ML15203A042: Difference between revisions

CAP with a proposed action to revise the associated calculation to remove the dependence on the opposite unit, and/or review the implications of crediting the opposite unit

CFR [[50.59(d)(1), "Changes, Tests, and Experiments," and an associated finding of very-low safety significance (Green) for the licensee's failure to perform a written safety evaluation that provided the bases for the determination that a change which resulted in the sharing of the refueling water storage tanks (RWSTs) of both reactor units did not require a license amendment. Specifically, the licensee did not evaluate the adverse effect of reducing reactor unit independence. The licensee captured this issue into their]]

RWST under their 10 CFR 50.59 process. The performance deficiency was more than minor because it was associated with the Mitigating Systems cornerstone attribute of design control, and affected the cornerstone objective of ensuring the availability, reliability, and capability of mitigating systems to respond to initiating events to prevent undesirable consequences. In addition, it was associated with the Barrier Integrity cornerstone attribute of design control, and affected the cornerstone objective of providing reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. In addition, the associated traditional enforcement violation was more than minor because the team could not reasonably determine that the changes would not have

ultimately required NRC prior approval. The finding screened as very-low safety significance (Green) because it did not result in the loss of operability or functionality, and it did not represent an actual open pathway in the physical integrity of the reactor

containment. Specifically, the licensee reviewed the affected calculation and reasonably determined that enough conservatism existed such that adequate net positive suction head (NPSH) could be maintained without sharing the

RWST [[of both reactor units. The team did not identify a cross-cutting aspect associated with this finding because it was confirmed not to be reflective of current performance due to the age of the performance deficiency. (Section 1R21.5.b(1)) Green. The team identified a finding of very-low safety significance (Green), and an associated]]

III , "Design Control," for the licensee's failure to translate applicable design basis into Technical Specifications (TSs) Surveillance Requirement 3.5.4.2 implementing procedures. Specifically, these procedures did not verify the

RWST vent line was free of ice blockage at the locations, and during all applicable

MODE of reactor operation assumed by the

ECCS and containment spray (

CS ) pump

NPSH calculation. The licensee captured this issue into their

CAP to reconcile the affected procedures and calculation. The performance deficiency was determined to be more than minor because it was associated with the Mitigating Systems cornerstone attribute of design control, and affected the cornerstone objective of ensuring the availability, reliability, and capability of mitigating systems to respond to initiating events to prevent undesirable consequences. Additionally, it was associated with the Barrier Integrity cornerstone attribute of design control, and affected the cornerstone objective of providing reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. The finding screened as very-low safety significance (Green) because it did not result in the loss of operability or functionality, and it did not represent an actual open pathway in the physical integrity of reactor containment. Specifically, the licensee performed a historical review of the last 3 years of operation, and did not find any instances in which the vent path temperature fell below 35 degrees Fahrenheit.

The inspectors did not identify a cross-cutting aspect associated with this finding because it was confirmed not to be reflective of current performance due to the age of the performance deficiency. (Section 1R21.5.b(2)) Severity Level

IV. The team identified a Severity Level

IV [[]]

UFSAR did not require a license amendment. Specifically, the associated 10

CFR [[50.59(d)(1), "Changes, Tests, and Experiments," and an associated finding of very-low safety significance (Green) for the licensee's failure to perform a written evaluation that provided the bases for the determination that the changes to the emergency service water cooling tower (SXCT) tornado analysis as described in the]]

CFR [[50.59 Evaluation did not address the introduction of a new failure mode, the resulting loss of heat removal capacity during worst postulated conditions, and addition of operator actions that have not been demonstrated can be completed within the required time to restore the required]]

SXCT heat removal capacity during worst case conditions. The licensee captured this issue in their

CAP with a proposed action to revise the 10 CFR 50.59 Evaluation and submit a Licensee Amendment Request. The performance deficiency was determined to be more than minor because it was associated with the Mitigating Systems cornerstone attribute of protection against

external events, and affected the cornerstone objective of ensuring the availability, reliability, and capability of mitigating systems to respond to initiating events to prevent undesirable consequences. In addition, the associated tradition enforcement violation was determined to be more than minor because the team could not reasonably determine that the changes would not have ultimately required prior

NRC approval. The finding screened as of very-low safety significance (Green) using a detailed evaluation because a loss of

SXCT [[during a tornado event would degrade one or more trains of a system that supports a risk-significant system or function. The bounding change to the core damage frequency was less than 5.4E-8/year. The team did not identify a cross-cutting aspect associated with this finding because the finding was not representative of current performance due to the age of the performance deficiency. (Section 1R21.5.b(3)) Green. The team identified a finding of very-low safety significance and an associated]]

TS 5.4, "Procedures," for the failure to maintain emergency operating procedures (EOPs) for transfer to cold leg recirculation. Specifically, the

EOP for transfer to cold leg recirculation did not contain instructions for transferring the

CS systems to the recirculation mode that ensured prevention of potential pump damage when the

RWST is emptied. The licensee captured this finding into their

CAP to create a standing order instructing operators to secure all pumps aligned to the

RWST when it is emptied, and implement long term corrective actions to restore compliance. The performance deficiency was determined to be more than minor because it was associated with the Mitigating Systems cornerstone attribute of procedure quality, and affected the cornerstone objective of ensuring the availability, reliability, and capability of mitigating systems to respond to initiating events to prevent undesirable consequences. In addition, it was associated with the Barrier Integrity cornerstone attribute of procedure quality, and affected the cornerstone objective of providing reasonable assurance that physical design barriers protect the public from radionuclide releases caused by

accidents or events. The finding screened as of very-low safety significance (Green) because it did not result in the loss of operability or functionality of mitigating systems, represent an actual open pathway in the physical integrity of reactor containment, and

involved an actual reduction in function of hydrogen igniters in the reactor containment. Specifically, the incorrect caution would only be used in the event that transfer to sump recirculation was not completed prior to reaching tank low-level, or if the RWST suction isolation valves fail to close. With respect to transfer to sump recirculation prior to reaching tank low-level, a review of simulator test results reasonably determined that operators reliably complete the transfer to sump recirculation prior to reaching this set

point. With respect to the failure of the RWST suction isolation valves, a review of quarterly test results reasonably determined the valves would have isolated the tank

when required. The team did not identify a cross-cutting aspect associated with this finding because it was not confirmed to reflect current performance due to the age of the performance deficiency. (Section 1R21.6.b(1)) Green. The team identified a finding of very-low safety significance (Green), and an associated

SXCT degraded condition used probabilities of occurrence of tornado events which was contrary to the requirements of the licensee procedure established for assessing operability of structures, systems, and components (

CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures,

and Drawings," for the failure to make an operability determination without relying on the use of probabilistic tools. Specifically, an operability evaluation for an

SSCs). The licensee captured the team's concern in their CAP to revise the affected operability evaluation without using probability of occurrence of tornado events. The performance deficiency was more than minor because it was associated with the

Mitigating Systems cornerstone attribute of protection against external events, and affected the cornerstone objective of ensuring the availability, reliability, and capability of mitigating systems to respond to initiating events to prevent undesirable consequences. The finding screened as of very-low safety significance (Green) using a detailed evaluation because a loss of

SXCT [[during a tornado event would degrade one or more trains of a system that supports a risk-significant system or function. The bounding change to the core damage frequency was less than 5.4E-8/year. The team determined that this finding had a cross-cutting aspect in the area of human performance because the licensee did not ensure knowledge transfer to maintain a knowledgeable and technically competent workforce. Specifically, the licensee did not ensure personnel were trained on the prohibition of the use of probabilities of occurrence of an event when performing operability evaluations, which was contained in licensee procedure established for assessing operability of]]

SSC [[. [H.9] (Section 4OA2.1.b(3)) Cornerstone: Barrier Integrity Green. The team identified a finding of very-low safety significance, and an associated]]

TS limit of 120 degrees Fahrenheit. Specifically, in 2007, the licensee cancelled the periodic preventive maintenance (

CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and

Drawings," for the failure to have procedures to maintain the accuracy within necessary limits of the instrument loops used to verify compliance with the containment average air temperature

PM) intended to maintain the necessary instrument loops accuracy. The licensee entered this issue into their CAP and reasonably established that the 120 degrees Fahrenheit limit was not exceeded by reviewing applicable historical records from 2002 to time of this inspection.

The performance deficiency was determined to be more than minor because it was associated with the configuration control attribute of the Barrier Integrity Cornerstone, and adversely affected the cornerstone objective to ensure that physical design barriers protect the public from radionuclide releases caused by accidents or events. The finding screened as very-low safety significance (Green) because it did not represent an actual open pathway in the physical integrity of reactor containment or involved an actual reduction in hydrogen igniter function. Specifically, the containment integrity remained intact and the finding did not impact the hydrogen igniter function. The team determined

that this finding had a cross-cutting aspect in the area of problem identification and resolution because the licensee did not identify issues completely and accurately in accordance with the CAP. Specifically, on January 15, 2015, the licensee captured the

lack of periodic

PM activities for the containment air temperature instrument loops in the

CAP. However, the licensee failed to completely and accurately identify the issue in that it was not treated as a

CAQ. [[As a consequence, no corrective actions were implemented. [P.1] (Section 4]]

OA 2.1.b(2))

REPORT [[]]

DETAIL S 1. REACTOR

SAFETY "Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity 1R21 Component Design Bases Inspection ([[Inspection procedure" contains a listed "[" character as part of the property label and has therefore been classified as invalid.) .1 Introduction The objective of the Component Design Bases Inspection (]]

CDBI ") is to verify that design bases have been correctly implemented for the selected risk-significant components, and that operating procedures and operator actions are consistent with design and licensing bases. As plants age, their design bases may be difficult to determine, and an important design feature may be altered or disabled during a modification. The Probabilistic Risk Assessment (PRA) model assumes the capability of safety systems and components to perform their intended safety function successfully. This inspectable area verifies aspects of the Initiating Events, [[Cornerstone" contains a listed "[" character as part of the property label and has therefore been classified as invalid., and Barrier Integrity cornerstones for which there are no indicators to measure performance. Specific documents reviewed during the inspection are listed in the Attachment to the report. .2 Inspection Sample Selection Process The team used information contained in the licensee's]]

PRA and the Byron Station, Units 1 and 2, Standardized Plant Analysis Risk (

SPAR [[) Model to identify two scenarios to use as the basis for component selection. The scenarios selected were a feed and bleed of the reactor coolant system (RCS), and a loss of ultimate heat sink (UHS). Based on these scenarios, a number of risk-significant components, including those with Large Early Release Frequency (LERF) implications, were selected for the inspection. The team also used additional component information such as a margin assessment in the selection process. This design margin assessment considered original design margin reductions caused by design modification, power uprates, or reductions due to degraded material condition. Equipment reliability issues were also considered in the selection of components for detailed review. These included items such as performance test results, significant corrective actions, repeated maintenance activities, Maintenance Rule (a)(1) status, components requiring an operability evaluation,]]

U.S. Nuclear Regulatory Commission (

NRC) resident inspector input of problem areas/equipment, and system health reports. Consideration was also given to the uniqueness and complexity of the design, operating experience, and the available defense in depth margins. A summary of the reviews performed and the specific inspection findings identified are included in the following sections of the report. The team also identified procedures and modifications for review that were associated with the selected components. In addition, the team selected operating experience issues associated with the selected components.

This inspection constituted 16 samples (12 components, of which 3 had

LERF implications, and 4 operating experience) as defined in Inspection Procedure 71111.21-05. .3 Component Design a. Inspection Scope The team reviewed the Updated Final Safety Analysis Report (

UFSAR [[), Technical Specification (TS), design basis documents, drawings, calculations and other available design basis information, to determine the performance requirements of the selected components. The team used applicable industry standards, such as the American Society of Mechanical Engineers Code, and Institute of Electrical and Electronics Engineers Standards, to evaluate acceptability of the systems' design. The]]

NRC also evaluated licensee actions, if any, taken in response to

NRC [[issued operating experience, such as Information Notices (INs). The review verified that the selected components would function as designed when required and support proper operation of the associated systems. The attributes that were needed for a component to perform its required function included process medium, energy sources, control systems, operator actions, and heat removal. The attributes to verify that the component condition and tested capability were consistent with the design bases and appropriate may have included installed configuration, system operation, detailed design, system testing, equipment and environmental qualification, equipment protection, component inputs and outputs, operating experience, and component degradation. For each of the components selected, the team reviewed the maintenance history,]]

PM [[activities, system health reports, operating experience-related information, vendor manuals, electrical and mechanical drawings, and licensee corrective action documents. Field walkdowns were conducted for all accessible components to assess material condition, including age-related degradation, and to verify that the as-built condition was consistent with the design. Other attributes reviewed are included as part of the scope for each individual component. The following 12 components (samples) were reviewed: Safety Injection Pump (1]]

SI01PB): The team reviewed analyses associated with inadvertent safety injection (SI) actuation and hydraulic calculations to assess the pump capability to provide its required accident mitigation function. The reviewed hydraulic analyses included pump minimum required flow, runout flow, flow capacity/balance, minimum required net positive suction head (NPSH), and air entraining vortices. In addition, the team reviewed a sample of operating procedures associated with pump operation under normal and accident conditions to assess their consistency with applicable design basis analyses. The team also reviewed test procedures and completed surveillance tests, including quarterly and comprehensive in-service testing and flow balances, to assess the associated acceptance criteria and test results. The team also reviewed the supporting electrical calculations associated with performance of the SI pump under design basis conditions. This included review of brake horsepower requirements for the pump motor, performance under degraded

voltage conditions, and motor protection to assess the capability of the motor to perform its safety function under design basis conditions. In addition, the team

reviewed voltage drop calculations to assess the availability of direct current (DC) control voltage at the associated bus needed to operate the pump circuit breaker. The team also performed a non-intrusive visual inspection of the component to assess overall material condition, configuration, and potential vulnerabilities to hazards. To assess operating trends and the licensee's ability to evaluate and correct problems, the team reviewed system health reports, selected corrective action documents, and

PM procedures and records. Pressurizer Power-Operated Relief Valve (1

RY 456): The team reviewed the pressure and temperature limit report and calculations associated with the power-operated relief valve (PORV) lift settings, relief capacity, and set points for low-temperature overpressure (LTOP) scenarios to assess the

PORV capability to provide its

RCS [[overpressure protection function. The team also reviewed test procedures and completed surveillances to assess the associated acceptance criteria and test results. In addition, the team reviewed a sample of associated operating procedures to assess their consistency with applicable design basis analyses. The team also reviewed the schematic diagrams for the]]

PORV [[control circuit to assess its suitability for bleed-and-feed operation as prescribed by operating procedures, and to assess the pilot solenoid and position limit switches qualification for post-accident environmental conditions. The team reviewed voltage drop calculations to assess the availability of the voltage needed at the solenoid valve to operate the]]

PORV. [[The team also reviewed control wiring schematics and associated instrument loop diagrams to assess the consistency between operations and system design requirements. This review included a circuit protection evaluation intended to demonstrate that the containment electrical penetration was not adversely affected by in-containment faults. The team also reviewed documentation associated with environmental qualifications for the postulated containment accident conditions and replacement of components susceptible to aging. The team reviewed system health reports, selected corrective action documents, and]]

PM procedures and records to assess operating trends and the licensee's ability to evaluate and correct problems. Power-Operated Relief Valve Accumulator (1

RY 32MB): The team reviewed the accumulator sizing calculation,

PORV pressure set point, accumulator stress analysis, and maximum allowed accumulator leak rate to assess the accumulator capability to supply the required amount of air pressure and volume to stroke open its associated

PORV on a loss of normal air supply. Additionally, the team reviewed the design calculation that established the minimum number of

PORV strokes required during certain events, such as

LTOP and natural circulation

cooldown. The team also reviewed test procedures and completed surveillances to assess the associated acceptance criteria and test results. In addition, the team reviewed a sample of associated operating procedures to assess their consistency with applicable design basis analyses. Finally, the team reviewed system health reports, selected corrective action documents, and recent modifications and operability evaluations to assess operating trends and the licensee's ability to evaluate and correct problems. Refueling Water Storage Tank (1SI01T): The team reviewed a sample of associated operating procedures under normal and emergency conditions to assess their consistency with applicable design basis analyses. The team also performed a non-intrusive visual inspection of the refueling water storage

tank (RWST) to assess overall material condition, configuration, and potential vulnerabilities to hazards. To assess operating trends, component health, and the licensee's ability to evaluate and correct problems, the team reviewed system health reports, selected corrective action documents, and recent modifications. The team reviewed design analyses associated with the ability of the

RWST system to maintain its design function during external events such as tornados and earthquakes. Additionally, the team reviewed design calculations related to level set points, temperature limits, and minimum required

RWST volume to mitigate a loss of coolant accident (LOCA), and to support feed-and-bleed scenarios. The team also reviewed the schematic diagrams and instrument uncertainty calculations to assess the low-low

