IR 05000254/2019003

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Integrated Inspection Report 05000254/2019003 and 05000265/2019003
ML19304B518
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 10/31/2019
From: Kenneth Riemer
NRC/RGN-III
To: Bryan Hanson
Exelon Generation Co
References
IR 2019003
Download: ML19304B518 (16)
v • d • e


Text

{{#Wiki_filter:ber 31, 2019

SUBJECT:

QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000254/2019003 AND 05000265/2019003

Dear Mr. Hanson:

On September 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Quad Cities Nuclear Power Station, Units 1 and 2. On October 1, 2019, the NRC inspectors discussed the results of this inspection with Mr. P. Boyle, Acting Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.

No NRC-identified or self-revealing findings were identified during this inspection.

A licensee-identified violation which was determined to be of very low safety significance is documented in this report. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, /RA/ Kenneth R. Riemer, Chief Branch 1 Division of Reactor Projects Docket Nos. 05000254 and 05000265 License Nos. DPR-29 and DPR-30

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000254 and 05000265 License Numbers: DPR-29 and DPR-30 Report Numbers: 05000254/2019003 and 05000265/2019003 Enterprise Identifier: I-2019-003-0061 Licensee: Exelon Generation Company, LLC Facility: Quad Cities Nuclear Power Station, Units 1 and 2 Location: Cordova, IL Inspection Dates: July 01, 2019 to September 30, 2019 Inspectors: J. Cassidy, Senior Health Physicist M. Garza, Emergency Preparedness Inspector C. Mathews, Illinois Emergency Management Agency R. Murray, Senior Resident Inspector C. Norton, Senior Resident Inspector D. Tesar, Resident Inspector Approved By: Kenneth R. Riemer, Chief Branch 1 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Quad Cities Nuclear Power Station, Units 1 and 2 in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

A licensee-identified non-cited violation is documented in report section: 71124.05.

List of Findings and Violations No findings or violations of more than minor significance were identified.

Additional Tracking Items None.

PLANT STATUS

Unit 1 The unit began the inspection period at full rated thermal power, where it remained until August 25, 2019, with the exception of short term power reductions as requested by the transmission system operator. On August 25, 2019, the unit experienced an automatic SCRAM following the actuation of the Unit 1 main generator ground fault detection relay. The licensee entered Mode 2 on August 29, 2019, and commenced startup. The unit entered Mode 1 on August 30, 2019.

Following replacement of several insulators on the 'A' phase of the isophase bus duct leading to the unit auxiliary transformer, the licensee synchronized to the grid and achieved full power on September 1, 2019. The unit remained at or near full power for the remainder of the inspection period.

Unit 2 The unit began the inspection period at full rated thermal power, where it remained for the entire inspection period, with the exception of short term power reductions as requested by the transmission system operator.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71111.01 - Adverse Weather Protection Impending Severe Weather Sample (IP Section 03.03)

Main article: IP 71111.01
(1) The inspectors evaluated readiness for impending adverse weather conditions for extreme hot temperatures expected for the week of July 15, 2019.

71111.04Q - Equipment Alignment Partial Walkdown Sample (IP Section 03.01)

Main article: IP 71111.04Q

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Unit 2 emergency diesel generator during 1/2 emergency diesel generator surveillance test on July 22, 2019
(2) Unit 1/2 and Unit 2 emergency diesel generator during extended maintenance on Unit 1 emergency diesel generator on September 9, 2019
(3) Unit 2A, 'B', and 'D' residual heat removal service water loops during planned maintenance on Unit 2C residual heat removal service water loop on September 17, 2019

71111.04S - Equipment Alignment Complete Walkdown Sample (IP Section 03.02)

Main article: IP 71111.04S
(1) The inspectors evaluated system configurations during a complete walkdown of the Unit 1/2 emergency diesel generator and Unit 2 emergency diesel generator during residual heat removal outage on June 16, 2019.
(2) The inspectors evaluated system configurations during a complete walkdown of the Unit 1 standby liquid control system following air sparge for chemistry sample on August 1, 2019.

71111.05Q - Fire Protection Quarterly Inspection (IP Section 03.01)

Main article: IP 71111.05Q

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Fire Zone 8.2.6.E; Unit 2 turbine building, elevation 595'-0", hallway on June 25, 2019
(2) Fire Zones 8.2.7.A, 6.1.A, 6.1.B, and 7.1; Unit 2 turbine building, elevation 615' and 628', battery charger rooms, hydrogen seal oil areas, and battery room on September 17, 2019
(3) Fire Zones 8.2.7.E, 6.2.A, 6.2.B, and 7.2; Unit 1 turbine building, elevation 615' and 628', battery charger rooms, hydrogen seal oil areas, and battery room on September 18, 2019
(4) Fire Zone 11.2.1; Unit 1 reactor building, elevation 554'-0", southwest corner room, 1B core spray on September 19, 2019
(5) Fire Zone 11.2.3; Unit 1 reactor building, elevation 554'-0", northwest corner room, 1A core spray on September 19, 2019

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

Main article: IP 71111.11Q
(1) The inspectors observed and evaluated licensed operator performance in the control room during the Unit 1 startup from Forced Outage Q1F67 on August 29, 2019.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated cycle 5 training on September 23, 2019.

71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01)

Main article: IP 71111.13

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) work week risk and impending extreme hot temperatures for week of July 15, 2019
(2) emergent work and operational risk activity for the failure of the Unit 2 250 Vdc battery charger on July 30, 2019
(3) emergent work and work week risk following Unit 1 SCRAM and ground on Unit 1 main generator on August 26, 2019
(4) work week risk during week of September 9, 2019 (Unit 1 emergency diesel generator work risk)

==71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 02.02) (3 Samples 2 Partials) The inspectors evaluated the following operability determinations and functionality assessments: 

  (1)     (Partial)

Issue Report 4254547, Unit 1 HPCI [high pressure coolant injection] Did Not Trip Locally During QCOS 2300-13 on June 5, 2019

(2) Issue Report 4263259, Unit 2 DWEDS [drywell equipment drain sump pump] Level Switch Issues Prevent Accurate Trending on July 9, 2019
(3) Issue Report 4267234, Failure of [Unit]1B 24/48 Volt Battery Charger on July 11, 2019
(4) Issue Report 4267593, Received 902-10 A10, [Unit 2] 250V Battery Charger 2 Trip, on July 29, 2019 (5) (Partial)

Issue Report 4278317, [Unit] 2A RHRSW [residual heat removal service water] Vault Door Found Not Dogged Closed with Unit 1 EDG [emergency diesel generator] OOS 

          [out-of-service] for Maintenance on September 12, 2019

71111.19 - Post-Maintenance Testing Post-Maintenance Test Sample (IP Section 03.01)

Main article: [[=

=IP 71111.15|count=4}}

The inspectors evaluated the following post maintenance tests:

(1) QCOS 1000-4, Unit 1 Residual Heat Removal Service Water Pump Operability Test on July 25, 2019
(2) Work Order 4945512, Unit 2 250 Vdc Battery Charger #2 Trip Alarm 902-8 A10 (2-8350) on July 30, 2019
(3) testing and synchronization to the grid following repairs to the Unit 1A phase of the isophase bus on August 31, 2019
(4) Unit 2C residual heat removal service water post-maintenance testing following discharge elbow replacement on September 16, 2019

71111.20 - Refueling and Other Outage Activities Refueling/Other Outage Sample (IP Section 03.01)

Main article: IP 71111.20
(1) The inspectors evaluated Forced Outage Q1F67 from Unit 1 reactor SCRAM due to generator ground fault on August 28, 2019.

