IR 05000454/2006003

IR 05000454-06-003; 05000455-06-003; 05000454-06-010; 05000455-06-010; on 04/01/2006-06/30/2006; Byron Station, Units 1 and 2; Routine Integrated Inspection Report

ML062150249
Person / Time
Site:	Byron
Issue date:	08/03/2006
From:	Richard Skokowski NRC/RGN-III/DRP/RPB3
To:	Crane C Exelon Generation Co, Exelon Nuclear
References
IR-06-003, IR-06-010
Download: ML062150249 (37)

Text

August 3, 2006Mr. Christopher M. CranePresident and Chief Nuclear Officer Exelon Nuclear Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555SUBJECT:BYRON STATION, UNITS 1 AND 2 NRC INTEGRATED INSPECTIONREPORT 05000454/2006003; 05000455/2006003; AND 05000454/2006010; 05000455/2006010

Dear Mr. Crane:

On June 30, 2006, the U.S. Nuclear Regulatory Commission (NRC) completed an integratedinspection at your Byron Station, Units 1 and 2. The enclosed report documents the inspectionfindings which were discussed on July 10, 2006, with Mr. Dave Hoots and other members of your staff. The inspection examined activities conducted under your license as they relate to safety andcompliance with the Commission's rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. Based on the results of this inspection, no findings of significance were identified. However,three licensee-identified violations which were determined to be of very low safety significance are listed in this report. The NRC is treating these violations as non-cited violations (NCVs)consistent with Section VI.A.1 of the NRC Enforcement Policy because of the very low safety significance of the violations and because they are entered into your corrective action program.If you contest the subject or severity of a Non-Cited Violation, you should provide a responsewithin 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, D.C.

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 ofEnforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the Resident Inspector office at the Byron facility.

C. Crane-2-In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letterand its enclosure will be made available electronically for public inspection in the NRCPublic 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/Richard A. Skokowski, ChiefBranch 3 Division of Reactor ProjectsDocket Nos. 50-454; 50-455License Nos. NPF-37; NPF-66Enclosure:Inspection Report 05000454/2006003; 05000455/2006003; and 05000454/2006010; 05000455/2006010; w/Attachment: Supplemental Informationcc w/encl:Site Vice President - Byron StationPlant Manager - Byron Station Regulatory Assurance Manager - Byron Station Chief Operating Officer Senior Vice President - Nuclear Services Vice President - Mid-West Operations Support Vice President - Licensing and Regulatory Affairs Director Licensing Manager Licensing - Braidwood and Byron Senior Counsel, Nuclear Document Control Desk - Licensing Assistant Attorney General Illinois Emergency Management Agency State Liaison Officer, State of Illinois State Liaison Officer, State of Wisconsin Chairman, Illinois Commerce Commission B. Quigley, Byron Station

SUMMARY OF FINDINGS

IR 05000454/2006003; 05000455/2006003; 05000454/2006010; 05000455/2006010; on04/01/2006-06/30/2006; Byron Station, Units 1 and 2; Routine Integrated Inspection Report.This report covers a 3-month period of baseline resident inspection and announced baselineinspections on emergency preparedness and maintenance rule. These inspections were conducted by regional inspectors and the resident inspectors. No significant findings were identified. The NRC's program for overseeing the safe operation of commercial nuclear powerreactors is described in NUREG-1649, "Reactor Oversight Process," Revision 3, datedJuly 2000.A.Inspector-Identified and Self-Revealed FindingsNo findings of significance were identified.

B.Licensee Identified Violations

Three violations of very low safety significance, which were identified by the licensee,have been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program. These violations and the licensee's corrective action tracking numbers are listed in Section 4OA7 of this report.

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REPORT DETAILS

Summary of Plant StatusUnit 1 operated at or near full power throughout the inspection period with the followingexception:*On May 6, 2006, the unit reduced power to 88 percent to perform main turbine valvetesting. Following the test, the unit returned to full power on May 7, 2006.Unit 2 operated at or near full power throughout the inspection period with the followingexceptions:.*On April 23, 2006, the unit reduced power to 94 percent to swap main feedwater pumpsfor repair. Following the swap, the unit returned to full power on April 24, 2006.*On April 29, 2006, the unit reduced power to 86 percent to perform main turbine valvetesting. Following the test, the unit returned to full power on April 30,

REACTOR SAFETY

===Cornerstone: Initiating Events, Mitigating Systems, and Barrier Integrity1R01Adverse Weather Protection (71111.01)

a. Inspection Scope

The inspectors completed two inspection samples. The first sample was associatedwith the licensee's readiness for high wind/tornado conditions during the summer===

season. The inspections reviewed the licensee's procedures, operating policy and the limiting conditions of operation for the Ultimate Heat Sink (UHS) related to adverse weather. The inspectors also evaluated the implementation of these procedures andthe licensee preparations for the weather conditions. Specifically, the inspectors reviewed the impact on the following two systems.*Switchyard; and*Essential service water system.The second sample was associated with the review of the licensee's preparations forpotential high temperature conditions. Specifically, the inspectors reviewed the impact on the following three systems:*Switchyard;*Main Steam Pipe Tunnel and Safety Valve Enclosures Ventilation System (VV);

and*Essential service water system (SX).