RWST level signal (i.e.,

LO-2) capability to automatically open the containment sump isolation valves (i.e., 1SI8811A/B) following a LOCA, and its consistency with the associated set point calculation including instrument uncertainty considerations. To assess operating trends, component health, and the licensee's ability to evaluate and correct problems, the team reviewed system health reports, selected corrective action documents, recent modifications, and PM/calibration procedures and records. Emergency Service Water Makeup Pump (0SX02PA): The team reviewed design documents and procedures to assess consistency with vendor specifications. The team reviewed calculations associated with pump capability and performance to assess the pump capability to perform its design function of providing sufficient inventory to the associated Emergency Service Water Cooling Tower (SXCT) basin under different postulated scenarios. The team reviewed the water inventory availability from the suction source under routine service as well as extreme conditions. This review included low and high-river water levels and temperatures, pump NPSH, pump suction submergence, and minimum flow protection. The team also reviewed procedures associated with protection against flooding, seismic, and tornado events since the makeup pump is credited to some extent during these postulated events. The team also performed a non-intrusive visual inspection of the pump to assess overall material condition, configuration, and potential vulnerabilities to hazards. Work orders and maintenance procedures were reviewed to verify effectiveness of site maintenance. The team also reviewed test procedures and completed surveillances to assess the associated acceptance criteria and test results. To assess operating trends, component health, and the licensee's ability to evaluate and correct problems, the team reviewed system health reports and selected corrective action documents. Emergency Service Water Makeup Pump Diesel Engine (0SX02PA-K): The team reviewed design documents and procedures to assess consistency with vendor specifications. The team reviewed diesel fuel oil day tank level alarm response procedures and sizing analyses including the engine diesel fuel oil consumption rate calculation, tank capacity, vortexing calculation, level indicators, and alarm setpoint. In addition, the team reviewed the control circuit electrical diagram to assess the consistency between operations and design basis requirements. The team also reviewed the set point calculation for the SXCT basin level switch associated with the starting logic of the diesel engine to assess consistency between the specified setting and applicable design basis requirements. In addition, the team reviewed recent level instrument calibration

results. The team also reviewed circuit protection and control voltage to assess the diesel engine capability to start on demand. The inspectors reviewed completed work orders to assess the as-found and as-left condition of the diesel engine following recent maintenance activities. The team also reviewed test procedures and completed surveillances to assess the associated acceptance criteria and test results. The team also performed a non-intrusive visual inspection of the engine to assess overall material condition, configuration, and potential vulnerabilities to hazards. To assess operating trends and the licensee's ability to evaluate and correct problems, the team reviewed system health reports, selected corrective action documents, modifications, and

PM procedures and records. Emergency Service Water Cooling Tower (0

SX [[02AA/B and 0SX03CA/H): The team reviewed design calculations and procedures associated with fan performance, basin sizing, heat transfer, and makeup requirements during postulated events including LOCA, tornado, and seismic events. The electrical calculations associated with fan performance under design basis conditions were reviewed to assess consistency with the design bases and the motor capability to perform its specified safety function. This review considered fan motor brake horsepower requirements, performance under degraded voltage conditions, and motor protection. The team reviewed voltage drop calculations to assess the availability of the]]

DC control voltage needed at the associated load center for the closing and tripping of the cooling tower fan circuit breakers. The team also reviewed the alternating current (

AC ) and

DC electrical distribution systems to assess the

SXCT [[capability to perform its specified safety function assuming a single failure of electrical components. The team also reviewed control wiring diagrams of the deep well pump and associated control valves to assess consistency between their operation and design requirements. The team also performed a non-intrusive visual inspection of the]]

SXCT [[basin structure, fan motors, valve houses, and electrical equipment rooms to assess overall material condition, configuration, and potential vulnerabilities to hazards. The team also reviewed test procedures and completed surveillances to evaluate the associated acceptance criteria and test results. To assess operating trends and the licensee's ability to evaluate and correct problems, the team reviewed system health reports, selected corrective action documents, operability evaluations, modifications, and]]

PM procedures and records. 4160 Volts Alternating Current Bus 142: The team reviewed voltage drop calculations to assess the availability of the

DC [[control voltage needed at the associated bus for the operation of the associated circuit breakers. The team reviewed calculations associated with load flow, degraded voltage, and protective settings for selected electrical load paths served by the bus and associated with the inspection samples to assess the bus capability to support the loads required safety functions under design basis conditions. The team also performed a non-intrusive visual inspection of the switchgear to assess overall material condition, configuration, and potential vulnerabilities to hazards or extreme service environments. To assess operating trends and the licensee's ability to evaluate and correct problems, the team reviewed system health reports, selected corrective action documents, and selected]]

PM procedures and records.

120 Volts Alternating Current Instrument Bus 111: The team reviewed the

DC voltage drop calculations to assess the availability of the voltage needed for the proper operation of the associated inverter, including during a loss of

AC [[power. The team also reviewed the bus loading and breaker ratings to assess the bus and loads protection against spurious tripping. In addition, the team reviewed a modification which installed forced air cooling units for the inverter serving the bus to assess the modification implementation and any potential impact on the inverter. To assess operating trends and the licensee's ability to evaluate and correct problems, the team reviewed system health reports, selected corrective action documents, and]]

PM [[procedures and records for the bus. 125 Volts Direct Current Bus 111: The team reviewed bus loading and short circuit calculations as well as cable, bus, and circuit breaker ratings to assess bus and cable capabilities of carrying the maximum anticipated loading and protection against faulted conditions. The team also reviewed voltage drop and battery sizing calculations to assess the capability to support momentary and continuous loading for the duration of the duty cycle during accident conditions and the loss of all]]

AC power (i.e., station blackout). Additionally, the team reviewed the battery charger sizing calculation to assess its capability of maintaining the battery in a charged state and recharging the battery in a timely manner following a loss of

AC power event. The team also reviewed room heat-up calculations to ensure that the

DC [[components were not adversely affected by steam line breaks in the turbine building. In addition, the team reviewed purchase specifications, vendor documents, seismic test reports, certificate of compliance, and cable separation to assess consistency of the installed component to the design requirements. For the battery, this review included an assessment of the inter-cell resistance conformance to voltage drop calculations. Breaker/fuse coordination was also reviewed to assess the capability to interrupt overloads and faulted conditions. The team also reviewed testing procedures and associated recent results, recent system health reports, molded-case circuit breaker testing, maintenance activities, and recent corrective action documents to assess component health history. 24 Volts Direct Current Bus 035-2: The team reviewed the sizing calculation for the diesel start system and the control batteries to assess their capability of providing adequate voltage to the associated components for the duration of the duty cycle during accident conditions and loss of all]]

AC [[power. The team also reviewed components and wiring schematics related to the diesel start and control logic to assess the bus capability to perform its intended function. Additionally, the team reviewed the battery charger sizing calculation to assess its capability to maintain the batteries in a charged state, and to recharge them in a timely manner following a loss of]]

AC power event. The team reviewed purchase specifications, vendor documents, seismic test report, and certificate of conformance to assess consistency of the installed component to the design requirements. The team also reviewed testing procedures and associated recent results, health reports, maintenance activities, and recent corrective action documents to assess component health history. 480 Volts Alternating Current Motor Control Center 132Z1: The team assessed conformance to the applicable design and licensing basis by performing an engineering review of the motor control center (MCC) loading, MCC and control

circuits degraded voltage and maximum voltage, electrical protection, and electrical isolation/physical circuit separation of the

MCC from non-safety class loads. The loads considered during this review were the

SXCT riser motor operated valves (MOVs) (i.e., 0SX163E/F),

SXCT makeup

MOV (i.e., 0SX157A), and basin bypass

MOV (i.e., 0

SX 162B). The team reviewed the calculations that determined minimum terminal voltages for these

MOV to assess consistency with the associated

MOV thrust calculations. The team also reviewed the thermal overload sizing calculations for these

MOV circuits to assess their protection against premature thermal overload trip and the minimum voltage calculations for the 120 volts alternating current (

VAC) service to the SXCT basin level control system to assess the availability of the voltage needed for the level

instrumentation under design basis conditions. To evaluate whether there were adverse operating trends and to assess the licensee's ability to evaluate and correct problems, the team reviewed system health reports, selected corrective action documents, and

PM procedures and records for the

MCC. [[b. Findings (1) Question Regarding the Maximum Wet Bulb Temperature Value Assumed in the Emergency Service Water Cooling Tower Tornado Analysis Introduction: The team identified an unresolved item (URI) regarding the maximum wet-bulb temperature value assumed in the]]

SXCT tornado analysis. Specifically, the team noted the analysis used a value which was less restrictive than the highest 3-hour wet-bulb temperature recorded for the site as described in the

UFSAR. Description: In Section 3.5.4 of the UFSAR, "Analysis of Missiles Generated by a Tornado," stated that, "An analysis of the

UHS cooling capability for a tornado missile event has been made." It also stated that, "A maximum outside air wet-bulb temperature of 78 degrees Fahrenheit is assumed and is conservatively held constant throughout the transient." In addition, this

UFSAR section stated that, "The analysis was performed using service water cooling tower performance curves generated using the method

described in

UFSAR [[Section 9.2.5.3.1.1.2 [...]." The analysis of the]]

UHS cooling capability for a tornado missile event was calculation BYR09-002, "UHS Capability with Loss of

SX [[[Emergency Service Water] Fans due to a Tornado Event," which used a constant maximum outside air wet-bulb temperature value of 78 degrees Fahrenheit consistent with]]

UFSAR Section 3.5.4. However, the team noted the assumed maximum outside air wet-bulb temperature value of 78 degrees Fahrenheit appeared to be inconsistent with the method described in

UFSAR Section 9.2.5.3.1.1.2, "Steady State Tower Performance Analysis." Specifically, it stated that, "The design wet-bulb temperature during warm weather operation is 82 degrees Fahrenheit (Refer to

UFSAR "Section 2.3.1.2.4)." In Section 2.3.1.2.4 of the UFSAR, "[[Topic" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Design," stated that, "This analysis [described in Section 9.2.5.3.1.1] includes scenarios with the highest 3-hour wet-bulb temperature, 82 degrees Fahrenheit, which was recorded on July 30, 1961, at 3:00 pm." This]]

UFSAR [[section also stated that, "Per Regulatory Guide 1.27, the ultimate heat sink must be capable of performing its cooling function during the design basis event for this worst case 3-hour wet-bulb temperature." In addition, it stated, "However, the design operating wet-bulb temperature of the ultimate heat sink is 78 degrees Fahrenheit (]]

ASHRAE 1 percent exceedance value)."

This issue is unresolved pending further review by the Office of Nuclear Reactor Regulation (NRR) of the licensing basis related to the wet-bulb temperature value applicable for the

SXCT tornado analysis, and the team determination of further

NRC actions to resolve the issue. (URI 05000454/2015008-01; 05000455/2015008-01, Question Regarding the Maximum Wet-Bulb Temperature Value Assumed in the

SXCT Tornado Analysis) (2) Maximum Wet-Bulb Temperature Value Assumed in Emergency Service Water Cooling Tower Analysis Was Not Monitored Introduction: The team identified an

URI regarding the lack of monitoring the maximum wet-bulb temperature value assumed in

SXCT analysis. Specifically, the team noted the maximum wet-bulb temperature value was a critical parameter for the

SXCT analyses, but the licensee had not established a testing program to verify actual values were bounded. Description: In Section 3.5.4 of the UFSAR, "Analysis of Missiles Generated by a Tornado," stated that, "An analysis of the

UHS [[cooling capability for a tornado missile event has been made." It also stated that, "A maximum outside air wet-bulb temperature of 78 degrees Fahrenheit is assumed, and is conservatively held constant throughout the transient." In Section 9.2.5.3.1.1 of the]]

UFSAR , "Design Basis Reconstitution," stated that, "The design basis event for the Byron ultimate heat sink is a

LOCA coincident with a loss-of-off-site power (

LOOP [[) in one unit, and the concurrent orderly shutdown from maximum power to cold shutdown of the other unit using normal shutdown operating procedures." It also stated that, "The design wet-bulb temperature during warm weather operation is 82 degrees Fahrenheit (Refer to the]]

UFSAR Section 2.3.1.2.4)." In Section 2.3.1.2.4 of the

UFSAR ", "[[Topic" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Design," stated that, "This analysis [described in Section 9.2.5.3.1.1] includes scenarios with the highest 3-hour wet-bulb temperature, 82 degrees Fahrenheit, which was recorded on July 30, 1961, at 3:00 pm." The analysis of the]]

UHS cooling capability for a tornado missile event was calculation

BYR 09-002, "UHS Capability with Loss of

SX Fans due to a Tornado Event," which used a constant maximum outside air wet-bulb temperature value of 78 degrees Fahrenheit consistent with

UFSAR Section 3.5.4. The analysis of the

UHS cooling capability for a

LOCA coincident with a

LOOP was calculation

UHS -01, "Ultimate Heat Sink Design Basis

LOCA Single Failure Scenarios," which used a constant maximum outside air wet-bulb temperature value of 82 degrees Fahrenheit consistent with the

UFSAR Section 9.2.5.3.1.1. However, the licensee had not established a testing program to verify actual environmental conditions were bounded by these analyses and design basis limits. In response to the team questions, the licensee stated that this approach was acceptable because historical data showed wet-bulb temperature had a cyclic nature, maximum wet-bulb temperature lasted for relatively short durations, and the analyses assumed constant wet-bulb temperature values.

This issue is unresolved pending further

NRR review of the acceptability of the licensee approach to ensure the

SXCT analyses bounded actual environmental conditions, and the team determination of further

NRC actions to resolve the issue. (

URI 05000454/2015008-02; 05000455/2015008-02, Maximum Wet-Bulb Temperature Value Assumed in

SXCT Analysis Was Not Monitored) .4 Operating Experience a. Inspection Scope The team reviewed four operating experience issues (samples) to ensure that

NRC generic concerns had been adequately evaluated and addressed by the licensee. The operating experience issues listed below were reviewed as part of this inspection:

IN 2013-05, "Battery Expected Life and Its Potential Impact on Surveillance Requirements;"

IN 2010-26, "Submerged Electrical Cables;"

IN 2013-12, "Improperly Sloped Instrument Sensing Lines;" and

IN [[2012-01, "Refueling Water Storage Tank Degradation." b. Findings No findings were identified. .5 Modifications a. Inspection Scope The team reviewed five permanent plant modifications related to selected risk-significant components to verify that the design bases, licensing bases, and performance capability of the components had not been degraded through modifications. The modifications listed below were reviewed as part of this inspection effort: Engineering Change (EC) 385951, "Multiple Spurious Operation - Scenario 14, 1SI8811A/B;" EC396016, "Increase U1 Pressurizer]]

PORV Accumulator Tank Operating Pressure to Increase Number of

PORV Open/Close Cycles from Accumulator;" EC388735, "Detailed Review of the

FC Purification for Use of Non-Safety Related Portion Connected to Safety Related Piping;"

DRP 11-052, "Clarify References to

RWST Internal Pressure in the

ECCS and the

CS Pumps

NPHS Analysis;" and EC385829, "Tornado Missile Design Basis for the Essential Service Water

Cooling Towers."

b. Findings (1) Failure to Evaluate the Adverse Effects of Sharing the Refueling Water Storage Tanks of Both Reactor Units Introduction: The team identified a Severity Level

IV [[]]

RWST air space of both reactor units. Description: Each reactor unit has one

10 CFR [[50.59(d)(1), "Changes, Tests, and Experiments," and an associated finding of very-low safety significance (Green) for the licensee's failure to perform a written safety evaluation that provided the bases for the determination that a change which resulted in the sharing of the]]

RWST "of both reactor units did not require a license amendment. Specifically, screening 6E-05-0172, "UFSAR Change Package (DRP)[[SSC" contains a listed "[" character as part of the property label and has therefore been classified as invalid.," did not address the reduction in reactor unit independence associated with sharing the]]

RWST [[, which supplies borated water to both trains of the Emergency Core Cooling System (ECCS) and Containment Spray (CS) systems during the injection phase of a]]

LOCA recovery. The

UFSAR Section 6.3, "Emergency Core Cooling System," and

UFSAR Section 6.5.2, "Containment Spray Systems," described the

NPSH analyses for the

CS pumps when their suctions are aligned to their associated

RWST. Before November 16, 2005, these

UFSAR sections described the

RWST as being under atmospheric pressure during the injection mode. The licensee changed these

UFSAR descriptions following the discovery that the

RWST would not be under atmospheric pressure because the

RWST vent did not have the capacity to prevent vacuum during the high outflow expected during the injection phase, and the vent vacuum relief device was not safety related. This discovery was captured in the

AR 00239280. The licensee reviewed this

UFSAR change in Title 10, Code of Federal Regulations (

CFR ), Part 50.59 screening 6E-05-0172, "Clarify References to

RWST Internal Pressure in the

NPSH Analysis." The screening concluded that the change did not require a

CS Pumps

10 CFR 50.59 safety evaluation and, consequently,

NRC prior approval because the change did not result in an adverse effect to the

CS systems. Specifically, the licensee determined the expected vacuum would not affect the structural integrity of the tank. In addition, the licensee determined in calculation

BYR [[04-016, "[Residual Heat Removal]]]

RHR [[, SI, [Chemical and Volume Control] CV, and]]

CS Pump

NPSH during

ECCS Injection Mode," that the available

NPSH for the pumps while taking suction from the

RWST remained adequate when considering the expected vacuum. However, the team noted that revised calculation

BYR 04-016 credited the entire

RWST vent line, which was common to the

RWST of both reactor units. Consequently, the change credited the free air space of both tanks to mitigate the vacuum expected during tank drawdown. The team also noted that

UFSAR Section 3.1.2.1.5, "Evaluation Against Criterion 5 - Sharing of Structures, Systems, and Components," described those

SSC important to safety shared by the two reactor units, and the

RWST were not included as shared

SSC . Thus, the team noted the licensee implemented a change to the facility as described in the

UFSAR that resulted in a reduction of reactor unit independence. Changes to the facility as described in the

UFSAR that reduce reactor unit independence adversely impact

10 CFR 50.59 change evaluation criteria because they result in more than a minimal increase in the likelihood of occurrence of a malfunction of an

SSC important to safety. Since the licensee failed to appropriately

evaluate this adverse effect in a

10 CFR 50.59 safety evaluation, the team could not reasonably determine that the change would not have ultimately required

NRC prior approval. The licensee captured this issue in their

AR 02496142. The corrective actions considered at the time of this inspection were to revise calculation BYR04-016 to not credit the opposite unit

RWST air space and/or revise 10

CFR 50.59 screening 6E-05-0172 to consider the implications of crediting the opposite unit RWST air space. The team also noted the licensee did not correctly implement this change into

associated surveillance procedures intended to verify

RWST [[operability. This separate concern is discussed in detail in Section 1R21.5.b(2) of this report. Analysis: The team determined that the failure to provide a written evaluation that provided the bases for the determination that a change which resulted in the sharing of the]]

RWSTs of both reactor units did not require a license amendment, was contrary to the requirements of 10 CFR 50.59(d)(1), and was a performance deficiency. The performance deficiency was more than minor because it was associated with the Mitigating Systems cornerstone attribute of design control, and affected the cornerstone objective of ensuring the availability, reliability, and capability of mitigating systems to respond to initiating events to prevent undesirable consequences. In addition, it was associated with the Barrier Integrity cornerstone attribute of design control, and affected the cornerstone objective of providing reasonable assurance that physical design

barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the change did not ensure the

