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IR 05000454-08-005, 05000455-08-005; Exelon Generation Company, LLC; October 1 - December 31, 2008; Byron Station, Units 1 & 2; Refueling and Other Outage Activities, and Access Control to Radiologically Significant Areas
	ML090420213
Person / Time
Site:	Byron
Issue date:	02/10/2009
From:	Richard Skokowski; Region 3 Branch 3
To:	Pardee C; Exelon Generation Co, Exelon Nuclear
References
	IR-08-005
	Download: ML090420213 (49)
	v • d • e

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE ROAD, SUITE 210

LISLE, IL 60532-4352

February 10, 2009

Mr. Charles G. Pardee

Senior Vice President, Exelon Generation Company, LLC

President and Chief Nuclear Officer (CNO), Exelon Nuclear

4300 Winfield Road

Warrenville IL 60555

SUBJECT: BYRON STATION, UNITS 1 AND 2 INTEGRATED INSPECTION

REPORT 05000454/2008-005 05000455/2008-005

Dear Mr. Pardee:

On December 31, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an

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

documents the inspection findings which were discussed on January 15, 2009, with

Mr. D. Hoots and other members of your staff.

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

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

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

personnel.

Based on the results of this inspection, two NRC-identified findings of very low safety

significance were identified. The findings involved violations of NRC requirements. However,

because of their very low safety significance, and because the issues were entered into your

corrective action program, the NRC is treating the issues as Non-Cited Violations in accordance

with Section VI.A.1 of the NRC Enforcement Policy. Furthermore, four licensee identified

violations are listed in Section 4OA7 of this report.

If you contest the subject or severity of a Non-Cited Violation, you should provide a

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

to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington,

DC 20555-0001, with a copy to the Regional Administrator, U.S. Nuclear Regulatory

Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the

Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC

20555-0001; and the Resident Inspector Office at the Byron Station.

C. Pardee -2-

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

its enclosure and your response (if any) will be available electronically for public inspection

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

component of NRC's document system (ADAMS), accessible from the NRC Web site at

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

Sincerely,

/RA/

Richard A. Skokowski, Chief

Branch 3

Division of Reactor Projects

Docket Nos. 50-454; 50-455

License Nos. NPF-37; NPF-66

Enclosure: Inspection Report No. 05000454/2008-005 and 05000455/2008-005

w/Attachment: Supplemental Information

cc w/encl: Site Vice President - Byron Station

Plant Manager - Byron Station

Manager Regulatory Assurance - Byron Station

Senior Vice President - Midwest Operations

Senior Vice President - Operations Support

Vice President - Licensing and Regulatory Affairs

Director - Licensing and Regulatory Affairs

Manager Licensing - Braidwood, Byron, and LaSalle

Associate General Counsel

Document Control Desk - Licensing

Assistant Attorney General

Illinois Emergency Management Agency

J. Klinger, State Liaison Officer,

Illinois Emergency Management Agency

P. Schmidt, State Liaison Officer, State of Wisconsin

Chairman, Illinois Commerce Commission

B. Quigley, Byron Station

C. Pardee -2-

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

its enclosure and your response (if any) will be available electronically for public inspection

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

component of NRC's document system (ADAMS), accessible from the NRC Web site at

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

Sincerely,

Richard A. Skokowski, Chief

Branch 3

Division of Reactor Projects

Docket Nos. 50-454; 50-455

License Nos. NPF-37; NPF-66

Enclosure: Inspection Report No. 05000454/2008-005 and 05000455/2008-005

w/Attachment: Supplemental Information

cc w/encl: Site Vice President - Byron Station

Plant Manager - Byron Station

Manager Regulatory Assurance - Byron Station

Senior Vice President - Midwest Operations

Senior Vice President - Operations Support

Vice President - Licensing and Regulatory Affairs

Director - Licensing and Regulatory Affairs

Manager Licensing - Braidwood, Byron, and LaSalle

Associate General Counsel

Document Control Desk - Licensing

Assistant Attorney General

Illinois Emergency Management Agency

J. Klinger, State Liaison Officer,

Illinois Emergency Management Agency

P. Schmidt, State Liaison Officer, State of Wisconsin

Chairman, Illinois Commerce Commission

B. Quigley, Byron Station

DOCUMENT NAME: G:\1-SECY\1-WORK IN PROGRESS\BYRO 2008 005.DOC

G Publicly Available G Non-Publicly Available G Sensitive G Non-Sensitive

To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy

OFFICE RIII

NAME RSkokowski:dtp

DATE 02/10/09

OFFICIAL RECORD COPY

Letter to C. Pardee from R. Skokowski dated February 10, 2009

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

05000454/2008-005 05000455/2008-005

DISTRIBUTION:

Tamara Bloomer

RidsNrrDorlLpl3-2

RidsNrrPMByron Resource

RidsNrrDirsIrib Resource

Mark Satorius

Kenneth OBrien

Cynthia Pederson

DRPIII

DRSIII

Patricia Buckley

Tammy Tomczak

ROPreports@nrc.gov

U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket Nos: 50-454; 50-455

License Nos: NPF-37; NPF-66

Report Nos: 05000454/2008-005 and 05000455/2008-005

Licensee: Exelon Generation Company, LLC

Facility: Byron Station, Units 1 and 2

Location: Byron, IL

Dates: October 1, 2008, through December 31, 2008

Inspectors: B. Bartlett, Senior Resident Inspector

R. Ng, Resident Inspector

J. Cassidy, Senior Health Physicist

A. Dunlop, Reactor Inspector

B. Jones, Reactor Inspector

D. Jones, Reactor Inspector

R. Langstaff, Reactor Inspector

D. McNeil, Reactor Inspector

R. Winter, Reactor Inspector

C. Thompson, Resident Inspector

Illinois Department of Emergency Management

Observer: J. Gilliam, Reactor Engineer

Approved by: R. Skokowski, Chief

Branch 3

Division of Reactor Projects

Enclosure

TABLE OF CONTENTS

SUMMARY OF FINDINGS 1

REPORT DETAILS .3

Summary of Plant Status .3

1. REACTOR SAFETY .....3

1R01 Adverse Weather Protection (71111.01) .....................................................3

1R04 Equipment Alignment (71111.04) ................................................................4

1R05 Fire Protection (71111.05)...........................................................................4

1R06 Flooding (71111.06) .....6

1R07 Annual Heat Sink Performance (71111.07).................................................6

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

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

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

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

1R18 Plant Modifications (71111.18) ..................................................................11

1R19 Post-Maintenance Testing (71111.19) ......................................................12

1R20 Outage Activities (71111.20) .....................................................................13

1R22 Surveillance Testing (71111.22)................................................................15

1EP6 Drill Evaluation (71114.06) ........................................................................18

2. Radiation SAFETY ........19

2OS1 Access Control to Radiologically Significant Areas (71121.01) .................19

2OS2 As-Low-As-Reasonably-Achievable Planning and Controls (71121.02) ...22

4OA1 Performance Indicator Verification (71151) ...............................................23

4OA2 Identification and Resolution of Problems (71152)....................................28

4OA5 Other Activities 30

4OA6 Management Meetings ..32

4OA7 Licensee-Identified Violations....................................................................33

SUPPLEMENTAL INFORMATION ..1

Key Points of Contact ..1

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

List of Documents Reviewed ..2

Enclosure

SUMMARY OF FINDINGS

IR 05000454/2008-005, 05000454/2008-005; October 1 - December 31, 2008; Byron Station,

Units 1 & 2; Refueling and Other Outage Activities, and Access Control to Radiologically

Significant Areas.

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

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

inspectors. The findings were considered to be Non-Cited Violations of NRC regulations.

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

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

for which the SDP does not apply may be Green or be assigned a severity level after NRC

management review. The NRCs program for overseeing the safe operation of commercial

nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4,

dated December 2006.

A. NRC-Identified and Self-Revealed Findings

Cornerstone: Mitigating Systems

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

Non-Cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion V, Instructions,

Procedures, and Drawings, for the licensees failure to follow procedure BAP 1450-1,

Access to Containment. Specifically, the inspectors determined that the licensee failed

to remove loose debris items from Unit 2 containment prior to Mode 4 or to perform an

engineering evaluation per procedure. The licensee entered this issue into the

corrective action program (CAP) as Issue Report (IR) 867171, removed the loose debris,

and completed an evaluation to verify that the containment sump was not adversely

affected.

