IR 05000254/2020003

Integrated Inspection Report 05000254/2020003; 05000265/2020003 and 07200053/2020001

ML20315A134
Person / Time
Site:	Browns Ferry, Quad Cities
Issue date:	11/09/2020
From:	Kenneth Riemer NRC/RGN-III/DRP/B1
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
References
IR 2020001, IR 2020003
Download: ML20315A134 (28)

Text

November 9, 2020

SUBJECT:

QUAD CITIES NUCLEAR POWER STATION - INTEGRATED INSPECTION REPORT 05000254/2020003; 05000265/2020003 AND 07200053/2020001

Dear Mr. Hanson:

On September 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Quad Cities Nuclear Power Station and discussed the results of this inspection with Mr. K. Ohr, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. One Severity Level IV violation without an associated finding is documented in this report. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations or the significance or severity of the violations documented in this inspection report, 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 copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Quad Cities Nuclear Power Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Quad Cities Nuclear Power Station. 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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Kenneth R. Riemer, Chief Branch 1 Division of Reactor Projects Docket Nos. 05000254; 05000265; 07200053 License Nos. DPR-29 and DPR-30

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000254; 05000265; 07200053 License Numbers: DPR-29 and DPR-30 Report Numbers: 05000254/2020003; 05000265/2020003; 07200053/2020001 Enterprise Identifier: I-2020-003-0035 Licensee: Exelon Generation Company, LLC Facility: Quad Cities Nuclear Power Station Location: Cordova, IL Inspection Dates: July 01, 2020 to September 30, 2020 Inspectors: J. Dalzell, Health Physicist N. Fields, Health Physicist M. Holmberg, Senior Reactor Inspector B. Lin, Health Physicist C. Mathews, Illinois Emergency Management Agency R. Murray, Senior Resident Inspector J. Neurauter, Senior Reactor 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, 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.

List of Findings and Violations

Failure to Perform Adequate Risk Assessment During Emergent Plant Activities Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.13] - 71111.13 Systems NCV 05000265/2020003-01 Consistent Open/Closed Process The inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR 50.65(a)(4), "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," when the licensee failed to adequately assess plant risk following a loss of instrument air, resulting in an unidentified and unmitigated Yellow plant risk situation.

Motor-Operated Valves Fail to Meet Design Basis Safety Functions Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [P.1] - 71111.15 NCV 05000254,05000265/2020003-02 Identification Open/Closed The inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensee's failure to ensure that measures were established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, procedures, and instructions. Specifically, the minimum closure thrust as determined in MIDAS calculations for MOs 1-0220-2 and 2-0220-2, were not translated into the work order instructions performed on the motor-operated valves under Work Order 4713400 in 2019 and Work Order 4687470 in 2020, respectively.

Failure to Report a Condition that Could Have Prevented the Fulfillment of a Safety Function Cornerstone Significance Cross-Cutting Report Aspect Section Not Applicable NCV 05000254,05000265/2020003-03 Not Applicable 71152 Open/Closed The inspectors identified a traditional enforcement, Severity Level IV, violation of 10 CFR 50.72(b)(3)(v) when, on July 22, 2020, the licensee failed to notify the NRC within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of the identification of the inoperability of the oscillating power range monitoring system, a system needed to shut down the reactor and mitigate the consequences of an accident.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000265/2020-003-00 LER 2020-003-00 for Quad 71153 Closed Cities Nuclear Power Station, Unit 2, Oscillation Power Range Monitors (OPRMs) Count Setpoint Discrepancy Due to Inadequate Instructions

PLANT STATUS

Unit 1 The unit began the inspection period at full-rated thermal power, where it remained for the entire inspection period, with the exception of planned power reductions for turbine testing, scram timing testing, control rod pattern adjustments, and other short-term power reductions as requested by the transmission system operator.

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 planned power reductions for turbine testing, scram timing testing, control rod pattern adjustments, and other 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 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.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week and during that time conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities, and completed on-site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on-site. The inspections documented below met the objectives and requirements for completion of the IP.

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of impending severe thunderstorms and heavy winds for the following systems:

impending severe thunderstorms and heavy winds on August 10, 2020

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

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

(1) Unit 1 residual heat removal service water (RHRSW) system walkdown during 1A RHRSW pump overhaul on July 23, 2020

(2) Unit 1/2 service water system during summer period with multiple degraded pumps on August 4, 2020

(3) high pressure coolant injection (HPCI) system walkdown on August 19, 2020

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Fire Zone 1.1.1.6, Unit 1/2 reactor building, elevation 690'-6", refuel floor - DCS (dry cask storage) campaign in progress on July 7, 2020

(2) Fire Zones 8.2.6.A/8.2.6.E, turbine building 73/turbine building 95, elevation 595'-0",

reactor feed pumps on July 20, 2020

(3) Fire Zone 11.4.B, crib house, elevation 595'-0", ground floor/service water on August 4, 2020

(4) Fire Zone 8.2.7.E, Unit 2 turbine building, elevation 615'-6", north mezzanine floor on September 10, 2020

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the control room during Unit 1 downpower for rod pattern adjustment on September 5, 2020.