RWST capability to support

CS mitigating and barrier functions because it eliminated the capability to achieve the

RWST supporting function while maintaining separation of the reactor units. In addition, the associated violation was determined to be more than minor because the team could not reasonably determine the changes would not have ultimately required

NRC prior approval. Violations of 10

CFR 50.59 are dispositioned using the traditional enforcement process

instead of the Significance Determination Process (SDP) because they are considered to be violations that potentially impede or impact the regulatory process. This violation is

associated with a finding that has been evaluated by the

SD , and communicated with an

SDP color reflective of the safety impact of the deficient licensee performance. The

SDP, however, does not specifically consider the regulatory process impact. Thus,

although related to a common regulatory concern, it is necessary to address the violation and finding using different processes to correctly reflect both the regulatory importance of the violation and the safety significance of the associated finding. In this case, the team determined that the finding could be evaluated using the

SDP in accordance with Inspection Manual Chapter (

IMC) 0609, "Significance Determination Process" by using Attachment 0609.04, "Initial Characterization of Findings." Since the finding impacted the Mitigating Systems and Barrier Integrity cornerstones, the inspectors screened the finding through IMC 0609 Appendix A, "The Significance Determination Process for Findings At-Power," using Exhibit 2, "Mitigating Systems Screening Questions," and Exhibit 3, "Barrier Integrity Screening Questions." The finding screened as very-low safety significance (Green) because it did not result in the loss of operability or functionality, and it did not represent an actual open pathway in the physical integrity of the reactor containment. Specifically, the licensee reviewed

calculation

BYR 04-016, and reasonably determined that enough conservatism existed such that adequate

NPSH could be maintained without sharing the

RWST of both reactor units. In accordance with Section 6.1.d of the

NRC Enforcement Policy, this violation is categorized as Severity Level

IV because the resulting change was evaluated by the

SDP [[as having very-low safety significance (i.e., Green finding). The inspectors did not identify a cross-cutting aspect associated with this finding because it was confirmed not to be reflective of current performance. Specifically, the finding occurred approximately 10 years ago. Enforcement: Title]]

10 CFR 50.59, "Changes, Tests, and Experiments," Section (d)(1) requires, in part, the licensee to maintain records of changes in the facility, of changes in procedures, and of tests and experiments made pursuant 10

CFR [[50.59(c). These records must include a written evaluation which provides the bases for the determination that the change, test, or experiment does not require a license amendment pursuant to Paragraph (c)(2) of this section. Paragraph (c)(2)(ii) states, in part, that a licensee shall obtain a license amendment pursuant to]]

10 CFR 50.90 prior to implementing a proposed change, test, or experiment if the change, test, or experiment would result in more than a minimal increase in the likelihood of occurrence of a malfunction of an

SSC important to safety previously evaluated in the

UFSAR. In the

UFSAR Sections 6.3 and 6.5 describe the

NPSH evaluations for

CS pumps when their suctions are aligned to their associated

RWST. Additionally,

UFSAR [[Section 3.1.2.1.5 states that "Those systems, structures, and components important to safety shared by the two units are the ultimate heat sinks and the associated Byron makeup water systems; various heating, ventilating, and air conditioning systems within the shared auxiliary and fuel handling building; and a component cooling heat exchanger which can be valved to serve one unit or the other." The]]

RWST are not included as shared SSCs. Contrary to the above, on November 16, 2005, the licensee failed to maintain a record of a change in the facility made pursuant to

10 CFR 50.59(c) that included a written evaluation which provided the bases for the determination that the change did not require a license amendment pursuant to 10

CFR 50.90(c)(2). Specifically, the licensee changed the

NPSH calculation for their injection mode of operation (i.e., calculation

CS pumps

BYR 04-016) to credit the entire vent line common to the RWSTs of both reactor units and, consequently, the free air space of both tanks to mitigate the vacuum expected during tank drawdown. However, the licensee failed to

perform a written evaluation that provided the bases for the determination that the change effect of reducing reactor unit independence by sharing their RWSTs did not result in more than a minimal increase in the likelihood of occurrence of a malfunction of

the

RWST [[and their supported safety systems. The licensee is still evaluating its planned corrective actions. However, the team determined that the continued non-compliance does not present an immediate safety concern because the licensee reasonably determined that the affected analysis contained enough conservatism such that adequate]]

NPSH could be maintained without sharing the RWSTs of both reactor units.

Because this was a Severity Level

IV violation and was entered into the licensee Corrective Action Program (

CAP ) as

AR 02496142, this violation is being treated as an

NCV , consistent with Section 2.3.2 of the

NCV 05000454/2015008-03; 05000455/2015008-03; Failure to Evaluate the Adverse Effects of Sharing the

RWST of Both Reactor Units) The associated finding is evaluated separately from the traditional enforcement violation and, therefore, the finding is being assigned a separate tracking number. (

FIN 05000454/2015008-04; 05000455/2015008-04; Failure to Evaluate the Adverse Effects of Sharing the

RWST of Both Reactor Units) (2) Failure to Adequately Implement a Design Change Associated with the

RWST Introduction: The team identified a finding of very-low safety significance (Green), and an associated

CFR Part 50, Appendix B, Criterion III, "Design Control," for the licensee's failure to translate applicable design basis into

TS Surveillance Requirement (

SR ) 3.5.4.2 implementing procedures. Specifically, these procedures did not verify

RWST vent line was free of ice blockage at the locations and during all applicable

MODE of reactor operation assumed by the

NPSH calculation. Description: Each reactor unit has one

CS pump

RWST , which supplies borated water to both trains of the

TS 3.5.4, "Refueling Water Storage Tank," required the

CS systems during the injection phase of a LOCA recovery.

The

RWST to be operable when their associated reactor unit is in

MODE 1, 2, 3, or 4. A vent line is installed at the top of each

RWST. The vent lines are routed into the auxiliary building where they connect to a common header which joins to a filtration system. Because the header is common to both vents, the free air spaces of the

RWST are communicated via their vent lines. The vent line portions located between the tanks and the auxiliary building are exposed to outside ambient conditions. For this reason,

TS [[]]

SR 3.5.4.2 stated, "Verify

RWST vent path temperature is 35 degrees Fahrenheit." The associated

TS Basis explained that "Heat traced portions of the

RWST vent path should be verified to be within the temperature limit needed to prevent ice blockage and subsequent vacuum formation in the tank during rapid level decreases caused by accident conditions." The licensee established procedures 1/2

BOSR 01-1,2,3, "Modes 1, 2, and 3 Shiftily and Daily Operating Surveillance," and 1/2

BOSR 01-4, "Mode 4 Shiftily and Daily Operating Surveillance," as the implementing procedures for

SR 3.5.4.2. Originally, the

RWST [[design assumed they were atmospheric tanks by crediting their associated vent line capability to prevent vacuum during tank drawdown. However, on November 16, 2005, the licensee implemented a design change to credit the vent lines capability to communicate the free air space of both tanks following the discovery that the]]

RWST vents did not have the capacity to prevent vacuum during the high outflow expected during the injection phase, and the vent vacuum relief devices were not safety related. This discovery was captured in the

CAP as AR00239280. As a result, calculation

ECCS Injection Mode," credited the vent lines of both

RWST to mitigate the vacuum expected during the drawdown of one tank during accident conditions. However, the team noted this change was not correctly implemented into procedures 1/2

BOSR 01-1,2,3 and 1/2

BOSR 01-4. Specifically, these procedures were reactor unit specific in that their instructions only required verifying the

RWST vent line portions that were associated

with the applicable reactor unit

RWST ; that is, the portions between the associated

RWST and the auxiliary building. As a consequence, the team was concerned because, if one vent line is found to be blocked with ice, the procedures would only recognize one

RWST as being inoperable. In addition, the procedures were only implemented when the associated reactor unit was in

MODE 1, 2, 3, or 4 consistent with the applicability requirements of

TS 3.5.4. Thus, the team was also concerned that a potentially inoperable condition would not be detected because the procedures would not verify both vent lines were free of ice blockage when one reaction unit is in

MODE 5 or 6 while the other reactor unit is in

MODE 1, 2, 3, or 4. The licensee captured the team concerns in their

SR 3.5.4.2 implementing procedures was contrary to

AR 02496766. The immediate corrective action was to verify that outside air temperatures were not forecasted to fall below 35 degrees Fahrenheit for the foreseeable future. Additionally, the licensee determined the RWSTs remained operable during the last 3 years by performing a

historical review which did not find instances in which the vent lines temperature fell below 35 degrees Fahrenheit. The proposed corrective actions to restore compliance at the time of this inspection included revising the applicable calculations to remove dependence on the opposite unit, and/or revising the affected procedures to be consistent with the applicable calculation. The team also noted the licensee did not perform a written safety evaluation that provided the bases for the determination that this change, which resulted in a reduction of reactor unit independence, did not require a license amendment. This separate concern is discussed in detail in Section 1R21.5.b(1) of this report. Analysis: The team determined the failure to translate applicable design basis into

TS [[]]

SR 3.5.4.2 implementing procedures were inadequate to verify

III, "Design Control," and was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the Mitigating Systems cornerstone attribute of design control, and affected the cornerstone objective of ensuring the availability, reliability, and capability of mitigating systems to respond to initiating events to prevent undesirable consequences. Additionally, it was associated with the Barrier Integrity cornerstone attribute of design control, and affected the cornerstone objective of providing reasonable assurance that physical design

barriers protect the public from radionuclide releases caused by accidents or events. Specifically,

TS [[]]

RWST operability because they did not verify all critical assumptions made by the design calculations. The

RWST supports ECCS, which is a mitigating system, and CS, which is part of the physical design barrier. The team determined the finding could be evaluated using the

IMC 0609, "Significance Determination Process," Attachment 0609.04, "Initial Characterization of Findings." Since the finding impacted the Mitigating Systems and

Barrier Integrity cornerstones, the inspectors screened the finding through IMC 0609, Appendix A, "The Significance Determination Process for Findings At-Power," using Exhibit 2, "Mitigating Systems Screening Questions," and Exhibit 3, "Barrier Integrity Screening Questions." The finding screened as very-low safety significance (Green) because it did not result in the loss of operability or functionality, and it did not represent an actual open pathway in the physical integrity of reactor containment. Specifically, the licensee performed a historical review of the last 3 years of operation and did not find any instances in which the vent path temperature fell below 35 degrees Fahrenheit.

The inspectors did not identify a cross-cutting aspect associated with this finding because it was confirmed not to be reflective of current performance due to the age of the performance deficiency. Specifically, the finding occurred approximately 10-years ago. Enforcement: Title

III [[, "Design Control," requires, in part, that design changes, including field changes, be subjected to design control measures commensurate with those applied to the original design. Contrary to the above, on November 16, 2005, the licensee performed a design change and failed to subject it to design control measures commensurate to those applied to the original design. Specifically, the licensee changed the]]

NPSH calculation for their injection mode of operation (i.e., calculation

CS pump

BYR 04-016) to credit the capability of the vent lines of both

RWST to support the operability of any one

RWST. However, the design control measures failed to correctly translate the new design basis into procedures 1/2

BOSR 01-1,2,3 and 1/2

BOSR 01-4 in that they were not revised to verify the capability of the vent lines of both

RWST to support the operability of any one

RWST. [[The licensee is still evaluating its planned corrective actions. However, the team determined that the continued non-compliance does not present an immediate safety concern because outside air temperatures were not forecasted to fall below 35 degrees Fahrenheit for the foreseeable future. Additionally, a corrective action tracking item was created to develop compensatory actions if compliance is not restored prior to the next season when temperatures can potentially decrease below 35 degrees Fahrenheit. Because this violation was of very-low safety significance and was entered into the licensee's]]

AR 02496766, this violation is being treated as a NCV, consistent with Section 2.3.2 of the

NCV "05000454/2015008-05; 05000455/2015008-05; Failure to Adequately Implement a Design Change Associated with the RWSTs) (3) Failure to Evaluate the Adverse Effects of Changing the Emergency Service Water [[Ultimate Heat Sink" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Tornado Analysis as Described in the Updated Final Safety Analysis Report Introduction: The team identified a Severity Level]]

IV [[]]

10 CFR 50.59(d)(1), "Changes, Tests, and Experiments," and an associated finding of very-low safety significance (Green) for the licensee's failure to perform a written evaluation that provided the bases for the determination that the changes to the

SXCT tornado analysis as described in the

UFSAR "did not require a license amendment. Specifically, 50.59 Evaluation 6G-11-0041, "Tornado Missile Design Basis for the Essential Service Water [[Ultimate Heat Sink" contains a listed "[" character as part of the property label and has therefore been classified as invalid.s," did not address the introduction of a new failure mode, the resulting loss of heat removal capacity during worst postulated conditions, and addition of operator actions that have not been demonstrated can be completed within the required time to restore the required]]

SXCT heat removal capacity during worst case conditions. Description: During the

2005 NRC Safety Systems Design, Performance and Capability (

SSDPC ) inspection, the inspectors noted that the UFSAR-described tornado analysis for the

SXCT had not been updated to reflect changes that increased the heat load. The

SSDPC documented this concern as URI 05000454/2005002-07;

05000455/2005002-07. In 2007, this

URI was subsequently closed to

NCV 05000454/ 2007004-03; 05000455/2007004-03. As a result, on February 14, 2012, the licensee completed

EC 385829, "

SX Fans Due to Tornado Missiles," to change the

UHS tornado missile design basis as described in Revision 7 of the

UFSAR. The

EC 385829 evaluated these design basis changes in

10 CFR "50.59 safety evaluation 6G-11-004, "Tornado Missile Design Basis for the Essential Service Water [[Ultimate Heat Sink" contains a listed "[" character as part of the property label and has therefore been classified as invalid.s," dated February 9, 2012. This 10]]

CFR 50.59 safety evaluation concluded that the design basis changes could be implemented without obtaining a license amendment. However, the team noted that the licensee did not address the adverse effects of the changes in the

10 CFR 50.59 safety evaluation. Specifically, the change reduced the amount of missiles from "multiple" to "single," and changed the

SXCT design from natural draft cooling to mechanical draft cooling (i.e., from passive to active system). These changes adversely impacted

10 CFR 50.59 change evaluation criteria because they would result in more than a minimal increase in the likelihood of occurrence of a malfunction of the

SXCT during a tornado event. Specifically: The change introduced a new failure mode (i.e., fan failures) that was not bounded by the previous analysis. Specifically, Revision 7 of the

UFSAR Section 3.5.4, "Analysis of Multiple Missiles Generated by a Tornado," stated that the

SXCT "fans, fan motors, and fan drives were not protected from tornado missiles. It also stated, "An analysis of [[Ultimate Heat Sink" contains a listed "[" character as part of the property label and has therefore been classified as invalid. capacity without fans [emphasis added] has been made." In contrast, this statement was revised to, "An analysis of the]]

UHS [[cooling capability for a tornado missile event has been made." The new analysis required multiple operating fans to ensure enough cooling capacity to mitigate the effects of a single tornado missile. The fans, fan motors, and fan drives were not modified to add tornado missile protection. In addition, Revision 7 of the]]

UFSAR "Section 9.2.5.3.2, "Essential Service Water [[Ultimate Heat Sink" contains a listed "[" character as part of the property label and has therefore been classified as invalid.s," stated "An analysis of the effect of multiple [emphasis added] tornado missiles on the essential service water cooling towers has been performed." This statement was revised to delete the word "multiple." Following this revision, the analysis only considered the effects of one tornado-generated missile. Revision 1 of]]

NEI 96-07, "Guidelines for 10

CFR 50.59 Evaluations," which has been endorsed by the

NRC in Regulatory Guide 1.187, "Guidance for Implementation of 10

CFR 50.59, Changes, Tests, and Experiments," stated, in part, that a change would result in less than a minimal increase in the likelihood of occurrence of an SSC malfunction provided it "-satisfies applicable design

basis requirements." In contrast, this change did not satisfy the design basis requirements for protection against natural phenomena as described in the

USAR Section 3.1.2.1.2, "Evaluation Against Criterion 2 - Design Bases for Protection Against Natural Phenomena." Specifically, Revision 7 and the revision in effect at the time of this inspection of

UFSAR Section 3.1.2.1.2 stated, "The systems, components, and structures important to safety have been designed to accommodate, without loss of capability [emphasis added], effects of the design-basis natural phenomena along with appropriate combinations of normal and accident conditions." However, this change would result in the loss of SXCT capability to perform its safety function during the worst case conditions

in that the required number of fans would not be available necessitating operator

actions to delay shutdown cooling initiation until an adequate number of

SXCT fans are available to support the shutdown cooling heat load and, consequently, transition to

MODE 5 where design basis accidents (DBAs) are not postulated. The change involved a new operator action that supports the

SXCT function which is not reflected in plant procedures and training programs. Specifically,

UFSAR Section 3.5.4 was revised to credit new operator actions "-to delay

RHR initiation until an adequate number of

SXCT "fans are available for [[system" contains a listed "[" character as part of the property label and has therefore been classified as invalid. [emphasis added]-" and to stagger]]

RHR initiation for the two units. The revised

UFSAR -described analysis assumed "For the worst case design conditions the first unit is assumed to be placed on

RHR cooling 24 hours after the event and the second unit at 30 hours after the event."

NEI 96-07 states, in part, that a new operator action that supports a design function credited in a safety analysis results in less than a minimal increase in the likelihood of occurrence of an SSC malfunction provided the action is reflected in plant procedures and training programs, and these actions have been demonstrated

can be completed in the time required considering the aggregate effects.