The finding is more than minor because, if left uncorrected, the issue could have

become a more significant safety concern. The inspectors evaluated the finding using

IMC 0609, Significance Determination Process, Attachment 0609.04, Phase 1 - Initial

Screening and Characterization of Finding, dated January 10, 2008, for the Mitigating

Systems Cornerstone. Since this finding was not a design or qualification deficiency, did

not result in loss of system or train safety function, and was not safety significant due to

external events, this issue is screened as very low safety significance. This finding is

related to the Work Control component of the Human Performance cross-cutting area for

the licensees failure to coordinate work activities and the need for work groups to

coordinate with each other. (H.3(b)) The personnel who left the material in containment

assumed it was acceptable as they had documented the material in a surveillance data

sheet, and the personnel who reviewed the completed data sheet assumed the material

had been or would be removed from containment, and none questioned the potential

impact upon the recirculation sump screens or coordinated with each other to ensure

resolution of the material prior to a mode change. (Section 1R20.b)

Cornerstone: Occupational Radiation Safety

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

NCV of Technical Specification 5.4.1 for failure to implement procedures required to

evaluate radiological hazards for airborne radioactivity. Specifically, the inspectors

1 Enclosure

identified that the licensee failed to re-start an air sampler on the refuel floor which

provided the only air monitoring system while workers were performing activities in the

area. The corrective actions taken by the licensee included starting the required air

sampler. The issue was entered in the licensees corrective action program as

IR 828767.

The finding is more than minor because it impacted the program and process attribute of

the Occupational Radiation Safety Cornerstone and affected the cornerstone objective of

ensuring adequate protection of worker health and safety from exposure to radiation, in

that the failure to fully evaluate the radiological hazards present in work areas could

result in unplanned exposure to workers. The finding was determined to be of very low

safety significance because it was not an As-Low-As-Is-Reasonably-Achievable

(ALARA) planning issue, there was no overexposure nor potential for overexposure, and

the licensees ability to assess dose was not compromised. This finding was caused by

inadequate self-checking and peer checking. Consequently, the cause of this deficiency

had a cross-cutting aspect in the area of Human Performance. (H.4(a)) Specifically, the

licensee failed to utilize human error prevention techniques commensurate with the risk

of the task. (Section 2OS1.1)

B. Licensee-Identified Violations

Four violations of very low safety significance that were identified by the licensee have

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

been entered into the licensees CAP. These violations and corrective action tracking

numbers are listed in Section 4OA7 of this report.

2 Enclosure

REPORT DETAILS

Summary of Plant Status

Unit 1 operated at or near full power throughout the inspection period with minor exceptions.

Unit 2 operated at or near full power throughout the inspection period with one exception. Unit 2

was in a refueling outage from October 6 through October 24, 2009.

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems and Barrier Integrity

1R01 Adverse Weather Protection (71111.01)

.1 Winter Seasonal Readiness Preparations

a. Inspection Scope

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

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

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

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

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

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

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

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

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

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

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

inspectors also reviewed corrective action program (CAP) items to verify that the

licensee was identifying adverse weather issues at an appropriate threshold and

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

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

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

significance or susceptibility to cold weather issues:

Diesel Generator Ventilation; and

Essential Service Water Cooling Towers.

This inspection constituted one winter seasonal readiness preparations sample as

defined in IP 71111.01-05.

b. Findings

No findings of significance were identified.

3 Enclosure

1R04 Equipment Alignment (71111.04)

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

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

systems:

Unit 2 Train B Auxiliary Feedwater System following Refueling Outage

Maintenance;

Unit 2 Essential Service Water System Following Refueling Outage; and

Unit 1 Train A Diesel Generator While Unit 1 Train B Diesel Generator was Out

of Service.

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

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

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

potentially increase risk. The inspectors reviewed applicable operating procedures,

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

orders, condition reports, and the impact of ongoing work activities on redundant trains

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

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

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

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

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

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

identified and resolved equipment alignment problems that could cause initiating events

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

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

Attachment.

These activities constituted three partial system walkdown samples as defined in

IP 71111.04-05.

b. Findings

No findings of significance were identified.

1R05 Fire Protection (71111.05)

.1 Routine Resident Inspector Tours (71111.05Q)

a. Inspection Scope

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

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

plant areas:

Division 12 Switchgear Room (Zone 5.1-1);

Division 21 Switchgear Room (Zone 5.6-2);

4 Enclosure

Auxiliary Building Elevation 451 (Zone 5.6-1);

Auxiliary Building Elevation 426 (Zone 5.1-1);

Auxiliary Building Elevation 426 (Zone 5.2-1); and

Auxiliary Building Elevation 383 (Zone 11.4-0).

