290831; 1A RD MG Set Increased Vibrations, November 15, 2011
- BOP RD-5; Control Rod Drive MG Set Up and Paralleling to Operating Control Rod Drive MG
Set, Revision 10
Section 1R13: Maintenance Risk Assessments and Emergent Work Control (Quarterly)
- ER-AA-600-1042; On-Line Risk Management, Revision 7
- ER-AA-600-1021; Risk Management Application Methodologies, Revision 4
- PC-AA-1014; Risk Management, Revision 2
- 0BOA ENV-1; Adverse Weather Conditions Unit 0, Rev. 108
- 1BOA ENV-1; Adverse Weather Conditions Unit 0, Rev. 102
- 0BOA ENV-2; Rock River Abnormal Water Level Unit 0, Rev. 100
- IR 1285254; Rock River Level Low, November 2, 2011
Section 1R15: Operability Evaluations (Quarterly)
- IR 240597; Unplanned LOCAR Entry for 2A Emergency Diesel Generator Due to 2VD024YB
- IR 240972; Fire Damper S Hook Installed Improperly, August 2, 2004
- IR 240985; Need Work Request for Fire Damper Inspections, August 2, 2004
- IR 248940; Fire Damper Issues Identified by NRC, August 31, 2004
- IR 249486; Fire Damper S Hook Issue Identified by NRC, September 2, 2004
- IR 297682; NRC Question About Fire Damper S-Hooks, February 4, 2005
- IR 757875; Fire Damper S-Hooks, April 1, 2008
- IR 1285361; Potential Multiple Starts of Diesel Driven AF Pump, November 2, 2011
- IR 1291986; NRC Identified Fire Damper S-Hook Orientation Issue, November 17, 2011
- IR 1292337; Piping Between 2AF006B and 2AF017B Found Not Full, November 18, 2011
- IR 1295958; AF Improvement Suggestion, November 18, 2011
- IR 1295958; AF Improvement Suggestion, November 18, 2011
- IR 1295488; EOC Review of Byron IP 1291986 Fire Damper S-Hooks, November 29, 2011
- Three Mile Island Corrective Action Program Number TI999-0943 linked to ETTS # 25169;
One Section of Fire Damper AH-FD-22 Did Not Close During Test, October 1, 1999
- EC 350613; Evaluation of Fire Damper S-Hook Orientation Impact on Dampers 2VD24YB,
VC191Y and OVC193Y, August 11, 2004
- EC 350550; Evaluation of Fire Damper S-Hook Orientation Impact, August 31, 2004
- WO 1197473 01; Technical Specification Fire Damper 18 Month Visual Inspection,
December 3, 2009
5 Attachment
- EC 383229; Fill Empty Pipe Between 1AF006A and 1AF017A, Close Drain Valve 1AF018A,
and Throttle Open Vent Valve 1AF030A, Revision 0
- EC 383308; OP EVAL 11-003, Small Voids in 2A and 2B SX to AF Suction Piping, Revision 0
- EC 386578; OP Evaluation 11-009 Multiple Starts of Diesel AF Pump, November 8, 2011
- WO 1124519 01; Technical Specification Fire Damper 18 Month Visual Inspection,
April 14, 2008
- WO 848828 01; Technical Specification Fire Damper 18 Month Visual Inspection,
December 15, 2006
- BOP AF-3, Filling and Venting the Auxiliary Feedwater System, Revision 4
- M-1FW01147X; Drawing, Byron Unit 1 Support M-1FW01147X, Rev. D
- M-1SI06010X; Drawing, Byron Unit 1 M-1SI06010X Sub. E
- 13.1.29; Calculation for Mechanical Component Support M-1SI06010X, Rev. D
- 13.1.29; Calculation for Mechanical Component Support M-1SI06010X, Rev. E
- 13.1.29; Calculation for Mechanical Component Support M-1SI06025V, Rev. F
- 13.1.29-BYR97-359; 1SI06010X, 1SI06012X, 1SI06031X, 1SI06075X, 1SI06105X, and
1SI06155X. Evaluate Subsystem 1SI06 Supports for Additional Loads, Rev. 5