4During these reviews the inspectors performed the following:*reviewed the Updated Final Safety Analysis Report (UFSAR), TechnicalSpecifications (TS) and other plant documents to identify areas potentiallychallenged by summer temperatures;*reviewed applicable licensee procedures and surveillance tests appropriate formonitoring plant conditions during summer weather;*determined through interviews and record review, that Nuclear Shift Operatorswere familiar with plant systems potentially affected by high temperatures and that necessary procedural and/or contingency plans were in place; and*visually inspected the selected plant systems.The inspectors also reviewed selected issues documented in condition reports (CRs), todetermine if they had been properly addressed in the licensee's corrective action program. The documents reviewed during this inspection are listed in the Attachment to this report.

b. Findings

No findings of significance were identified.

1R04 Equipment Alignment (71111.04).1Partial Walkdowns

a. Inspection Scope

The inspectors performed four partial walkdown samples of accessible portions of trainsof risk-significant mitigating systems equipment during times when the trains were ofincreased importance due to the redundant trains or other related equipment beingunavailable. The inspectors utilized the valve and electric breaker lineups andapplicable system drawings to determine that the components were properly positionedand that support systems were lined up as needed. The inspectors also examined thematerial condition of the components and observed operating parameters of equipment to determine that there were no obvious deficiencies. The inspectors used the information in the appropriate sections of the UFSAR and TS to determine the functional requirements of the systems.The inspectors verified the alignment of the following:

• Unit 1 Train B Diesel Generator Fuel Oil;*Unit 1 Train A Auxiliary Feedwater;*Unit 1 and Unit 2 Diesel Generator Ventilation; and

• Unit 2 Train A Auxiliary Feedwater.The inspectors also reviewed selected issues documented in CRs, to determine if theyhad been properly addressed in the licensee's corrective action program. The documents reviewed during this inspection are listed in the Attachment to this report.

b. Findings

No findings of significance were identified.

1R05 Fire Protection (71111.05)

a. Inspection Scope

The inspectors conducted fire protection walkdowns that were focused on availability,accessibility, and the condition of fire fighting equipment; the control of transientcombustibles and ignition sources; and on the condition and operating status of installed fire barriers. The inspectors reviewed applicable portions of the Byron Station Fire Protection Report and selected fire areas for inspection based on their overall contribution to internal fire risk, as documented in the Individual Plant Examination of External Events Report.The inspectors verified that fire hoses and extinguishers were in their designatedlocations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and that firedoors, dampers, and penetration seals appeared to be in satisfactory condition. The Byron Station Pre-Fire Plans applicable for each area inspected were used by the inspectors to determine approximate locations of firefighting equipment.The inspectors completed nine inspection samples by examining the plant areas listedbelow to observe conditions related to fire protection:*Fuel Handling Building 401' (Zone 12.1-0);*Unit 1 Train B Diesel Fuel Oil Storage Tank Room (Zone 10.1-1);

• Unit 1 and Unit 2 Train B Diesel Generator Ventilation (Zones 18.1-1 and 18.1-2);*Unit 1 and Unit 2 Train A Diesel Generator Ventilation (Zones 18.2-1 and 18.2-2);*Unit 1 Division 11 Miscellaneous Electrical Equipment and Battery Room(Zone 5.6-1); *Unit 1 Division 12 Miscellaneous Electrical Equipment and Battery Room(Zone 5.4-1);*Unit 1 Cable Tunnel & Cable Riser Room (Zone 3.1-1);

• Unit 1 Auxiliary Building Laundry Room (Zone 11.6C-0); and*Unit 2 Auxiliary Building General Area 346' (Zone 11.2-0).The inspectors reviewed selected issues documented in CRs, to determine if they hadbeen properly addressed in the licensee's corrective action program. The inspectors also verified that minor issues identified during the inspection were entered into the licensee's corrective action program. The documents reviewed during this inspection are listed in the attachment to this report.

b. Findings

No findings of significance were identified.

61R06Flood Protection Measures (71111.06)

a. Inspection Scope

The inspectors evaluated the licensee's controls for mitigating internal and externalflooding by completing one semi-annual sample. The specific areas evaluated for the semi-annual internal flooding sample included the turbine building elevations 380 and 401, circulating water screen house and auxiliary building elevation 401. During theevaluation, the inspectors performed the following:*Reviewed the licensee's design basis documents including the UFSAR andSafety Evaluation Report, to identify the design basis for flood protection and to identify areas susceptible to flooding;*Assessed plant configurations that may be impacted by flooding;

• Inspected areas for control of material that could potentially clog floor drains; and

• Inspected water doors and flood seals.The inspectors also reviewed selected issues documented in CRs to determine if theyhad been properly addressed in the licensee's corrective action program. The documents reviewed during this inspection are listed in the attachment to this report.b.FindingsNo findings of significance were identified.