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Surveillance Tests (other) (IP Section 03.01)

Main article: IP 71111.22
(1) QCOS 6620-01, [Unit 1] SBO [station blackout] DG [diesel generator] Quarterly Load Test on July 29, 2019
(2) QCOS 1100-07, [Unit 1A] SBLC [standby liquid control] Pump Flow Rate Test on

July 22, 2019 Inservice Testing (IP Section 03.01) (2 Samples)

(1) QCOS 1000-31, [Unit 1A] RHR [residual heat removal] Logic Test on May 22, 2019
(2) QCOS 2300-06, [Unit 2] HPCI System Air Operated Valve Test on July 30, 2019

71114.04 - Emergency Action Level and Emergency Plan Changes Inspection Review (IP Section 02.01-02.03)

Main article: IP 71114.04
(1) The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes:
  • Evaluation 18-45, Exelon Nuclear Standardized Radiological Emergency Plan, Revision 30 This evaluation does not constitute NRC approval.

RADIATION SAFETY

71124.05 - Radiation Monitoring Instrumentation Walk Downs and Observations (IP Section 02.01)

Main article: IP 71124.05

The inspectors evaluated radiation monitoring instrumentation during plant walkdowns.

(1) The inspectors reviewed the following:

Portable Survey Instruments

  • RO20 - 0014095
  • RO20 - 0020433
  • RO20 - 0018385
  • RO20 - 0014093
  • RO20 - 0012237
  • RAMGAM - 0010619
  • Model 3 - 0020028
  • Model 3 - 0021709
  • Telepole - 00141189 Source Check Demonstration
  • RO20 - 0014095
  • RO20 - 0020433
  • Model 3 - 0021709
  • Telepole - 00141189 Area Radiation Monitors and Continuous Air Monitors
  • Area Radiation Monitor, Low Range, Unit 1 Refuel Floor, 690'
  • Area Radiation Monitor, High Range, Unit 1 Refuel Floor, 690'
  • Area Radiation Monitor, Low Range, Unit 2 Refuel Floor, 690'
  • Area Radiation Monitor, High Range, Unit 2 Refuel Floor, 690'
  • Area Radiation Monitor, Low Range, Unit 1 Spent Fuel Pool, 690'
  • Area Radiation Monitor, High Range, Unit 1 Spent Fuel Pool, 690'
  • Area Radiation Monitor, Low Range, Unit 2 Spent Fuel Pool, 690'
  • Area Radiation Monitor, High Range, Unit 2 Spent Fuel Pool, 690'
  • Area Radiation Monitor, Outside Unit TIP Room, 595'
  • Continuous Air Monitor, Unit 1 Refuel Floor, 690
  • Continuous Air Monitor, Unit 1 13-Line, 595' Personnel Contamination Monitors, Portal Monitors and Small Article Monitors
  • IPM 9, Instrument Number I350
  • SAM 12, Instrument Number 12205
  • PM 12, Instrument Number 12047
  • SAM 11, Instrument Number LAM1

Calibration and Testing Program (IP Section 02.02) (1 Sample)

The inspectors evaluated the calibration and testing program implementation.

(1) The inspectors reviewed the following:

Alarm Setpoint and Calibration Method Check of Personnel Contamination Monitors, Portal Monitors and Small Article Monitors

  • PM 9, Instrument Number I350
  • SAM 12, Instrument Number 12205
  • PM 12, Instrument Number 12047 Failure to Meet Calibration or Source Check Acceptance Criteria
  • RO20 - 0018385
  • RO20 - 0014093
  • RO20 -

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below: MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) ===

Main article: IP 71151
(1) Unit 1 (07/01/2018 - 06/30/2019)
(2) Unit 2 (07/01/2018 - 06/30/2019)

MS06: Emergency AC Power Systems (IP Section 02.05) (2 Samples)

(1) Unit 1 (07/01/2018 - 06/30/2019)
(2) Unit 2 (07/01/2018 - 06/30/2019)

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues (IP Section 02.03)

Main article: IP 71152

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Issue Report (IR) 4238831, [Unit] 1C RHRSW High Pressure Outboard Seal Leak During Run

71153 - Follow-up of Events and Notices of Enforcement Discretion Event Follow-up (IP Section 03.01)

Main article: IP 71153
(1) Unit 1 reactor SCRAM event follow-up activities on August 25,

INSPECTION RESULTS

Licensee-Identified Non-Cited Violation 71124.05 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: Technical Specification 5.5.1 states, in part, that the Offsite Dose Calculation Manual shall be established, implemented, and maintained.

Section 12.2.1, Radioactive Liquid Effluent Monitoring Instrumentation, of the Offsite Dose Calculation Manual (Revision 13) includes Radiological Effluent Surveillance Requirement 12.2.1.3, which requires channel functional tests of the Unit 1 and Unit 2 service water effluent gross activity monitors to be performed on a 92 day frequency.

Contrary to the above, between December 19, 2018 and August 6, 2019, the licensee failed to implement radiological effluent surveillance requirements contained within the Offsite Dose Calculation Manual. Specifically, the licensee did not perform channel functional tests on Unit 1 or Unit 2 service water effluent gross activity monitors.

Significance/Severity: Green. The finding was determined to be of very low safety significance (Green) because the issue involved a radioactive effluent release, but did not: (1)represent a substantial failure to implement the radioactive effluent release program; or (2)result in public exposure that exceeded the dose values in Appendix I to 10 CFR Part 50 and/or 10 CFR 20.1301(e) limits.

Corrective Action References: Issue Report 4268906 Observation: 1C Residual Heat Removal Service Water Outboard Seal Leak 71152 The inspectors reviewed Issue Report 4238831, 1C RHRSW High Pressure Outboard Seal Leak During Run, dated April 12, 2019. The condition report documented a large amount of water leaking and spraying from the outboard seal of the 1C residual heat removal service water pump shortly after pump start in support of a surveillance test. Once the report was received in the control room, operators secured the pump. The licensee declared the pump inoperable and entered the appropriate Technical Specification. After the pump was secured, operators reported that the seal was continuing to leak approximately 3 gallons per minute.

The licensee had been tracking the leaking seal on this pump since it was first reported on March 18, 2019, which was documented in Issue Report 4230672, 1C RHRSW HP [high pressure] O/B [outboard] Seal Leaking. Following the seal leak identified in Issue Report 4230672, the licensee determined that seal replacement would be required, and planned the repair for a future residual heat removal work window. The licensee completed all necessary repairs on April 15, 2019, and the pump was restored to an operable status. The inspectors determined that the licensee's corrective action for this issue was appropriate and in accordance with the significance of the issue. The licensee identified that the cause of the seal failure was inadequate pump seal cooling water flow due to a small pebble getting stuck in a flow-restricting orifice, which blocked flow in the seal cooling line. The inspectors reviewed the licensees responses to Issue Reports 4230672 and 4238831, the design of the RHRSW system, prior RHRSW bay inspections, and internal operating experience. The inspectors determined that the cause of the pump failure and seal leak was not within the licensee's ability to foresee and correct, and no performance deficiency was identified.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