- 14.1.18-1FW01147; Calculation for Mechanical Component Support Number M-1FW01147X,
Rev. 0
- IR 1272187; Issues Applicable to Byron from Braidwood Mod/50.59 Inspection,
October 4, 2011
- BRW-97-0827-M; Piping Evaluation for Lead Shielding on Subsystem 2SI06, Rev. 0
- RH-2; Large Bore Isometric, Residual Heat Removal System, Rev. 22
- IR 1276280; UFSAR Section 3.6 and Piping Design Specifications are Inconsistent,
October 13, 2011
- IR 1276069; 1/2FW01 Piping Calculation Revisions Do Not Meet UFSAR Requirements,
October 13, 2011
- IR 1272834; Incorrect Coding of Support Skew on 1FW01 Piping, October 5, 2011
- EMD-064195; Calculation, Addendum E to Piping Stress Report for Subsystem 1SI06, Rev. 5
- IR 1262559; BOP ID: Small Shift Trend in Major Plant Parameters, September 13, 2011
- IR 1265515; U1 RX Power Lowered Below 99.5% for LEFM Troubleshooting,
September 16, 2011
- IR 1253439; LEFM Computer Point Is Off Normal Per 1BOSR CX-M1, August 19, 2011
- IR 1263929; LEFM Alarms in IR 1241271 and Card Analysis- OEM Review Results,
September 16, 2011
- IR 1241271; LEFM Trouble Alarm - Ramp Back, July 19, 2011
- IR 1241629; LEFM Trouble Alarm Causing Unit 1 Ramp Back Again, July 19, 2011
- IR 1277627; NRC Questions on HELB - Presence of Openings, October 17, 2011
- IR 1279759; Added Scope to Turbine Building HELB Effort, October 21, 2011
- IR 1244251; HELB Discussion with the NRC Residents, July 26, 2011
- IR 1240295; Two New Line Break Locations Identified During HELB Analysis, July 15, 2011
- IR 1238611; Inoperability of ESF Components Due To HELB, July 11, 2011
- IR 1237133; Non-Conservatism in Turbine Building HELB Analysis, July 6, 2011
- IR 1184258; Non-Conservatism in Turbine Building HELB Analysis, March 7, 2011
- IR 1276895; NRC Question - Effect of Turbine Building HELB on Reactor Trip Breakers,
October 14, 2011
Section 1R19: Post Maintenance Testing (Quarterly)
- IR 1272802; 2B CS Pump Did Not Auto Start During 2B DG Sequence Test, October 5, 2011
- WO 1476986 02; 2B CS Pump Did Not Auto Start During 2B DG Sequence Test,
October 5, 2011
6 Attachment
- WO 1476986 03; 2B CS Pump Did Not Auto Start During 2B DG Sequence Test,
October 5, 2011
- ER-AA-1200; Critical Component Failure Clock, Revision 7
- WO 1324847; 2AF014E IST Disassembly and Inspection, October 5, 2011
- WO 1324407; 2AF014G IST Disassembly and Inspection, October 5, 2011
- WO 1365478; 2AF014H IST Disassembly and Inspection, October 5, 2011
- 2BOSR 7.5.7-2; Unit 2 Train B Auxiliary Feedwater Flow Path Operability Surveillance
Following Shutdown, Rev. 6
- IR 1272927; 2B AF Static Pressure Gauge Indication Failed Low, October 5, 2011
- 2BOSR 0.5-2.RH.4-1; Unit 2 ASME Surveillance Requirements for Residual Heat Removal
Pump Miniflow Valve 2RH610, Revision 5
Section 1R20: Refueling and Other Outage Activities
- 2BGP 100-1; Plant Heatup, Revision 50
- 2BGP 100-2; Plant Startup, Revision 40
- 2BGP 100-3; Power Ascension, Revision 73
Section 1R22: Surveillance Testing (Quarterly)
- IR 128875; Error in RCS Leakrate Data in MCR Logs, November 10, 2011
- BOP AF-1; Diesel Driven Aux Feedwater Pump Alignment to Standby Condition, Revision 24