However, the licensee had not created procedures and training material to restore an adequate number of SXCT fans. In addition, the licensee had not

demonstrated that these actions can be completed in the time required considering the aggregate effects, such as the expected conditions when the actions are required. In addition, the change would create a possibility for an

SXCT malfunction with a different result than any previously evaluated in the

UFSAR because: Nuclear Energy Institute (NEI) 96-07 states, "A malfunction that involves an initiator or failure whose effects are not bounded by those explicitly described in the

UFSAR is a malfunction with a different result." In contrast, this change would result in the loss of

SXCT capability to perform its safety function during the worst case conditions in that the required number of fans would not be available to support

RHR initiation necessitating a delay of

RHR initiation until an adequate number of fans are available. The previous UFSAR-described analysis assumed the

SXCT design remained capable of performing its safety function during the worst case conditions because it did not require any fans to support

RHR initiation and operation; and

NEI [[96-07 stated, "An example of a change that would create the possibility for a malfunction with a different result is a substantial modification- that creates a new or common cause failure that is not bounded by previous analyses or evaluations." In contrast, this change introduced a new failure that was not bounded by previous analysis as previously explained. The licensee captured the team concern in their]]

AR 2506214 to request a license amendment. The potential operability implications of this issue are discussed in Section 4

OA 2.1.b(3) of this report. Analysis: The team determined that the failure to perform a written evaluation that provided the bases for the determination that the changes to the

SXCT tornado analysis as described in the

UFSAR did not require a license amendment was contrary to the requirements of 10 CFR 50.59(d)(1) and was a performance deficiency. The

performance deficiency was more than minor because it was associated with the Mitigating Systems cornerstone attribute of protection against external events, and affected the cornerstone objective of ensuring the availability, reliability, and capability of mitigating systems to respond to initiating events to prevent undesirable consequences. Specifically, the change did not ensure the

SXCT reliability and availability during and following a tornado event because it introduced a new failure mode, and added reliance on operator actions that have not been demonstrated can be completed in the required time. The change also did not ensure the

SXCT [[capability to perform its safety function during the worst case conditions during and following a tornado event in that the required number of fans would not be available necessitating timely operator action to restore the required heat removal capability. In addition, the associated violation was determined to be more than minor because the team could not reasonably determine the changes would not have ultimately required]]

NRC prior approval. Violations of 10

CFR 50.59 are dispositioned using the traditional enforcement process instead of the

SDP because they are considered to be violations that potentially impede or impact the regulatory process. This violation is associated with a finding that has been evaluated by the

SDP , and communicated with an

SDP color reflective of the safety impact of the deficient licensee performance. The

SDP, however, does not specifically consider the regulatory process impact. Thus, although related to a common regulatory concern, it is necessary to address the violation and finding using different processes to correctly reflect both the regulatory importance of the violation and the safety significance of the associated finding. In this case, the team determined the finding could be evaluated using the SDP in

accordance with IMC 0609, "Significance Determination Process," Attachment 0609.04, "Initial Characterization of Findings." Because the finding impacted the Mitigating

System cornerstone, the team screened the finding through

IMC [[0609, Appendix A, "The Significance Determination Process for Findings At-Power," using Exhibit 2, "Mitigating Systems Screening Questions." In accordance with Exhibit 2, the team screened the finding using Exhibit 4, "External Events Screening Questions," because the finding involved the degradation of equipment or function specifically designed to mitigate a severe weather initiating event. The team conservatively screened the finding as necessitating a detailed risk evaluation because the loss of]]

UHS during a tornado event would degrade one or more trains of a system that supports a risk-significant system or function. The Senior Reactor Analysts (SRAs) performed a bounding risk evaluation for the delta event at Byron due to damage to the

SXCT fans: The

SRAs assumed that a tornado with wind speed exceeding 100 mph would be required to generate damaging missiles; The frequency of this tornado for Byron is approximately 1.13E-4/yr from the Risk Assessment Standardization Project (RASP) website;

The tornado missiles were assumed to cause damage and fail an entire set of

SXCT fans in addition to a set of fans that were initially out of service (i.e., 4 fans conservative assumption); and The

SRA further assumed that the tornado also caused a severe weather loss of offsite power event. The Byron

SPAR Model Version 8.27 and Systems Analysis Programs for Hands-on Integrated Reliability Evaluations (

SAPHIR E) Version 8.1.2 software were used by the

SRA to evaluate the risk significance of this finding. Using the Byron

SPAR model, the Conditional Core Damage Probability (CCDP) (i.e., if the tornado event occurred and damaged one train of

SXCT fans) is approximately 4.8E-calculated due to the

SXCT vulnerability to missiles is approximately 5.4E-8/yr (i.e., 1.13E-4/yr x 4.8E-4 = 5.4E-8/yr). Based on the detailed risk evaluation, the

SRA determined that the finding was of very-low safety significance (Green). As a result, this violation is categorized as Severity Level

IV in accordance with Section 6.1.d of the

NRC [[Enforcement Policy. The team did not identify a cross-cutting aspect associated with this finding because the finding was not representative of current performance. Specifically, the change was evaluated through the licensee 50.59 process in February 9, 2012. Enforcement: Title 10]]

CFR 50.59, "Changes, Tests, and Experiments," Section (d)(1) requires, in part, the licensee to maintain records of changes in the facility, of changes in procedures, and of tests and experiments made pursuant

10 CFR [[50.59(c). These records must include a written evaluation which provides the bases for the determination that the change, test, or experiment does not require a license amendment pursuant to paragraph (c)(2) of this section. Paragraph (c)(2)(ii) states, in part, that a licensee shall obtain a license amendment pursuant to 10]]

CFR 50.90 prior to implementing a proposed change, test, or experiment if the change, test, or experiment would result in more than a minimal increase in the likelihood of occurrence of a malfunction of an

SSC important to safety previously evaluated in the

UFSAR. In addition, 10 CFR(c)(2)(vi) states, in part, that a licensee shall obtain a license amendment pursuant to

10 CFR 50.90 prior to implementing a proposed change, test, or experiment if the change, test, or experiment would create a possibility for a malfunction of an

SSC important to safety with a different result than any previously evaluated in the Final Safety Analysis Report (FSAR)-as updated. The

UFSAR [[Section 9.2.5.3.2 in effect prior to the change implementation stated, "An analysis of the effect of multiple [emphasis added] tornado missiles on the essential service water cooling towers has been performed." In addition,]]

UFSAR Sections 3.5.4.1 and 9.2.5.3.2 in effect prior to the change implementation stated, "An analysis of cooling tower capacity without fans [emphasis added] has been made." Moreover, UFSAR Section 3.1.2.1.2 in effect prior to the change implementation and at the time of this

inspection stated, "The systems, components, and structures important to safety have been designed to accommodate, without loss of capability [emphasis added], effects of the design-basis natural phenomena along with appropriate combinations of normal and accident conditions."

Contrary to the above, on February 9, 2012, the licensee failed to maintain a record of a change in the facility made pursuant to

10 CFR 50.59(c) that included a written evaluation which provided the bases for the determination that the change did not require a license amendment pursuant to 10

CFR 50.59(c)(2). Specifically, the licensee made changes to the UFSAR-described SXCT tornado analysis and evaluated this change in 50.59 Evaluation 6G-11-0041. However, this evaluation did not consider the adverse effects of the introduction of a new failure mode, the resulting loss of heat removal capacity during worst postulated conditions, and addition of operator actions

that have not been demonstrated can be completed in the required time to restore the required

SXCT heat removal capacity during worst case conditions. As a result, the evaluation did not provide a basis for the determination that the change did not result in a more than a minimal increase in the likelihood of occurrence of a malfunction of the

SXCT during and following a tornado event, and would not create a possibility for a malfunction of the

SXCT with a different result than any previously evaluated. The licensee is still evaluating its planned corrective actions to restore compliance. As an immediate corrective action, the licensee performed an operability evaluation. At the time of the

CDBI exit meeting on June 16, 2015, the team was still reviewing the revised operability evaluation with the assistance of

NRR. Because this was a Severity Level

IV violation, and was entered into the licensee's

AR 02506214, this violation is being treated as an NCV, consistent with Section 2.3.2 of the

NCV 05000454/2015008-06; 05000455/2015008-06, Failure to Evaluate the Adverse Effects of Changing the

UFSAR [[) The associated finding is evaluated separately from the traditional enforcement violation and, therefore, the finding is being assigned a separate tracking number. (FIN 05000454/2015008-07; 05000455/2015008-07, Failure to Evaluate the Adverse Effects of Changing the]]

PRI -7, "Loss of Ultimate Heat Sink Unit 0," Revision 1;

UFSAR [[) .6 Operating Procedure Accident Scenarios a. Inspection Scope The team performed a detailed reviewed of the procedures listed below. The procedures were chosen because they were associated with feed-and-bleed of the RCS, a loss of UHS, and other aspects of this inspection. For the procedures listed time critical operator actions were reviewed for reasonableness, in plant action were walked down with a licensed operator, and any interfaces with other departments were evaluated. The procedures were compared to the UFSAR, design assumptions, and training materials to assess consistency. The following operating procedures were reviewed in detail: 1BFR-H1, "Response to Loss of Secondary Heat Sink Unit1," Revision 203;]]

0BOA [[]]

1BOA [[]]

PRI -7, "Essential Service Water Malfunction Unit 1," Revision 106;

1BOA [[]]

PRI -5, "Control Room Inaccessibility," Revision 108;

1BOA [[]]

ELEC -5, "Local Emergency Control of Safe Shutdown Equipment," Revision 106;

1BEP [[]]

ES [[-1.3, "Transfer to Cold Leg Recirculation Unit 1," Revision 204; and 1BCA-1.2, "LOCA Outside Containment Unit 1," Revision 200. b. Findings (1) Failure to Provide Proper Direction for Low Level Isolation of the Refueling Water Storage Tank in Emergency Operating Procedures Introduction: The team identified a finding of very-low safety significance (Green), and an associated]]

TS 5.4, "Procedures," for the failure to

EOP for transfer to cold leg recirculation. Specifically, Revision 204 of

EOP 1/2BEP ES-1.3, "Transfer to Cold Leg Recirculation," did not contain instructions for transferring the

CS systems to the recirculation mode that ensured prevention of potential pump damage when the

RWST is emptied following a

LOCA. Description: Procedures 1/2BEP ES-1.3 were established as the implementing

EOP for transferring

CS system suction from the

RWST to containment sump recirculation. These EOPs were intended to be consistent with the technical guidelines

of Westinghouse Owners Group Guidelines (WOG) Emergency Response Guideline (ERG)

ES -1.3, "Transfer to Cold Leg Recirculation," dated April 30, 2005. The technical guideline of

WOG [[]]

ERG ES-1.3 included the following caution statement: "Any pumps taking suction from the

RWST should be stopped if

RWST level decreases to (U.03)." The

ERG defined (U.03) as "

RWST empty alarm set point in plant specific units." It also stated, "Based on pump suction piping configuration, the plant specific value of (U.03) may need to consider the possibility of vortexing and air entrainment." The

ERG basis for this caution stated, "Any pumps taking suction from the

RWST must be stopped when the level in the tank reaches the empty alarm set point in order to prevent loss of suction flow and potential pump damage." The licensee established 9 percent

RWST level as the empty alarm set point to prevent air-entraining vortices and ensured adequate pump

NPSH. In 1996, the licensee changed

EOP 1/2

BEP ES-1.3 to include a deviation to this

ERG caution. Specifically, the revised

EOP caution stated "Any pumps taking suction from the

RWST should be stropped if level drops to 9 percent, unless a flow path also exists from the

CNMT [containment] sump." The EOP deviation document stated "This will

allow continuing with switchover without securing pumps if an acceptable flow path exists." It also stated "CNMT pressure should isolate the

RWST flow path once aligned to the sump." However, the licensee did not perform any evaluation to support this rationale. The team was concerned because the revised caution did not assure to prevent air entrainment into the piping system to avoid

CS pump air binding and/or cavitation leading to potential damage. The licensee captured the team concern in their

AR 02495580. The immediate corrective action was to create a standing order instructing operators to secure all pumps aligned to the

RWST when it reaches 9 percent level. The proposed corrective actions to restore compliance at the time of this inspection included performing a detailed engineering analysis of the hydrodynamic fluid mechanics with a dual suction source option or removing the dual suction source option.

Analysis: The team determined that the failure to maintain an

EOP for transfer to cold leg recirculation was contrary to

TS "5.4, "Procedures," and was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the Mitigating Systems cornerstone attribute of procedure quality, and affected the cornerstone objective of ensuring the availability, reliability, and capability of mitigating systems to respond to initiating events to prevent undesirable consequences. In addition, it was associated with the [[Cornerstone" contains a listed "[" character as part of the property label and has therefore been classified as invalid. cornerstone attribute of procedure quality, and affected the cornerstone objective of providing reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, failure to maintain an]]

EOP for transfer to cold leg recirculation does not ensure that air entrainment into the piping system is prevented. As a consequence, the availability, reliability, and capability of the

ECCS pumps to meet their mitigating function are not ensured. Similarly, the performance deficiency does not provide reasonable assurance the

CS pumps would remain capable of supporting the reactor containment barrier function. The team determined the finding could be evaluated using the

IMC 0609, "Significance Determination Process," Attachment 0609.04, "Initial Characterization of Findings." Because the finding impacted the Mitigating Systems and Barrier Integrity cornerstones, the team screened the finding through

IMC 0609, Appendix A, "The Significance Determination Process for Findings At-Power," using Exhibit 2, "Mitigating Systems Screening Questions," and Exhibit 3, "Barrier Integrity Screening Questions." The finding screened as of very-low safety significance (Green) because it did not result in the loss of operability or functionality of mitigating systems,

represent an actual open pathway in the physical integrity of reactor containment, and involved an actual reduction in function of hydrogen igniters in the reactor containment. Specifically, the incorrect caution would only be used in the event that transfer to sump recirculation was not completed by 9 percent tank level or if the

RWST [[suction isolation valves fail to close. With respect to transfer to sump recirculation by 9 percent tank level, this is a time critical operator action that is tested and verified periodically on the plant simulator. A review of these simulator test results reasonably determined that operators reliably complete the transfer to sump recirculation prior to reaching this set point. With respect to the failure of the]]

RWST [[suction isolation valves, these valves are test quarterly to demonstrate operability. A review of these test results for the last 3 years reasonably determined the valves would have isolated the tank when required. The team did not identify a cross-cutting aspect associated with this finding because the finding was not representative of current performance. Specifically, the inadequate caution had been added to 1/2BEP ES-1.3 in 1996. Enforcement: In]]

TS Section 5.4.1b states, in part, that written procedures shall be established, implemented, and maintained covering the

EOP "required to implement the requirements of NUREG-0737 and NUREG-0737, Supplement 1, as stated in Generic Letter (GL) 82-33, Section 7.1. [[NUREG" contains a listed "[" character as part of the property label and has therefore been classified as invalid., Supplement 1, Section 7.1.c, states, "Upgrade]]

EOP to be consistent with Technical Guidelines and an appropriate procedure Writer's Guide." The applicable technical guideline contained in

WOG [[]]

ERG [[]]

ES -1.3, "Transfer to Cold Leg Recirculation," dated April 30, 2005, stated, "Any pumps taking suction from the

RWST should be stopped if

RWST level decreases to (U.03)." The

ERG defined (U.03) as "

RWST empty alarm set point in plant specific units." It also stated, "Based on pump suction piping configuration, the plant specific value of (U.03) may need to consider the possibility of vortexing and air entrainment."

The licensee established Revision 204 of 1/2BEP

ES -1.3, "Transfer to Cold Leg Recirculation," as the implementing procedures for

WOG [[]]

ERG ES-1.3 to specify the actions required for transfer to containment sump recirculation. In addition, the licensee established 9 percent

RWST level as the empty alarm set point, in part, to prevent air entrainment. Contrary to the above, between 1996 to at least May 4, 2015, the licensee failed to maintain a written procedure covering the

EOP required to implement the requirements of NUREG-0737 and NUREG-0737, Supplement 1, as stated in

GL 82-33, Section 7.1. Specifically, the licensee did not upgrade

EOP 1/2BEP ES-1.3 to be consistent with the technical guideline contained in

WOG [[]]

ERG ES-1.3 in that the

EOP did not instructed operators to stop any pumps taking suction from the

RWST if level decreases below the 9 percent

RWST [[empty alarm set point when a flow path from the containment sump existed. The licensee is still evaluating its planned corrective actions. However, the team determined that the continued non-compliance does not present an immediate safety concern because the licensee created a standing order instructing operators to secure all pumps aligned to the]]

RWST when it reaches 9 percent level. Because this violation was of very-low safety significance, and was entered into the licensee's

AR 02495580, this violation is being treated as an NCV, consistent with Section 2.3.2 of the

NCV 05000454/2015008-08; 05000455/2015008-08, Failure to Provide Proper Direction for Low Level Isolation of the

RWST in

EOP ) 4.