  • On October 1, 2019, the inspectors presented the integrated inspection results to Mr. P. Boyle, Acting Plant Manager, and other members of the licensee staff.
  • On September 20, 2019, the inspectors presented the radiation protection inspection results inspection results to Mr. K. Ohr, Site Vice President, and other members of the licensee staff.
  • On October 3, 2019, the inspectors presented the Exit Meeting for EP Inspection per IP 71114, Attachment inspection results to Mr. L. Baker, EP Fleet Programs Manager and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or Procedure Date 71111.04Q Procedures QCOP 1000-04 RHR Service Water System Operation 22 QCOP 6600-04 Diesel Generator 1/2 Preparation for Standby Operation 34 QCOP 6600-24 Unit 2 Diesel Generator Preparation for Standby Operation 3 71111.04S Corrective Action IR 4025834 Replace Unit 1 SBLC Heat Trace and Insulation 06/26/2017 Documents Procedures M-40 Diagram of Standby Liquid Control Piping QOM 1-1100-01 Unit 1 Standby Liquid Control Valve Checklist 10 Work Orders WO 4657736 EM Replace/Upgrade 1-1101 U1 SBLC Heat Trace & 09/06/2018 Insulation 71111.05Q Fire Plans FZ 11.2.1 Unit 1 RB 554'-0 Elev. SW Corner Room - 1B Core Spray July 2009 FZ 11.2.3 Unit 1 RB 554'-0 Elev. NW Corner Room - 1A Core Spray November 2011 FZ 6.1.A Unit 1 TB 615'-6 Elev. 'A' Battery Charger Room U-1 October 2013 FZ 6.1.B Unit 1 TB 615'-6 Elev. 'B' Battery Charger Room U-1 October 2013 FZ 6.2.A Unit 2 TB 615'-6 Elev. 'A' Battery Charger Room U-2 July 2009 FZ 6.2.B Unit 2 TB 615'-6 Elev. 'B' Battery Charger Room U-2 October 2013 FZ 7.1 Unit 1 TB 628'-6 Elev. 250V Battery Room October 2013 FZ 7.2 Unit 2 TB 628'-6 Elev. 250V Battery Room July 2009 FZ 8.2.6.E Unit 2 TB 595'-0 Elev. Hallway November 2018 FZ 8.2.7.A Unit 1 TB 615'-6 Elev. Hydrogen Seal Oil Area and MCC's October 2015 FZ 8.2.7.E Unit 2 TB 615'-6 Elev. North Mezzanine Floor November 2018 71111.12 Miscellaneous Unavailability July 2018 - Report June 2019 71111.13 Corrective Action IR 4267593 Received 902-10 A10, 250V Battery Charger 2 Trip 07/28/2019 Documents IR 4268103 250 Vdc Drawing Enhancement 07/30/2019 Inspection Type Designation Description or Title Revision or Procedure Date IR 4268124 250 Vdc Charger Require Updates 07/30/2019 71111.15 Corrective Action IR 4262214 7/6/19 DWEDS Pumping had Step Change in Total Gallons 07/06/2019 Documents Pumped IR 4262426 U2 DWED Sump Level Switch Fails to Stop 2A Pump at Low 07/07/2019 Level IR 4263259 U2 DWEDS Level Switch Issues Prevent Accurate Trending 07/11/2019 IR 4263286 EO ID: Water Leak from 0-2007-22 AOV FDF Backwash 07/11/2019 Inlet IR 4264763 NRC ID: U2 DWFDS Leakage Increase Above NRC 07/17/2019 Threshold IR 4267593 Received 902-10 A10, 250V Battery Charger 2 Trip 07/28/2019 Drawings Drawing 4E-1319 Key Diagram and Elevations 48-24 Vdc Distribution Centers N Miscellaneous Alarm 902-8 A10 250V Battery Charger 2 Trip OP-AA-108-111 Adverse Condition Monitoring and Contingency Plan 07/18/2019 

                                            (ACMP) U2 Drywell Equipment Drain Sump (DWEDS) Pump

Degraded Flow (Rev. 1) Procedures QOM 1-6300-T01 48/24 Vdc Distribution Panel + 1A Bus 4E-1319 4 QOM 1-6300-T02 48/24 Vdc Distribution Panel + 1B Bus 4E-1319 5 UFSAR Table Drywell Equipment Drain Sump Sources for Radioactive 11.1-4 Material 71111.19 Procedures QCOS 1000-04 RHR Service Water Pump Operability Test 63 Work Orders WO 4916933 QCOS 1000-4 'A' RHR Serv Wtr Pump Flow Group 'A' Test 07/23/2019 

                                            (IST)

WO 4916934 QCOS 1000-6 'A' RHR Pump Flow Rate Group 'A' Test (IST) 07/23/2019 WO 4916935 QCOS 1000-6 'B' RHR Pump Flow Rate Group 'A' Test (IST) 07/23/2019 WO 4916936 QCOS 1000-4 'B' RHR Serv Wtr Pump Flow Group 'A' Test 07/23/2019 

                                            (IST)

WO 4916937 QCOS 1000-06 'A' Loop LPCI Mode RHR Flow Rate 07/23/2019 WO 4945512 250 Vdc Battery Charger 2 Trip Alarm 902-8 A10 (2-8350) 07/30/2019 71111.20 Corrective Action IR 4274286 U-1 Reactor Scram Gen Trip from Ground Relay (GIX 104) 08/25/2019 Documents 71111.22 Procedures ER-AA-310 Maintenance Rule 12 OP-AA-108-115 Operability Determinations 22 Inspection Type Designation Description or Title Revision or Procedure Date QCOS 1100-07 SBLC Pump Flow Rate Test 38 QCOS 2300-06 HPCI System Air Operated Valve Test 44 QCOS 6620-01 SBO DG 1(2) Quarterly Load Test 54 WC-AA-101 On-line Work Control Process 28 WC-AA-101-1006 On-line Risk Management and Assessment 2 Work Orders WO 4916523-01 HPCI Valve Timing Test (IST) 0 WO 4918552-01 SBO Load Test 0 71114.04 Miscellaneous Evaluation 18-45 Exelon Nuclear Standardized Radiological Emergency Plan, 02/14/2019 Revision 30 71124.05 Calibration Certificate Certificate of Calibration RO20AA 02/14/2019 Records #0011135270 Certificate Certificate of Calibration Model 3 11/29/2018 

                            #0011138654

Certificate Certificate of Calibration Model 3 02/01/2019 

                            #0011150060

Certificate Certificate of Calibration RAM GAM 1 05/28/2019 

                            #0011173293

Certificate Certificate of Calibration BAK-2270 08/19/2019 

                            #0011173354

Certificate Certificate of Calibration RO-20AA 02/26/2019 

                            #001153485

RP-AA-232-1001 ACCUSCAN II Calibration Acceptance Criteria 07/25/2018 RP-AA-232-1001 Calibration Acceptance Criteria FASTSCAN 07/24/2018 RP-AA-700-1210 IPM Calibration Data Sheet #I350 10/24/2018 RP-AA-700-1235 PM-12 Calibration Data Sheet #12047 08/30/2019 RP-AA-700-1239 SAM-12 Calibration Data Sheet #12205 12/18/2018 Corrective Action AR 04157428 Out of Tolerance Instrumentation During Calibration 07/20/2018 Documents AR 04207695 Out of Tolerance Instrumentation During Calibration 01/03/2019 AR 04264231 Instruments Not Marked Information Only As Required 07/15/2019 Inspection Type Designation Description or Title Revision or Procedure Date AR 04268906 Request Re-establish SWRM Channel Functional Test 08/01/2019 Frequency to 92 Days Corrective Action AR 04280816 Portable Instrument Source Check Acceptance Criteria 09/19/2019 Documents Exceeds Range of Scale Resulting from AR 04280821 Portable Instrument Source Check Acceptance Criteria 09/19/2019 Inspection Significant Figure Issue Miscellaneous C&C Irradiator Service LLC; Dose vs. Distance Curves 07/17/2019 Ref No S125722 Radcal Corporation Service Report 04/15/2019 Procedures CY-AA-130-201 Radiochemistry Quality Control 7 RP-AA-232-1001 Calibration Verification of Whole Body Counting Systems 1 Using APEX In-Vivo RP-AA-700-1208 Irradiator Reference Data Sheet 07/17/2019 RP-AA-700-1210 Operation and Calibration of IPM Whole Body Frisking 2 Monitor RP-AA-700-1235 Operation and Calibration of the PM-12 Gamma Portal 5 Monitor RP-AA-700-1239 Operation and Calibration of the Model SAM-12 Small 5 Articles Monitor Self-Assessments AR 4207564 NRC: Rad Protection - Rad Monitoring Instrumentation 07/16/2019 Inspection Work Orders 01949080-01 QCIS 2400-05 Division II Rad Monitor Calibration/Functional 04/19/2018 Test 71152 Corrective Action ACE 1C Residual Heat Removal Service Water (RHRSW) High Documents Pressure Pump Outboard (OB) Seal Failure IR 4161140 1C RHRSW HP Pump O/B Seal Has Increased 08/02/2018 IR 4230672 EO ID: 1C RHRSW HP O/B Seal Leaking 03/18/2019 IR 4232246 EO ID: 1C RHRSW HP O/B Seal Leaking (Leak Template 03/18/2019 IR) IR 4234945 EOID: 1C RHRSW High Pressure Pump Outboard Seal 03/31/2019 Leak Increase IR 4238831 1C RHRSW High Pressure Pump OB Seal Leak During Run 04/12/2019 IR 4254019 Pump Failed to Start During QCOS 1000-04 06/03/2019 IR 4272141 Eold - 1C RHRSW High Pressure Pump Inboard Seal Leak 08/15/2019 Inspection Type Designation Description or Title Revision or Procedure Date IR 4272309 1C RHRSW HP Pump 1B Seal Leak Follow-up to IR 08/15/2019 272141 IR 490375 PSU Q1M19 1C RHRSW Pump Seal Leak 05/16/2006 IR 580419 Gap Below RHRSW Separation Screen 01/18/2007 Drawings Drawing B-35 Crib House Plan El. 595'-0 South Area P Drawing B-36 Crib House Plan El. 595'-0 North Area N Drawing B-37 Crib House Plan El. 559'-8 F Drawing M-11 General Arrangement Crib House E Drawing M-79, Diagram of RHR Service Water Piping BJ Sheet 1 Miscellaneous UCC Job #02-14- RHR Service Water Bay Inspection Report 02/07/2018 233.296 Letter UCC Job #02-14- RHR Service Water Bay Inspection Report 08/07/2018 233.327 Letter UCC Job #02-14- RHR Service Water Bay Inspection Report 02/07/2019 233.367 71153 Corrective Action IR 4274286 U-1 Reactor Scram Gen Trip from Ground Relay (GIX 104) 08/25/2019 Documents 14|= =IP 71111.15|count=4}}