- BOP AF-7; Diesel Driven Auxiliary Feedwater Pump 1B Startup on Recirc, Revision 37
- BOP AF-7T1; Diesel Driven Auxiliary Feedwater Pump Operating Log, Revision 21
- BOP AF-8; Diesel Driven Auxiliary Feedwater Pump 1B Shutdown, Revision 22
- WO 1459476 01; 1AF01PB Group B IST Requirements for Diesel Driven AF Pump,
October 28, 2011
- 1BOSR 7.5.4-2; Unit 1 Diesel Driven Auxiliary Feedwater Pump Monthly Surveillance,
Revision 14
- 2BOSR 8.1.11-2; 2B Diesel Generator Sequencer Test 18 Month, Revision 11
- WO 1337989 01; 2B Diesel Generator Sequencer Test, October 5, 2011
- IR 1281160; 1SI8958B Failed Acceptance Criteria During 1B RH PP IST, October 25, 2011
- IR 1298289; Unit 2 RCS Leakrate Surveillance Needs Improvements, December 05, 2011
- 0BMSR FP-5; Fire Hydrant Yard Loop Annual Flush, Revision 8
- WO 1454082; 1RH01PB Group A IST Requirements for Residual Heat Removal Pump,
October 25, 2011
- IR 1281160; 1SI8958B Failed Acceptance Criteria During 1B RH PP IST, October 25, 2011
Corrective Action Documents As a Result of NRC Inspection
- IR 1304054; Surveillance Improvements Needed, December 17, 2011
2RS1: Radiological Hazard Assessment and Exposure Controls (71124.01)
- AR 1214604; NOS ID B1R17 RP Outage Adverse Trend; 5/11/2011
- AR 1243013; RP Response to Fire Alarm Did Not Meet Expectations; 7/22/2011
- AR 1248312; NOS ID Poor Contamination Boundary Controls in FHB; 8/5/2011
- BRP 5800-3; Area Radiation Monitoring System Alert/High Alarm Setpoints; Revision 25
- BRP 5820-14; Process Radiation Monitoring System Alert/High Alarm Setpoints; Revision 42
- RP-AA-460; Controls for High and Locked High Radiation Areas; Revision 20
- RP-AA-460-001; Controls for Very High Radiation Areas; Revision 2
7 Attachment
- RP-AA-460-003; Access to HRAs/LHRAs in Response to a Potential or Actual Emergency;
Revision 1
- RP-AP-460; Access to Reactor In-Core Sump Area; Revision 2
2RS3: In-Plant Airborne Radioactivity Control and Mitigation (71124.03)
- Work Order 1094446 01; Non Accessible Charcoal Adsober Operability Test; 8/31/2009
- Work Order 1149597 01; Perform Recirc Charcoal Halide Test Control Room Ventilation
System; 3/16/2010
2RS4: Occupational Dose Assessment (71124.04)
- National Voluntary Laboratory Accreditation Program; Selected Records; Various Dates
2RS5: Radiation Monitoring Instrumentation (71124.05)
- AR 1106461; Non-Conservative Liquid Discharge Alarm Setpoints; 8/26/2010
- AR 1107149; Additional Investigation Required for ODCM/LCO Implementation; 8/29/2010
- AR 1302586; Non-Conservative Setpoints Found for TRM Rad Monitors; 12/14/2011
- AR 1303888; Potential RETS Impact Due to Non-Conservative PRM Setpoints; 12/16/2011
- BRP 5800-3; Area Radiation Monitoring System Alert/High Alarm Setpoints; Revision 25
- BRP 5820-12; Response to Area and Process Radiation Monitor LCOARS or Out of Service
Conditions; Revision 28
- BRP 5820-14; Process Radiation Monitoring System Alert/High Alarm Setpoints; Revision 42
- BYR-10-001; Calculation of Liquid Process Radiation Monitor Set Points; 8/30/2010
- RP-BR-951; Set Point Changes for Process Radiation Monitors; ODCM (Effluent) Monitors;
Revision 0.