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

(1) The inspectors observed and evaluated licensed operator re-qualification training on September 14, 2020.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Maintenance Rule a(3) Report Evaluation on August 5, 2020

(2) main steam isolation valves on September 14, 2020

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Work Week Risk and actions for hot weather alert during week of July 6, 2020

(2) Emergent Risk associated with loss of instrument air on July 2, 2020

(3) Issue Report 4358380, "Unexpected change in U1 Feedwater Temperature" on July 22, 2020

(4) Issue Reports 4359380, 4359346, and 4359546, "1/2 Group 1 Isolation & Group 3 Isolation Due to Blown Fuse," on July 29, 2020

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (7 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Issue Report 4352024, "M&TE Evaluation per MA-AA-716-040," on July 13, 2020

(2) Issue Report 4354116, "2-0220-2 As-Left C-14 was Below the Midas Calc Requirement," on July 7, 2020

(3) Issue Report 4356814, "Unit 2 125 Vdc Alternate Battery Low Specific Gravity," on July 20, 2020

(4) Issue Report 4358571, "2-2301-8 HPCI MOV [motor-operated valve] Torque Switch Operability," on July 27, 2020

(5) Issue Report 4358276, "U2 OPRMs [oscillating power range monitor] Identified as INOP," (past operability review due August 14) on August 14, 2020

(6) HPCI operability during loss of 73-AA on August 15, 2020

(7) Issue Report 4366560, "Unit 1 A/B RHR [residual heat removal] Room Cooler Inlet Piping Leak," on August 31, 2020

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:

(1) Work Order 5035356, "QCOS 1000-28 RHRSW Pump A Comprehensive/Performance Test (IST)," on August 3, 2020

(2) QCOS 2300-05 HPCI flow test on September 16, 2020

(3) reactor core isolation cooling overspeed trip post-maintenance test on September 16, 2020

(4) Unit 1A core spray flow rate test following planned maintenance on September 21, 2020

(5) Unit 1/2 emergency diesel generator endurance run test following planned maintenance on September 22, 2020

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) QCOS 1400-01, "2A Core Spray System Flow Rate Test," on July 1, 2020

(2) QCOS 6600-41, "Unit 1 Emergency Diesel Generator Load Test," on July 13, 2020

Inservice Testing (IP Section 03.01) (1 Sample)

(1) QCOS 1100-7, "Standby Liquid Control Flow Rate Test," on September 15, 2020

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)

(1 Sample)

(1) dropped cask in fuel pool/loss of fuel pool inventory on July 7,

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) ===

(1) Unit 1 (07/01/2019-06/30/2020)

(2) Unit 2 (07/01/2019-06/30/2020)

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

(1) Unit 1 (07/01/2019-06/30/2020)

(2) Unit 2 (07/01/2019-06/30/2020)

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)

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

(1) Issue Report 4358276, "U2 OPRMs identified as INOP," on July 22, 2020

(2) Issue Report 4371385, "[Unit] 1C RHRSW Seal Cooling Line Break," on September 23, 2020

71153 - Followup of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 2020-003-00 for Quad Cities Nuclear Power Station, Unit 2, Oscillation Power Range Monitors Count Setpoint Discrepancy Due to Inadequate Instructions (ADAMS Accession No. ML20261H588). The inspection conclusions associated with this LER are documented in this report under Inspection Results Section 4OA2.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

60855.1 - Operation of an Independent Spent Fuel Storage Installation at Operating Plants Operation of an Independent Spent Fuel Storage Installation at Operating Plants

(1) The inspectors evaluated the licensees independent spent fuel storage installation (ISFSI) cask loading activities July 20 through July 24. This evaluation focused on the licensee's corrective and recovery actions, following unexpected contamination found on the inside of the transfer cask (HI-TRAC) pool lid after the download evolution was performed. Specifically, the inspectors observed the following activities remotely via camera:

• upload of loaded MPC-68M-641 from the storage cask (HI-STORM) into the HI-TRAC on July 20

• flushing and sampling of the annulus water between the MPC-68M-641 and the HI-TRAC on July 21

• stack-up and download of MPC-68M-641 from the HI-TRAC into the HI-STORM, following satisfactory water chemistry samples from the annulus on July 23

• vertical cask transporter picking up the loaded HI-STORM from the low profile transporter outside the reactor building trackway doors on July 24 The inspectors also evaluated the licensees ISFSI cask loading on September 8 through September 10. Specifically, the inspectors observed the following activities on-site:

• loading spent fuel into MPC-68M-645 and fuel verification on September 8

• contamination surveys of the annulus of MPC-68M-645 on September 9

• welding of the root pass of the lid-to-shell weld of MPC-68M-645 on September 9

• forced helium dehydration of MPC-68M-645 on September 10 The inspectors performed a walkdown of the ISFSI pad, including independent radiation surveys, and a walkdown of the ISFSI haul path.

The inspectors evaluated the following:

• spent fuel selection for the seven casks for this loading campaign

• selected corrective action program action requests

• selected 72.48 screenings

INSPECTION RESULTS

Failure to Perform Adequate Risk Assessment During Emergent Plant Activities Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.13] - 71111.13 Systems NCV 05000265/2020003-01 Consistent Open/Closed Process The inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR 50.65(a)(4), "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," when the licensee failed to adequately assess plant risk following a loss of instrument air, resulting in an unidentified and unmitigated Yellow plant risk situation.

Description:

At the Quad Cities Nuclear Station (QCNS), the instrument air system has one instrument air compressor (IAC) dedicated to each unit (1A and 2) as well as two swing IACs (1/2 and 1/2B)that can supply both units, providing a maximum of three IACs available for each unit. Each of the IACs has a dryer downstream of the compressor. The instrument air system also has a backup supply from the service air system through a cross connect valve ("Little Joe Valve").

Normal system lineup is the dedicated unit IAC online with backup available from the two swing air compressors.

On July 2, 2020, during a planned maintenance outage of the service air system, the QCNS Unit 2 experienced a disruption in the instrument air system when the Unit 2 IAC failed to maintain header pressure. The station entered QOA 4700-06, Loss of Instrument Air, and operations personnel started the 1/2 IAC, the 1/2B IAC, and the 1A service air compressor.

The 1/2 IAC tripped immediately on low oil pressure, and the 1/2B instrument air dryer also failed.

This resulted in the QCNS Unit 2 having only one of three IACs available (with a degraded dryer) and the service air system considered unavailable for backup due to planned maintenance. Operations personnel entered the failed/unavailable equipment into the plant risk evaluation tool (PARAGON) and determined that plant risk and fire risk remained Green.