The inspectors evaluated the following post maintenance tests:

(1) QCOS 1000-4, Unit 1 Residual Heat Removal Service Water Pump Operability Test on July 25, 2019
(2) Work Order 4945512, Unit 2 250 Vdc Battery Charger #2 Trip Alarm 902-8 A10 (2-8350) on July 30, 2019
(3) testing and synchronization to the grid following repairs to the Unit 1A phase of the isophase bus on August 31, 2019
(4) Unit 2C residual heat removal service water post-maintenance testing following discharge elbow replacement on September 16, 2019

71111.20 - Refueling and Other Outage Activities Refueling/Other Outage Sample (IP Section 03.01)

Main article: IP 71111.20
(1) The inspectors evaluated Forced Outage Q1F67 from Unit 1 reactor SCRAM due to generator ground fault on August 28, 2019.

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Surveillance Tests (other) (IP Section 03.01)

Main article: IP 71111.22
(1) QCOS 6620-01, [Unit 1] SBO [station blackout] DG [diesel generator] Quarterly Load Test on July 29, 2019
(2) QCOS 1100-07, [Unit 1A] SBLC [standby liquid control] Pump Flow Rate Test on

July 22, 2019 Inservice Testing (IP Section 03.01) (2 Samples)

(1) QCOS 1000-31, [Unit 1A] RHR [residual heat removal] Logic Test on May 22, 2019
(2) QCOS 2300-06, [Unit 2] HPCI System Air Operated Valve Test on July 30, 2019

71114.04 - Emergency Action Level and Emergency Plan Changes Inspection Review (IP Section 02.01-02.03)

Main article: IP 71114.04
(1) The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes:
  • Evaluation 18-45, Exelon Nuclear Standardized Radiological Emergency Plan, Revision 30 This evaluation does not constitute NRC approval.

RADIATION SAFETY

71124.05 - Radiation Monitoring Instrumentation Walk Downs and Observations (IP Section 02.01)

Main article: IP 71124.05

The inspectors evaluated radiation monitoring instrumentation during plant walkdowns.

(1) The inspectors reviewed the following:

Portable Survey Instruments

  • RO20 - 0014095
  • RO20 - 0020433
  • RO20 - 0018385
  • RO20 - 0014093
  • RO20 - 0012237
  • RAMGAM - 0010619
  • Model 3 - 0020028
  • Model 3 - 0021709
  • Telepole - 00141189 Source Check Demonstration
  • RO20 - 0014095
  • RO20 - 0020433
  • Model 3 - 0021709
  • Telepole - 00141189 Area Radiation Monitors and Continuous Air Monitors
  • Area Radiation Monitor, Low Range, Unit 1 Refuel Floor, 690'
  • Area Radiation Monitor, High Range, Unit 1 Refuel Floor, 690'
  • Area Radiation Monitor, Low Range, Unit 2 Refuel Floor, 690'
  • Area Radiation Monitor, High Range, Unit 2 Refuel Floor, 690'
  • Area Radiation Monitor, Low Range, Unit 1 Spent Fuel Pool, 690'
  • Area Radiation Monitor, High Range, Unit 1 Spent Fuel Pool, 690'
  • Area Radiation Monitor, Low Range, Unit 2 Spent Fuel Pool, 690'
  • Area Radiation Monitor, High Range, Unit 2 Spent Fuel Pool, 690'
  • Area Radiation Monitor, Outside Unit TIP Room, 595'
  • Continuous Air Monitor, Unit 1 Refuel Floor, 690
  • Continuous Air Monitor, Unit 1 13-Line, 595' Personnel Contamination Monitors, Portal Monitors and Small Article Monitors
  • IPM 9, Instrument Number I350
  • SAM 12, Instrument Number 12205
  • PM 12, Instrument Number 12047
  • SAM 11, Instrument Number LAM1

Calibration and Testing Program (IP Section 02.02) (1 Sample)

The inspectors evaluated the calibration and testing program implementation.

(1) The inspectors reviewed the following:

Alarm Setpoint and Calibration Method Check of Personnel Contamination Monitors, Portal Monitors and Small Article Monitors

  • PM 9, Instrument Number I350
  • SAM 12, Instrument Number 12205
  • PM 12, Instrument Number 12047 Failure to Meet Calibration or Source Check Acceptance Criteria
  • RO20 - 0018385
  • RO20 - 0014093
  • RO20 -

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below: MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) ===

Main article: IP 71151
(1) Unit 1 (07/01/2018 - 06/30/2019)
(2) Unit 2 (07/01/2018 - 06/30/2019)

MS06: Emergency AC Power Systems (IP Section 02.05) (2 Samples)

(1) Unit 1 (07/01/2018 - 06/30/2019)
(2) Unit 2 (07/01/2018 - 06/30/2019)

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues (IP Section 02.03)

Main article: IP 71152

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Issue Report (IR) 4238831, [Unit] 1C RHRSW High Pressure Outboard Seal Leak During Run

71153 - Follow-up of Events and Notices of Enforcement Discretion Event Follow-up (IP Section 03.01)

Main article: IP 71153
(1) Unit 1 reactor SCRAM event follow-up activities on August 25,

INSPECTION RESULTS

Licensee-Identified Non-Cited Violation 71124.05 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: Technical Specification 5.5.1 states, in part, that the Offsite Dose Calculation Manual shall be established, implemented, and maintained.

Section 12.2.1, Radioactive Liquid Effluent Monitoring Instrumentation, of the Offsite Dose Calculation Manual (Revision 13) includes Radiological Effluent Surveillance Requirement 12.2.1.3, which requires channel functional tests of the Unit 1 and Unit 2 service water effluent gross activity monitors to be performed on a 92 day frequency.

Contrary to the above, between December 19, 2018 and August 6, 2019, the licensee failed to implement radiological effluent surveillance requirements contained within the Offsite Dose Calculation Manual. Specifically, the licensee did not perform channel functional tests on Unit 1 or Unit 2 service water effluent gross activity monitors.