OTHER [[]]

ACTIVI TIES 4OA2 Identification and Resolution of Problems .1 Review of Items Entered Into the Corrective Action Program a. Inspection Scope The team reviewed a sample of the selected component problems identified by the licensee, and entered into the

CAP. [[The team reviewed these issues to verify an appropriate threshold for identifying issues, and to evaluate the effectiveness of corrective actions related to design issues. In addition, corrective action documents written on issues identified during the inspection were reviewed to verify adequate problem identification and incorporation of the problem into the]]

CAP. The specific corrective action documents sampled and reviewed by the team are listed in the attachment to this report. The team also selected three issues identified during previous

CDBI to verify that the concern was adequately evaluated and corrective actions were identified and implemented to resolve the concern, as necessary. The following issues were reviewed:

NCV 05000454/2012007-01; 05000455/2012007-01, "Non-Conforming 480/120

VAC Motor Control Contactors;"

NCV 05000454/2012007-03; 05000455/2012007-03, "Non-Conservative Calibration Tolerance Limits for Electrical Relay Settings;" and

NCV 05000454/2012007-05; 05000455/2012007-05, "Failure to Provide Means to Detect Leak in Emergency Core Cooling Flow Path." b. Findings (1) Failure to Promptly Correct an

NRC -Identified Non-Cited Violation Associated with the Capability to Detect and Isolate Emergency Core Cooling System Leakage Introduction: A finding of very-low safety significance (Green), and an associated cited violation of

XVI , "Corrective Actions," was identified by the team for the failure to correct a condition adverse to quality (CAQ). Specifically, on June 15, 2012, the

NRC issued an

NCV for the failure to provide means to detect and isolate a leak in the

ECCS within 30 minutes as described in the

UFSAR , which is a

CAQ. As of May 22, 2015, the licensee had not corrected the

CAQ. Description: On June 15, 2012 the

NRC identified that the licensee had failed to provide a means to detect and isolate a leak in the

ECCS flow path within 30 minutes, as described in

UFSAR 6.3.2.5, "System Reliability." Specifically,

UFSAR [[6.3.2.5 stated, in part, that the design of the auxiliary building and related equipment was based upon handling of leaks up to a maximum of 50 gallons per minute (gpm). In addition, it stated "Means were provided to detect and isolate such leaks in the emergency core cooling flow path within 30 minutes." The]]

2012 CDBI team identified that the licensee had failed to provide a means to detect and isolate an

ECCS leak within 30 minutes. This issue was documented as

NCV 05000454/2012007-05; 05000455/2012007-05, "Failure to Provide Means to Detect Leak in

ECCS Flow Path," in Inspection Report (IR) 05000454/ 2012007; 05000455/2012007. The licensee captured this

NCV in their

CA due date was extended eight times and, eventually, the

AR 01378257 and

AR 01398434. The assigned corrective action tracking item (CA) was AR01378257-04, which stated: "Investigate the bases/sources of the values assigned to the single failure (50 gpm and 30 minutes), including whether there is a commitment associated. Create additional corrective actions (CA type) as necessary. If UFSAR change is determined feasible, include an action to determination of the impact of the leak duration lasting longer than 30 minutes on flood level inside containment and the

Auxiliary Building." The

CA was downgraded to an action tracking item (ACIT) because the licensee recognized that it did not correct the issue. Procedure PI-AA-125, "Corrective Action Program Procedure," defined

ACIT as "Action items that are completed to improve performance, or correct minor problems that do not represent

CAQ. " On February 18, 2015, the licensee discovered that a new

CA type assignment was not generated to address the

NCV following the

AR 01378257-04 downgrade from a

CA to an

ACIT type. This was inconsistent with step 4.5.2 of procedure

PI -AA-125 in that it required, in part, the creation of a

CA for any planned action necessary to correct a

CAQ. This discovery was captured in the

AR 02454767. The associated

CA assignment stated: "Design Engineering will determine if

UFSAR section 6.3.2.5 requires revision using the information provided in

IR 01378257 and

IR 1398434. If it is concluded a revision is required, an additional CA to track the change will be created."

During this inspection period, the team noted that the actions assigned by this

CA were similar to those of

AR 01378257-04, which the licensee had previously determined did not correct the

NCV. The team was concerned because, as of May 22, 2015, the licensee failed to restore compliance and failed to have objective plans to restore compliance in a reasonable period following the

NRC identification of the

NCV on June 15, 2012. The licensee captured the team's concern in their

AR 02501454 to promptly restore compliance. As an immediate corrective action, the licensee reasonably determined

ECCS remained operable by reviewing procedures and calculations. Specifically, the licensee reasonably determined procedures used when responding to postulated events would direct operators to detect and isolate an

ECCS leak before it could adversely affect the system mitigating function or result in a radionuclide release in excess of applicable limits. Analysis: The team determined that the failure to correct an

NRC -identified

NCV associated with the capability to detect and isolate

ECCS leakage, which is a CAQ, was contrary to

ECCS flow path within 30 minutes could compromise long term cooling, adversely affecting its capability to mitigate a

XVI, "Corrective Action," and was a

performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the Mitigating Systems cornerstone attribute of design control, and affected the cornerstone objective of ensuring the availability, reliability, and capability of mitigating systems to respond to initiating events to prevent undesirable consequences. In addition, it was associated with the Barrier Integrity cornerstone attribute of design control, and affected the cornerstone objective of providing reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the failure to detect and isolate a leak in the

DBA. In addition, a detection and isolation time greater than the time assumed by the design basis for an

ECCS [[leak following an accident would result in greater radionuclide release to the auxiliary building, and the environment and, thus, does not assure that physical design barriers protect the public from radionuclide releases caused by accidents or events. The team determined the finding could be evaluated using the]]

IMC 0609, "Significance Determination Process," Attachment 0609.04, "Initial Characterization of Findings." Because the finding impacted the Mitigating Systems and Barrier Integrity cornerstones, the team screened the finding through

IMC [[0609, Appendix A, "The Significance Determination Process for Findings At-Power," using Exhibit 2, "Mitigating Systems Screening Questions," and Exhibit 3, "Barrier Integrity Screening Questions." The finding screened as very-low safety significance (Green) because it did not result in the loss of operability or functionality, and it did not represent an actual pathway in the physical integrity of reactor containment. Specifically, the licensee reasonably demonstrated that an]]

ECCS [[leak could be detected and isolated before it could adversely affect long-term cooling of the plant. The team determined that the associated finding had a cross-cutting aspect in the area of human performance because the licensee did not use a consistent and systematic approach to make decisions. Specifically, the licensee downgraded the original]]

CA to an

ACIT without creating a new

CA , which was inconsistent with the instructions contained in procedure PI-AA-125. Additionally, when the licensee subsequently discovered a

CA type assignment was not created to address the

NCV, the licensee

created a

CA assignment to track actions that were similar to those tracked by the

ACIT , which was inconsistent with the licensee previous determination that those actions did not correct the

NCV. [[[H.13] Enforcement: Title 10]]

CFR [[Part 50, Appendix B, Criterion XVI, "Corrective Action," states, 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, from June 15, 2012, to at least May 22, 2015, the licensee failed to correct a]]

CAQ. Specifically, on June 15, 2012, the

NRC issued

NCV 05000454 /2012007-05; 05000455/2012007-05 for the failure to provide means to detect and isolate a leak in the

ECCS within 30 minutes for Byron Station, Units 1 and 2, as described in

UFSAR Section 6.3.2.5, which is a

CAQ. As of May 22, 2015, the licensee had not corrected the

CAQ in a reasonable period. Instead, the licensee created

ACTI [[to develop a plan to correct the CAQ, and the associated due date was extended at least eight times. The licensee is still evaluating corrective actions. However, the team determined that the continued non-compliance does not present an immediate safety concern because the licensee reasonably demonstrated that a leak could be detected and isolated before it could adversely affect long-term cooling of the plant or result in a radionuclide release in excess of applicable limits. This violation is being cited as described in the Notice, which is enclosed with this]]

IR. This is consistent with the

NRC Enforcement Policy, Section 2.3.2.a.2, which states, in part, that the licensee must restore compliance within a reasonable period of time (i.e., in a timeframe commensurate with the significance of the violation) after a violation is identified. The

NRC identified

NCV 05000454/2012007-05; 05000455/2012007-05 on June 15, 2012, and documented it in

IR 05000454/2012007. The team determined that the licensee failed to restore compliance within a reasonable time following issuance of this

NCV and failed to have objective plans to restore compliance. (VIO 05000454 /2015008-09; 05000455/2015008-09, Failure to Promptly Correct an NRC-Identified

NCV Associated with the Capability to Detect and Isolate

ECCS [[Leakage) (2) Failure to Maintain the Accuracy of the Instrument Loops Used to Verify Compliance with the Containment Average Air Temperature Technical Specification Limit Introduction: The team identified a finding of very-low safety significance (Green), and an associated]]

TS limit of 120 degrees Farhenheit. Specifically, in 2007, the licensee cancelled the periodic

CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for the failure to have procedures to maintain the accuracy

within the necessary limits of instrument loops used to verify compliance with the containment average air temperature

PM intended to maintain the instrument accuracy necessary for verifying compliance with the limiting condition for operation (LCO) of

TS 3.6.5, "Containment Air Temperature." Description: The team reviewed selected corrective action documents initiated by the licensee as a result of their recent Focused Self-Assessment titled, "Readiness Review for 2015

NRC Component Design Basis Inspection." The reviewed corrective action document sample included AR 02437973. This corrective action document was initiated on January 15, 2015, in part, for the discovery that the four instrument loops used for

determining containment average air temperature (i.e., loops 1/2VP-030, 1/2VP-031, 1/2VP-032, and 1/2VP-033) were removed from the

PM Program in 2007 via Service Request 47654. The corrective action document also noted that the

PM "were last performed in 2001 for 1VP-030; 2002 for 1/2VP-031, 1/2VP-032, 2VP-030, and 2VP-033; and 2009 for [[SSC" contains a listed "[" character as part of the property label and has therefore been classified as invalid.. This corrective action document created an]]

ACIT to determine if the

PM should be reestablished. Procedure PI-AA-125, "Corrective Action Program Procedure," defined

ACIT as "Action items that are completed to improve performance, or correct minor problems that do not represent

CAQ. " On March 3, 2015, the

ACIT concluded that there was no need to reestablish the

PM due to the instrument loop reliability, previous calibration history, loop design, redundancy, and daily monitoring which the licensee believed would notice instrument drift. However, the team noted that

TS [[]]

SR [[3.6.5.1 required verifying containment air temperature is less than 120 degrees Fahrenheit by averaging the instrument readings and, thus, instrument reading variability was expected. In addition, the team noted the licensee had not established a variability limit (i.e., acceptance criteria) among the instrument loops and relied on operator judgment to identify adverse drifts. The team was concerned because these instrument loops were not maintained to ensure their accuracy was within the necessary limits to verify compliance with the containment average air temperature]]

TS limit of 120 degrees Fahrenheit. Containment average air temperature is an initial condition used in

DBA analyses, and is an important consideration in establishing the containment environmental qualification operating envelope for both pressure and temperature. This

TS limit ensures that initial conditions assumed in these analyses are met during unit operations. The licensee captured the team's concern in their

PM procedures for these instrument loops to assure they are maintained. Analysis: The team determined that the failure to have procedures to maintain the accuracy within necessary limits of the instrument loops used during

AR [[02502846. As an immediate corrective action, the licensee reasonably established that the 120 degrees Fahrenheit limit was not exceeded by reviewing applicable historical records from 2002 to time of this inspection. The proposed corrective action to restore compliance at the time of this inspection was to reconstitute]]

SR 3.6.5.1 was contrary to 10

CFR [[Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," and was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the configuration control attribute of the Barrier Integrity Cornerstone, and adversely affected the cornerstone objective to ensure that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the failure to have procedures to maintain the accuracy of the containment air temperature instrumentation loops within necessary limits does not ensure the instrument loop accuracy is maintained such that]]

SR 3.6.5.1 activities are effective at verifying compliance with the containment average air temperature

TS limit. As a result, the potential exists for an inoperable condition to go undetected. The team determined the finding could be evaluated using the

CAP. Specifically, on January 15, 2015, the licensee captured the lack of periodic

IMC 0609, "Significance Determination Process," Attachment 0609.04, "Initial Characterization of Findings." Because the finding impacted the Barrier Integrity

cornerstone, the team screened the finding through

IMC "0609, Appendix A, "The Significance Determination Process for Findings At-Power," using Exhibit 3, "Barrier Integrity Screening Questions." The finding screened as of very-low safety significance (Green) because it did not represent an actual open pathway in the physical integrity of reactor containment or involved an actual reduction in hydrogen igniter function. Specifically, the containment integrity remained intact and the finding did not impact the [[Atomic Element" contains a listed "[" character as part of the property label and has therefore been classified as invalid. igniter function. The team determined that this finding had a cross-cutting aspect in the area of problem identification and resolution because the licensee did not identify issues completely and accurately in accordance with the]]

PM activities for the containment air temperature instrument loops in the

CAP. However, the licensee failed to completely and accurately identify the issue in that it was not treated as a

CAQ. [[As a consequence, no corrective actions were implemented. [P.1] Enforcement: Title 10]]

CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," requires, in part, that activities affecting quality be prescribed by

documented procedures of a type appropriate to the circumstances and be accomplished in accordance with these procedures. Contrary to the above, since 2007 to at least May 22, 2015, the licensee failed to have a procedure for maintaining the accuracy within the necessary limits of the instrument loops used while implementing

SR 3.6.5.1. Specifically, in 2007, the licensee cancelled the

PM intended to maintain the instrument loops accuracy necessary for verifying compliance with

LCO [[3.6.5 limit. The licensee is still evaluating its planned corrective actions. However, the team determined that the continued non-compliance does not present an immediate safety concern because containment average air temperature readings were significantly lower than the associated]]

TS limit, and are reasonably expected to maintain that margin in the foreseeable future based on past performance. Because this violation was of very-low safety significance, and was entered into the licensee's

AR 02502846, this violation is being treated as an NCV, consistent with Section 2.3.2 of the

NRC Enforcement Policy (

NCV 05000454/2015008-10; 05000455/2015008-10, Failure to Maintain the Instrument Loops Used to Verify Compliance with the Containment Average Air Temperature

TS Limit) (3) Operability Evaluation Relied on Probabilities of Occurrence of the Associated Event Introduction: The team identified a finding of very-low safety significance (Green), and an associated

10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for the failure to make an operability determination without relying on the use of probabilistic tools. Specifically, an operability evaluation related to an

SXCT degraded condition used probabilities of occurrence of tornado events which was contrary to the requirements of Revision 16 of procedure OP-AA-108-115, "Operability Determinations." Description: Revision 7 of

UFSAR Section 3.5.4, "Analysis of Multiple Missiles Generated by a Tornado," stated that the

SXCT fans, fan motors, and fan drives were not protected from tornado missiles. It also stated that "An analysis of cooling tower

capacity without fans has been made." In addition, it stated that "Using the most conservative design conditions, it is predicted if the plant is shut down under non-LOCA conditions with loss of offsite power, the temperature of the service water supplied to the plant will not exceed 110 degrees Farhernheit." However, during the

2005 NRC [[]]

SSDPC inspection, the inspectors noted that this analysis had not been updated to

reflect changes that increased the heat load. The

SSDPC documented this concern as

URI 05000454/2005002-07; 05000455/2005002-07. In 2007, this

URI was subsequently closed to

NCV 05000454/2007004-03; 05000455/2007004-03. As a result, on February 14, 2012, the licensee completed

EC 385829, "

SX Fans Due to Tornado Missiles," to change the

UHS tornado missile design basis to require a minimum of two

SXCT fans and motors for cooling following a tornado event. The change did not include adding tornado protection to the fans, fan motors, and fan drives. On August 9, 2013, the licensee initiated corrective action document

IR 01545153 for the

NRC [[discovery that the associated written safety evaluation intended to provide the bases for the determination that this change did not require a license amendment failed to consider the change adverse effects. On August 14, 2013, the licensee initiated corrective action document]]

AR [[1546621 to address the associated technical implications. This corrective action document resulted in Revision 0 of Operability Evaluation 13-007, "Ultimate Heat Sink Capability with Loss of Essential Service Water Cooling Tower Fans," intended to reasonably demonstrate]]

UHS operability until corrective actions to restore compliance were implemented. During this inspection period, the

CDBI team noted that Operability Evaluation 13-007 relied on the probability of occurrence of a tornado. Specifically, it stated "The

UHS is capable of providing the required cooling because, given a tornado strike under the design conditions in the

UFSAR , the probability of occurrence is less than the acceptance criteria of 10E-7 /year in

SRP [[2.2.3." It also stated that "The software used to determine the missile hit probability is called [Tornado Missile Risk Evaluation Methodology]]]

TORMIS [[." In addition, it stated that "The software uses site specific factors such as predicted tornado characteristics, tornado occurrence rates, building layout, potential missile sources and types, missile distribution and the number of potential missiles." The supporting analysis used the]]

UFSAR Section 2.3.1.2.2, "Tornadoes and Severe Winds." tornado probability of occurrence value of 21E-4 per year. Procedure

OP [[-AA-108-115, "Operability Determinations," Section 4.5.13, "Use of PRA," stated: "PRA is a valuable tool for evaluating accident scenarios because it can consider the probabilities of occurrence of accidents or external events. Nevertheless, the definition of operability is that the]]

SSC must be capable of performing its specified function or functions, which inherently assumes that the event occurs and that the safety function or functions can be performed. Therefore, the use of

PRA or probabilities of occurrence of accidents or external events is not consistent with the assumption that the event occurs, and is not acceptable for making operability decisions." Thus, the team determined that the use of TORMIS, the probability for occurrence of tornados, and the probabilities of missile strikes was not acceptable and contrary to licensee procedure OP-AA-108-115. The team, in consultation with NRR, also

determined that this procedure requirement was consistent with Attachment

C. 06 of

NRC [[]]

IMC 0326, "Operability Determinations & Functionality Assessments for Conditions Adverse to Quality or Safety," which was established to assist

NRC inspectors review of licensee determinations of operability and resolution of degraded or nonconforming conditions. In addition, the team noted that Byron had not obtained

NRC approval for the site specific use of

TORMIS as stated in Regulatory Issue Summary (

RIS ) 2008-14, "Use of

TORMIS Computer Code for Assessment of Tornado Missile Protection." Specifically, the

RIS stated that "The initial use of the

TORMIS methodology as described in this

RIS requires a license amendment in accordance with

10 CFR 50.59(c)(2)(viii) and subsequent revision to the plant licensing basis because it is a 'Departure from the method of evaluation described in the

FSAR , as updated, used in establishing the design bases or in the safety analysis' as defined in

10 CFR 50.59(a)(2)." The team was concerned because Operability Evaluation 13-007 did not reasonably demonstrate the degraded

UHS would be capable of performing its function following a tornado event. The licensee captured the team concern in their

AR 2504624 to revise Operability Evaluation 13-007 without using

PRA tools. Analysis: The team determined that the failure to make an operability determination without relying on the use of probabilistic tools was contrary to licensee procedure

OP [[-AA-108-115 and was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the Mitigating Systems cornerstone attribute of protection against external events, and affected the cornerstone objective of ensuring the availability, reliability, and capability of mitigating systems to respond to initiating events to prevent undesirable consequences. Specifically, failure to perform an adequate operability evaluation does not ensure the]]

SXCT would remain capable of performing its safety function, and had the potential to allow an inoperable condition to go undetected. The team determined the finding could be evaluated using the

IMC 0609, "Significance Determination Process," Attachment 0609.04, "Initial Characterization of Findings." Because the finding impacted the Mitigating System cornerstone, the team screened the finding through