1R11 Licensed Operator Requalification (71111.11).1Resident Inspector Quarterly Review

a. Inspection Scope

The inspectors completed one inspection sample by observing and evaluating anoperating crew during their response to a simulated dropped control rod, medium sized reactor coolant hot leg break along with the failure of one residual heat removal suction valve to close. The inspectors evaluated crew performance in the areas of:*Clarity and formality of communications;*Ability to take timely actions;

• Prioritization, interpretation, and verification of alarms;

• Procedure use;

• Control board manipulations;

• Supervisor's command and control;

• Management oversight; and

• Group dynamics.The inspectors verified that the crew completed the critical tasks listed in the abovesimulator guide. The inspectors also compared simulator configurations with actual control board configurations. For any weaknesses identified, the inspectors observed the licensee evaluators to determine whether they also noted the issues and discussed 7them in the critique at the end of the session. The inspectors verified that minor issueswere placed into the licensee's corrective action program.The documents reviewed during this inspection are listed in the attachment to thisreport.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness (71111.12).1Resident Inspector Quarter Review

a. Inspection Scope

The inspectors completed two inspection samples by evaluating the licensee'simplementation of the maintenance rule, 10 CFR 50.65, as it pertained to identifiedperformance problems associated with the following structures, systems, and/orcomponents:*Unit 1 SX Return Isolation Valves Degraded (1SX011 & 1SX136); and*SX Cooling Tower Fan Blade Degradation.The inspectors evaluated the licensee's appropriate handling of structur es, system s, and components (SSC) condition problems in terms of appropriate work practices and characterizing reliability issues. Equipment problems were screened for review using aproblem oriented approach. Work practices related to the reliability of equipmentmaintenance were observed during the inspection period. Items chosen were risk significant, and extent of condition was reviewed as applicable. Work practices were reviewed for contribution to potential degraded conditions of the affected SSCs. Related work activities were observed and corrective actions were discussed with licensee personnel. The licensee's handling of the issues being reviewed was evaluated under the requirements of the maintenance rule.The inspectors also reviewed selected issues documented in CRs, to determine if theyhad been properly addressed in the licensee's corrective action program. The documents reviewed during this inspection are listed in the attachment to this report.

b. Findings

No findings of significance were identified..2Maintenance Effectiveness Periodic Evaluation (71111.12B)

a. Inspection Scope

The inspectors examined the Maintenance Rule periodic evaluation report completed forthe period of July 2003 through December 2004. To evaluate the effectiveness of (a)(1)8and (a)(2) activities, the inspectors examined a sample of (a)(1) Action Plans,Performance Criteria, Functional Failures, and Condition Reports (CRs). These same documents were reviewed to verify that the threshold for identification of problems was at an appropriate level and the associated corrective actions were appropriate. Also, the inspectors reviewed the maintenance rule procedures and processes. The inspectors focused the inspection on the following four systems (samples):*DC System;*Essential Service Water;

• Service Air System; and

• Auxiliary Feedwater.The inspectors verified that the periodic evaluation was completed within the timerestraints defined in 10 CFR 50.65 (once per refueling cycle, not to exceed 24 months). The inspectors also ensured that the licensee reviewed its goals, monitored Structures, Systems, and Components (SSCs) performance, reviewed industry operating experience, and made appropriate adjustments to the maintenance rule program as a result of the above activities.The inspectors verified that:

• the licensee balanced reliability and unavailability during the previous cycle,including a review of high safety significant SSCs; *(a)(1) goals were met, that corrective action was appropriate to correct thedefective condition, including the use of industry operating experience, and that (a)(1) activities and related goals were adjusted as needed; and*the licensee has established (a)(2) performance criteria, examined any SSCsthat failed to meet their performance criteria, and reviewed any SSCs that have suffered repeated maintenance preventable functional failures including a verification that failed SSCs were considered for (a)(1).In addition, the inspectors reviewed maintenance rule self-assessments and auditreports that addressed the maintenance rule program implementation.

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the licensee's management of plant risk during emergentmaintenance activities or during activities where more than one signific ant system ortrain was unavailable. The inspectors chose activities based on their potential to increase the probability of an initiating event or impact the operation of safety-significantequipment. The inspectors verified that the evaluation, planning, control, and 9performance of the work were done in a manner to reduce the risk and the workduration was minimized where practical. The inspectors also verified that contingency plans were in place where appropriate.The inspectors reviewed configuration risk assessment records, UFSAR, TS, andIndividual Plant Examination. The inspectors also observed operator turnovers, observed plan-of-the-day meetings, and reviewed other related documents to determine that the equipment configurations had been properly listed, that protected equipmenthad been identified and was being controlled where appropriate, and that significant aspects of plant risk were being communicated to the necessary personnel.The inspectors completed six inspection samples by reviewing the following activities:

• Unit 1 Train A Auxiliary Feedwater Pump Testing while Bus Tie Breaker 5-6 wasOut of Service (OOS);*Unit 1 Bus Tie Breaker 6-7 Testing while Unit 0 Train A SX Makeup Pump was OOS;*Unit 1 Train A Centrifugal Charging Pump OOS while Bus 7 was in a WorkWindow;*Unit 1 Train A Residual Heat Removal Pump OOS while Unit 0 Train A SXMakeup Pump was OOS for Planned Maintenance;*Unit 2 Train A Residual Heat Removal Pump OOS during Reactor ContainmentFan Cooler Surveillance; and*Unit 1 Train B Safety Injection Pump OOS with Trip of Unit 0 Train A Station AirCompressor.The documents reviewed during this inspection are listed in the Attachment to thisreport.