The inspectors identified that the station failed to recognize and evaluate the risk associated with the increased potential for a complete loss of instrument air due to the loss of redundancy. As documented in Issue Report 4355766, based upon questions from the NRC resident inspectors office, the station determined that they should have considered the instrument air lineup a high-risk evolution for loss of instrument air in PARAGON.

With the loss of instrument air high-risk evolution selected in PARAGON, the resultant risk profile is Yellow for plant risk, with additional protected equipment required.

Contributing to this event, plant procedures do not provide guidance for when or how to evaluate plant risk for emergent events. In addition, the guidance for when to select high-risk evolutions in PARAGON is outdated (2007) and in the case of instrument air, does not reflect current plant configuration.

Corrective Actions: The licensee has entered this into their corrective action program.

Corrective Action References: Issue Report 4355766, "NRC ID: Paragon HRE [high-risk evolution] not Triggered"

Performance Assessment:

Performance Deficiency: Specifically, the licensees failure to assess and manage risk associated with an off-normal lineup of the instrument air system prior to performing corrective maintenance did not comply with the requirements of 10 CFR 50.65(a)(4). Title 10 CFR 50.65(a)(4) requires that: Before performing maintenance activities (including but not limited to surveillance, post-maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities." Following the malfunction of the online instrument air compressor and the trip of the standby instrument air compressor which resulted in an off-normal system lineup, the licensee failed to adequately assess and manage the risk prior to performing corrective maintenance resulting in an unrecognized and unmitigated Yellow plant risk situation. The inspectors determined that the licensee's failure to assess and manage the risk prior to performing troubleshooting and corrective maintenance was a performance deficiency. Contributing to this event, plant procedures do not provide guidance for when or how to evaluate plant risk for emergent events. In addition, the guidance for when to select high-risk evolutions in PARAGON is outdated (2007) and in the case of instrument air, does not reflect current plant configuration.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Additionally, the inspectors identified that the more than minor examples 8.d and 8.e from Inspection Manual Chapter 0612, Appendix E, Examples of Minor Issues, most closely resemble this event.

Significance: The inspectors assessed the significance of the finding using Appendix K, Maintenance Risk Assessment and Risk Management SDP. Because the performance deficiency was associated with 10 CFR 50.65(a)(4) performance (Flow Chart 1), the incremental core damage probability deficit was <1E-6, and the incremental large early release probability deficit was <1E-7, the finding screened to Green.

Cross-Cutting Aspect: H.13 - Consistent Process: Individuals use a consistent, systematic approach to make decisions. Risk insights are incorporated as appropriate. The licensees failure to incorporate guidance into procedures to assess risk during emergent activities and the failure to maintain up-to-date high-risk evolution guidance prevented the implementation of a consistent process which incorporated risk insights.

Enforcement:

Violation: Title 10 CFR 50.65(a)(4) requires that Before performing maintenance activities (including but not limited to surveillance, post-maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. The scope of the assessment may be limited to structures, systems, and components that a risk-informed evaluation process has shown to be significant to public health and safety.

Contrary to the above, on July 2, 2020, before performing maintenance activities on the instrument air system, the licensee failed to assess and manage the increase in risk that resulted from the corrective maintenance activities associated with the disruption in instrument air.

Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Motor-Operated Valves Fail to Meet Design Basis Safety Functions Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [P.1] - 71111.15 NCV 05000254,05000265/2020003-02 Identification Open/Closed The inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensee's failure to ensure that measures were established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, procedures, and instructions. Specifically, the minimum closure thrust as determined in MIDAS calculations for MOs 1-0220-2 and 2-0220-2, were not translated into the work order instructions performed on the motor-operated valves under Work Order 4713400 in 2019 and Work Order 4687470 in 2020, respectively.

Description:

On July 1, 2020, the licensee generated Issue Report 4354116 that documented the as-left thrust for motor-operated valve MO 2-0220-2, Unit 2 main steam outboard main steam line drain isolation valve, was lower than the required minimum thrust as calculated by the motor-operated valve program MIDAS Software. The licensee determined that the valve was operable because it was in its safety position of closed, had not been opened since it was shut during the last refueling outage in April 2020, and the valve had passed its local leak rate test during the outage. These valves are normally closed primary containment isolation valves that are opened to drain the main steam lines and as a means of equalizing pressure across the main steam isolation valves prior to opening during startup or following a steam line isolation. These valves must close to: 1) prevent coolant inventory loss and protect plant personnel in the event of a line break downstream of the isolation valve; 2) complete the containment boundary after a loss-of-coolant accident.

The shift manager requested that engineering provide a formal OpEval (operability evaluation) to support the operability determination. On July 23, 2020, the licensee wrote Issue Report 4358561, "1-0220-2 OPEX Review Issues," which documented a similar condition for MO 1-0220-2, the Unit 1 main steam inboard main steam isolation drain valve.

The licensee completed multiple revisions to the OpEval associated with Issue Report 4354116 (which included an evaluation of MO 1-0220-2), and on September 9, 2020, after the licensee approved Revision 4, the inspectors questioned the licensee on their conclusions that the valve would remain operable under all conditions with the implementation of compensatory measures. The inspectors were concerned that the licensee did not adequately evaluate the use of manual actions as compensatory measures to perform automatic functions (i.e. did not evaluate the difference between the time required to close the valves and did not evaluate the feasibility of performing the compensatory measures under all design basis conditions). Additionally, the inspectors questioned whether the licensee could demonstrate that the valves could pass all of their required Technical Specification (TS) surveillance requirements. Following the challenge from the resident inspectors, the licensee performed additional evaluations and research, identifying a 1988 memo, which was later incorporated into NRC Inspection Manual, Part 9900 Technical Guidance STS3464.TG, "Standard Technical Specifications Section 3/4.6.4 Containment and Drywell Isolation Valves," which provides the NRC position on operability of containment isolation valves. Specifically, STS3464 states, in part, that just because a containment isolation valve is in its closed position does not make it operable. The guidance discusses that inoperable valves may still be opened and not able to perform their automatic safety function. The conclusion of the guidance is clear when it states, "an inoperable valve should be declared inoperable and licensees should comply with applicable Action Statements." On September 11, 2020, the licensee declared MOs 1-0220-2 and 2-0220-2 inoperable, entered the applicable TS 3.6.1.3, and complied with the TS action statement by closing and de-energizing the upstream valves for the associated penetration header (MO 1-0220-1 and MO 2-0220-1).