IMC 0609, Appendix A, "The Significance Determination Process for Findings At-Power," using Exhibit 2, "Mitigating Systems Screening Questions." In accordance with Exhibit 2, the team screened the finding using Exhibit 4, "External Events Screening Questions," because the finding involved the degradation of equipment or function specifically designed to mitigate a

severe weather initiating event. The team conservatively screened the finding as necessitating a detailed risk evaluation because the loss of

UHS during a tornado event would degrade one or more trains of a system that supports a risk-significant system or function. strike(s) causing a core damage event at Byron due to damage to the

SXCT fans: The

SRA assumed that a tornado with wind speed exceeding 100 mph would be required to generate damaging missiles. The frequency of this tornado for Byron is approximately 1.13E-4/yr from the

RASP website;

The tornado missiles were assumed to cause damage and fail an entire set of

SXCT fans in addition to a set of fans that were initially out of service (i.e., 4 fans - conservative assumption); and The

SRA further assumed that the tornado also caused a severe weather loss of offsite power event. The Byron

SPAR Model Version 8.27 and

SAPHIRE Version 8.1.2 software were used

by the

SRA to evaluate the risk significance of this finding. Using the Byron

SPAR model, the

CCDP (i.e., if the tornado event occurred and damaged one train of

SXCT fans) is approximately 4.8E-vulnerability to missiles is approximately 5.4E-8/yr (i.e., 1.13E-4/yr x 4.8E-4 = 5.4E-8/yr). Based on the detailed risk evaluation, the SRAs determined that the finding was of very low safety significance (Green). The team determined that this finding had a cross-cutting aspect in the area of human performance because the licensee did not ensure knowledge transfer to maintain a knowledgeable and technically competent workforce. Specifically, the licensee did not ensure personnel were trained on the prohibition of the use of probabilities of occurrence

of an event when performing operability evaluations, which was contained in procedure

OP [[-AA-108-115. [H.9] Enforcement: Title]]

10 CFR [[Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," requires, in part, that activities affecting quality be prescribed by documented procedures of a type appropriate to the circumstances and be accomplished in accordance with these procedures. The licensee established Revision 16 of procedure]]

OP-AA-108-115, "Operability Determinations," as the implementing procedure for assessing operability of SSCs, an activity affecting quality. Section 4.5.13, "Use of Probabilistic Risk Assessment," stated "[-] the use of PRA or probabilities of occurrence of accidents or external events is not consistent with the assumption that the event occurs, and is not acceptable for making

operability decisions." Contrary to the above, on August 20, 2013, the licensee failed to follow Section 4.5.13 of procedure

OP -AA-108-115. Specifically, the licensee used a

PRA tool (i.e.,

TORMIS ) and probabilities of occurrence of an external event (i.e., tornado) when making an operability decision related to the

SXCT degradation when mitigating tornado events. Establishing a reasonable expectation of operability is an activity affecting quality. As an immediate corrective action, the licensee revised the affected operability evaluation without using

PRA tools. At the time of the

CDBI exit meeting on June 16, 2015, the team was still reviewing the revised operability evaluation with the assistance of

NRR. Because this violation was of very-low safety significance and was entered into the licensee's

AR 2504624, this violation is being treated as an NCV, consistent with Section 2.3.2 of the

NRC policy on proprietary information.

NCV 05000454/2015008-11; 05000455/2015008-11, Operability Evaluation Relied on Probabilities of Occurrence of the Associated Event)

4OA6 Management Meetings .1 Interim Exit Meeting Summary On May 22, 2015, the team presented the inspection results to Mr. R. Kearney, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors had outstanding questions that required additional review and a follow-up exit meeting. .2 Exit Meeting Summary On June 16, 2015, the team presented the inspection results to Mr. B. Currier, and other members of the licensee staff. The licensee acknowledged the issues presented. The

team asked the licensee whether any materials examined during the inspection should be considered proprietary. Several documents reviewed by the team were considered proprietary information and were either returned to the licensee or handled in accordance with

ATTACHMENT: SUPPLEMENTAL INFORMATION

SUPPLE MENTAL INFORMATION

KEY [[]]

POINTS [[]]

OF [[]]

CONTAC T Licensee

R. Kearney, Site Vice President T. Chalmers, Plant Manager C. Keller, Engineering Director B. Currier, Senior Manager of Design Engineering D. Spitzer, Regulatory Assurance Manager J. Cunzeman, Mechanical/Structural Design Manager A. Corrigan,

NRC Coordinator

U.S. Nuclear Regulatory Commission C. Lipa, Chief, Engineering Branch 2 J. Ellegood, Chief, Reactor Projects Branch 3 (Acting) N. Féliz Adorno, Senior Reactor Inspector C. Zoia, Senior Resident Inspector (Acting) J. Draper, Resident Inspector

LIST [[]]

OF [[]]

ITEMS OPENED, CLOSED,

AND [[]]

DISCUS SED Opened 05000454/2015008-01; 05000455/2015008-01

URI Question Regarding the Maximum Wet Bulb Temperature Value Assumed in the

SXCT Tornado Analysis (Section 1R21.3.b(1)) 05000454/2015008-02; 05000455/2015008-02

URI Maximum Wet Bulb Temperature Value Assumed in

SXCT Analysis Was Not Monitored (Section 1R21.3.b(2)) 05000454/2015008-03; 05000455/2015008-03

NCV Failure to Evaluate the Adverse Effects of Sharing the

RWST of Both Reactor Units (Section 1R21.5.b(1)) 05000454/2015008-04; 05000455/2015008-04

FIN Failure to Evaluate the Adverse Effects of Sharing the

RWST of Both Reactor Units (Section 1R21.5.b(1)) 05000454/2015008-05; 05000455/2015008-05

NCV Failure to Adequately Implement a Design Change Associated with the

RWST (Section 1R21.5.b(2)) 05000454/2015008-06; 05000455/2015008-06

NCV Failure to Evaluate the Adverse Effects of Changing the

UFSAR (Section 1R21.5.b(3)) 05000454/2015008-07; 05000455/2015008-07

FIN Failure to Evaluate the Adverse Effects of Changing the

UFSAR (Section 1R21.5.b(3)) 05000454/2015008-08; 05000455/2015008-08

NCV Failure to Provide Proper Direction for Low Level Isolation of the

RWST in

EOP (Section 1R21.6.b(1)) 05000454/2015008-09; 05000455/2015008-09

VIO Failure to Promptly Correct an NRC-Identified

NCV Associated with the Capability to Detect and Isolate

ECCS Leakage (Section 4OA2.1.b(1))05000454/2015008-10; 05000455/2015008-10

NCV Failure to Maintain the Instrument Loops Used to Verify Compliance with the Containment Average Air Temperature

TS Limit (Section 4OA2.1.b(2)) 05000454/2015008-11; 05000455/2015008-11

NCV Operability Evaluation Relied on Probabilities of Occurrence of the Associated Event (Section 4

OA 2.1.b(3)) Closed 05000454/2015008-03; 05000455/2015008-03

NCV Failure to Evaluate the Adverse Effects of Sharing the

RWST of Both Reactor Units (Section 1R21.5.b(1)) 05000454/2015008-04; 05000455/2015008-04

FIN Failure to Evaluate the Adverse Effects of Sharing the

RWST of Both Reactor Units (Section 1R21.5.b(1)) 05000454/2015008-05; 05000455/2015008-05

NCV Failure to Adequately Implement a Design Change Associated with the

RWST (Section 1R21.5.b(2)) 05000454/2015008-06; 05000455/2015008-06

NCV Failure to Evaluate the Adverse Effects of Changing the

UFSAR (Section 1R21.5.b(3)) 05000454/2015008-07; 05000455/2015008-07

FIN Failure to Evaluate the Adverse Effects of Changing the

UFSAR (Section 1R21.5.b(3)) 05000454/2015008-08; 05000455/2015008-08

NCV Failure to Provide Proper Direction for Low Level Isolation of the

RWST in

EOP (Section 1R21.6.b(1)) 05000454/2015008-10; 05000455/2015008-10

NCV Failure to Maintain the Instrument Loops Used to Verify Compliance with the Containment Average Air Temperature

TS Limit (Section 4

OA 2.1.b(2)) 05000454/2015008-11; 05000455/2015008-11

NCV Operability Evaluation Relied on Probabilities of Occurrence of the Associated Event (Section 4

OA 2.1.b(3))

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.

CALCUL "ATIONS Number Description or Title Revision 4391/19D-11 Sizing of Replacement Battery Charger for Diesel Driven Pumps 0 BYR08-035 Essential Service Water Cooling Tower Basin Level Indication Uncertainty Analysis 0 BYR12-070 Auxiliary Building Environment following a High Energy Line Break in the Turbine Building 2 BYR12-072 Thermal Endurance Evaluation of the Safety Related Electrical Equipment in the Essential [[system" contains a listed "[" character as part of the property label and has therefore been classified as invalid. (SX) Cooling Tower Switchgear Rooms 0 BYR97-193 Battery Duty Cycle and Sizing for the Byron Diesel Driven Auxiliary Feedwater Pumps and the Byron Diesel Driven Essential Service Water Makeup Pumps 1-1E BYR97-205]]

125VDC Battery Charger Sizing Calculation 2

BYR 97-204

125 VDC Battery Sizing Calculation 3-3K

BYR 97-224 125Vdc Voltage Drop Calculation 4-4A BYR97-226 125 V

DC System Short Circuit Calculation 4

BYR 97-239

SX Cooling Tower Basin Level Auto Start Level Set Point Analysis 1

BYR 97-336

SX Cooling Tower Basin - Time to Reach the Low Level Alarm Set Point 1

BYR 2000-136 Voltage Drop Calculation for 4160V Switchgear Breaker Control Circuits 1 BYR2000-191 Voltage Drop Calculation for 480V Switchgear Breaker Control Circuits 0 -0C 4391/19-AN-3 Protective Relay Settings for 4.16 kV

ESF Switchgear 16 19-

AQ -24 Voltage Drop on 480-120V

AC Control Transformer Circuits 8 19-

AQ [[-63 Division Specific Degraded Voltage Analysis 7A 19-AQ-69 Evaluation of the Adequacy of the 120 Vac Distribution Circuit at the Degraded Voltage Setpoint 16 19-AQ-75 Essential Service Water Cooling Tower 480V Buses Maximum Voltage 1 19-AU-4 480 V Unit Substation Breaker and Relay Settings 19 19-G-1 Cable Ampacity 2 19-T-5 Diesel Generator Loading During LOOP/LOCA 7 BYR01-068 Environmental Parameters of]]

EQ Zones 2

BYR01-084 Generic Thermal Overload Heater Sizing Calculation for Motor Operated Valves 000

CALCUL ATIONS Number Description or Title Revision BYR01-095 Motor Operated Valves (MOV) Actuator Motor Terminal Voltage and Thermal Overload Sizing Calculation - Essential Service Water (SX) System 1 BYR06-111 Model APT-30K-11

SXCT Fan Blade Pitch Setting 1

BYR 12-042 Essential Service Water Discharge Header Temperature Indication Uncertainty 0 BYR95-005

120 VAC Instrument Bus/

SSPS Cabinet Fuse Sizing and Coordination 0 BYR96-128 Refueling Water Storage Tank (RWST) Level Alarm Bistables and Level Indication Accuracy

2 DIT [[]]

BB -EPED-0189 Design Information Transmittal: Minimum Starting/Running Voltages for Essential Motors 5/14/93

DIT [[]]

BB "-EXT-0406 Design Information Transmittal: Essential Service Water [[Ultimate Heat Sink" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Fan Motors [starting duty] 12/9/92 DIT-BRW-2002-033 Design Information Transmittal: Basis for]]

EDG loading 10/15/02

SI -90-01 Minimum Containment Flood Level 11 BYR04-016 RHR, SI, CV, and

CS Pump

NPSH During

ECCS Injection Mode 2

BYR 14-053 Pressurizer

PORV Air Accumulator Tank Requirements 0

BYR 06-029 Byron/Braidwood SI/RHR/CS/CV system hydraulic analysis in support of GSI-191 5 BYR06-058

NPSHA for

RHR &

CS Pumps During Post-

LOCA Recirculation 0 BYR07-055 Determination of the Correlation for the Critical Submergence Height (Vortexing) for the

RWST 0

SM -SI0930

RWST Level D

SITH -1 Refueling Water Storage Tank (RWST) Level Set points 8 CN-RRA-00-47 Byron/Braidwood Natural Circulation Cooldown

TREAT Analysis for

RSG and Uprating Programm 3 CN-RRA-00-47 Byron/Braidwood Natural Circulation Cooldown

TREAT Analysis for

RSG and Uprating Program 4 CQD-200074

PORV Accumulator Tank Z2 8.1.16 Refueling Water Storage Tanks Analysis and Design 5

BYR 97-287 Determination of

RWST Free Air Volume above Maximum

RWST Water Level 2 SM-SI0930

ATD -0062 Heat Load to the Ultimate Heat Sink During a Loss of Coolant Accident 5 BYR03-131 Evaluation of

UHS Make Up for

CST -based Cooldown Profile 1 BYR05-018 Tornado Missile Risk Assessment of Vulnerable Targets of Essential Service Water Cooling Towers 0 BYR06-111 Model APT-30K-11

SXCT Fan Blade Pitch Setting 1

CALCUL ATIONS Number Description or Title Revision BYR09-002

SX Fans due to a Tornado Event 1 BYR09-002

SX Fans due to a Tornado Event 1 BYR97*239

SX Cooling Tower Basin Level Auto Start Setpoint Error Analysis 1

BYR "97-034 Essential Service Water Cooling Tower Basin Minimum Volume Versus Level and Minimum Usable Volume Calculation 0a BYR97-034 Essential Service Water [[Ultimate Heat Sink" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Basin Minimum Volume Versus Level and Minimum Usable Volume Calculation 0A BYR97-127 Byron Ultimate Heat Sink Cooling Tower Performance Calculations 1 BYR97-134 Heat Load on the]]

UHS - 2 Unit Shutdown 3

BYR 97-366

SX Cooling Tower Basin - Time to Reach the Low Level Alarm Set Point 1

BYRO "8-035 Essential Service Water Cooling Tower Basin Level Indication Uncertainty Analysis 0 NED-M-MSD-009 Byron Ultimate Heat Sink [[Ultimate Heat Sink" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Basin Temperature Calculation: Part]]

IV 8B

NED -M-MSD-014 Byron Ultimate Heat Sink Cooling Tower Basin Makeup Calculation 9 UHS-01 Ultimate Heat Sink Design Basis

LOCA Single Failure Scenarios 4

SL [[-101 ELMS-AC Report: Running Voltage Summary, Division 12 1/21/15 SL-102 ELMS-AC Report: Short Circuit Summary for High Voltage Buses 1/21/15 SL-109 ELMS-AC Report: Connection Loading, Division 12 1/21/15 SL-112 ELMS-AC Report: Single Bus Summary, Bus 142 4/20/15 CORRECTIVE]]

ACTION [[]]

DOCUME NTS Generated Due to the Inspection Number Description or Title Date AR02488878

2015 CDBI - Design Analysis Inconsistency Identified 4/21/15

AR 02489108

NRC [[]]

CDBI Loose Parts Found During Walkdown of

RWST 4/22/15

AR 02489149

CDBI - Bucket Collecting Diesel Fuel Drips from 0

DO 088A 4/22/15 AR02489198

SX Make-Up Pump Temperature Recorder Panel Memory Full 4/22/15 AR02489297

CDBI - Outdated Information in System

IQ 4/22/15 AR02489456

NRC [[]]

ID Jumpers Not Readily Available for 1/2BOA PRI-5 4/22/15 AR02489360 Negative Vibration Reading on Idle 0E

WO As-Found Not as Expected, No

IR Written 4/24/15 AR02493191

CDBI - Issues Identified in Calculation

BYR 97-224 4/30/15 AR02493990

CDBI - Issue Identified in Calculation 19-

AQ -69 5/1/15 AR02495580

CDBI Question Related to

BEP ES-1.3 Cold Leg Recirculation 5/4/15

DOCUME NTS Generated Due to the Inspection Number Description or Title Date AR02495584

ACTION [[]]

FC Purification Flow Not Considered in

RWST [[]]

NPSH Calc 5/4/15 AR02495866

NRC Identified Issues in BYR97-193 5/5/15 AR02496142

CDBI - 50.59 and

DRP did not explicitly evaluate

GDC 5 5/5/15

AR 02495973

NRC [[]]

CDBI - Error Discovered in

EACE Investigation 5/6/15

AR 02496766

RWST Calc May Lead to Inconsistent Application of

TS 5/6/15

AR 02497347

NRC [[]]

CDBI Procedure Enhancement for

ECCS Flow Balancing 5/6/15

AR 02497940

CDBI Deficiency Identified -

THD Testing for Instrument Inverter 5/8/15 AR02497925 Lightning Rod on

SX Cooling Tower Bent; Clarify Inspection

WO Instructions 5/8/15 AR02501392

CDBI 2015 -

VTIP for Containment

DP Has Limited Lead Length 5/15/15

AR 02501454

NCV Does Not Resolve Issue 5/15/15

CA Created for

AR 02502846 No Routine

PM on Containment Temperature Loops 5/19/15

AR 02504624

CDBI Concern Regarding Op Eval 13-007 5/22/15

AR 02504475

TS Clarification Needed for Transition to

LTOP 5/22/15

AR 02506214 2012 50.59 for

SXCT Tornado Analysis 5/19/15

DOCUME NTS Reviewed During the Inspection Number Description or Title Date AR00301744 Design of

ACTION [[]]

RWST Vacuum Relief System 2/15/05

AR 00239280

RWST Vent / Vacuum Breaker Design Basis Issues 7/27/04

AR 00880223 0A

SX M/U

PP Failures 2/13/09 AR00881611 0A

SX [[]]

MU Pump Did Not Stop When Local

CS Taken to Off 2/17/09

AR 01053940 1DC08E Battery, 1DC08E 123 Bus and

DC 123 Batt Low 4/8/10

AR 01115570

DC Bus 123 Low Voltage 9/21/10

AR "01204963 Megger Test of Submerged Cable (1SX172) 4/20/11 AR01217212 Check/Adjust Charger 123 Float Voltage 5/17/11 [[AR" contains a listed "[" character as part of the property label and has therefore been classified as invalid. 0A]]