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations (71111.15)

a. Inspection Scope

The inspectors evaluated plant conditions, selected condition reports, engineeringevaluations, and operability determinations for risk-significant com ponents and systemsin which operability issues were questioned. These conditions were evaluated todetermine whether the operability of components was justified. The inspectors completed five inspection samples by reviewing the following evaluationsand issues:*Unit 0 Train A SX Cooling Tower Fan Blade Degradation;*Unit 1 SX Return Isolation Valves Degraded (1SX011 & 1SX136);

• Unit 0 Train B SX Makeup Pump Fuel Oil Contamination; 10*Unit 1 Auxiliary Building Ventilation while the Bilco Hatch was Removed; and*Unit 1 and Unit 2 Turbine Building Crane with Cracked Welds.The inspectors compared the operability and design criteria in the appropriate section ofthe TS including the TS Basis, the Technical Requirements Manual (TRM) and UFSAR to the licensee's evaluations to determine that the components or systems wereoperable. The inspectors determined whether compensatory measures, if needed, were taken, and determined whether the evaluations were consistent with the requirements oflicensee procedures. The inspectors also discussed the details of the evaluations with the shift managers and appropriate members of the licensee's engineering staff.The inspectors also reviewed selected issues documented in CRs, to determine if theyhad been properly addressed in the licensee's corrective action program. The documents reviewed during this inspection are listed in the attachment to this report.

b. Findings

Introduction:

The inspectors identified an unresolved item (URI) concerning the ability ofthe essential service water system (SX) to perform its safety function after a large leak.Description: On November 29, 2005, during the execution of a clearance order forplanned maintenance, 1SX011, the Unit 1 Train A & B Essential Service Water Cooling Tower (SXCT) basin return header cross-tie isolation valve, and 1SX136, the Unit 1 Train B SXCT return header isolation valve failed to close on demand. The licensee determined that the failure of these isolation valves to close was a maintenancepreventable functional failure and had exceeded the maintenance rule performance criteria for the isolation function. A Maintenance Rule (a)(1) action plan was initiated to address this issue. The inspectors reviewed the operability evaluation for the two degraded valves andidentified a deficiency in the evaluation with respect to the ability of the SX system toperform its safety function after a large leak/break. UFSAR Table 9.2.2, Single-failure Analysis of the Essential Service Water System, showed that upon a break of an SX return line, the remaining return line continues to service one loop in each unit. The licensee determined that the loops could not be separated with the above valves notcapable of closing. However, the licensee's review determined that the SX return line met the exception criterion described in USFAR Section 3.6. Therefore, the licensee determined that they were not required to postulate that the SX lines would crack orbreak and they did not have to evaluate the operability of the system in the event of apipe crack or break.Specifically, UFSAR Section 3.6, "Protection Against Dynamic Effects Associated withthe Postulated Break of Piping," evaluated high and moderate energy line breaks based on Standard Review Plan (SRP) 3.6.1, plant design for protection against postulated piping failures in fluid systems outside containment, and SRP 3.6.2, Determination ofRupture Locations and Dynamic Effects Associated with the Postulated Rupture ofPiping. The licensee based their operability determination that piping failure was notneeded to be evaluated on an exception criterion allowed in SRP 3.6.2.

11The inspectors noted that the licensee was committed to meet General Design Criterion(GDC) 44, Cooling Water System. This GDC required that "suitable redundancy in components and features, and suitable interconnections, leak detection, and isolation capabilities shall be provided to assure that ..... the system safety function can beaccomplished, assuming a single failure. UFSAR 3.1.2.4.15, "Evaluation AgainstCriterion 44 - Cooling Water" stated that "...essential service water systems .... are designed with appropriate redundancy. A single failure can be accommodated without impairing the safety function of the systems."Based on the apparent contradiction between UFSAR Sections 3.6 and 9.2, theinspectors continue to evaluate the design basis requirements of the SX return line with respect to a pipe break and the adequacy of the associated operability evaluation. Specifically whether the operability evaluation must include all aspects of the currentlicensing bases requirements such as single failure, flooding, earthquake, and loss of coolant accident. Therefore, this issue is considered an URI pending internal NRC clarification of the design basis with respect to single failure in the SX system and thepotential impact on the conclusion of the licensee's operability evaluation. (URI05000454/2006003-01)1R17Permanent Plant Modification (71111.17A)

a. Inspection Scope

The inspectors completed one inspection sample by reviewing the following permanentplant modification:*Setpoint Scaling Change for Unit 0 Train A SX Makeup Pump Low Lube OilPressure Trip Time Delay Relay.The inspectors reviewed the setpoint scaling change after the SX makeup pump lowlube oil pressure trip was received prematurely during pump operation. The inspectors verified that the design basis, licensing basis, and performance capability of SX werenot degraded by the scaling change. The inspectors considered the design adequacy of the modification by performing a review of the modification's impact on plant electrical requirements, response time, control signals, equipment protection, operation, failuremodes, and other related process requirements. Implementation and testing was reviewed to ensure SSC performance criteria were met.The inspectors utilized the following references during the completion of their review:

• Updated Final Safety Analysis Report; and*Technical Specifications.The documents reviewed during this inspection are listed in the attachment to thisreport.

b. Findings

No findings of significance were identified.