2RS6: Radioactive Gaseous and Liquid Effluent Treatment (71124.06)
- 2009 Byron Station Annual Radioactive Effluent Release Report; April 30, 2010
- 2010 Byron Station Annual Radioactive Effluent Release Report; April 29, 2011
- AR 00978684; Effluent Monitor Surveillance Not Performed Per Procedure; dated October 13,
2009
- AR 00996917; Effluent Release Process - Potential Gaps; dated November 22, 2009
- AR 01106461; Non-Conservative Liquid Discharge Alarm Setpoints; dated August 26, 2010
- AR 01107146; Additional Investigation Required for ODCM/LCO Implementation; dated
August 29, 2010
- AR 01108146; Treatment of Ar-41 in Gaseous Effluents; dated August 31, 2010
- AR 1247902; 1/2 RE-PR-028 Particulate Filters Could Not Be Located; 8/4/2011
- BCP-400-TWX01; Liquid Radwaste Release from Release Tank OWX01T; Revision 59
- CY-AA-120-400; Closed Cooling Water Chemistry; Revision 13
- CY-AA-120-420; Auxiliary Boiler Chemistry; Revision 10
- CY-AA-130-201; Radiochemistry Quality Control; Revision 1
- CY-AA-170-000; Radioactive Effluent and Environmental Monitoring Programs; Revision 5
- CY-BY-170-301; Offsite Dose Calculation Manual; Revision 6
- CY-BY-170-301; Offsite Dose Calculation Manual; Revision 7
- FASA 1013272; Radioactive Gaseous and Liquid Effluents (RETS); 9/17/2010
- FASA 831375; Radioactive Gaseous and Liquid Effluents (RETS); 3/31/2009
- Gaseous Discharge Permit Number 110411; dated October 13, 2011
- Gaseous Discharge Permit Number 110445; dated October 31, 2011
8 Attachment
- Liquid Discharge Permit Number 110437; dated October 25, 2011
- RP-BY-900-1PR29J; 1PR29J Process Radiation Monitor Radiological Air Sampling;
Revision 2
- RP-BY-900-2PR29J; 2PR29J Process Radiation Monitor Radiological Air Sampling;
Revision 2
- Work Order 1110220 01; Fuel Handling Building Exhaust Charcoal Adsorber Bank Operability
Test; 12/21/2009
- Work Order 1236016 01; Perform Calibration of Rad Monitor 1PR28J; 1/18/2011
- Work Order 1249358 01; Perform Surveillance Test of 2PR28J; 4/26/2011
2RS7: Radiological Environmental Monitoring Program (71124.07)
- 2009 Byron Station Annual Radiological Environmental Operating Report; May 2010
- 2010 Byron Station Annual Radiological Environmental Operating Report; May 2011
- 2010 Land Use Census; dated August 30, 2010
- AR 00958298; ODCM Vent Stack Coordinates Inaccurate; dated August 27, 2009
- AR 01034880; REMP Milk Sample - Invalid Result; dated February 24, 2010
- AR 01090911; REMP Groundwater Sample Location No Longer Participating; dated July 15,
2010
- AR 01122156; REMP Sample Results above Detection Limit; dated October 5, 2010
- AR 01129610; Check-In Self-Assessment on the Radiological Environmental Monitoring
Program (REMP); Approved June 20, 2011
- AR 01223226; REMP Air Samples - Positive Detects for I-131; dated June 1, 2011
- Environmental, Inc. Sampling Manual, Revision 13
2RS8: Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,
and Transportation (71124.08)
- AR 1015646; Non-Conforming Waste Found in Radwaste Shipment; 1/12/2010
- AR 1067394; Non-Conforming Radioactive Waste in Shipment; 5/10/2010
- AR 1173307; RWS10-013 Contained Unapproved Mixed Waste; 2/10/2011
- AR 1221229; RWS11-006 Contained Un-Manifested Asbestos; 5/26/2011
- AR 1231158; RWS11-001 Manifested for Material Not Present; 6/21/2011
- AR 1233858; NOS ID: Cause of IR Incorrect RW Shipping Paperwork Not Identified;
6/28/2011
- AR 1250262; NOS ID: RP Failed to Address NOS Issues - Finding; 8/11/2011
- AR 1270337; Sea/Land Inventory Not Documented in Accordance with T&RM; 9/30/2011
- AR 1285148; QHPI Request for RP - RWS Manifest; 11/2/2011
- AR 1285591; NRC Identified: DAW Container Inspections Outside of Procedure Guidance;
11/3/2011
- AR 928393; Non-Conforming Metal Shipped to Bear Creek Processing; 6/5/2009
- Course Code N-RPCTAR; DBIG RAM Shipping/Inspection; Revision 0
- FASA 9866572-03; Radioactive Solid Waste Processing and Radioactive Material Handling,
Storage and Transportation; 4/26/2011
- Letter BYRON-2008-0123; Report of Changes, Tests, and Experiments; 12/12/2008
- Letter BYRON-2010-0147; Report of Changes, Tests, and Experiments; 12/13/2010
- Module/LP ID RPTI 8.05; Radioactive Material Shipments; Revision 18