This issue is being considered "NRC identified" in accordance with IMC 0612 which defines NRC identified issues as those "initially identified by the licensee to which the inspector has identified inadequacies in the licensees characterization or evaluation of the issue of concern." The inspectors identified inadequacies with the licensee's operability evaluation which ultimately led to the licensee declaring the containment isolation valves inoperable.

The licensee investigated the cause of the valves' thrust being below minimum design basis value. During Refuel Outage Q2R25, a diagnostic test was performed under Work Order 4687470. Electrical maintenance technicians identified the C14 thrust as UNSAT low and informed the program engineer. The program engineer reviewed the issue and determined the valve showed similar results to the previous diagnostic test and accepted the condition as-is. The licensee also determined that the MIDAS valve calculation program had the valve closed control scheme set at "Limit Controlled." While the motor-operated valve program documents allowed the licensee to use this control scheme, there were additional work instructions that were required in order to ensure that the valve met the minimum thrust requirement. The inspectors noted that the licensee did not enter this issue into their corrective action program and was a significant contributor to the cause of the valve being left in the inoperable condition. The inspectors also concluded that the licensee's work instructions for setting up the motor-operated valves did not correctly translate all of the requirements from the MIDAS program calculation for the valves to be able to perform their design functions.

Corrective Actions: The licensee declared MOs 2-0220-2 and 1-0220-2 inoperable on September 11, 2020. The licensee complied with TS 3.6.1.3 by closing and de-energizing drain header upstream valves for the respective penetrations (MO 2-0220-1 and MO 1-0220-1). The licensee also planned to perform work on these valves in each of the next unit's refuel outages to correct the valves' set-up so they would be able to perform all of their design basis functions.

Corrective Action References: Issue Report 4354116, "2-0220-2 As-Left C-14 was Below the Midas Calc Requirement"; Issue Report 4358561, "1-0220-2 OPEX Review Issues"; and Issue Report 4360180, "MO-2-0220-2 CTSB OPEX Review Results"

Performance Assessment:

Performance Deficiency: The licensee failed to ensure that design requirements, as determined by their motor-operated valve program and MIDAS program calculations for MO 1-0220-2 and MO 2-0220-2 were met.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the SSC and Barrier Performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the licensee's failure to ensure the valve design requirements were met caused the valves to be inoperable and unable to perform their safety-related automatic close function.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 3, "Barrier Integrity," the finding screened as having very low safety significance (Green) because the finding did not represent an actual open pathway in the physical integrity of reactor containment, did not represent the failure of containment pressure control equipment, did not represent the failure of containment heat removal components, and did not involve the actual reduction in function of hydrogen igniters in the reactor containment.

Cross-Cutting Aspect: P.1 - Identification: The organization implements a corrective action program with a low threshold for identifying issues. Individuals identify issues completely, accurately, and in a timely manner in accordance with the program. P.1 Identification: The organization implements a corrective action program with a low threshold for identifying issues. Individuals identify issues completely, accurately, and in a timely manner in accordance with the program (PI.1). Specifically, during performance of Work Order 4687470, the licensee failed to justify, correct, or document in their corrective action program that the as-left thrust value for MO 2-0220-2 was less than the minimum acceptable value listed in the work instructions.

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that measures be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. The licensee established their motor-operated valve calculation program called MIDAS to determine motor-operated valve design basis requirement parameters.

Contrary to the above, from approximately April 2019 until September 11, 2020, for Unit 1, and from approximately March 2014 until September 11, 2020 for Unit 2, the licensee failed to assure that applicable regulatory requirements and the design basis were correctly translated into specifications, drawings, procedures, and instructions. Specifically, the licensee failed to assure that the design basis parameters for MO 1-0220-2 and MO 2-0220-2, the Unit 1 and Unit 2 main steam line drain outboard isolation valves, respectively, were correctly translated into specifications and instructions in Work Order 4713400 on Unit 1 and Work Order 4687470 on Unit 2.

Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Report a Condition that Could Have Prevented the Fulfillment of a Safety Function Cornerstone Severity Cross-Cutting Report Aspect Section Not Severity Level IV Not 71152 Applicable NCV 05000254,05000265/2020003-03 Applicable Open/Closed The inspectors identified a traditional enforcement, Severity Level IV, violation of 10 CFR 50.72(b)(3)(v) when, on July 22, 2020, the licensee failed to notify the NRC within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of the identification of the inoperability of the oscillating power range monitoring system, a system needed to shut down the reactor and mitigate the consequences of an accident.

Description:

In April of 2020, Quad Cities performed Work Order 4766992 to perform oscillating power range monitor (OPRM) setpoint changes during Refuel Outage Q2R25.

On July 22, 2020, during the performance DIV I OPRM RESPONSE TIME TEST (U2 QCIS

[Quad Cities Instrumentation Surveillance] 0700-19, Work Order 4852293), it was identified that the as-found OPRM maximum confirmation count setpoint on Unit 2 OPRMs did not match the values in the Core Operating Limits Report (COLR) Quad Cities 2, Revision 14, Section 7. All OPRMs for Unit 2 were declared inoperable at 10:30 a.m. on July 22, 2020.

Operations entered TS Limiting Condition for Operation (LCO) 3.3.1.3 Condition A for OPRMs 1-8 and Condition B for loss of trip capability. The setpoint discrepancy was corrected under Work Order 5063228-01 and declared operable on July 23, 2020 at 12:10 p.m.