Significance/Severity: Green. The finding was determined to be of very low safety significance (Green) because the issue involved a radioactive effluent release, but did not: (1)represent a substantial failure to implement the radioactive effluent release program; or (2)result in public exposure that exceeded the dose values in Appendix I to 10 CFR Part 50 and/or 10 CFR 20.1301(e) limits.

Corrective Action References: Issue Report 4268906 Observation: 1C Residual Heat Removal Service Water Outboard Seal Leak 71152 The inspectors reviewed Issue Report 4238831, 1C RHRSW High Pressure Outboard Seal Leak During Run, dated April 12, 2019. The condition report documented a large amount of water leaking and spraying from the outboard seal of the 1C residual heat removal service water pump shortly after pump start in support of a surveillance test. Once the report was received in the control room, operators secured the pump. The licensee declared the pump inoperable and entered the appropriate Technical Specification. After the pump was secured, operators reported that the seal was continuing to leak approximately 3 gallons per minute.

The licensee had been tracking the leaking seal on this pump since it was first reported on March 18, 2019, which was documented in Issue Report 4230672, 1C RHRSW HP [high pressure] O/B [outboard] Seal Leaking. Following the seal leak identified in Issue Report 4230672, the licensee determined that seal replacement would be required, and planned the repair for a future residual heat removal work window. The licensee completed all necessary repairs on April 15, 2019, and the pump was restored to an operable status. The inspectors determined that the licensee's corrective action for this issue was appropriate and in accordance with the significance of the issue. The licensee identified that the cause of the seal failure was inadequate pump seal cooling water flow due to a small pebble getting stuck in a flow-restricting orifice, which blocked flow in the seal cooling line. The inspectors reviewed the licensees responses to Issue Reports 4230672 and 4238831, the design of the RHRSW system, prior RHRSW bay inspections, and internal operating experience. The inspectors determined that the cause of the pump failure and seal leak was not within the licensee's ability to foresee and correct, and no performance deficiency was identified.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

  • On October 1, 2019, the inspectors presented the integrated inspection results to Mr. P. Boyle, Acting Plant Manager, and other members of the licensee staff.
  • On September 20, 2019, the inspectors presented the radiation protection inspection results inspection results to Mr. K. Ohr, Site Vice President, and other members of the licensee staff.
  • On October 3, 2019, the inspectors presented the Exit Meeting for EP Inspection per IP 71114, Attachment inspection results to Mr. L. Baker, EP Fleet Programs Manager and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or Procedure Date 71111.04Q Procedures QCOP 1000-04 RHR Service Water System Operation 22 QCOP 6600-04 Diesel Generator 1/2 Preparation for Standby Operation 34 QCOP 6600-24 Unit 2 Diesel Generator Preparation for Standby Operation 3 71111.04S Corrective Action IR 4025834 Replace Unit 1 SBLC Heat Trace and Insulation 06/26/2017 Documents Procedures M-40 Diagram of Standby Liquid Control Piping QOM 1-1100-01 Unit 1 Standby Liquid Control Valve Checklist 10 Work Orders WO 4657736 EM Replace/Upgrade 1-1101 U1 SBLC Heat Trace & 09/06/2018 Insulation 71111.05Q Fire Plans FZ 11.2.1 Unit 1 RB 554'-0 Elev. SW Corner Room - 1B Core Spray July 2009 FZ 11.2.3 Unit 1 RB 554'-0 Elev. NW Corner Room - 1A Core Spray November 2011 FZ 6.1.A Unit 1 TB 615'-6 Elev. 'A' Battery Charger Room U-1 October 2013 FZ 6.1.B Unit 1 TB 615'-6 Elev. 'B' Battery Charger Room U-1 October 2013 FZ 6.2.A Unit 2 TB 615'-6 Elev. 'A' Battery Charger Room U-2 July 2009 FZ 6.2.B Unit 2 TB 615'-6 Elev. 'B' Battery Charger Room U-2 October 2013 FZ 7.1 Unit 1 TB 628'-6 Elev. 250V Battery Room October 2013 FZ 7.2 Unit 2 TB 628'-6 Elev. 250V Battery Room July 2009 FZ 8.2.6.E Unit 2 TB 595'-0 Elev. Hallway November 2018 FZ 8.2.7.A Unit 1 TB 615'-6 Elev. Hydrogen Seal Oil Area and MCC's October 2015 FZ 8.2.7.E Unit 2 TB 615'-6 Elev. North Mezzanine Floor November 2018 71111.12 Miscellaneous Unavailability July 2018 - Report June 2019 71111.13 Corrective Action IR 4267593 Received 902-10 A10, 250V Battery Charger 2 Trip 07/28/2019 Documents IR 4268103 250 Vdc Drawing Enhancement 07/30/2019 Inspection Type Designation Description or Title Revision or Procedure Date IR 4268124 250 Vdc Charger Require Updates 07/30/2019 71111.15 Corrective Action IR 4262214 7/6/19 DWEDS Pumping had Step Change in Total Gallons 07/06/2019 Documents Pumped IR 4262426 U2 DWED Sump Level Switch Fails to Stop 2A Pump at Low 07/07/2019 Level IR 4263259 U2 DWEDS Level Switch Issues Prevent Accurate Trending 07/11/2019 IR 4263286 EO ID: Water Leak from 0-2007-22 AOV FDF Backwash 07/11/2019 Inlet IR 4264763 NRC ID: U2 DWFDS Leakage Increase Above NRC 07/17/2019 Threshold IR 4267593 Received 902-10 A10, 250V Battery Charger 2 Trip 07/28/2019 Drawings Drawing 4E-1319 Key Diagram and Elevations 48-24 Vdc Distribution Centers N Miscellaneous Alarm 902-8 A10 250V Battery Charger 2 Trip OP-AA-108-111 Adverse Condition Monitoring and Contingency Plan 07/18/2019 

                                            (ACMP) U2 Drywell Equipment Drain Sump (DWEDS) Pump

Degraded Flow (Rev. 1) Procedures QOM 1-6300-T01 48/24 Vdc Distribution Panel + 1A Bus 4E-1319 4 QOM 1-6300-T02 48/24 Vdc Distribution Panel + 1B Bus 4E-1319 5 UFSAR Table Drywell Equipment Drain Sump Sources for Radioactive 11.1-4 Material 71111.19 Procedures QCOS 1000-04 RHR Service Water Pump Operability Test 63 Work Orders WO 4916933 QCOS 1000-4 'A' RHR Serv Wtr Pump Flow Group 'A' Test 07/23/2019 

                                            (IST)

WO 4916934 QCOS 1000-6 'A' RHR Pump Flow Rate Group 'A' Test (IST) 07/23/2019 WO 4916935 QCOS 1000-6 'B' RHR Pump Flow Rate Group 'A' Test (IST) 07/23/2019 WO 4916936 QCOS 1000-4 'B' RHR Serv Wtr Pump Flow Group 'A' Test 07/23/2019 

                                            (IST)

WO 4916937 QCOS 1000-06 'A' Loop LPCI Mode RHR Flow Rate 07/23/2019 WO 4945512 250 Vdc Battery Charger 2 Trip Alarm 902-8 A10 (2-8350) 07/30/2019 71111.20 Corrective Action IR 4274286 U-1 Reactor Scram Gen Trip from Ground Relay (GIX 104) 08/25/2019 Documents 71111.22 Procedures ER-AA-310 Maintenance Rule 12 OP-AA-108-115 Operability Determinations 22 Inspection Type Designation Description or Title Revision or Procedure Date QCOS 1100-07 SBLC Pump Flow Rate Test 38 QCOS 2300-06 HPCI System Air Operated Valve Test 44 QCOS 6620-01 SBO DG 1(2) Quarterly Load Test 54 WC-AA-101 On-line Work Control Process 28 WC-AA-101-1006 On-line Risk Management and Assessment 2 Work Orders WO 4916523-01 HPCI Valve Timing Test (IST) 0 WO 4918552-01 SBO Load Test 0 71114.04 Miscellaneous Evaluation 18-45 Exelon Nuclear Standardized Radiological Emergency Plan, 02/14/2019 Revision 30 71124.05 Calibration Certificate Certificate of Calibration RO20AA 02/14/2019 Records #0011135270 Certificate Certificate of Calibration Model 3 11/29/2018 