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

protection program that adequately controlled combustibles and ignition sources within

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

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

adequate compensatory measures for out of service, degraded or inoperable fire

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

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

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

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

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

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

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

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

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

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

during the inspection were entered into the licensees CAP.

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

IP 71111.05-05.

b. Findings

No findings of significance were identified.

.2 Annual Fire Protection Drill Observation (71111.05A)

a. Inspection Scope

On September 14 and 21, 2008, the inspectors observed a fire brigade activation for a

Security Diesel Charger Fire. Based on this observation, the inspectors evaluated the

readiness of the plant fire brigade to fight fires. The inspectors verified that the licensee

staff identified deficiencies; openly discussed them in a self-critical manner at the drill

debrief, and took appropriate corrective actions. Specific attributes evaluated were:

(1) proper wearing of turnout gear and self-contained breathing apparatus; (2) proper

use and layout of fire hoses; (3) employment of appropriate fire fighting techniques;

(4) sufficient firefighting equipment brought to the scene; (5) effectiveness of fire brigade

leader communications, command, and control; (6) search for victims and propagation of

the fire into other plant areas; (7) smoke removal operations; (8) utilization of pre

planned strategies; (9) adherence to the pre-planned drill scenario; and (10) drill

objectives. In addition, the inspectors evaluated the fire brigades training qualification

and the licensees self-contained breathing apparatus inspection and maintenance

program. Documents reviewed are listed in the Attachment to this report.

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

IP 71111.05-05.

5 Enclosure

b. Findings

No findings of significance were identified.

1R06 Flooding (71111.06)

.1 Internal Flooding

a. Inspection Scope

The inspectors reviewed selected risk important plant design features and licensee

procedures intended to protect the plant and its safety related equipment from internal

flooding events. The inspectors reviewed flood analyses and design documents,

including the UFSAR, engineering calculations, and abnormal operating procedures to

identify licensee commitments. The specific documents reviewed are listed in the

Attachment to this report. In addition, the inspectors reviewed licensee drawings to

identify areas and equipment that may be affected by internal flooding caused by the

failure or misalignment of nearby sources of water, such as the fire suppression or the

circulating water systems. The inspectors also reviewed the licensees corrective action

documents with respect to past flood-related items identified in the corrective action

program to verify the adequacy of the corrective actions. The inspectors performed a

walkdown of the following plant area(s) to assess the adequacy of watertight doors and

verify drains and sumps were clear of debris and were operable, and that the licensee

complied with its commitments:

Turbine Building Internal Flooding.

This inspection constituted one internal flooding sample as defined in IP 71111.06-05.

b. Findings

No findings of significance were identified.

1R07 Annual Heat Sink Performance (71111.07)

.1 Heat Sink Performance

a. Inspection Scope

The inspectors reviewed the licensees testing of Unit 2 Train B Diesel Generator Jacket

Water Heat Exchanger and Unit 2 Train C Reactor Containment Fan Cooler (RCFC)

Heat Exchanger to verify that potential deficiencies did not mask the licensees ability to

detect degraded performance, to identify any common cause issues that had the

potential to increase risk, and to ensure that the licensee was adequately addressing

problems that could result in initiating events that would cause an increase in risk. The

inspectors reviewed the licensees observations as compared against acceptance

criteria, the correlation of scheduled testing and the frequency of testing, and the impact

of instrument inaccuracies on test results. Inspectors also verified that test acceptance

criteria considered differences between test conditions, design conditions, and testing

conditions. Documents reviewed are listed in the Attachment to this report.

6 Enclosure

This annual heat sink performance inspection constituted two samples as defined in

IP 71111.07-05.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification Program (71111.11)

.1 Resident Inspector Quarterly Review (71111.11Q)

a. Inspection Scope

On November 4, 2008, the inspectors observed a crew of licensed operators in the

plants simulator during licensed operator requalification examinations to verify that

operator performance was adequate, evaluators were identifying and documenting crew

performance problems, and training was being conducted in accordance with licensee

procedures. The inspectors evaluated the following areas:

licensed operator performance;

crews clarity and formality of communications;

ability to take timely actions in the conservative direction;

prioritization, interpretation, and verification of annunciator alarms;

correct use and implementation of abnormal and emergency procedures;

control board manipulations;

oversight and direction from supervisors; and

ability to identify and implement appropriate TS actions and Emergency Plan

actions and notifications.

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

expectations and successful critical task completion requirements. Documents reviewed

are listed in the Attachment to this report.