The licensee's evaluation of the issue under Issue Report 4358276, "OPRM PBDA Count Setpoint Discrepancy," determined that during performance of Work Order 4766992-01, the work instructions only directed instrument maintenance department technicians to update the amplitude setpoint. The work order package did not direct technicians to update the count setpoint in accordance with the COLR Quad Cities 2, Revision 14, Section 7.

Quad Cities identified that their OPRMs on Unit 2 had been inoperable since they started the unit following their outage in April. The inspectors noted that the licensee did not report this issue to the NRC in accordance with 10 CFR 50.72(b)(3)(v). The inspectors determined this issue was reportable based on the following:

Title 10 CFR 50.72(b)(3)(v) requires that licensees report to the NRC:

Any event or condition that at the time of discovery could have prevented the fulfillment of the safety function of structures or systems that are needed to:

(A) shut down the reactor and maintain it in a safe shutdown condition; (B) remove residual heat; (C) control the release of radioactive material; or (D) mitigate the consequences of an accident.

The OPRM system is one that is needed to shut down the reactor and maintain it in a shutdown condition as well as a system needed to mitigate the consequences of an accident (as described in Chapter 15 of the Updated Final Safety Analysis Report (UFSAR)).

NUREG 1022, "Event Report Guidelines 10 CFR 50.72 and 50.73," Revision 3, Section 3.2.7, states, in part:

"SSCs within scope include only safety-related SSCs required by the TS to be operable that are intended to mitigate the consequences of an accident as discussed in Chapters 6 and 15 of the Final Safety Analysis Report (or equivalent chapters). Accidents are identified as events of moderate frequency, infrequent incidents, or limiting faults as discussed in Regulatory Guide 1.70, 'Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants (LWR Edition),' (or equivalent classifications of the three types of events)."

Quad Cities Updated Final Safety Analysis Report Chapter 15, Section 15.4.11.1, states, in part, "Anticipated stability-related neutron flux oscillations are those instabilities that result from normal operating conditions, including conditions resulting from anticipated operational occurrences. This category of events is equivalent to the standard terminology for the analysis of events of moderate frequency (Reference 29)."

Additionally the Quad Cities UFSAR Section 15.4.11.2 C.2, states, "With the OPRM installed, armed, and operational, the operator may be able to take action based on pre-trip alarms to insert control rods or increase flow. If the operator is not able to take action because of the rate of increasing oscillations, the OPRM automatically scrams the reactor before the Safety Limit MCPR is violated."

Based on the above discussion, the inspectors concluded this event was reportable in accordance with 10 CFR 50.72(b)(3)(v) and informed the licensee of this determination the week of August 10, 2020.

Corrective Actions: The licensee made the required 50.72 notification to the NRC on September 29, 2020, in Event Notification 54923. The licensee reported this event in a LER (in accordance with 10 CFR 50.73) on September 17, 2020 (referenced in IPs 71152 and 71153 of this report).

Corrective Action References: Issue Report 4358276, OPRM PBDA Count Setpoint Discrepancy

Performance Assessment:

The inspectors determined this violation was associated with a minor performance deficiency.

Enforcement:

The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance.

Severity: The inspectors used NRC Enforcement Policy, dated January 15, 2020, to determine the severity level of this violation. Section 6.9, "Inaccurate and Incomplete Information or Failure to Make a Required Report," part d., "Examples of Severity Level IV Violations," example 9 states, "A licensee fails to make a report required by 10 CFR 50.72 or 10 CFR 50.73."

Violation: Title 10 CFR 50.72(b)(3)(v) requires, in part, that the licensee shall notify the NRC as soon as practical and in all cases within eight hours of the occurrence of any event or condition that at the time of discovery could have prevented the fulfillment of the safety function of structures or systems that are needed to shut down the reactor and maintain it in a safe shutdown condition or mitigate the consequences of an accident.

Contrary to the above on July 22, 2020, the licensee failed to notify the NRC within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of the occurrence of any event or condition that at the time of discovery could have prevented the fulfillment of the safety function of structures or systems that are needed to shut down the reactor and maintain it in a safe shutdown condition or mitigate the consequences of an accident. Specifically, on July 22, 2020, the licensee failed to notify the NRC within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of the identification of the inoperability of the OPRM system, a system needed to shut down the reactor and mitigate the consequences of an accident.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Minor Violation 71152 Minor Violation: In April of 2020, Quad Cities performed Work Order 4766992 to perform OPRM setpoint changes during Refuel Outage Q2R25.

On July 22, 2020, during the performance DIV I OPRM RESPONSE TIME TEST (U2 QCIS

[Quad Cities Instrumentation Surveillance] 0700-19, Work Order 4852293), it was identified that the as-found OPRM maximum confirmation count setpoint (value of 16) on Unit 2 OPRMs did not match the value of 15 in the COLR Quad Cities 2, Revision 14, Section 7. All OPRMs for Unit 2 were declared inoperable at 10:30 a.m. on July 22, 2020. Operations entered TS LCO 3.3.1.3 Condition A for OPRMs 1-8 and Condition B for loss of trip capability. The setpoint discrepancy was corrected under Work Order 5063228-01 and declared operable on July 23, 2020 at 12:10 p.m.

The licensee's evaluation of the issue under Issue Report 4358276, "OPRM PBDA Count Setpoint Discrepancy," determined that during performance of Work Order 4766992-01, the work instructions only directed instrument maintenance department technicians to update the amplitude setpoint. The work order package did not direct technicians to update the count setpoint in accordance with the COLR Quad Cities 2, Revision 14, Section 7. The inspectors determined the lack of adequate work instructions constituted a violation of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," which requires, in part, that "activities affecting quality shall be prescribed by documented instructions and procedures of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."

Screening: The inspectors determined the performance deficiency was minor. The basis for the minor determination was similar to the basis as described in IMC 0612 Appendix E, Example 13a. Specifically, the performance deficiency could not reasonably be expected to lead to a significant event since there was no significant degradation in the safety function.