121R19Post Maintenance Testing (71111.19)

a. Inspection Scope

The inspectors reviewed the post maintenance testing activities associated withmaintenance or modification of mitigating, barrier integrity, and support systems thatwere identified as risk significant in the licensee's risk analysis. The inspectors reviewed these activities to determine that the post maintenance testing was performed adequately, demonstrated that the maintenance was successful, and that operabilitywas restored. During this inspection activity, the inspectors interviewed maintenance and engineering department personnel and reviewed the completed post maintenance testing documentation. The inspectors used the appropriate sections of the TS, TRM, and UFSAR, and other related documents to evaluate this area.The inspectors completed five inspection samples by observing and evaluating the postmaintenance testing subsequent to the following maintenance activities:*Unit 1 Train A Centrifugal Charging Pump Work Window;*Unit 1 Train B Residual Heat Removal Miniflow Isolation Valve Time Delay RelayCalibration;*Unit 2 Train B Residual Heat Removal Pump Work Window;

• Calibration of Unit 1 Steam Generator Narrow Range Level Loop 528 Followingthe Identification of a Crack in a Transformer on the Card; and *Unit 0 Train B SX Makeup Pump Diesel Generator.The inspectors also reviewed selected issues documented in CR's to determine if theyhad been properly addressed in the licensee's corrective action program. The documents reviewed during this inspection are listed in the attachment to this report.

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing (71111.22)

a. Inspection Scope

The inspectors witnessed selected surveillance tests and/or reviewed test data todetermine that the equipment tested using the surveillance procedures met the TS, theTRM, the UFSAR and licensee procedural requirements. The inspectors also reviewed applicable design documents including plant drawings, to verify that the surveillance tests demonstrated that the equipment was capable of performing its intended safety functions. The activities were selected based on their importance in ensuring mitigating systems capability and barrier integrity.These activities represented one routine, one containment isolation valve, and one in-service surveillance testing sample. The following surveillance tests were selected:

13*Unit 2 Main Steam System Containment Isolation Valve Stroke Time andPosition Indication Test;*Unit 1 Train B Diesel Generator Semi-Annual Surveillance;*Unit 2 SX Return Isolation Valve Motor Operator Valve Test 2SX136.Additionally the inspectors used the documents listed in the attachment to this report todetermine that the testing met the frequency requirements; that the tests wereconducted in accordance with procedures, that the test acceptance criteria were met; and that the results of the tests were properly reviewed and recorded. The inspectors verified that the individuals performing the tests were qualified to perform the test in accordance with the licensee's requirements, and that the test equipment used duringthe test were calibrated within the specified periodicity. In addition, the inspectors interviewed operations, maintenance, and engineering department personnel regarding the tests and test results.

b. Findings

No findings of significance were identified.Cornerstone: Emergency Preparedness1EP2Alert and Notification System (ANS) Testing (71114.02)

a. Inspection Scope

The inspectors reviewed and discussed with corporate Emergency Preparedness (EP)staff records on the operation, maintenance, and testing of the ANS in the ByronStation's Emergency Planning Zone, to verify that the ANS equipment was adequatelymaintained and tested during 2005 and 2006, in accordance with emergency plan commitments and procedures. The inspectors reviewed a random sample of records of 2005 and 2006 non-scheduled maintenance activities to determine whether equipment examinations and repairs were initiated in a timely manner following identification of apparent malfunctions. The inspectors also reviewed records of ANS tests conducted in January 2005 through March 2006. The documents reviewed during this inspection are listed in the attachment to thisreport.These activities completed one inspection sample.

b. Findings

No findings of significance were identified.

141EP3Emergency Response Organization (ERO) Augmentation Testing (71114.03)

a. Inspection Scope

The inspectors reviewed and discussed implementing procedures that contained detailson the primary and alternate means of initiating an ERO activation to augment the on-shift ERO. The inspectors also discussed administrative provisions for maintaining Byron Station's ERO roster and ERO members' contact information. The inspectors reviewed records of monthly unannounced off-hours augmentation drills, which wereconducted between January 2005 and April 2006, to determine the adequacy of the drills' critiques and associated use of the corrective action program. The inspectorsreviewed and discussed a program implemented in 2005 that trended each Station ERO member's participation in the off-hours augmentation drills. The inspectors alsoreviewed training records of a random sample of 16 Byron Station ERO personnel, who were assigned to key and support positions, to verify that they were currently trained for their assigned positions. The inspectors also reviewed the Byron Station's and corporate office's ERO rosters, to verify the numbers of persons assigned to each key and support position.The documents reviewed during this inspection are listed in the attachment to thisreport.These activities completed one inspection sample.

b. Findings

No findings of significance were identified.1EP5Correction of Emergency Preparedness Weaknesses and Deficiencies (71114.05)

a. Inspection Scope

The inspectors reviewed Nuclear Oversight (NOS) staff's 2005 audits of the licensee'sEP program to verify that these independent assessments met the requirements of10 CFR 50.54(t). The inspectors reviewed records of EP drills, and exercises conductedduring 2005 and 2006, to verify that the licensee fulfilled its drill and exercisecommitments. The inspectors also discussed with EP staff to verify that representatives of State and county agencies, and other off-site support organizations, were provided the opportunity to obtain NOS staff's assessment of the adequacy of the licensee's interfaces with these organizations. Additionally, the inspectors reviewed two actual emergency plan activations to determine if the licensee effectively implemented the requirements of the emergency plan for an event that occurred on February 28, 2005,which was inspected and dispositioned in NRC Inspection Report 05000454/2005003,and an Unusual Event declared for a fire on February 24, 2006. Samples of corrective action program records, and completed corrective actions, were reviewed to determine whether NOS-identified concerns, dr ill and exercise critique concerns, and other EPprogram concerns, were adequately addressed.