This inspection constituted one quarterly licensed operator requalification program

sample as defined in IP 71111.11.

b. Findings

No findings of significance were identified.

.2 Licensed Operator Requalification Program (LORT)

a. Inspection Scope

The inspectors performed an inspection of the licensees LORT test/examination

program for compliance with the stations Systems Approach to Training (SAT) program

which would satisfy the requirements of 10 CFR 55.59(c)(4). The reviewed operating

examination material consisted of six operating tests, each containing two or three

dynamic simulator scenarios per operating test and 36 job performance measures

(JPMs). The written examinations reviewed consisted of six written examinations, each

including a Part A, Plant and Control Systems, and Part B, Administrative

7 Enclosure

Controls/Procedure Limits. The examinations contained approximately 35 questions.

The inspectors reviewed the annual requalification operating test and biennial written

examination material to evaluate general quality, construction, and difficulty level. The

inspectors assessed the level of examination material duplication from week-to-week

during the current year operating test. The examiners assessed the amount of written

examination material duplication from week-to-week for the written examination

administered in 2006. The inspectors reviewed the methodology for developing the

examinations, including the LORT program 2-year sample plan, probabilistic risk

assessment insights, previously identified operator performance deficiencies, and plant

modifications. The documents reviewed during this inspection are listed in the

Attachment.

b. Findings

No findings of significance were identified.

.3 Annual Operating Test Results

a. Inspection Scope

The inspectors reviewed the overall pass/fail results of the biennial written examination,

the individual JPM operating tests, and the simulator operating tests, which were

required to be given per 10 CFR 55.59(a)(2)) administered by the licensee from

September 22, 2008, through December 15, 2008, as part of the licensees operator

licensing requalification cycle. These results were compared to the thresholds

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

Determination Process (SDP)." The evaluations were also performed to determine if the

licensee effectively implemented operator requalification guidelines established in

NUREG-1021, Operator Licensing Examination Standards for Power Reactors, and

Inspection Procedure 71111.11, Licensed Operator Requalification Program. The

documents reviewed during this inspection are listed in the Attachment.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness (71111.12)

.1 Routine Quarterly Evaluations (71111.12Q)

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following risk

significant systems:

Auxiliary Building Ventilation System;

Unit 1 Train A Diesel Generator Ventilation Failure; and

Unit 2 Train A Diesel Generator Failure to Start During Manual Start Surveillance.

8 Enclosure

The inspectors reviewed events such as where ineffective equipment maintenance had

resulted in valid or invalid automatic actuations of engineered safeguards systems and

independently verified the licensee's actions to address system performance or condition

problems in terms of the following:

implementing appropriate work practices;

identifying and addressing common cause failures;

scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule;

characterizing system reliability issues for performance;

charging unavailability for performance;

trending key parameters for condition monitoring;

ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and

verifying appropriate performance criteria for structures, systems, and

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

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

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

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

effectiveness issues were entered into the CAP with the appropriate significance

characterization. Documents reviewed are listed in the Attachment to this report.

This inspection constituted three quarterly maintenance effectiveness samples as

defined in IP 71111.12-05.

b. Findings

No findings of significance were identified.

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

a. Inspection Scope

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

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

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

prior to removing equipment for work:

Unit 0 Component Cooling Heat Exchanger Out of Service while Unit 2 Train B

Diesel Generator was Out Of Service (OOS) and Bus Tie Breaker 12-13 was

open;

Shutdown Safety during Core Reload with Essential Service Water System

Return X-Tie Valve & Unit 0 Component Cooling Heat Exchanger OOS

Unit 2 Train A Residual Heat Removal System Work Window while Unit 2

Component Cooling Heat Exchanger was OOS; and

Unit 2 Train A Diesel Generator Failure to Start During Manual Start Surveillance.

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

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

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

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

9 Enclosure

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

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

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

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

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

analysis assumptions were valid and applicable requirements were met. Documents

reviewed are listed in the Attachment to this report.

These maintenance risk assessments and emergent work control activities constituted

four samples as defined in IP 71111.13-05.

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations (71111.15)

a. Inspection Scope

The inspectors reviewed the following issues:

Unit 2 Train B Auxiliary Feedwater Pump Jacket Water System Overflow;

Unit 1 Loose Part Monitoring System Noise;

Unit 2 Train B Containment Sump Isolation Valve Motor Degradation; and

Unit 1 Train B Diesel Generator Cylinder and Head Indications.