- NOSA-BYR-10-04 (AR 969170); Chemistry, Radwaste, Effluent and Environmental Monitoring
Audit Report; 6/2/2010
- NOSA-BYR-11-06 (AR 1130876); Radiation Protection; 8/18/2011
9 Attachment
- Performance Training and Evaluation; Task 509-004; Provide Radiological Protection
Coverage During the Preparation of a Shipment of Radioactive Material; 11/5/2009
- Performance Training and Evaluation; Task 509-010; Perform Surveys on Radioactive
Material Transport Vehicles; date not provided
- Performance Training and Evaluation; Task 509-013; Receipt Survey of Radioactive Material;
- Radiation Protection Technician/Continuing Training; DBIG: Waste Acceptance Guidelines;
Revision 0
- RP-AA-100; Process Control Program for Radioactive Wastes; Revision 7
- RP-AA-600; Radioactive Material/Waste Shipments; Revision 12
- RP-AA-600-1001; Exclusive Use and Emergency Response Information; Revision 6
- RP-AA-600-1003; Radioactive Waste Shipments to Barnwell and Defense Consolidation
Facility (DCF); Revision 7
- RP-AA-600-1004; Radioactive Waste Shipments to Energy Solutions Clive Utah Disposal Site
Containerized Waste Facility; Revision 9
- RP-AA-600-1005; Radioactive Material and Non Disposal Site Waste Shipments; Revision 12
- RP-AA-601; Surveying Radioactive Material Shipments; Revision 13
- RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 01/20/2011
- RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 06/02/2011
- RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 10/03/2009
- RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 10/19/2010
- RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 2/17/2010
- RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 8/18/2010
- RP-AA-605 Attachment 1; Trending for Shifts in Scaling Factors; 9/16/2011
- RP-AA-605 Attachment 2; Waste Stream Results Review; DAW; 1/20/2011
- RP-AA-605 Attachment 2; Waste Stream Results Review; DAW; 3/30/2011
- RP-AA-605 Attachment 2; Waste Stream Results Review; DAW; 4/18/2010
- RP-AA-605 Attachment 2; Waste Stream Results Review; Primary Resin; 3/10/2010
- RP-AA-605 Attachment 2; Waste Stream Results Review; Secondary Radwaste Filter;
4/24/2010
- RP-AA-605 Attachment 2; Waste Stream Results Review; Secondary Resin; 3/25/2010
- RP-AA-605; 10 CFR Part 61 Program; Revision 4
- Shipment RMS09-094; Rx Vessel Dosimetry; Type A Package; 11/18/2009
- Shipment RMS11-078; Dirty Laundry; Low Specific Activity (LSA-II); 4/27/2011
- Shipment RWS10-011; Dewatered Bead Resin; Low Specific Activity (LSA-II); 6/29/2010
- Shipment RWS10-012; DAW Trash; Low Specific Activity (LSA-II); 9/1/2010
- Shipment RWS10-013; DAW Trash and TR Pond Sludge; Low Specific Activity (LSA-II);
9/1/2010
Section 4OA1: Performance Indicator Verification (71151)
- IR 1139610; Potential Non-Conservative Tech Specs for Component Cooling;
November 12, 2010
- IR 1139728; CC System OLR Impact From IR 1139610; November 12, 2010
- IR 1141591; 2A DG Emergency Stopped Due to Oil Leak; November 17, 2010
- IR 1158910; RH System Issue Resulting in LER - Tracking; January 05, 2011
- IR 1128409; Threshold for SSFF Approaching White Region; June 14, 2011
- IR 1284054; Legacy Issues with Main Steam Tunnel Pressurization Calculation;
October 31, 2011
- LS-AA-2080; NRC Safety System Functional Failure - July 2010 to July 2011, Revision 4
- EC 382262; Byron OpEval #10-006 - U-0 CC Pump Potential Non-Conservative Tech Spec
10 Attachment
- LER 454/2010-001; Technical Specifications Allowed Outage Time Extension Request for
Component Cooling System Contained Inaccurate Design Information that Significantly
Impacted the Technical Justification, November 12, 2010
- LER 454/2011-001; Potential Loss of Residual Heat Removal System Safety Function in Mode
4 When Aligned for Shutdown Cooling Due to Potential for Flashing or Voiding of Coolant
During a Shutdown Loss of Cooling Accident, January 5, 2011
- LER 455/2011-001; Unit 2 Emergency Diesel Generator Inoperable for Longer than Allowed
by Technical Specifications Due to Inadequate Work, November 17, 2011
- NEI 99-02 Revision 6; Regulatory Assessment Performance Indicator Guideline, October 2009
- Reactor Oversight Program MSPI Basis Document Revision 3; December 2006