                            #0011138654

Certificate Certificate of Calibration Model 3 02/01/2019 

                            #0011150060

Certificate Certificate of Calibration RAM GAM 1 05/28/2019 

                            #0011173293

Certificate Certificate of Calibration BAK-2270 08/19/2019 

                            #0011173354

Certificate Certificate of Calibration RO-20AA 02/26/2019 

                            #001153485

RP-AA-232-1001 ACCUSCAN II Calibration Acceptance Criteria 07/25/2018 RP-AA-232-1001 Calibration Acceptance Criteria FASTSCAN 07/24/2018 RP-AA-700-1210 IPM Calibration Data Sheet #I350 10/24/2018 RP-AA-700-1235 PM-12 Calibration Data Sheet #12047 08/30/2019 RP-AA-700-1239 SAM-12 Calibration Data Sheet #12205 12/18/2018 Corrective Action AR 04157428 Out of Tolerance Instrumentation During Calibration 07/20/2018 Documents AR 04207695 Out of Tolerance Instrumentation During Calibration 01/03/2019 AR 04264231 Instruments Not Marked Information Only As Required 07/15/2019 Inspection Type Designation Description or Title Revision or Procedure Date AR 04268906 Request Re-establish SWRM Channel Functional Test 08/01/2019 Frequency to 92 Days Corrective Action AR 04280816 Portable Instrument Source Check Acceptance Criteria 09/19/2019 Documents Exceeds Range of Scale Resulting from AR 04280821 Portable Instrument Source Check Acceptance Criteria 09/19/2019 Inspection Significant Figure Issue Miscellaneous C&C Irradiator Service LLC; Dose vs. Distance Curves 07/17/2019 Ref No S125722 Radcal Corporation Service Report 04/15/2019 Procedures CY-AA-130-201 Radiochemistry Quality Control 7 RP-AA-232-1001 Calibration Verification of Whole Body Counting Systems 1 Using APEX In-Vivo RP-AA-700-1208 Irradiator Reference Data Sheet 07/17/2019 RP-AA-700-1210 Operation and Calibration of IPM Whole Body Frisking 2 Monitor RP-AA-700-1235 Operation and Calibration of the PM-12 Gamma Portal 5 Monitor RP-AA-700-1239 Operation and Calibration of the Model SAM-12 Small 5 Articles Monitor Self-Assessments AR 4207564 NRC: Rad Protection - Rad Monitoring Instrumentation 07/16/2019 Inspection Work Orders 01949080-01 QCIS 2400-05 Division II Rad Monitor Calibration/Functional 04/19/2018 Test 71152 Corrective Action ACE 1C Residual Heat Removal Service Water (RHRSW) High Documents Pressure Pump Outboard (OB) Seal Failure IR 4161140 1C RHRSW HP Pump O/B Seal Has Increased 08/02/2018 IR 4230672 EO ID: 1C RHRSW HP O/B Seal Leaking 03/18/2019 IR 4232246 EO ID: 1C RHRSW HP O/B Seal Leaking (Leak Template 03/18/2019 IR) IR 4234945 EOID: 1C RHRSW High Pressure Pump Outboard Seal 03/31/2019 Leak Increase IR 4238831 1C RHRSW High Pressure Pump OB Seal Leak During Run 04/12/2019 IR 4254019 Pump Failed to Start During QCOS 1000-04 06/03/2019 IR 4272141 Eold - 1C RHRSW High Pressure Pump Inboard Seal Leak 08/15/2019 Inspection Type Designation Description or Title Revision or Procedure Date IR 4272309 1C RHRSW HP Pump 1B Seal Leak Follow-up to IR 08/15/2019 272141 IR 490375 PSU Q1M19 1C RHRSW Pump Seal Leak 05/16/2006 IR 580419 Gap Below RHRSW Separation Screen 01/18/2007 Drawings Drawing B-35 Crib House Plan El. 595'-0 South Area P Drawing B-36 Crib House Plan El. 595'-0 North Area N Drawing B-37 Crib House Plan El. 559'-8 F Drawing M-11 General Arrangement Crib House E Drawing M-79, Diagram of RHR Service Water Piping BJ Sheet 1 Miscellaneous UCC Job #02-14- RHR Service Water Bay Inspection Report 02/07/2018 233.296 Letter UCC Job #02-14- RHR Service Water Bay Inspection Report 08/07/2018 233.327 Letter UCC Job #02-14- RHR Service Water Bay Inspection Report 02/07/2019 233.367 71153 Corrective Action IR 4274286 U-1 Reactor Scram Gen Trip from Ground Relay (GIX 104) 08/25/2019 Documents

14]]

[[IP sample::=

=IP 71111.15|count=4}}

The inspectors evaluated the following post maintenance tests:

(1) QCOS 1000-4, Unit 1 Residual Heat Removal Service Water Pump Operability Test on July 25, 2019
(2) Work Order 4945512, Unit 2 250 Vdc Battery Charger #2 Trip Alarm 902-8 A10 (2-8350) on July 30, 2019
(3) testing and synchronization to the grid following repairs to the Unit 1A phase of the isophase bus on August 31, 2019
(4) Unit 2C residual heat removal service water post-maintenance testing following discharge elbow replacement on September 16, 2019

71111.20 - Refueling and Other Outage Activities Refueling/Other Outage Sample (IP Section 03.01)

Main article: IP 71111.20
(1) The inspectors evaluated Forced Outage Q1F67 from Unit 1 reactor SCRAM due to generator ground fault on August 28, 2019.

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Surveillance Tests (other) (IP Section 03.01)

Main article: IP 71111.22
(1) QCOS 6620-01, [Unit 1] SBO [station blackout] DG [diesel generator] Quarterly Load Test on July 29, 2019
(2) QCOS 1100-07, [Unit 1A] SBLC [standby liquid control] Pump Flow Rate Test on

July 22, 2019 Inservice Testing (IP Section 03.01) (2 Samples)

(1) QCOS 1000-31, [Unit 1A] RHR [residual heat removal] Logic Test on May 22, 2019
(2) QCOS 2300-06, [Unit 2] HPCI System Air Operated Valve Test on July 30, 2019

71114.04 - Emergency Action Level and Emergency Plan Changes Inspection Review (IP Section 02.01-02.03)

Main article: IP 71114.04
(1) The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes:
  • Evaluation 18-45, Exelon Nuclear Standardized Radiological Emergency Plan, Revision 30 This evaluation does not constitute NRC approval.

RADIATION SAFETY

71124.05 - Radiation Monitoring Instrumentation Walk Downs and Observations (IP Section 02.01)

Main article: IP 71124.05

The inspectors evaluated radiation monitoring instrumentation during plant walkdowns.

(1) The inspectors reviewed the following:

Portable Survey Instruments

  • RO20 - 0014095
  • RO20 - 0020433
  • RO20 - 0018385
  • RO20 - 0014093
  • RO20 - 0012237
  • RAMGAM - 0010619
  • Model 3 - 0020028
  • Model 3 - 0021709
  • Telepole - 00141189 Source Check Demonstration
  • RO20 - 0014095
  • RO20 - 0020433
  • Model 3 - 0021709
  • Telepole - 00141189 Area Radiation Monitors and Continuous Air Monitors
  • Area Radiation Monitor, Low Range, Unit 1 Refuel Floor, 690'
  • Area Radiation Monitor, High Range, Unit 1 Refuel Floor, 690'
  • Area Radiation Monitor, Low Range, Unit 2 Refuel Floor, 690'
  • Area Radiation Monitor, High Range, Unit 2 Refuel Floor, 690'
  • Area Radiation Monitor, Low Range, Unit 1 Spent Fuel Pool, 690'
  • Area Radiation Monitor, High Range, Unit 1 Spent Fuel Pool, 690'
  • Area Radiation Monitor, Low Range, Unit 2 Spent Fuel Pool, 690'
  • Area Radiation Monitor, High Range, Unit 2 Spent Fuel Pool, 690'
  • Area Radiation Monitor, Outside Unit TIP Room, 595'
  • Continuous Air Monitor, Unit 1 Refuel Floor, 690
  • Continuous Air Monitor, Unit 1 13-Line, 595' Personnel Contamination Monitors, Portal Monitors and Small Article Monitors
  • IPM 9, Instrument Number I350
  • SAM 12, Instrument Number 12205
  • PM 12, Instrument Number 12047
  • SAM 11, Instrument Number LAM1

Calibration and Testing Program (IP Section 02.02) (1 Sample)

The inspectors evaluated the calibration and testing program implementation.