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

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

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

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

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

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

whether the components or systems were operable. Where compensatory measures

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

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

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

evaluations. Additionally, the inspectors also reviewed a sampling of corrective action

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

associated with operability evaluations. Documents reviewed are listed in the

Attachment to this report.

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

b. Findings

No findings of significance were identified.

10 Enclosure

1R18 Plant Modifications (71111.18)

.1 Temporary Plant Modifications

a. Inspection Scope

The inspectors reviewed the following temporary modification:

Temporary Line to Connect the Drain Lines of Unit 2 A and D Reactor Coolant

Pump Standpipes.

The inspectors compared the temporary configuration change and associated

10 CFR 50.59 screening and evaluation information against the design basis, the

UFSAR, and the TS, as applicable, to verify that the modification did not affect the

operability or availability of the affected system. The inspectors also compared the

licensees information to operating experience information to ensure that lessons learned

from other utilities had been incorporated into the licensees decision to implement the

temporary modification. The inspectors verified that as applicable that the modifications

operated as expected; modification testing adequately demonstrated continued system

operability, availability, and reliability; and that operation of the modifications did not

impact the operability of any interfacing systems. Lastly, the inspectors discussed the

temporary modification with operations, and engineering personnel to ensure that the

individuals were aware of how extended operation with the temporary modification in

place could impact overall plant performance. Documents reviewed are listed in the

Attachment to this report.

This inspection constituted one temporary modification sample as defined in

IP 71111.18-05.

b. Findings

No findings of significance were identified.

.2 Permanent Plant Modifications

a. Inspection Scope

The following engineering design package was reviewed and selected aspects were

discussed with engineering personnel:

Unit 2 Residual Heat Removal System Vent Valve Addition.

This document and related documentation were reviewed for adequacy of the

associated 10 CFR 50.59 safety evaluation screening, consideration of design

parameters, implementation of the modification, post-modification testing, and relevant

procedures, design, and licensing documents were properly updated. The inspectors

observed ongoing and completed work activities to verify that installation was consistent

with the design control documents. The modification added vent locations to safety

related piping in order to allow the removal of air/voids as necessary such as following

maintenance. Documents reviewed are listed in the Attachment to this report.

11 Enclosure

This inspection constituted one permanent plant modification sample as defined in

IP 71111.18-05.

b. Findings

No findings of significance were identified.

1R19 Post-Maintenance Testing (71111.19)

a. Inspection Scope

The inspectors reviewed the following post-maintenance (PM) activities to verify that

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

capability:

Unit 2 Safety Injection System Accumulator Injection Check Valve 2SI8818C

Repair;

Unit 2 Charging/Safety Injection System Flow Balance following Outage

Maintenance;

Unit 1 Train B Charging Pump Return to Service Following Maintenance;

Unit 2 Train B Auxiliary Feedwater Valve Emergency Actuation Signal

Verification Test;

Work Order (WO) 1171264, Operate Diesel Generator 2A in Local Following

Switch Repair;

WO 00999110, Unit 1 Train B RCFC Following Breaker Maintenance; and

Relay Actuation Surveillance 2BOSR 3.2.8-632A to Test Valve 2AF004A.

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

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

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

for the maintenance performed; acceptance criteria were clear and demonstrated

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

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

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

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

documentation was properly evaluated. The inspectors evaluated the activities against

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

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

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

reviewed corrective action documents associated with post-maintenance tests to

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

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

safety. Documents reviewed are listed in the Attachment to this report.

This inspection constituted seven post-maintenance testing samples as defined in

IP 71111.19-05.

b. Findings

No findings of significance were identified.

12 Enclosure

1R20 Outage Activities (71111.20)

a. Inspection Scope

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

Unit 2 refueling outage (RFO - B2R14), conducted October 6 through October 24, 2008,

that the licensee had appropriately considered risk, industry experience, and previous

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

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

and cooldown processes and monitored licensee controls over the outage activities

listed below. Documents reviewed during the inspection are listed in the Attachment to

this report.

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

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

applicable TS when taking equipment out-of-service.

Implementation of clearance activities and confirmation that tags were properly

hung and equipment appropriately configured to safely support the work or

testing.

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

instruments to provide accurate indication, accounting for instrument error.

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

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

Monitoring of decay heat removal processes, systems, and components.

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

to operate the spent fuel pool cooling system.