15The documents reviewed during this inspection are listed in the attachment to thisreport.These activities completed one inspection sample.

b. Findings

No findings of significance were identified.4.OTHER ACTIVITIES

4OA1 Performance Indicator Verification

Cornerstone: Initiating Events, Barrier Integrity, Emergency Preparedness.1Initiating Events and Barrier Integrity Performance Indicators

a. Inspection Scope

The inspectors sampled the licensee's submitted materials for performance indicators(PIs) and periods listed below. The inspectors used PI definitions and guidance contained in Revision 2 of Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," to verify the accuracy of the PI data.

The following four PIs for Unit 1 and Unit 2, for a total of eight samples, were reviewed:*Unit 1 Unplanned Scrams per 7000 Critical Hours (April 2004 toDecember 2005); *Unit 2 Unplanned Scrams per 7000 Critical Hours (April 2004 toDecember 2005);*Unit 1 Scrams with Loss of Normal Heat Removal (April 2004 toDecember 2005); *Unit 2 Scrams with Loss of Normal Heat Removal (April 2004 toDecember2005);*Unit 1 Unplanned Transients per 7000 Critical Hours (April 2004 toDecember 2005);*Unit 2 Unplanned Transients per 7000 Critical Hours (April 2004 toDecember 2005);*Unit 1 Reactor Coolant System Specific Activity (April 2004 to December 2005);

and*Unit 2 Reactor Coolant System Specific Activity (April 2004 to December 2005).The inspectors reviewed selected applicable condition reports and data from logs,licensee event reports, and work orders from April 2004 through December 2005 for each PI area specified above. The inspectors independently reperformed calculations where applicable. The inspectors compared that information with the performance indicator definitions in the guideline to ensure that the licensee reported the dataaccurately.

16For the reactor coolant system specific activity PI, the inspectors reviewed the licensee'sChemistry Department records and selected isotopic analyses to verify that the greatest Dose Equivalent Iodine value obtained during those months corresponded with the value reported to the NRC. The inspectors also reviewed selected dose equivalentiodine calculations to verify that appropriate conversion factors were used in the assessment as required by TSs.The documents reviewed during this inspection are listed in the Attachment to thisreport.

b. Findings

No findings of significance were identified..2Emergency Preparedness Performance Indicators

a. Inspection Scope

The inspectors reviewed the licensee's records associated with the three EPperformance indicators (PIs) listed below. The inspectors verified that the licensee accurately reported these indicators, in accordance with relevant procedures and Nuclear Energy Institute guidance endorsed by NRC. Specifically, the inspectorsreviewed licensee records associated with PI data reported to the NRC for the periodApril 2005 through December 2005. Reviewed records included: procedural guidance on assessing opportunities for the three PIs; assessments of PI opportunities during pre-designated Control Room Simulator training sessions, the 2005 biennial exercise, and integrated emergency response facility drills; revisions of the roster of pers onnelassigned to key ERO positions; and results of ANS operability tests. The following PIswere reviewed:*ANS;*ERO Drill Participation; and

• Drill and Exercise Performance.These activities completed three inspection samples.

The documents reviewed during this inspection are listed in the attachment to thisreport.

b. Findings

No findings of significance were identified.

174OA2Identification and Resolution of Problems (71152).1Routine Review of Identification and Resolution of Problems

a. Inspection Scope

As discussed in previous sections of this report, the inspectors routinely reviewed issuesduring baseline inspection activities and plant status reviews to determine that they were being entered into the licensee's corrective action system at an appropriate threshold,that adequate attention was being given to timely corrective actions, and that adversetrends were identified and addressed. Minor issues entered into the licensee's corrective action system as a result of inspectors' observations are generally denoted inthe list of documents reviewed at the back of the report.

b. Findings

No findings of significance were identified..2Selected Issue Follow-up Review - Incorrect Main Control Board (MCB) ManipulatedDuring Training ActivityIntroduction: On April 24, 2006, an Initial License Training (ILT) student under theoversight of a Nuclear Station Operator (NSO) manipulated the wrong valve during aboration of the reactor coolant system. During this boration evolution, the ILT studentwas supposed to open the primary water to Unit 2 boric acid blender inlet flow control valve to flush the boration line. Instead, the boric acid to Unit 2 boric acid Blender inlet flow control valve was opened. The NSO, a second NSO, who was assigned as a peer checker, and a Senior Reactor Operator (SRO), who was designated by procedure to observe any reactivity maneuver, did not recognize that the wrong valve was being manipulated by the ILT trainee. The incorrect manipulation was immediately discovered when the expected primary water flow was not observed at the primary water totalizer by the second NSO. The boric acid flow control valve was closed, and the issue was entered into the licensee's corrective action program as IR 482467.Since the boric acid transfer pump was not running at the time, no boric acid wasinjected into the reactor coolant system as a result of the incorrect valve manipulation. However, it indicated a degradation of one or more barriers to proper reactivity management. In addition, this event revealed the human performance deficiencies of three licensed operators and one ILT trainee. The inspectors selected this issue as one annual sample of the licensee's problem identification and resolution program.Documents reviewed as part of this inspection are listed in the Attachment to this report.