(1) The inspectors reviewed the following:

Alarm Setpoint and Calibration Method Check of Personnel Contamination Monitors, Portal Monitors and Small Article Monitors

  • PM 9, Instrument Number I350
  • SAM 12, Instrument Number 12205
  • PM 12, Instrument Number 12047 Failure to Meet Calibration or Source Check Acceptance Criteria
  • RO20 - 0018385
  • RO20 - 0014093
  • RO20 -

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below: MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) ===

Main article: IP 71151
(1) Unit 1 (07/01/2018 - 06/30/2019)
(2) Unit 2 (07/01/2018 - 06/30/2019)

MS06: Emergency AC Power Systems (IP Section 02.05) (2 Samples)

(1) Unit 1 (07/01/2018 - 06/30/2019)
(2) Unit 2 (07/01/2018 - 06/30/2019)

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues (IP Section 02.03)

Main article: IP 71152

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Issue Report (IR) 4238831, [Unit] 1C RHRSW High Pressure Outboard Seal Leak During Run

71153 - Follow-up of Events and Notices of Enforcement Discretion Event Follow-up (IP Section 03.01)

Main article: IP 71153
(1) Unit 1 reactor SCRAM event follow-up activities on August 25,

INSPECTION RESULTS

Licensee-Identified Non-Cited Violation 71124.05 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: Technical Specification 5.5.1 states, in part, that the Offsite Dose Calculation Manual shall be established, implemented, and maintained.

Section 12.2.1, Radioactive Liquid Effluent Monitoring Instrumentation, of the Offsite Dose Calculation Manual (Revision 13) includes Radiological Effluent Surveillance Requirement 12.2.1.3, which requires channel functional tests of the Unit 1 and Unit 2 service water effluent gross activity monitors to be performed on a 92 day frequency.

Contrary to the above, between December 19, 2018 and August 6, 2019, the licensee failed to implement radiological effluent surveillance requirements contained within the Offsite Dose Calculation Manual. Specifically, the licensee did not perform channel functional tests on Unit 1 or Unit 2 service water effluent gross activity monitors.

Significance/Severity: Green. The finding was determined to be of very low safety significance (Green) because the issue involved a radioactive effluent release, but did not: (1)represent a substantial failure to implement the radioactive effluent release program; or (2)result in public exposure that exceeded the dose values in Appendix I to 10 CFR Part 50 and/or 10 CFR 20.1301(e) limits.

Corrective Action References: Issue Report 4268906 Observation: 1C Residual Heat Removal Service Water Outboard Seal Leak 71152 The inspectors reviewed Issue Report 4238831, 1C RHRSW High Pressure Outboard Seal Leak During Run, dated April 12, 2019. The condition report documented a large amount of water leaking and spraying from the outboard seal of the 1C residual heat removal service water pump shortly after pump start in support of a surveillance test. Once the report was received in the control room, operators secured the pump. The licensee declared the pump inoperable and entered the appropriate Technical Specification. After the pump was secured, operators reported that the seal was continuing to leak approximately 3 gallons per minute.

The licensee had been tracking the leaking seal on this pump since it was first reported on March 18, 2019, which was documented in Issue Report 4230672, 1C RHRSW HP [high pressure] O/B [outboard] Seal Leaking. Following the seal leak identified in Issue Report 4230672, the licensee determined that seal replacement would be required, and planned the repair for a future residual heat removal work window. The licensee completed all necessary repairs on April 15, 2019, and the pump was restored to an operable status. The inspectors determined that the licensee's corrective action for this issue was appropriate and in accordance with the significance of the issue. The licensee identified that the cause of the seal failure was inadequate pump seal cooling water flow due to a small pebble getting stuck in a flow-restricting orifice, which blocked flow in the seal cooling line. The inspectors reviewed the licensees responses to Issue Reports 4230672 and 4238831, the design of the RHRSW system, prior RHRSW bay inspections, and internal operating experience. The inspectors determined that the cause of the pump failure and seal leak was not within the licensee's ability to foresee and correct, and no performance deficiency was identified.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

  • On October 1, 2019, the inspectors presented the integrated inspection results to Mr. P. Boyle, Acting Plant Manager, and other members of the licensee staff.
  • On September 20, 2019, the inspectors presented the radiation protection inspection results inspection results to Mr. K. Ohr, Site Vice President, and other members of the licensee staff.
  • On October 3, 2019, the inspectors presented the Exit Meeting for EP Inspection per IP 71114, Attachment inspection results to Mr. L. Baker, EP Fleet Programs Manager and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or Procedure Date 71111.04Q Procedures QCOP 1000-04 RHR Service Water System Operation 22 QCOP 6600-04 Diesel Generator 1/2 Preparation for Standby Operation 34 QCOP 6600-24 Unit 2 Diesel Generator Preparation for Standby Operation 3 71111.04S Corrective Action IR 4025834 Replace Unit 1 SBLC Heat Trace and Insulation 06/26/2017 Documents Procedures M-40 Diagram of Standby Liquid Control Piping QOM 1-1100-01 Unit 1 Standby Liquid Control Valve Checklist 10 Work Orders WO 4657736 EM Replace/Upgrade 1-1101 U1 SBLC Heat Trace & 09/06/2018 Insulation 71111.05Q Fire Plans FZ 11.2.1 Unit 1 RB 554'-0 Elev. SW Corner Room - 1B Core Spray July 2009 FZ 11.2.3 Unit 1 RB 554'-0 Elev. NW Corner Room - 1A Core Spray November 2011 FZ 6.1.A Unit 1 TB 615'-6 Elev. 'A' Battery Charger Room U-1 October 2013 FZ 6.1.B Unit 1 TB 615'-6 Elev. 'B' Battery Charger Room U-1 October 2013 FZ 6.2.A Unit 2 TB 615'-6 Elev. 'A' Battery Charger Room U-2 July 2009 FZ 6.2.B Unit 2 TB 615'-6 Elev. 'B' Battery Charger Room U-2 October 2013 FZ 7.1 Unit 1 TB 628'-6 Elev. 250V Battery Room October 2013 FZ 7.2 Unit 2 TB 628'-6 Elev. 250V Battery Room July 2009 FZ 8.2.6.E Unit 2 TB 595'-0 Elev. Hallway November 2018 FZ 8.2.7.A Unit 1 TB 615'-6 Elev. Hydrogen Seal Oil Area and MCC's October 2015 FZ 8.2.7.E Unit 2 TB 615'-6 Elev. North Mezzanine Floor November 2018 71111.12 Miscellaneous Unavailability July 2018 - Report June 2019 71111.13 Corrective Action IR 4267593 Received 902-10 A10, 250V Battery Charger 2 Trip 07/28/2019 Documents IR 4268103 250 Vdc Drawing Enhancement 07/30/2019 Inspection Type Designation Description or Title Revision or Procedure Date IR 4268124 250 Vdc Charger Require Updates 07/30/2019 71111.15 Corrective Action IR 4262214 7/6/19 DWEDS Pumping had Step Change in Total Gallons 07/06/2019 Documents Pumped IR 4262426 U2 DWED Sump Level Switch Fails to Stop 2A Pump at Low 07/07/2019 Level IR 4263259 U2 DWEDS Level Switch Issues Prevent Accurate Trending 07/11/2019 IR 4263286 EO ID: Water Leak from 0-2007-22 AOV FDF Backwash 07/11/2019 Inlet IR 4264763 NRC ID: U2 DWFDS Leakage Increase Above NRC 07/17/2019 Threshold IR 4267593 Received 902-10 A10, 250V Battery Charger 2 Trip 07/28/2019 Drawings Drawing 4E-1319 Key Diagram and Elevations 48-24 Vdc Distribution Centers N Miscellaneous Alarm 902-8 A10 250V Battery Charger 2 Trip OP-AA-108-111 Adverse Condition Monitoring and Contingency Plan 07/18/2019 