Reactor water inventory controls including flow paths, configurations, and

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

Controls over activities that could affect reactivity.

Refueling activities, including fuel handling.

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

walkdown of the containment to verify that debris had not been left which could

block emergency core cooling system suction strainers, and reactor physics

testing.

Licensee identification and resolution of problems related to RFO activities.

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

b. Findings

Introduction: The inspectors identified a finding of very low safety significance and an

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

Drawings, for the licensees failure to follow Procedure BAP 1450-1, Access to

Containment.

Description: On October 22, 2008, the licensee was in the process of restarting Unit 2

from the refueling outage. The inspectors performed an assessment for loose debris

inside of containment following the licensees completion of their readiness for changing

from Mode 5 to Mode 4. During the assessment, the inspectors identified items that

required removal prior to the change in mode, most of which were of a minor nature.

13 Enclosure

Examples included pieces of duct tape, cable ties, several signs, and some trash.

However, items found on the polar crane and items that had been left to support control

rod drop timing testing were required by procedure either to be removed prior to Mode 4

or to have an engineering analysis to support their presence inside containment in

Mode 4 and above.

In Mode 4 and above, the licensee was required by TS to have the emergency sump

operable and thus containment cleanliness was required. At the time when the

inspectors performed their assessment of containment cleanliness, the licensee was in

Mode 5 but was within hours of making the change to Mode 4. Therefore, at the time of

identification by the inspectors, the items were not a challenge to the TS requirements

but should have been removed in preparation for the mode change. The items left for

the control rod drop testing were evaluated by engineering to be left and found to be

acceptable. However, due to an internal licensee miss-communication, the items on the

polar crane were left in place without an engineering evaluation performed. This

condition was not identified until after Mode 4 was achieved. In addition, the licensees

IR, which documented the items found by the inspectors, stated that items on the polar

crane were removed; when in fact, they were still on the crane.

The items that had been left through the mode change into Mode 4 were subsequently

evaluated by the licensee as being acceptable and not a significant challenge to blocking

the containment recirculation sump screens following a postulated accident. After the

final use of the polar crane, these items were removed. They consisted mainly of work

orders, copies of procedures, and fibrous rope.

Analysis: The inspectors determined that the failure to remove loose debris items from

containment prior to Mode 4 or to perform an engineering evaluation as required by

procedure was a performance deficiency warranting a significance determination. Using

IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated

September 20, 2007; the inspectors concluded that the finding was greater than minor

because, if left uncorrected, the issue could have become a more significant safety

concern. The inspectors evaluated the finding using IMC 0609, Significance

Determination Process, Attachment 0609.04, Phase 1 - Initial Screening and

Characterization of Finding, dated January 10, 2008, for the Mitigating Systems

Cornerstone. Since this finding was not a design or qualification deficiency, did not

result in loss of system or train safety function and was not safety significant due to

external events, it was screened as very low safety significance (Green).

This finding is related to the Work Control component of the Human Performance

cross-cutting area for the licensees failure to coordinate work activities and the need for

work groups to coordinate with each other. The personnel who left the material in

containment assumed it was acceptable as they had documented the material in a

surveillance data sheet and the personnel who reviewed the completed data sheet

assumed the material had been or would be removed from containment and none

questioned the potential impact upon the recirculation sump screens or coordinated with

each other to ensure resolution of the material prior to a mode change. (H.3(b))

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

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

procedures and accomplished in accordance to these procedure. Byron Administrative

Procedure BAP 1450-1, Revision 37, Access to Containment, was written in

14 Enclosure

accordance with Appendix B. Step 3.2.1 stated in part that, Tools and Equipment taken

into containment in Modes 1, 2, 3, or 4 will be removed when personnel exit

containment. Engineering evaluation and approval is required to leave materials, tools,

and equipment unattended in containment. Contrary to the above, on

October 22, 2008, the inspectors identified that licensee personnel left material inside of

containment in Mode 5 with the knowledge that the material would remain present in

Mode 4 and Mode 3 and an engineering evaluation had not been performed. Because

this violation was of very low safety significance and was captured in the licensees

corrective action program (IR 835427), it is being treated as a NCV consistent with

Section VI.A.1 of the NRC Enforcement Policy. (NCV 05000455/2008005-01)

The inspectors determined that the licensees subsequent failure to promptly correct the

loose debris left inside of containment even though the items had been entered into the

corrective action system was a performance deficiency. Since this violation was

licensee-identified, the enforcement aspect and its safety significance are described in

Section 4OA7 of this report.