- Monthly Data Elements for NRC Reactor Coolant System (RCS) Specific Activity, October
2010 - September 2011
- PWR High Pressure Safety Injection Function, October 2010 - September 2011
- Residual Heat Removal Function, October 2010 - September 2011
- PWR Auxiliary Feedwater/Emergency Feedwater Function, October 2010 - September 2011
- Cooling Water Support Function, October 2010 - September 2011
- IR 1154673; Unable to Perform Manual Stroke Surveillance of 1SX150A, December 20, 2010
- IR 1152376; Unit 2 CWS MSPI Exelon At-Risk, December 14, 2010
- IR 1263487; CWS2 (SX) MSPI Low Margin, September 15, 2011
- IR 1090691; Unit 1 CWS MSPI At-Risk, July 14, 2010
- Monthly Data Elements for NRC Unplanned Power Changes Per 7000 Critical Hours, June
2010 - October 2011
- IR 1259684; Byron PI in Variance - P.8.1.2 Unplanned Power Changes, September 6, 2011
- IR 1116305; Runback of Byron Station U-1 Due to 1A FW PP Trip, September 22, 2010
Section 4OA2: Identification and Resolution of Problems (71152)
- IR 1271650; Difference Between Byron & Braidwood PPC Point Calcs Y2021 & Y2022
- IR 1282689; Pin Hole Leak in Area 7 on 2RY8028 P-44
- IR 1289655; IR Indicates DG Fire Pump Started in Over Ride for Test CCP,
November 04, 2011
- 2BwOSR 3.8.1.14-2; 2B DG 24 Hour Endurance Run, Revision 5
- WO 1323726; 2B DG 24 Hour Endurance Run 18 Month, September 13, 2011
- Analysis BYR11-036; Turbine Building HELB and Room Heat Up Analyses for MUR PU,
Revision 0
- EC 383599; Op Eval 11-005, Turbine Building HELB Analysis Input Errors, Revision 1
- OWA Board Meeting Minutes; Year 2010 Quarter 4, December 28, 2010
- OWA Board Meeting Minutes; Year 2011 Quarter 1, April 5, 2011
- OWA Board Meeting Minutes; Year 2011 Quarter 2, June 30, 2011
- OWA Board Meeting Minutes; Year 2011 Quarter 3, October 14, 2011
- OWA Related IRs; 4Q2010 - 3Q2011
- IR 806396; Both Units SD Systems Degraded for >5 Years, August 12, 2008
- IR 1007239; Review SJAE Strainer Plugging for OWA/OC, December 18, 2009
- IR 1106359; Common Cause - Recommend Venting SD During Stroke Time Surveillance,
August 26, 2010
- IR 1118055; 2A Main Feed Pump Recirc Not Modulating Properly, September 26, 2010
- IR 1122751; Missed Fire Watches in the Past, October 06, 2010
- IR 1151298; Unit 1 Tower Overflow, December 12, 2010
- IR 1155725; Caustic Dilution Flow Only Reading 6 GPM, December 24, 2010
- IR 1158940; Multiple Failure of Employee Alarm System, January 1, 2011
- IR 1169182; MMD Support for 2B FW Pump Turning Gear Operation, January 31, 2011
11 Attachment
- IR 1172246; 0CW278A, Through Wall Crack on Valve Body, February 08, 2011
- IR 1172509; 0CW220 Flow Control Valve Not Repositioning Upon Demand,
February 08, 2011
- IR 1194212; Operator Work Around, March 29, 2011
- IR 1194754; RSH CO2 TK Repair(s) Need to Be Expedited, March 30, 2011
- IR 1194754; Missed Closure of ATI, January 09, 2004
- IR 1211839; 2WG046 Drip Pan is Removed Consider Operator Challenge, May 4, 2011
- IR 1212344; Degradation of RSH CO2 Worsens, May 5, 2011
- IR 1216461; 2B CW PP Intake DP 9 Jumped to 2, May 16, 2011
Corrective Action Documents As a Result of NRC Inspection
- IR 1276895; NRC Question - Effect of TB HELB on Reactor Trip Breakers, October 14, 2011
- IR 1278980; NRC Question - Maintaining VCT Pressure High for Chemistry, October 18, 2011
Section 1EP4: Emergency Action Level and Emergency Plan Changes
- EP-AA-1002; Exelon Nuclear Radiological Emergency Plan Annex for Byron Station;
Revisions 26, 27, and 28
- EP-AA-120-1001; 50.54(q) Program Evaluation and Effectiveness Reviews for Revisions 27
and 28
- EP-AA-120-F-01; EP Document Approval Forms for Revisions 27 and 28
12 Attachment
LIST OF ACRONYMS USED
ADAMS Agencywide Document Access Management System
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
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
RFO Refueling Outage
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
Enclosure: Inspection Report No. 05000454/2011005 and 05000455/2011005
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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
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