                                            (ACMP) U2 Drywell Equipment Drain Sump (DWEDS) Pump

Degraded Flow (Rev. 1) Procedures QOM 1-6300-T01 48/24 Vdc Distribution Panel + 1A Bus 4E-1319 4 QOM 1-6300-T02 48/24 Vdc Distribution Panel + 1B Bus 4E-1319 5 UFSAR Table Drywell Equipment Drain Sump Sources for Radioactive 11.1-4 Material 71111.19 Procedures QCOS 1000-04 RHR Service Water Pump Operability Test 63 Work Orders WO 4916933 QCOS 1000-4 'A' RHR Serv Wtr Pump Flow Group 'A' Test 07/23/2019 

                                            (IST)

WO 4916934 QCOS 1000-6 'A' RHR Pump Flow Rate Group 'A' Test (IST) 07/23/2019 WO 4916935 QCOS 1000-6 'B' RHR Pump Flow Rate Group 'A' Test (IST) 07/23/2019 WO 4916936 QCOS 1000-4 'B' RHR Serv Wtr Pump Flow Group 'A' Test 07/23/2019 

                                            (IST)

WO 4916937 QCOS 1000-06 'A' Loop LPCI Mode RHR Flow Rate 07/23/2019 WO 4945512 250 Vdc Battery Charger 2 Trip Alarm 902-8 A10 (2-8350) 07/30/2019 71111.20 Corrective Action IR 4274286 U-1 Reactor Scram Gen Trip from Ground Relay (GIX 104) 08/25/2019 Documents 71111.22 Procedures ER-AA-310 Maintenance Rule 12 OP-AA-108-115 Operability Determinations 22 Inspection Type Designation Description or Title Revision or Procedure Date QCOS 1100-07 SBLC Pump Flow Rate Test 38 QCOS 2300-06 HPCI System Air Operated Valve Test 44 QCOS 6620-01 SBO DG 1(2) Quarterly Load Test 54 WC-AA-101 On-line Work Control Process 28 WC-AA-101-1006 On-line Risk Management and Assessment 2 Work Orders WO 4916523-01 HPCI Valve Timing Test (IST) 0 WO 4918552-01 SBO Load Test 0 71114.04 Miscellaneous Evaluation 18-45 Exelon Nuclear Standardized Radiological Emergency Plan, 02/14/2019 Revision 30 71124.05 Calibration Certificate Certificate of Calibration RO20AA 02/14/2019 Records #0011135270 Certificate Certificate of Calibration Model 3 11/29/2018 

                            #0011138654

Certificate Certificate of Calibration Model 3 02/01/2019 

                            #0011150060

Certificate Certificate of Calibration RAM GAM 1 05/28/2019 

                            #0011173293

Certificate Certificate of Calibration BAK-2270 08/19/2019 

                            #0011173354

Certificate Certificate of Calibration RO-20AA 02/26/2019 

                            #001153485

RP-AA-232-1001 ACCUSCAN II Calibration Acceptance Criteria 07/25/2018 RP-AA-232-1001 Calibration Acceptance Criteria FASTSCAN 07/24/2018 RP-AA-700-1210 IPM Calibration Data Sheet #I350 10/24/2018 RP-AA-700-1235 PM-12 Calibration Data Sheet #12047 08/30/2019 RP-AA-700-1239 SAM-12 Calibration Data Sheet #12205 12/18/2018 Corrective Action AR 04157428 Out of Tolerance Instrumentation During Calibration 07/20/2018 Documents AR 04207695 Out of Tolerance Instrumentation During Calibration 01/03/2019 AR 04264231 Instruments Not Marked Information Only As Required 07/15/2019 Inspection Type Designation Description or Title Revision or Procedure Date AR 04268906 Request Re-establish SWRM Channel Functional Test 08/01/2019 Frequency to 92 Days Corrective Action AR 04280816 Portable Instrument Source Check Acceptance Criteria 09/19/2019 Documents Exceeds Range of Scale Resulting from AR 04280821 Portable Instrument Source Check Acceptance Criteria 09/19/2019 Inspection Significant Figure Issue Miscellaneous C&C Irradiator Service LLC; Dose vs. Distance Curves 07/17/2019 Ref No S125722 Radcal Corporation Service Report 04/15/2019 Procedures CY-AA-130-201 Radiochemistry Quality Control 7 RP-AA-232-1001 Calibration Verification of Whole Body Counting Systems 1 Using APEX In-Vivo RP-AA-700-1208 Irradiator Reference Data Sheet 07/17/2019 RP-AA-700-1210 Operation and Calibration of IPM Whole Body Frisking 2 Monitor RP-AA-700-1235 Operation and Calibration of the PM-12 Gamma Portal 5 Monitor RP-AA-700-1239 Operation and Calibration of the Model SAM-12 Small 5 Articles Monitor Self-Assessments AR 4207564 NRC: Rad Protection - Rad Monitoring Instrumentation 07/16/2019 Inspection Work Orders 01949080-01 QCIS 2400-05 Division II Rad Monitor Calibration/Functional 04/19/2018 Test 71152 Corrective Action ACE 1C Residual Heat Removal Service Water (RHRSW) High Documents Pressure Pump Outboard (OB) Seal Failure IR 4161140 1C RHRSW HP Pump O/B Seal Has Increased 08/02/2018 IR 4230672 EO ID: 1C RHRSW HP O/B Seal Leaking 03/18/2019 IR 4232246 EO ID: 1C RHRSW HP O/B Seal Leaking (Leak Template 03/18/2019 IR) IR 4234945 EOID: 1C RHRSW High Pressure Pump Outboard Seal 03/31/2019 Leak Increase IR 4238831 1C RHRSW High Pressure Pump OB Seal Leak During Run 04/12/2019 IR 4254019 Pump Failed to Start During QCOS 1000-04 06/03/2019 IR 4272141 Eold - 1C RHRSW High Pressure Pump Inboard Seal Leak 08/15/2019 Inspection Type Designation Description or Title Revision or Procedure Date IR 4272309 1C RHRSW HP Pump 1B Seal Leak Follow-up to IR 08/15/2019 272141 IR 490375 PSU Q1M19 1C RHRSW Pump Seal Leak 05/16/2006 IR 580419 Gap Below RHRSW Separation Screen 01/18/2007 Drawings Drawing B-35 Crib House Plan El. 595'-0 South Area P Drawing B-36 Crib House Plan El. 595'-0 North Area N Drawing B-37 Crib House Plan El. 559'-8 F Drawing M-11 General Arrangement Crib House E Drawing M-79, Diagram of RHR Service Water Piping BJ Sheet 1 Miscellaneous UCC Job #02-14- RHR Service Water Bay Inspection Report 02/07/2018 233.296 Letter UCC Job #02-14- RHR Service Water Bay Inspection Report 08/07/2018 233.327 Letter UCC Job #02-14- RHR Service Water Bay Inspection Report 02/07/2019 233.367 71153 Corrective Action IR 4274286 U-1 Reactor Scram Gen Trip from Ground Relay (GIX 104) 08/25/2019 Documents 14| ]]

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