1R22 Surveillance Testing (71111.22)

.1 Routine Surveillance Testing

a. Inspection Scope

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

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

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

and TS requirements:

Unit 2 Train B Diesel Generator 18-month Safety Injection Signal Override Test;

Unit 2 Train B Auxiliary Feedwater Valve Verification Test;

Unit 2 Train A Diesel Generator Operability Surveillance; and

Unit 2 Train B Auxiliary Feedwater Pump Monthly Surveillance.

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

records to determine the following:

did preconditioning occur;

were the effects of the testing adequately addressed by control room personnel

or engineers prior to the commencement of the testing;

were acceptance criteria clearly stated, demonstrated operational readiness, and

consistent with the system design basis;

plant equipment calibration was correct, accurate, and properly documented;

as-left setpoints were within required ranges; and the calibration frequency were

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

measuring and test equipment calibration was current;

test equipment was used within the required range and accuracy; applicable

prerequisites described in the test procedures were satisfied;

15 Enclosure

test frequencies met TS requirements to demonstrate operability and reliability;

tests were performed in accordance with the test procedures and other

applicable procedures; jumpers and lifted leads were controlled and restored

where used;

test data and results were accurate, complete, within limits, and valid;

test equipment was removed after testing;

where applicable for inservice testing activities, testing was performed in

accordance with the applicable version of Section XI, American Society of

Mechanical Engineers code, and reference values were consistent with the

system design basis;

where applicable, test results not meeting acceptance criteria were addressed

with an adequate operability evaluation or the system or component was

declared inoperable;

where applicable for safety-related instrument control surveillance tests,

reference setting data were accurately incorporated in the test procedure;

where applicable, actual conditions encountering high resistance electrical

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

prior procedure changes had not provided an opportunity to identify problems

encountered during the performance of the surveillance or calibration test;

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

performance of its safety functions; and

all problems identified during the testing were appropriately documented and

dispositioned in the CAP.

Documents reviewed are listed in the Attachment to this report.

This inspection constituted four routine surveillance testing samples, as defined in

IP 71111.22, Section -05.

b. Findings

No findings of significance were identified.

.2 Inservice Testing (IST) Surveillance

a. Inspection Scope

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

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

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

and TS requirements:

Unit 2 Charging/Safety Injection System Flow Balance; and

Unit 2 Reactor Coolant System Pressure Isolation Valve and Cold Leg Injection

Isolation Valve Leakage Surveillance.

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

records to determine whether: any preconditioning occurred; effects of the testing were

adequately addressed by control room personnel or engineers prior to the

commencement of the testing; acceptance criteria were clearly stated, demonstrated

16 Enclosure

operational readiness, and were consistent with the system design basis; plant

equipment calibration was correct, accurate, and properly documented; as left setpoints

were within required ranges; and the calibration frequency were in accordance with TSs,

the UFSAR, procedures, and applicable commitments; measuring and test equipment

calibration was current; test equipment was used within the required range and

accuracy; applicable prerequisites described in the test procedures were satisfied; test

frequencies met TS requirements to demonstrate operability and reliability; tests were

performed in accordance with the test procedures and other applicable procedures;

jumpers and lifted leads were controlled and restored where used; test data and results

were accurate, complete, within limits, and valid; test equipment was removed after

testing; where applicable for inservice testing activities, testing was performed in

accordance with the applicable version of Section XI, American Society of Mechanical

Engineers Code, and reference values were consistent with the system design basis;

where applicable, test results not meeting acceptance criteria were addressed with an

adequate operability evaluation or the system or component was declared inoperable;

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

setting data were accurately incorporated in the test procedure; where applicable, actual

conditions encountering high resistance electrical contacts were such that the intended

safety function could still be accomplished; prior procedure changes had not provided an

opportunity to identify problems encountered during the performance of the surveillance

or calibration test; equipment was returned to a position or status required to support the

performance of its safety functions; and all problems identified during the testing were

appropriately documented and dispositioned in the corrective action program.

Documents reviewed are listed in the Attachment.

This inspection constituted two inservice inspection samples as defined in Inspection

Procedure 71111.22.

b. Findings

No findings of significance were identified.

.3 Containment Isolation Valve Testing

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

the risk-significant system and equipment were capable of performing their intended

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

procedural and TS requirements:

Local Leak Rate Test for Containment Isolation Valve 1RY8028.