18 a.Prioritization and Evaluation of Issues (1)Inspection ScopeThe inspectors reviewed the apparent cause evaluation (ACE) associated withIR 482467 and discussed the evaluation with members of the licensee's investigation team. The inspector compared the evaluation method used to guidance in the licensee's procedures, and discussed the technical aspects of the issue with members of the licensee's operation staff. The inspectors assessed the licensee's evaluation and disposition of performance issues and prioritization of issues. The inspectors also conducted an independent search on the licensee's corrective action program database to verify if there were similar events in the past.

(2)IssuesIn general the inspectors found that the licensee prioritized and evaluated issuesappropriately. The licensee used a TapRoot Root Cause Tree to determine if the root cause for each causal factor and the root causes identified were being addressed. The licensee concluded that the process requirements of this procedure were adequately followed but the issues occurred because of breakdowns in human performance tool usage. Since this personnel performance error did not result in an actual reactivity addition to the reactor, this issue is considered to be minor. However, personnel performance in the human performance area continues to show weakness and is being treated as a substantive cross-cutting issue under NRC's Inspection M anualChapter 0305. A trend review on this subject is described in Section 4OA2.2 of this report.The licensee also evaluated the extend of condition for the causes identified anddetermined that this issue was limited to the individuals involved as evident by the circumstances. Based on the search of the corrective action program database, the inspectors determined that the licensee had performed an adequate review of previous events in the ACE. No significant issues were identified in this area. b.Effectiveness of Corrective Actions (1)Inspection ScopeThe inspectors reviewed the correction actions prescribed for each apparent cause todetermine if the issues were being resolved promptly and appropriately.

(2)IssuesAs part of the corrective actions for this event, the licensee reinforced the use of humanperformance tools and quality peer-checks to all operating personnel. Training wouldalso be reinforced using the lessons learned from this event. The inspectors determined 19that the corrective actions addressed the causes that were identified. Although some ofthe corrective actions were not completed, the inspectors determined that they wereappropriate and were being implemented in a timely manner.No significant issues were identified in this area..3Semi-Annual Trending Review (71152)a.Inspection ScopeThe inspectors completed a semi-annual review for potential or identified trends. Thepurpose of this review was to determine if any potential or identified trends might indicate a more significant safety issue.The inspectors reviewed issues that were documented in the following licenseeprograms, analyses, assessments or lists:*Systems Classified as (a)(1) under the Maintenance Rule;*Trend Analysis of Operations Communications Issues;

• Byron Station Quarterly System Health Indication Program Report - First Quarter 2006;*Perform Common Cause Analysis on Modifications Process Quarterly TrendData;*Quarterly CAP Trend Analysis for Engineering, October 1, 2005, throughMarch 30, 2006;*Quarterly CAP Trend Analysis for Operations, October 1, 2005, throughMarch 30, 2006; *Common Cause Analysis for Contamination Events During the First and SecondQuarter 2006; *Common Cause Analysis of 2006 QHPI's;

• CCA for Potential Adverse Trend in Procedure Adherence, IR 428949,February 9, 2006; and *Operations Action Plan to Improve 2006 Human Performance.The inspectors reviewed the above information for the time period designated or for thepast 2 years and discussed these programs and reports with the applicable members of the licensee's staff. The inspectors also verified that any trends identified by these programs and reports were appropriately entered and classified in the licensee's corrective action program.The inspectors also considered aspects of the day-to-day inspection activities andcategorized CRs that the inspectors accumulated during their daily review of issues entered into the licensee's corrective action program to determine if trends existed that were overlooked by the licensee. Based on this consideration, the inspectors focused on issues associated with age-related material degradation of plant equipment.

20b. IssuesNo findings of significance were identified. The inspectors noted a number ofage-related material degradation items around the plant. Some of these items had been noted by the licensee and others had not. For example, a number of containment penetration feeder breakers had failed during testing. The licensee had appropriately documented the failures and this issue was added to the Maintenance Rule (a)(1) items.

Another example was the degradation of the Essential Service Water Cooling TowerFan Blades. This too had been observed by the licensee, but the licensee agreed thattheir response could have been more timely.During this and previous inspection periods, the NRC inspectors identified a number ofminor issues. Examples included, a support for the Unit 2 Train B D/G exhaust muffler sheared in two, ventilation barriers on the roof of the auxiliary building rusted andmissing, and a large clamp holding a non-safety related portion of the D/G exhaust rusted through.None of the issues discussed above resulted in violations of NRC requirements. Somecomponents above required complex operability assessments by the licensee, but noneof the TS-required equipment was determined to be inoperable. Licensee personnel, including system engineers, component engineers, operators and other plant personnelroutinely monitored systems and components for unusual, abnormal, or previouslyunobserved degradation.4OA3Event Follow-Up (71153).1(Closed) LER 454-2006-002-00: All Refueling Water Storage Tank LevelInstrumentation Channels Made Inoperable During a Single Channel Calibration Activity Due to a Design FlawOn March 15, 2006, the licensee identified that during calibration of a single refuelingwater storage tank (RWST) level channel, the other three channels were rendered inoperable as there is no isolation valve among the reference legs of all four level channels. The licensee determined that a 1989 modification to the RWST level instruments common reference leg was flawed in that it did not provide for a single channel calibration activity without impacting the other three channels. This licensee-identified finding involved a violation of 10 CFR 50, Appendix B, Criterion III. Theenforcement aspects of the violation are discussed in Section 4OA7. This LER is closed.40A4Review of Third Party ReportsDuring this assessment period, the inspectors reviewed a periodic assessment of thelicensee performed by INPO and WANO. The report was dated December 2005. The inspectors' review determined that the report findings were consistent with NRC observations and conclusions and that, as appropriate, items were added to the licensee's corrective action program.