Engineering Change 632237, "Evaluation of Impact of Quad Cities Unit 2 Cycle 26 having an OPRM confirmation count setpoint of 16 through 7/23/2020," documents that there was significant margin in the online minimum critical power ratio to ensure that the existing safety analysis would have supported the maximum confirmation count of 16 along with the as installed amplitude setpoint of 1.13.

Enforcement:

This failure to comply with 10 CFR 50 Appendix B, Criterion V constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Observation: Unit 1C Residual Heat Removal Service Water Pump Seal Cooling 71152 Line Break The inspectors noted that on September 23, 2020, the licensee generated Issue Report 4371385, "Documenting a Seal Cooling Line Leak from the Unit 1C RHRSW Pump." The inspectors walked down the pump on the same day and noted that the the seal cooling line had sheared at a union elbow joint. Additionally, the inspectors noted the piping at the elbow was completely blocked with debris and/or corrosion products and discussed with the licensee. The licensee documented the as-found conditions in condition report Issue Report 4371588, "As Found Condition of 1C RHRSW Pump Seal Cooling Line Leak," on September 23, 2020. The inspectors reviewed the licensee's evaluation of the blocked piping, which stated that the vendor indicated the seal cooling function for the low pressure end of the RHRSW pump (where this cooling line leak was located) was not impacted by blocked or very low flow due to the very small flow and differential pressure normally present. The inspectors planned on reviewing the licensee's extent of condition review due to the similar operating conditions for all of the RHRSW pumps on each unit. In addition to the blockage in the cooling line, which reduced the amount of cooling flow flowing through the line, the inspectors were concerned with the extremely low flow creating an environment for accelerated corrosion in the piping that potentially was a factor in the ultimate failure of this portion of pipe. The inspectors planned to review the licensee's causal evaluation, extent of condition evaluation, and corrective actions associated with this issue in the next inspection period.

EXIT MEETINGS AND DEBRIEFS

The inspectors confirmed that proprietary information was controlled to protect from public disclosure.

• On September 30, 2020, the inspectors presented the integrated inspection results to Mr. K. Ohr, Site Vice President, and other members of the licensee staff.

• On September 11, 2020, the inspectors presented the Independent Spent Fuel Storage Installation cask loading inspection inspection results to Mr. Ken Ohr, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

60855.1 ALARA Plans QC-00-20-00205 2020 Spent Fuel Dry Cask Storage Project 04/24/2020

Calculations FSP-0058 Fuel Selection Packages for MPC-68M-639 through MPC- 04/02/2020

through FSP- 68M-645

0064

HI-2053404 Dose Versus Distance from a Single Cask at the Quad Cities 1

ISFSI

HI-2053409 HI-STORM CoC Radiation Protection Program Dose Rates 1

Limits for Quad Cities

MPC-68M-ALT- Fuel Selection Package 04/02/2020

20

QDC-0000-N- QC Cask Loader/Models and CoC Amendment 8 Update - 06/22/2015

2176 ISFSI

SL-008202 Quad Cities Generating Station Independent Spent Fuel 06/16/2017

Storage Installation Fire Hazards

Corrective Action Selected Action Requests 10/01/2018

Documents through

09/11/2020

IR 4355273 Unexpected Water Flowing out of the MPC Drain Port 07/07/2020

IR 4356432 Contamination Annulus Portion of the HI-TRAC Pool Lid 07/13/2020

Corrective Action IR 4358849 The NRC Identified a Step in the MPC Delivery Inspection 07/24/2020

Documents Procedure that was not Circled for Either Accept or Reject

Resulting from IR 4368747 During NRC Walkdown of the ISFSI Pad #1 09/11/2020

Inspection

Drawings B-2159 ISFSI Area VBS Layout 08/03/2016

Engineering EC 619023 EOC ISFSI Vehicle Barrier System Expansion 000

Changes

Miscellaneous Gamma Spectrum Analysis Results from MPC 641 Annulus 07/21/2020

Samples through

07/23/2020

Quad Cities Nuclear Power Station Units 1 and 2 Annual 05/2020

Radiological Environmental Operating Report 1 January

through 31 December 2019

Inspection Type Designation Description or Title Revision or

Procedure Date

Selected 10 CFR 72.48 Screenings 10/2018 to

09/2020

Quad Cities Suspected MPC Contamination 07/15/2020

S24 Movement of RAM >100mrem/>5mrem Inside/Outside

RCA

20 DCS Dose Estimate 06/26/2020

Max Dose Rates RWP QC-00-20-00205 09/08/2020

LMS Qualifications for PCI Personnel 07/22/2020

Quad Cities Nuclear Power Station Units 1 and 2 10 CFR 15

2.212 Evaluation Report

NDE PT Level II Personnel Certificates and Vision 05/21/2020

Examination Reports

LMS Supervisor Matrix Report 06/24/2020

Independent Spent Fuel Storage Installation Annual 04/30/2020

Radioactive Effluent Release Report

2.48-0056 72.48 Review 72.212 Evaluation Change Request 4 09/27/2010

MC-GTAW ASME Section IX Welding Procedure Specification 16

MN-GTAW ASME Section IX Welding Procedure Specification 7

914664-04 ASME Section IX Welder Performance Qualifications 04/20/2020

CY-AA-170-1001, Facility Related Dose Comparison Year 2019 1

LS-AA-114-1001 ECO 5014-270 Impact Review Holtec ECO 5014-270 R0 09/20/2018

Proposed Change to the HI-STORM 100 FSAR R15

QC-72.48-S-20- 72.48 Review MPC Processing - Forced Helium Dehydration 0

00013 BWRs

Receipt #278506, Quality Receipt Inspection Packages Gas, Helium, 99.999% 02/28/2020,

