Text

Integrated Inspection Report 05000254/2023002 and 05000265/2023002
	ML23219A202
Person / Time
Site:	Quad Cities ; (DPR-029, DPR-030)
Issue date:	08/08/2023
From:	Robert Ruiz; NRC/RGN-III/DORS/RPB1
To:	Rhoades D; Constellation Energy Generation, Constellation Nuclear
References
	IR 2023002
	Download: ML23219A202 (27)
	v • d • e

SUBJECT:

QUAD CITIES NUCLEAR POWER STATION - INTEGRATED INSPECTION REPORT 05000254/2023002 AND 05000265/2023002

Dear David Rhoades:

On June 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Quad Cities Nuclear Power Station. On July 25, 2023, the NRC inspectors discussed the results of this inspection with Brian Wake, 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. 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.

August 8, 2023 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, Robert Ruiz, Chief Reactor Projects Branch 1 Division of Operating Reactor Safety 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:

05000254/2023002 and 05000265/2023002

Enterprise Identifier:

I-2023-002-0060

Licensee:

Constellation Nuclear

Facility:

Quad Cities Nuclear Power Station

Location:

Cordova, IL

Inspection Dates:

April 01, 2023 to June 30, 2023

Inspectors:

J. Bozga, Senior Reactor Inspector

J. Cassidy, Senior Health Physicist

Z. Coffman, Resident Inspector

T. Hooker, Health Physicist

C. Hunt, Senior Resident Inspector

C. Mathews, Illinois Emergency Management Agency

A. Shaikh, Senior Reactor Inspector

Approved By:

Robert Ruiz, Chief

Reactor Projects Branch 1

Division of Operating Reactor Safety

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

Inadequate Work Instructions for High-Pressure Coolant Injection Cooling Water Pressure Control Valve Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000254,05000265/2023002-01 Open/Closed

[H.14] -

Conservative Bias 71111.12 A self-revealed finding of very low safety significance (i.e., Green) and an associated non-cited violation (NCV) of Title 10 Code of Federal Regulations Part 50, Appendix B,

Criterion V, Instructions, Procedures, and Drawings, was identified for the licensees failure to perform activities affecting quality in accordance with documented instructions, appropriate for the circumstances, associated with the maintenance and restoration of high-pressure coolant injection (HPCI) cooling water pressure control valve (PCV), 1-2301-46. Specifically, the licensee failed to have acceptance criteria, appropriate for the circumstances, to ensure that the PCV spring setting was set as required per the associated site engineering calculation following maintenance. Additionally, the maintenance work instructions failed to include activities to ensure that the PCV sensing line was properly vented prior to returning the valve to service.

Shift Staffing Below Minimum Technical Specifications Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness Green NCV 05000254,05000265/2023002-03 Open/Closed

[H.8] -

Procedure Adherence 71152A A self-revealed finding of very low safety significance (Green) and an associated non-cited violation (NCV) of both Technical Specification 5.2.2, Unit Staff, as well as Title 10 Code of Federal Regulations (CFR) 50.47, Emergency Plans, was identified when the licensee failed to staff the shift technical advisor (STA) position for greater than 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months on May 4, 2023.

Additional Tracking Items

Type Issue Number Title Report Section Status URI 05000254,05000265/2023002-02 Clarification of the Dew Point Specification for the MSA Firehawk M7XT SCBA System 71124.03 Open

PLANT STATUS

Unit 1

The unit began the inspection period shut down for the Q1R27 refueling outage. The unit began power ascension following the Q1R27 outage on April 16, 2023. The unit reached full-rated thermal power on April 20, 2023, where it remained for the rest of the inspection period, with the exception of short-term power reductions for control rod sequence exchanges, testing, and as requested by the transmission system operator.

Unit 2

The unit began the inspection period at full-rated thermal power. The unit began its shutdown on May 8, 2023, for maintenance outage Q2M30. The unit began power ascension following the Q2M30 outage on May 15, 2023. The unit was returned to full-rated thermal power on May 18, 2023, where it remained with the exception of short-term power reductions for control rod sequence exchanges, testing, and 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 activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. 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

71111.04 - 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)2A core spray equipment walkdown during residual heat removal (RHR) maintenance on April 24, 2023

(2) Unit 0 emergency diesel generator (EDG) partial walkdown during a Unit 2 EDG work window on May 1, 2023

(3) Unit 2 EDG partial walkdown on May 10, 2023

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 8.2.1.C, Unit 1 turbine building, elevation 558'-6", area below hotwell on April 9, 2023

(2) Unavailable fire risk important component walkdown during 250Vdc battery replacement on May 22, 2023

(3) Fire Zone 8.2.8.B, Unit 1/2 turbine building, elevation 639'-0" on June 22, 2023

(4) Fire Zone 8.2.8.C, Unit 1/2 turbine building, elevation 639'-0" on June 22, 2023

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the onsite fire brigade training and performance during an announced fire drill on June 1, 2023.