214OA6Meetings.1The inspectors presented the inspection results to Mr. D. Hoots and other members oflicensee management on July 10, 2006. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified..2Interim Exit MeetingsInterim exits were conducted for:

• Emergency Preparedness inspection with Ms. M. Snow on April 21, 2006; and*Maintenance Effectiveness Periodic Evaluation with Mr. D. Hoots onJune 16, 2006.4OA7Licensee Identified ViolationsThe following violations of very low significance were identified by the licensee andwere violations of NRC requirements which met the criteria of Section VI of the NRCEnforcement Manual, NUREG-1600, for being dispositioned as an NCV.Cornerstone: Mitigating Systems

• 10 CFR 50, Appendix B, Criterion III, Design Control, requires, in part, thatmeasures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. Contrary to this, a 1989 modification to the RWST level instruments common reference leg was flawed in that it did not provide for a single channel calibration activity without impacting the other three channels.

Specifically, during calibration of a single channel, the other three channels were impacted as there was no isolation valve among the reference legs of all four level channels. Hence, the design requirement, as described in General Design Criteria 21 and 22, for channel separation during testing was not maintained.This violation was of very low safety significance because the duration of theinstrument calibration was very short and infrequent and the calibration did not affect the availability of borated water to cool the core when required. This issuewas entered into the licensee's corrective action program as CR 466676 and CR 477497.*Byron Station's Operating License Condition 2.C.(6) states, in part, that "Thelicensee shall implement and maintain in effect all provisions of the approved fire protection program as described in the SER." Section 9.5.1 of the UFSAR states that "The design bases, system descriptions, safety evaluation, inspection andtesting requirements, personnel qualification, and training are described in Reference 1 [the Fire Protection Report]." Section 2.3.12.1 of the Fire Protection Report states, in part, that "Fire dampers are provided in the fire wall separating the fuel handling building and the auxiliary building." Contrary to the above, thelicensee failed to have installed dampers in the firewall separating the spent fuel 22pool heat exchanger rooms of the fuel handling building and the Unit 1 andUnit 2 containment pipe penetration areas of the auxiliary building since originalconstruction. This violation is of very low safety significance because the steel ventilation ductprovided a minimum of 60 minutes fire endurance protection, and the location of combustibles were positioned such that the unprotected duct penetration would not be subjected to direct flame impingement. This issue was entered into the corrective action program as CR 478456.Cornerstone: Emergency Preparedness

• 10 CFR 50.54(q) requires, in part, that a licensee shall follow and maintain ineffect emergency plans which meet the standards in Section 50.47(b) and requirements in Appendix E of this part. The licensee may make changes to these plans without Commission approval only if the changes do not decrease the effectiveness of the plans. Contrary to the above, emergency action level (EAL) HU-5, Natural or destructive phenomenon inside the protected area or switchyard, was revised in a non-conservative manner. The non-conservative Unusual Event revision, which was implemented on January 17, 2006, erroneously referenced a seismic acceleration value for the Alert, and was identified by the licensee to be the result of inadequate technical reviews. The licensee identified and restored EAL HU-5 to the correct wording in a revision implemented on March 17, 2006.The licensee's implementation of changes to EAL HU-5 on January 17, 2006,decreased the effectiveness of the emergency plan without prior NRC approval,and was consequently a violation of 10 CFR 50.54(q). The finding is not suitable for SDP evaluation, but has been reviewed by NRC management and isdetermined to be a finding of very low safety significance. Because the violation has been entered into the licensee's corrective action program and it was of very low safety significance, it is being treated as a non-cited Severity Level IV violation.ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

D. Hoots, Site Vice President

M. Snow, Plant Manager

B. Adam, Work Control Director

D. Drawbaugh, Emergency Preparedness Manager

A. Giancatarino, Engineering Director

W. Grundmann, Regulatory Assurance Manager

S. Kerr, Chemistry Manager

W. Kouba, Nuclear Oversight Manager

M. Prospero, Operations Manager

S. Stimac, Training DirectorNuclear Regulatory Commission

R. Skokowski, Chief, Division of Reactor Projects

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000454/2006003-01URIUnit 1 Essential Service Water Return Isolation ValvesDegraded (1SX011 & 1SX136)

Opened and Closed

05000454/2006-002-00LERAll Refueling Water Storage Tank Level InstrumentationChannels Made Inoperable During a Single Channel

Calibration Activity Due to a Design Flaw.ClosedNone.

Discussed

None

2

LIST OF DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection.

Inclusion on this list doesnot imply that the NRC inspectors reviewed the documents in their entirety but rather that