278846, 280467 Purity, Ultra High Purity 03/10/2020,

04/17/2020

RRTI 3047-01 Response to Request for Technical Information (RRTI) 06/04/2020

Holtec International

Procedures AD-AA-101-F-09 Fleet Standard Document - Corporate Approval Form OU- 08/25/2020

MW-671-200, Revision 007

CY-AA-170-1001 Environmental Dosimetry - Performance Specifications, 1

Testing, and Data Analysis

Inspection Type Designation Description or Title Revision or

Procedure Date

LS-AA-108, QCNPS 72.212 Evaluation Report Change Requests 2018-

04, and 2019-01 through 2019-05

MA-AA-716-022 Control of Heavy Loads Program 14

NF-AA-310 Special Nuclear Material and Core Component Movement 23

NF-AA-621 Classification of Fuel Assemblies for Dry Storage 6

NF-AA-622 Fuel Selection and Documentation for Dry Cask Loading 5

OU-AA-630-101 Dry Cask Storage/ISFSI Inspection Surveillance Program 02

OU-AA-630-102 Holtec HI-STORM and MPC Delivery and Fit-up/Dimensional 2

Inspections

OU-AA-630-102, MPC Fit-up/Dimensional Inspection MPC 645 2

OU-AA-630-102, HI-STORM Fit-up/Dimensional Inspection MPC 645 07/30/2019

OU-MW-671-200 MPC Processing Forced Helium Dehydration (FHD) for 6, 7

BWRs

OU-MW-671-F-01 Building Ambient Temperature Log MPC-640 06/19/2020

OU-MW-671-F-01 Building Ambient Temperature Log MPC-640 06/23/2020

PI-AA-125, Investigation/CR Quick Reference 7

QCFHP 0800-05 Spent Fuel Cask Contingency Actions - ISFSI 9

QCFHP 0800-65 Spent Fuel Cask Site Transportation 23

QCFHP 0800-69 HI-TRAC Movement Within the Reactor Building - ISFSI TIC-3594

Revision 18A

QCTP 0950-02 Holtec MPC Fuel Spacer Matrix 4

QCTS 0800-01 Integrity Surveillance for the Independent Spent Fuel Storage 4

Installation

QOS 0005-01 Operations Department Weekly Summary of Daily 165

Surveillance

RP-AA-210 Dosimetry Issue, Usage, and Control 29

RP-AA-305 Holtec HI-TRAC Radiation Survey 3

RP-AA-306 Holtec HI-STORM Radiation Survey 1

RP-AA-307 Holtec Independent Spent Fuel Storage Installation (ISFSI) 1

Radiation Survey

Inspection Type Designation Description or Title Revision or

Procedure Date

RP-AA-401, ALARA Work-In-Progress Review RWP # QC-00-20-00205 06/19/2020

RP-AA-401-1002, Radiological Risk Assessment Worksheet 2020 DCS Project 04/24/2020

Radiation 2018-029988 ISFSI 12/07/2018

Surveys 2019-051601 ISFSI 09/07/2019

20-074167 Quad Cities HI-STORM Radiation Survey 06/08/2020

20-074983 Quad Cities HI-STORM Radiation Survey 06/23/2020

20-075923 North Side 07/13/2020

20-075940 North Side 07/13/2020

20-076001 U1 Refuel Floor 07/14/2020

20-076043 U1 Refuel Floor 07/15/2020

20-076316 North Side 07/21/2020

20-076497 North Side 07/23/2020

RP-AA-305, Quad Cities HI-TRAC Radiation Survey MPC 639 06/02/2020,

06/05/2020

RP-AA-305, Quad Cities HI-TRAC Radiation Survey MPC 640 06/16/2020,

06/17/2020

Radiation Work QC-00-20-00205, Cask 1 Processing 03

Permits (RWPs) Task 1

QC-00-20-00205, Cask 1 Processing with Neutron Correction Factor 03

Task 10

Self-Assessments NOSA-COMP-18- 2018 Independent Spent Fuel Storage Installation (ISFSI) 12/19/2018

Comparative Audit Report

NOSA-QDC-18- Independent Spent Fuel Storage Installation Audit Report 11/07/2018

AR 4177275

PI-AA-126-1001- Quad Cities Spent Fuel Loading Campaign (SFLC) 03/27/2020

F-01 Readiness Assessment

Work Orders WO 4796892 Perform an Integrity Inspection of the ISFSI IAW 04/26/2019

WO 4813866 ISFSI Inspection/Assemble 10 HI-STORM/MPC Components 04/12/2019

WO 4835408 RXS Reactor Building Overhead Crane Restricted Mode Test 04/15/2020

WO 4835408 DCS Special Lifting Device 90 Day Inspection 06/22/2020

WO 4873796 ISFSI HI-TRAC Trunnion Inspection 12/20/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

WO 4873797 ISFSI MPC Lift Cleat Inspection 01/10/2020

WO 4875600 ISFSI Transporter ANSI N14.6 Inspection 01/16/2020

WO 4875601 ISFSI HI-STORM Lift Bracket Inspection 01/10/2020

WO 4893327 ISFSI Lift Yoke Inspection 12/20/2019

WO 4946161 Reactor Building Overhead Crane Annual Inspection/NDE 04/22/2020

WO 4964550 Functionality Check and Calibration of the Reactor Building 04/23/2020