SX [[]]

MU [[]]

PP Failed to Start at the Desired Setpoint

SPC 9/15/11 AR01318043 0A

SX M/U

PP Battery Bank Test 1/25/12 AR01362643 Replace Breaker for

MCC 035-2-C5 (0

CW 03PC-C) 5/4/12 AR01368220

CDBI [[]]

ESF [[]]

MCC Contactors not Tested at Assumed Pickup Volt 5/18/12

AR 01376793

CDBI Follow-up on

MCC Contactors (IR 1368220) 6/11/12 AR01377764

NRC [[]]

CDBI "- Protective Relay Setting Tolerances 6/12/12 AR01378259 Need Engineering to Evaluate Test Frequency 6/15/12 AR01380744 Action Tracking Needed for Size 3 and 4 Contactors 6/22/12 [[AR" contains a listed "[" character as part of the property label and has therefore been classified as invalid. The Station]]

111 ESF Battery Needs to Be Replaced in B1R19 7/11/12

AR 01387520 The Station

112 ESF Battery Needs to be Replaced in B1R19 7/11/12

AR01390648 Protective Relay Tolerances Require Fleet Review 7/19/12

DOCUME NTS Reviewed During the Inspection Number Description or Title Date AR01398419

ACTION [[]]

NRC [[]]

ID 'D

CDBI Green

NCV Non-Conforming 480/120

VAC Motor Contactors 6/15/12

AR 01398426

NRC [[]]

CDBI Green

NCV Non-Conservative Cal Tolerance for Elec Relays 6/15/12

AR 01413695 Engineering Evaluate Frequency of Battery Capacity Test 9/16/12 AR01502583 0A

SX Makeup Pump Failed to Auto Start per 0

BOSR 7.9.6-1 4/16/13 AR01518720 Breaker Will Not Reset During Oden Testing 5/29/13 AR01570572 0A

SX M/U

PP Had To Be Tripped During Monthly Run 10/10/13 AR01588590 Loss of Instrument Bus 111 11/21/13 AR01589264 Need New Contingency Work Order ofr Instrument Inverter 111 11/23/13 AR01590368

NRC [[]]

ID -

PCM Template/Vendor Manual Recommendation 11/26/13

AR 01611287 0A

SX Makeup Pump Auto Start Level Setpoint 1/23/14

AR 01654589 Erratic Reading on Ammeter (111-IP001) for Inverter 111 4/30/14 AR01658463 Specific Gravity of Battery Cell Still Low After Equalize 5/10/14 AR01680303 0A

SX [[]]

MU [[]]

PP Trouble Alarm Continues to Alarm 7/10/14

AR "01693147 Gradual Float Current Trend on 111 Battery Charger 4/15/14 AR02407275 0SX02PA Kept Running 11/5/14 AR02417160 Pump "As Found" Condition/Dry Start Improvement Opportunity 11/25/14 AR02440865 [[Topic" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Needed on]]

FRT for Instrument Inverter 111 11/29/14

AR 02448283 0A

SX [[]]

MU Failed Surveillance 2/5/15 AR01299897 Replace Breaker for

MCC 132Z1-A4 (0

SX "157A) 12/8/11 AR01056715 NER-NC-10-008-Y - Buried Cable 4/14/10 AR01322720 B2F26 Bus 142 Undervoltage Relay 2/3/12 [[AR" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Safety-Related Cable Vault 1M1G(1G1) Inspection - Repairs 9/5/12 AR01417720]]

MCC 132Z1-A5 Tripped Out of Tolerance 9/24/12

AR [[01425642 Safety-Related Cable Vault 1J2 Inspection - Repairs 10/12/12 AR01592242 Operating Experience Applicable to Byron (SXCT Fan Reverse Rotation) 12/2/13 AR01625774 Degraded Voltage Relay Target did not Change State 2/25/14 AR01648079 Step Change Identified in Unit 1 Containment Air Temperature in]]

PI 4/16/14

AR 01687277 Safety Related Cable Vault

PM and Engineering Inspections 7/30/14

AR 02437410 Cable Vault

PM and Engineering Inspections 1/14/15

AR 02437973

CDBI [[]]

FASA - Review of Robinson and Wolf Creek Findings 1/15/15 AR00239280

RWST Vent/Vacuum Breaker Design Basis Issue 7/27/04

FC Purification 5/2/12 AR01361838 U-1

RWST level loss During Purification 5/3/12

AR 0128230

NRC Information Notice 2012-01: Seismic Considerations - Principally Issues Involving Tanks 5/9/12

AR 01398434

NRC [[]]

CDBI Green NCV-Leak Detection for

ECCS Flowpath Lacking 6/15/12

AR 01378257 CDBI, Question about

ECCS leakage 6/15/12

DOCUME NTS Reviewed During the Inspection Number Description or Title Date AR01465872 Review of Braidwood

ACTION [[]]

IR 1459353 Pzr

PORV Accumlator Press 1/23/13 AR01635829 1B

PZR [[]]

PORV Accum Failed Decay Test 3/19/14 AR02454767

NOS [[]]

ID No

CA to Correct an

NRC [[]]

NCV 2/18/15

IR 298958 SSD&PC: Inaccurate Setpoints Referenced in BYR97-034 6/30/05

AR 01546621 Inadequate 50.59 for

EC 385829 (SXCT Tornado Missiles) 8/14/13 AR295141295141Ssd&pc Question on Tornado Anaylsis Supporting

UFSAR Stmnt 1/28/05

AR 1677584 Clarification Needed on

UHS Passive Failure Design 7/1/14

AR 1567903

NRC Question and Feedback on

UHS Temperature Analysis 10/3/13 AR1677513

UFSAR Section 2.4.11.6 Needs Revision 7/1/14

AR 1677646 Recommendation from

UHS Assessment 7/1/14

AR 1546621 Inadequate 50.59 for

EC 385829 2/9/12

AR 2406579 Failed "Spider" Bearing on 0A

SX Makeup Pump 11/4/14

AR 1269014 Obsolete

SX Makeup Pump D/O Storage Tank Level Indicator 9/28/11

AR 2437508 Review of Flow Anomaly On 0B

SX Makeup 1/14/15

AR 2448283 0A

SX [[]]

MU "Failed Surveillance 2/5/15 DRAWINGS Number Description or Title Revision S-529 Essential Service Cooling Tower Drainage Duct Plan, Section Details H 6E-0-4030SX09 Schematic Diagram - Essential Service Water Make-up Pump 0A 0SX02PA P [[SSC" contains a listed "[" character as part of the property label and has therefore been classified as invalid.SX23 Schematic Diagram - Essential Service Water Make-up Pump 0A Control Cabinet (Diesel Driven) 0SX02JA S 6E-0-4030SX24 Schematic Diagram - Essential Service Water Make-up Pump 0A Control Cabinet (Diesel Driven) 0SX02JA Annunciator F 6E-0-4030CW11 Schematic Diagram - Essential service Water Cooling Tower 0A & 0B Well Water Make-up Valves 0CW100A & B D 6E-0-4030WW01 Schematic Diagram - Deep Well Pump 0A - 0WW01PA M 6E-0-4030WW02 Schematic Diagram - Deep Well Pump 0B - 0WW01PB H 6E-0-4030WW05 Schematic Diagram - Essential service Water Cooling Tower 0A & 0B Circulating Water Make-up Valves 0WW019A & B E 6E-1-4001A Station One Line Diagram P 6E-1-4001E Station Key Diagram O 6E-1-4002E Single Line Diagram - 120V]]

AC [[]]

ESF Instrument Inverter Bus 111 and 113, 125V

DC [[]]

ESF Distribution Center 111 K 6E-1-4007A Byron - Unit 1 - Key Diagram 480V

ESF Substation Bus 131X (1

AP 10E) M 6E-1-4010A Key Diagram - 125V

DC [[]]

ESF Distribution Center Bus 111 (1DC05E) Part 1 M

DRAWIN GS Number Description or Title Revision 6E-1-4010B Key Diagram - 125V

DC [[]]

ESF Distribution Center Bus 111 (1DC05E) Part 2 G 6E-1-4010C Key Diagram - 125V

DC Non Safety Related Distribution Panel 113 (1

DC 05EB) K 6E-1-4030DC05 Schematic Diagram -

125 VDC [[]]

ESF "Distribution Center, Bus 111, Part 1, 1DC05E U 6E-1-4030IP01 Schematic Diagram 7.5KVA Fixed Frequency Inverter for Instrument Bus 111 (1IP05E) 0 6E-1-4030RC31 Schematic Diagram - Reactor Coolant System High Pressure & Low Temperature Control & Alarms G [[SSC" contains a listed "[" character as part of the property label and has therefore been classified as invalid.RH02 Schematic Diagram - Residual Heat Removal Pump 1B - 1RH01PB N 6E-1-4030RY14 Schematic Diagram - Pressurizer Pressure & Level Control Safety Related & Non-Safety Related (Div 12) F 6E-1-4030RY17 Schematic Diagram - Pressurizer Power Relief Valves - 1RY455A & 1RY456; Pressurizer Relief Tank Primary Water Supply Isolation Valve - 1RY8030; Pressurizer Relief Tank Drain Isolation Valve 1RY8031 V 6E-1-4031RC26 Loop Schematic Diagram - Reactor Coolant System Cold Overpressurization System Control 1A & 1D Control Cabinet 5 & 6 S 6E-1-4031RY15 Loop Schematic Diagram - Pressurizer Pressure & Level Control Cabinet 6 (1PA06J) Part 1 O 6E-1-4031RY19 Loop Schematic Diagram - Pressurizer Pressure Safety Valve Discharge Temp & Pressure Control (ITE-0464) Control Cabinet 7 (1PA07J) F M-42 Sh. 6 Diagram of Essential Service Water]]

BC M-60 Sh. 5 Diagram of Reactor Coolant

AO M-2042 Sh. 5 P&ID/C&I Diagram

ESS Service Water System -

SX F 6E-0-1003 Duct Runs, Outdoor Plan, Southeast Area

AC 6E-0-1004 Duct Runs, Outdoor Plan, Southwest Area Y 6E-0-1009 Duct Runs, Sections F 6E-0-3502 Electrical Installation,

ESW Cooling Tower 0A Plan - Switchgear Room, Elev. 874'-6"

AZ 6E-0-3502

CT 1 Conduit Tabulation,

ESW Cooling Tower 0A Plan - Switchgear Room, Elev. 874'-6" T 6E-0-3502D01 Electrical Installation,

ESW Cooling Tower 0A Switchgear Room Partial Plans and Sections N 6E-0-3507 Electrical Installation,

ESW Cooling Tower 0B Plan - Switchgear Room, Elev. 874'-6"

BN 6E-0-3507CT1 Conduit Tabulation,

ESW Cooling Tower 0B Plan - Switchgear Room, Elev. 874'-6" Y 6E-0-3507D01 Electrical Installation,

ESW "Cooling Tower 0B Switchgear Room Partial Plans and Sections W 6E-0-4030SX01 Schematic Diagram, Essential Service Water Cooling Tower 0A, Fan 0A V [[SSC" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Duct Run Routing Outdoor - West of Station]]

AC [[]]

DRAWIN "GS Number Description or Title Revision 6E-0-4030SX02 Schematic Diagram, Essential Service Water Cooling Tower 0A, Fan 0B U [[SSC" contains a listed "[" character as part of the property label and has therefore been classified as invalid.SX03 Schematic Diagram, Essential Service Water Cooling Tower 0A, Fan 0C U 6E-0-4030SX04 Schematic Diagram, Essential Service Water Cooling Tower 0A, Fan 0D W 6E-0-4030SX05 Schematic Diagram, Essential Service Water Cooling Tower 0B, Fan 0E V 6E-0-4030SX06 Schematic Diagram, Essential Service Water Cooling Tower 0B, Fan 0F W 6E-0-4030SX07 Schematic Diagram, Essential Service Water Cooling Tower 0B, Fan 0G W 6E-0-4030SX08 Schematic Diagram, Essential Service Water Cooling Tower 0B, Fan 0H W 6E-1-4001A Station One Line Diagram P 6E-1-4006B Key Diagram, 4160V]]

ESF Switchgear Bus 142 J 6E-1-4008

AN Key Diagram, 480V

ESW Cooling Tower

ESF [[]]

MCC 132Z1 R 6E-1-4012A Key Diagram, 120 Vac Instrument Bus 111 W 6E-1-4018B Relaying & Metering Diagram, 4160

ESF Switchgear Bus 142 U 6E-1-4030AP115 Schematic Diagram, Tripping Circuit, 480V

ESW Cooling Tower

MCC [[131Z1A, 132Z1A A 6E-1-4030RY17 Schematic Diagram, Pressurizer Power Relief Valve 1RV456 V 6E-1-4030SI02 Schematic Diagram, Safety Injection Pump 1B N 6E-1-4030SI14 Schematic Diagram, Containment Sumps 1A and 1B Isolation Valves SI8811A & B Q 6E-1-4031VP11 Loop Schematic Diagram [containment inside/outside differential pressure] K M-61, Sh. 1B Diagram of Safety Injection]]

AX M-136, Sh. 1 Diagram of Safety Injection

BB M-63, Sh. 1A Diagram of Fuel Pool Cooling and Clean up

BI S-1404 Refueling Water Storage Tank Sections & Details I M-60, Sh. 8 Diagram of Reactor Coolant

AA 98Z512-001-2, Sh. 1 Pressurizer

PORV Air Relief Valve 0 M-60, Sh.5 Diagram of Reactor Coolant

AO [[]]

10 CFR 50.59

DOCUME NTS (Screenings/Safety Evaluations) Number Description or Title Date 6G-97-0110

DCP 9600355

ESW "Cooling Tower Basin Level Switch 7/3/97 EC385829 Tornado Missile Design Basis for the Essential Service Water [[Ultimate Heat Sink" contains a listed "[" character as part of the property label and has therefore been classified as invalid. 0 6G-11-004 Tornado Missile Design Basis for the Essential Service Water Cooling Towers 2/9/12 EC385951 Multiple Spurious Operation - Scenario 14, 1SI8811A/B 12/9/11 6E-05-0172]]

UFSAR Change Package (

DRP )11-052 11/16/05

10 CFR 50.59

DOCUME NTS (Screenings/Safety Evaluations) Number Description or Title Date 6E-15-035 Increase Pressurizer

PORV tank Operating Pressure to Increase Margin for

PORV Operation (Unit 1) 0 6H-00-0155 Technical Requirements Manual (TRM) Revision to Delete

TLCO 3.4.a, "Pressurizer Safety Valves-Shutdown" 9/19/00

MISCEL LANEOUS Number Description or Title Date or Revision

IST Program Plan - Service Water System 8/26/14 Standing Order 15-020 Emergency Operating Procedure Cold Leg Recirc. 5/15/15

DW -09-004

ERG Feedback 2/27/09 Stewart & Stevenson Certificate of Conformance for Battery Chargers Serial No. 2165, 2167, 2170, 2174, 4 Batterrie 20 Cells/Set and 8 Battery Racks, Purchase Order No. 203731 11/4/81 06

EN 003246

FLT Series Flex Switch - Flow, Level, Temperature Switch Monitor 2 01492090-03 Level 3

OPEX Evaluation -

NRC [[]]

IN [[2013-05: Battery Expected Life and Its Potential Impact on Surveillance Requirements 5/16/13 CQD-009436 Seismic Qualification Test Report for Nife Ni-Cad Batteries H-410 (1,2 AF01EA-A, EA-B, EB-A, EB-B/0SX02EA, EB-A, EC-A, ED-A 8/17/83 CQD-012527 Review of Seismic Qualification Test Report for Battery Chargers (1&2 DC03E, 04E) 10/2/13 CQD-049161 Justification for the Application of Permatex Form A Gasket with]]

EPT Diaphragms 1

CQD "-200164 Dynamic Qualification of Battery Chargers 0SX02EA-1 through 0SX02ED-1; 1,2AF01EA-1 and 1,2AF01EB-1 5/29/86 NEC-06-6066 Procurement of Safety Related 125 Volt Batteries B 604990-70-F1 Reliance Electric Dimension Sheet [SX [[Ultimate Heat Sink" contains a listed "[" character as part of the property label and has therefore been classified as invalid. fan motor data sheet] 4/4/78 EQ-GEN023]]

EQ Binder for

NAMCO EA180 limit switches 13 EC-397415

EQ Evaluation - Pressurizer

PORV Diaphragm Design Pressure 0 EQER-06-98-002

EQ Evaluation for

PORV "1(2) FSV-RY-455A & 1(2)FSV-RY-456 2/29/99 Low Temperature Protection (LTOP) System Evaluation for Byron and Braidwood Units 1 and 2 Measurement Uncertainty Recapture (MUR) [[Topic" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Program 9/7/10 Simulator Work Request]]

13961 PZR [[]]

PORV Testing reveals lower than design flow 4/25/12 Byron Unit 1 Pressure and Temperature Limits Report 3/14

EC 381986 Summary of the Design and Licensing Basis for Inadvertent

ECCS Actuation at Power 0

MODIFI "CATIONS Number Description or Title Date or Revision EC394865 Ultimate Heat Sink Capability with Loss of Essential Service Water [[Ultimate Heat Sink" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Fans 2 EC385829]]

FC Purification System for Use of Non Safety Related Portion Connected to Safety Related Piping 0

SX "Fans Due to Tornado Missiles 2/14/12 M6-1(2)-87-142 Install Fan Cooling to Instrument Power Inverter Cubicles 10/17/90 EC385951 Multiple Spurious Operation - Scenario 14, 1SI8811A/B 12/9/11 [[engineering change" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Detailed Review of]]

EC 396016 Increase U1 Pressurizer

PORV Accumulator Tank Operating Pressure to Increase number of

PORV Open/Close Cycles from Accumulator 0 OPERABILITY EVALUATIONS Number Description or Title Date 13-001 Capacity of the Pressurizer

PORV "Air Accumulator During Natural Circulation Cooldown 5 13-007 Ultimate Heat Sink Capability with Loss of Essential Service Water [[Ultimate Heat Sink" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Fans 1]]