Overhead Crane Lift Overload Trip

WO 4964559 EM Reactor Building Overhead Crane Annual Inspection 04/23/2020

WO 4973609 ISFSI General Dry Cask Storage Walkdown 06/02/2020

WO 5017200 ISFSI DCS Transporter Preventative Maintenance 05/21/2020

WO 5041805 Reactor Building Overhead Crane Monthly Inspection 06/05/2020

71111.04 Procedures QCOP 1000-04 RHR Service Water System Operation 022

QCOP 3900-01 Service Water System Operation 17

71111.05 Fire Plans 24-RB24 Unit 1/2 RB 690'-6" Elev. Refuel Floor - FZ 1.1.1.6 10/2013

73-TB73 Unit 1 TB 595'-0"Elev. Reactor Feed Pumps - FZ 8.2.6.A 10/2013

95-TB95 Unit 2 TB 595'-0" Elev. Reactor Feed Pumps - FZ 8.2.6.E 11/2018

FZ 11.4.B CH 595'-0" Elev. Ground Floor/Service Water 11/2018

71111.13 Corrective Action IR 4354318 U2 Instrument Air Compressor Failure 07/02/2020

Documents IR 4354319 Trip of 1/2 Instrument Air Compressor 07/02/2020

IR 859834 Documentation of 2D1 Bellows Failure Inspection and 12/23/2008

Recovery Actions

Drawings Drawing M-14 Diagram of Extraction Steam Piping AA

Engineering QDC-1-2020- Change in U1 FW Temperature

Changes 0276

71111.15 Corrective Action CAPE 4358276- OPRM PBDA Count Setpoint Discrepancy

Documents 05

IR 4354116 2-0220-2 As-Left C-14 was below the Midas Calc 07/01/2020

Requirement

IR 4356814 EO-ID: Unit 2 125 Vdc Alternate Battery Low Specific 07/15/2020

Gravity

IR 4358276 OPRM PBDA Count Setpoint Discrepancy 07/22/2020

IR 4358561 1-0220-2 OPEX Review Issues 07/23/2020

IR 4358571 2-2301-8 As Left C-14 was below the Midas Calc 07/23/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

Requirement

IR 4358834 2-0220-1 As Left C-14 was Evaluated Below Requirements 07/24/2020

IR 4360180 MO-2-0220-2 CTSB OPEX Review Results 07/31/2020

IR 4366560 U1 A/B RHR Room Cooler Inlet Piping Leak 08/31/2020

IR 4366560 U1 A/B RHR Room Cooler Inlet Piping Leak 08/31/2020

IR 4367102 Burn Through Occurred During Repair of Line 1-3958-6 09/02/2020

IR 4367102 Burn Through Occurred During Repair of Line 1-3958-6" 09/02/2020

IR 4369327 Loss of Power to ATS Panel 2201-73AA 09/14/2020

IR 4371507 NRC DBAI: Torus to RB Vacuum Breaker Design Bases 09/23/2020

IR 4371712 Operability Update for MSL Drain Isolation Valves 09/24/2020

Drawings 4E-2506 Schematic Diagram PCI System MO Valves 220-1, -2, -3, -4 W

Sheet 2

4E-2506 Schematic Diagram PCI System MOV MO 2-0220-1 Sheet 1 V

4E-7400A MOV Limit Switch Development (Critical Control Room F

Drawing)

Drawing 0250-01 Main Steam System 2

Drawing 4E-1527, High Pressure Coolant Injection System Sensors and V

Sheet 1 Auxiliary Relays

Drawing 4E-6857 Loop Schematic Functional Block Diagram Analog Trip AC

System Class 1E Instrument Upgrade

Drawing 4E- Analog Trip System - Division I, Panel 2201-73AA C

6857E

Engineering EC 632028 MO 2-0220-2 Setup with Lower Closing Thrust at Torque 08/05/2020

Changes Switch Trip than Required by the Sizing Calculation

EC 632028 M(1) 2-0220-2 Setup with Lower Closing Thrust at Torque 08/05/2020

Switch Trip than that Required by the Sizing Calculation

EC 632238 Technical Evaluation for the MOV 2-0220-2 Inertia for

Closure in the Sequoyah CTSB Issue

EC 632486 N-513-4 Evaluation for DGCW line 1-3958-6" Through-wall 0

Leak

EC 632487 Evaluation of Reinforcement Pad to Address Localized 0

Pitting on 1-3958-6-O Piping

Miscellaneous CASE N-513-4 Evaluation Criteria for Temporary Acceptance of Flaws in 05/07/2014

Inspection Type Designation Description or Title Revision or

Procedure Date

Moderate Energy Class 2 or 3 Piping Section XI, Division I

OP-AA-108-115 ASME Code Class Component Through-Wall Leak 22

Operability Determination Flow Charts

NDE Reports 20-VT2-014 PMT VT-2 on Line 1-3958-6"-O Repair 09/17/2020

20-MT -028 Patch Plate (Weld No. 1) 09/17/2020

20-UT -029 1-3958-6"-0 09/16/2020

20-UT-026 1-3958-6"-0 09/01/2020

Procedures LCO 3.6.1.3 Primary Containment Isolation Valves (PCIVs)

QCGP 1-2 Normal Unit 2 Startup 42

QDC-1-2020- ODM: Change in U1 FW Temp 0

276

71111.19 Procedures QCOS 1000-28 RHR Service Water Pump Comprehensive/Performance Test 25

Work Orders QCOS 1300-5 RCIC Pump Operability Test 57

QCOS 2300-5 HPCI Pump Operability (IST) 84

WO 5035356 RHR Service Water Pump A Flow (IST) 07/21/2020

71111.22 Corrective Action IR 4357573 EO ID: U1 EDG Engine Cooling Water Outlet Pipe Leak 07/18/2020

Documents

Procedures QCOS 1400-01 Core Spray System Flow Rate Test 50

Work Orders QCOS 1100-7 A SBLC Pump Flow Rate (IST) 40

71152 Corrective Action IR 4036374 NRC ID: FLEX Diesel Output Breaker Settings 07/27/2017

Documents IR 4358276 OPRM PBDA Count Setpoint Discrepancy 07/22/2020

IR 4364673 Investigate Cause of Repeat OOT 08/21/2020

IR 4368333 U2 RCIC Pump Trip During Flow Rate Test 09/09/2020

Corrective Action IR 4355764 Coming Paragon PRA Model Changes 07/09/2020

Documents IR 4358531 Maintenance Rule Misidentification for IR 4321603 07/23/2020

Resulting from

Inspection

25