PROCED URES Number Description or Title Revision

1BOA [[]]

PRI -5 Control Room Inaccessibility 108

1BOA [[]]

ELEC -5 Local Emergency Control of Safe Shutdown Equipment 106

0BOA [[]]

PRI -7 Loss of Ultimate Heat Sink Unit 0 1

1BOA [[]]

PRI -7 Essential Service Water Malfunction Unit 1 106

1BEP [[]]

ES -1.3 Transfer to Cold Leg Recirculation Unit 1 204 1BCA-1.2

LOCA Outside Containment Unit 1 200

OP -AA-102-106 Operator Response Time Program 3 OP-BY-102-106 Operator Response Time Program at Byron Station 7

1BOA S/D-2 Shutdown

LOCA Unit 1 105

1BOSR [[]]

XRS -Q1 Unit One Remote Shutdown Panel Quarterly Surveillance 13 1BFR-H1 Response to Loss of Secondary Heat Sink Unit1 203

0BHSR 8.4.2-1 Unit Zero Comprehensive Inservice Testing (

IST ) Requirements for Essential Service Water Makeup Pump 0A 8

0BHSR [[]]

SX -1 Unit 0 0A

SX Makeup Pump Battery Bank A Capacity Test 0 0

BHSR SX-5 0A

SX Makeup Pump Battery Bank D Capacity Test 0 0

BISR 7.a.4-200 Calibration of Essential Service Water Cooling Tower Basin 0A Level Switch (SX) 7

0BOSR Z.7.a.2-1 Unit Common Deepwell Pump Operability Monthly Surveillance 1 0

BOSR 7.9.6-1 Essential Service Water Makeup Pump 0A Monthly Operability Surveillance 32

0BVSR [[]]

SX -1 Unit 0 0A

SX Makeup Pump Battery Bank A Capacity Test 3 0

BVSR SX-4 Unit 0 0A

SX Makeup Pump Battery Bank D Capacity Test 3 0

BVSR WW-1 Biennial Deep Well Pump Structure Inspection 2

1BHSR 8.4.2-1 Unit 1 Bus 111 125V Battery Charger Operability 1

PROCED URES Number Description or Title Revision

1BHSR 8.4.3-1 Unit 1 125 Volt Battery Bank 111 Service Test 3 1

BHSR 8.6.6-1 Unit 1 Battery 111 125 Volt Battery Bank 5 Year Modified Performance Test 0 & 2

1BHSR [[]]

AF -1AA Unit 1 1B Diesel Aux Feed Pump Battery Bank A Battery A (1AF01EA-A) Capacity Test 1

1BOA [[]]

ELEC -1 Loss of

DC Bus Unit 1 103 1

BOSR 8.4-1 125V

DC Bus 111 Load Shed When Cross-Tied to

DC Bus 211 12

2BHSR 8.4.2-1 Unit 2 Bus 211 125V Battery Charger Operability 1

BISR 3.1.10-206 Pressurizer Pressure Protection Channel

II (

RY ) Test Report Package)

8 BISR 3.1.10-207 Pressurizer Pressure Protection Channel

III (RY) Test Report Package)

8 BISR 4.12.8-200 Wide Range Reactor Coolant Pressure Loop 1A Hot Leg (

RC ) 7 BOP-AP-93

MCC 035-2 Outage 1

BOP SX-3 Essential Service Water Make-up Pump Startup

30 BOP [[]]

SX 17 Shutdown of

SX Makeup Pump Battery Chargers 3

BOP SX18 Placing the

SX Makeup Pump Battery Chargers in Operation/Equalize 8

CC [[-AA-308 Control and Tracking of Electrical Load Changes 4 ER-AA-310-1004 Maintenance Rule - Performance Monitoring 13 MA-BY-026-1001 Seismic Housekeeping 2 MA-BY-721-060 125 Volt Battery Bank 18 Month Surveillance 11 MA-BY-721-061 125 Volt Battery Bank Quarterly Surveillance 12 & 15 MA-BY-723-053 Station Battery Charger 18 Month Surveillance 18 MA-BY-723-053-001 0B]]

SX Makeup Pump A Battery Charger 0

SX 02EA Battery Charger Test 0 MA-BY-723-053-002 0B

SX Makeup Pump D Battery Charger 0

SX 02ED Battery Charger Test 1 MA-BY-723-053-003 0B

SX Makeup Pump B Battery Charger 0

SX 02EB Battery Charger Test 0 MA-BY-723-053-004 0B

SX Makeup Pump C Battery Charger 0

SX 02EC Battery Charger Test 1 MA-BY-723-054 Nickel Cadmium Battery Bank Surveillance 14

0BHSR [[]]

SX -3 Annual Surveillance for Essential Service Water Cooling Tower Fan Motors 2

0BOSR 7.9.4-1

ESW Cooling Tower Fan Monthly Surveillance 6

1BOSR [[]]

IP -R1 Instructions to Cycle Instrument Bus 111 Distribution Panel Molded Case Circuit Breakers 0

1BOSR 3.2.9-1 Train A Manual Safety Injection Initiation and Manual Phase A Initiation Surveillance 22 1

BOSR 8.9.1-2 Unit

1 ESF Onsite Power Distribution Weekly Surveillance Division 12 10

BOP MP-19 Adjusting Reactive Load 12

PROCED URES Number Description or Title Revision ER-AA-300-150 Cable Condition Monitoring Program 1 MA-AA-723-330 Electrical Testing of

AC Motors Using Baker Instrument Advanced Winding Analyzer 3

MA -AA-725-102 Preventative Maintenance on Westinghouse Type

DHP 4kv, 6.9kv, and 13.8kv Circuit Breakers 8 1

BGP -100-5 Plant Shutdown and Cooldown

68 BOP [[]]

FC -7 Startup of the Purification System to Purify or Recirculate the Refueling Water Storage Tank 13

1BEP [[]]

ES -0.2 Natural Circulation Cooldown Unit 1

202 BAR 1-12-C4

RCS Press High at Low Temp 2

1BOSR 5.C.3.1 Safety Injection System Cold Leg Flow Balance 3 2

BOSR 0.1-4 Unit 2 Mode 4 Shiftly and Daily Operating Surveillance 25

1BOSR 0.1-1,2,3 Unit 1 Mode 1,2,3

TRM and Tech Spec and Non Tech Spec Data Sheet D5

56 BIP 2500-088 Calibration of Refueling Water Storage Tank Outlet Temperature Loop (

SI ) 5

1BOSR 5.5.8.

SI. 5-2C Unit 1 Comprehensive Inservice Testing (IST) Requirements for Safety Injection Pump 1SI01PB 5

1BOSR 5.5.8.

SI. 5-2a Unit 1 Group A Inservice Testing (IST) Requirements for Safty Injection Pumps 1SI01PB 1

0BOSR [[]]

NLO -TRM Non-Licensed Operator TRM, ISFSI, and

NPDES Data Daily Logs 18 1

BGP 100-5 Plant Shutdown and Cooldown

68 BOP [[]]

SX -T2

SX Basin Level Tree 5

BOP SX-11

SXCT Fan Startup 9

BOP SX-12 Makeup to an Essential Service Water Mechanical Draft Cooling Tower 10

0BOA [[]]

ENV -1 Adverse Weather Conditions 114

1BOA [[]]

PRI -5 Control Room Inaccessibility 108

1BOA [[]]

ELEC -5 Local Emergency Control of Safe Shutdown Equipment Unit 1 106 1BEP-1 Reactor Trip or Safety Injection 207

1BEP [[]]

ES -0.1 Reactor Trip Response 203

1BEP [[]]

ES -0.2 Natural Circulation Cooldown

202 BOP [[]]

RH -6 Operation of the

RH System In Shutdown Cooling 46

OP -AA-108 Oversight and and Control of Operator Burdens

2 BOP [[]]

CC -1 Component Cooling Water System Startup 12 SURVEILLANCES (Completed) Number Description or Title Date or Revision

0BHSR [[]]

SX -1 0A

SX Makeup Pump Battery Bank A Capacity Test 6/14/12 0

BHSR SX-5 0A

SX Makeup Pump Battery Bank D Capacity Test 9/14/12 0

BISR 7.a.4-200 Calibration of Essential Service Water Cooling Tower Basin 0A Level Switch (SX) 8/7/14

0BOSR 5.5.8.

SX. 5-1c 0SX02PA Comprehensive

IST Req for

SX Makeup Pump 2/5/15

SURVEI LLANCES (Completed) Number Description or Title Date or Revision

0BOSR 7.9.6-1 0A

SX Makeup Pump Operability Surveillance 3/12/13

0BOSR 7.9.6-1 0A

SX Makeup Pump Operability Surveillance 2/4/15

0BOSR 7.9.6-1 0A

SX Makeup Pump Battery Bank A Capacity Test 3/11/15

0BVSR [[]]

SX -1 0A

SX Makeup Pump Battery Bank A Capacity Test 10/17/06 0

BVSR SX-4 0A

SX Makeup Pump Battery Bank D Capacity Test 6/19/06 1

BHSR 8.4.2-1 Unit 1 Bus 111 125V Battery Charger Operability Test 11/8/11

1BHSR 8.4.2-1 Unit 1 Bus 111 125V Battery Charger Operability Test 9/17/13 1

BHSR 8.4.3-1 111 "A" Train 125V Battery Bank Service Test 3/20/14

1BHSR 8.6.6-1 111 "A" Train 125V Battery Bank 5Yr Capacity Test 4/1/08 1

BHSR 8.6.6-1 111 "A" Train 125V Battery Bank 5Yr Capacity Test 9/11/12

BISR 3.1.10-206 Pressurize Pressure Protection Channel 2 Loop 1

RY -0456 4/6/15

BISR 3.1.10-207 Pressurizer Pressure Protection Channel 3 Loop 1

RY -0457 4/13/15

BISR 4.12.8-200 Cal of Wide Range

RC [[Pressure Loop 1A Hot Leg 1P-406 4/28/14 M A-BY-721-060 125 Volt Battery Bank Quarterly Surveillance 9/11/12 M A-BY-721-060 125 Volt Battery Bank Quarterly Surveillance 3/20/14 M A-BY-721-061 125 Volt Battery Bank 18 Months Surveillance 9/16/12 M A-BY-721-061 125 Volt Battery Bank 18 Months Surveillance 3/22/14 M A-BY-721-061 125 Volt Battery Bank 18 Months Surveillance 9/15/14 M A-BY-721-061 125 Volt Battery Bank 18 Months Surveillance 12/16/14 MA-BY-723-053]]

EM 18 Month Battery Charger Surveillance - 0B

SX M/U Pump 0B Batt Chgr # 0SX02EB-1 1/15/13 MA-BY-723-053

EM 18 Month Battery Charger Surveillance - 0A

SX M/U Pump 0A Batt Chgr # 0SX02EA-1 2/6/14 MA-BY-723-053

EM 18 Month Battery Charger Surveillance - 0A

SX M/U Pump 0D Batt Chgr # 0SX02ED-1 8/5/14 MA-BY-723-053

EM 18 Month Battery Charger Surveillance - 0B

SX M/U Pump 0C Batt Chgr # 0SX02EC-1 3/27/15 MA-BY-723-053-001 0B

SX Makeup Pump A Battery Charger 0

SX 02EA Battery Charger Test 2/4/14 MA-BY-723-053-002 0B

SX Makeup Pump D Battery Charger 0

SX 02ED Battery Charger Test 8/6/14 MA-BY-723-053-003 0B

SX Makeup Pump B Battery Charger 0

SX 02EB Battery Charger Test 1/15/13 MA-BY-723-053-004 0B

SX Makeup Pump B Battery Charger 0

SX 02EC Battery Charger Test 3/27/15 MA-BY-723-054 Quarterly

24 VDC NiCad Battery Surveillance M/U Diesel

SX - 0SX02ED-A 8/5/14 MA-BY-723-054 Quarterly

24 VDC NiCad Battery Surveillance M/U Diesel

SX- 0SX02EA-A 9/5/14

SURVEI LLANCES (Completed) Number Description or Title Date or Revision MA-BY-723-054 Quarterly

24 VDC NiCad Battery Surveillance M/U Diesel

SX - 0SX02EA-A 10/30/14 MA-BY-723-054 NiCad Battery Surveillance M/U Diesel SX- 0SX02E 11/6/14 WO01579586 Unit 1 Pressurizer

PORV Accumulator Press Decay Test 3/19/14

WO 01774289

SI pump

ECCS Flow Balance Test (After System Alteration) 10/5/14 WO01243123

OP 2

BOSR 5.C.3-2 Unit

2 SI to

HL Flow Balance 4/2/10 WO01243120 Unit 1 Safety Injection System Hot Leg Flow Balance 9/4/09 WO01243119

SI pump

ECCS Flow Balance Test (After System Alterations) 9/4/09 WO01582134 1SI01PB Comprehensive

IST [[]]

RQMTS For Safety Injection Pump 1/28/14 WO01425077 1SI01PB Comprehensive

IST [[]]

RQMTS For Safety Injection Pump 8/9/12 WO01451296 STT/PIT For 1RY455A and 1RY456 9/28/12 WO01585186 STT/PIT For 1RY455A and 1RY456 2/7/14

PMID 140860 0

BOSR 7.9.6-1 0A

SX Makeup Pump Operability Review 4/18/13

TRAINI NG DOCUMENTS Number Description or Title Date or Revision

BY 14-2-2 Requalification Simulator Scenario Guide 1 10-1-5 Requalification Simulator Scenario Guide 0 P1-

SPBY -1401 BEP-1, BEP-2 2 OPBYLLORT5

BFR H, Heat Sink Series 8/28/13

WORK DOCUMENTS Number Description or Title Date or Revision 00961518 Replace Entire Solenoid to Meet

EQ Requirements -

EM [[]]

ASCO Solenoid Valve Replacement (

EQ ) - 1FSV-RY456-2 4/1/08 01057719 Test All

MCC Breakers in This

MCC in a Bus Outage - Assembly 480V

RSH [[]]

MCC "035-2 5/2813 01094421 Replace Float and Equalize Voltage Adjustment Potentiometer 11/29/11 01490541 111 "A" Train 125 V Battery Charger Operability Test 9/18/13 01536066 Essential Service Water Cooling Tower Level [[SSC" contains a listed "[" character as part of the property label and has therefore been classified as invalid.]]

IM Calibration 3/3/14 01558514 B1R19 Replace 111

ESF Batteries 3/29/14 01578627 Test Replace Actuator Hose 1RY456 3/14/14 01599481 Calibration of Wide Range

RC Pressure Loop 1A Hot Leg Pressure Loop 1

RC -0406 4/28/14 01600072 Clean/Inspect/Check Connections on

DC Bus/Panel 111 and Perform Therm. on Distr. Panel Breakers 3/30/14 01621944 Support Diver Insp./Cleaning

RSH South 0B Intake/SED

PM [[]]

ID 30 6/25/13 01652815 211 "A" Train 125 V Battery Charger Operability Test 5/14/14

WORK [[]]

DOCUME NTS Number Description or Title Date or Revision 01017127 Perform Dynamic Baker Testing - 1SI01PB Motor 8/26/08 01085998 Perform Static Baker Test and MA-AA-723-310 Inspection of

01117942 PM for 4kV Bus 142, breaker

SX 03CC 4/27/09

ACB [[1425Z 9/21/09 01119375 Lightning Protection System 5 Year Inspection [Includes Document 1 attachment to WO] 11/18/09]]

01120491 PM for 4kV Bus 142, breaker

ACB 1424 9/29/09 01129028 Inspection of

01136617 PM for 4kV Bus 142, breaker

SX 03D 10/28/09

ACB 1422 3/15/09 01141049 Perform Static Baker Test and MA-AA-723-310 Inspection of

SX 03CB 3/19/10 01216011 Perform Dynamic Baker Testing - 1SI01PB Motor 8/26/10 01258194 Calibration of OLS-XS097 1/6/11

01265167 PM for 4kV Bus 142, breaker

ACB 1421 10/26/11 01287321 Inspection of

SX 03CE 9/1/11 01299949 Containment Inside/Outside

DP Loop 1

VP -231 6/30/11 01343409 Inspection of

01367641 PM for 4kV Bus 142, breaker

SX 03CH 11/21/11

ACB 1SI01PB 2/21/12

01372340 PM for 4kV Bus 142, breaker

ACB 1422 11/11/12 01382271 Perform Static Baker Test and MA-AA-723-310 Inspection of

SX 03CC 6/12/12 01384474-01 Inspection of

SX 03CF 11/26/12 01380551-01 Inspection of

SX 03CA 6/8/12 01393782 Inspection of

SX 03CG 10/30/11 01401180 Calibration of OLS-XS097 8/24/12

01419437 PM for 4kV Bus 142, breaker

ACB 1425Z 9/23/12 01419758 Test All

MCC 132Z1 Breakers - Oden Testing 9/23/12 01420365

PM for 4kV Bus 142, breaker

ACB 1424 9/23/12 01421751 Unit 1 Train A Manual

SI and Manual Phase A Initiation Surveillance 9/11/12 01433378-01 Inspection of

SX 03CD 3/12/13 01453350 Containment Inside/Outside

DP Loop 1

VP -231 3/19/15 01471461 Calibration of OLS-XS096 9/6/11 01473594-01 Perform Static Baker Test and MA-AA-723-310 Inspection of

SX 03CB 5/17/13 01480666-01 Testing of Power Cables 2AP178 4/20/13 01486337 Calibration of OLS-XS096 2/8/13

01538412 PM for 4kV Bus 142, breaker

ACB 1423 11/30/13 01564018-01 Testing of Power Cables 1AP178 (North

SX towers) 3/18/14 01569220 Calibration of

OLS -XS097 6/2/14 01585654-02 Testing of Power Cables 2AP183 (Bus 242, Cubicle 20) 10/6/14 01615167 Calibration of OLS-XS096 8/8/14 01621573-01 Perform Surveillance of

01639602 PM for 4kV Bus 142, breaker

SX 03CE 9/16/14

ACB 1421 11/19/14

WORK [[]]

DOCUME NTS Number Description or Title Date or Revision 01644724-01 Perform Surveillance of