71111.07A - Heat Exchanger/Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) 1-6661-A and 1-6661-B EDG jacket water heat exchangers on April 1, 2023

71111.08G - Inservice Inspection Activities (BWR)

BWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding

Activities (IP Section 03.01)

Main article: IP 71111.08G

The inspectors evaluated boiling water reactor non-destructive testing by reviewing the following examinations from April 3-6, 2023:

(1) The inspectors verified that the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities:

03.01.a - Nondestructive Examination and Welding Activities

1. Magnetic particle examination on 'B' core spray pump-base weld

1402-W-204A

2. Ultrasonic examination on reactor water clean-up elbow-pipe weld 12S-S14R

3. Ultrasonic examination on reactor head meridonal weld RPV-THMS-240

4. Ultrasonic examination on reactor head meridonal weld RPV-THMS-60

5. Emergency generator cooling water pump elbow-to-pipe replacement weld

fabrication (Work Order [WO] 5196630)

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (3 Samples)

(1) The inspectors observed and evaluated licensed operator performance in the control room during the Unit 2 startup from refueling outage Q1R27 on April 16, 2023.

(2) The inspectors observed and evaluated licensed operator performance in the control room during Unit 2 down power and low power operations in preparation for maintenance outage Q2M30 on May 9, 2023.

(3) The inspectors observed and evaluated licensed operator performance in the control room during Unit 2 startup after completion of maintenance outage Q2M30 on May 15, 2023.

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

(1) The inspectors observed and evaluated licensed operator performance in the simulator during drills on June 5, 2023.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

(1) AR 4670834, "HPCI [high pressure coolant injection] Run Aborted," on April 17, 2023

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) Shutdown safety plan for Q2M30 on May 5, 2023

(2) E-2 certification meeting for work week 05/29/2023 and risk management for work week 05/22/2023 on May 22, 2023

(3) Shutdown safety and protected equipment walkdown during Q1R27 week of 04/03/2023 on April 3, 2023

(4) Shutdown safety and protected equipment walkdown during Q2M30 week of 05/08/2023 on May 13, 2023

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)

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

(1) AR 4670834, "Unit 1 HPCI Operability Determination After High Pressure Run Aborted," on April 17, 2023

(2) AR 4668661, "FME [foreign material exclusion] MO 1-2399-41 Found Nut in Seat of Valve," on April 20, 2023

(3) Cumulative effects review of lost parts in refueling outage Q1R27 on May 23, 2023

(4) Door seal leakage noted during QCTS 0440-05, "Control Room HVAC [heating, ventilation, and air conditioning] Component Inspection," on May 31, 2023

(5) AR 4665789, "U1 HPCI Control Valve Seat NDE [nondestructive examination]

Indications," on June 14, 2023

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)

(1) Unit 1 feedwater regulating valve electronic control system upgrade on April 11, 2023

(2) Unit 1 main steam isolation valve room camera cable penetration permanent mod on April 5, 2023

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (2 Samples)

(1) The inspectors evaluated refueling outage Q1R27 activities from April 1-16, 2023.

(2) The inspectors evaluated maintenance outage Q2M30 activities from May 9-15, 2023.

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:

Post-Maintenance Testing (PMT) (IP Section 03.01) (5 Samples)

(1) QCOS 0100-05, "Main Steam Isolation Valve Local Leak Rate Test," on April 6, 2023

(2) As-left local leak rate test on 1-0220-62A on April 5, 2023

(3) As-left local leak rate test on 1-0220-58A on April 5, 2023

(4) Reactor vessel class 1 and associated class 2 system leak test on April 10, 2023

(5) QCTS 0920-01, "Shutdown Margin Determination," on April 16, 2023

Surveillance Testing (IP Section 03.01) (1 Sample)

(1) Unit 1 integrated local leak rate test on April 12, 2023

Inservice Testing (IST) (IP Section 03.01) (1 Sample)

(1) Reactor core isolation cooling flow rate test comprehensive on April 17, 2023

Diverse and Flexible Coping Strategies (FLEX) Testing (IP Section 03.02) (1 Sample)

(1) Portable flex pump 'A' surveillance on April 4,

RADIATION SAFETY

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.

Instructions to Workers (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.

Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)

The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:

(1) Licensee surveys of potentially contaminated material leaving the radiologically controlled area (RCA) and workers exiting the RCA at main control point during a refueling outage

(2) Workers exiting the RCA at trackway control point during a refueling outage

Radiological Hazards Control and Work Coverage (IP Section 03.04) (4 Samples)

The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:

(1) Main steam isolation valve activities during refueling outage (RFO) Q1R27

(2) Feedwater heater repairs during RFO Q1R27

(3) Turbine building moisture separator activities during RFO Q1R27

(4) Reactor disassembly/reassembly activities during RFO Q1R27 High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (2 Samples)

The inspectors evaluated licensee controls of the following high radiation areas and very high radiation areas:

(1) Unit 1 drywell entrance

(2) Unit 2 low pressure heater bay Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)

(1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

Permanent Ventilation Systems (IP Section 03.01) (1 Sample)

The inspectors evaluated the configuration of the following permanently installed ventilation systems:

(1) Unit 0 standby gas treatment system train B

Temporary Ventilation Systems (IP Section 03.02) (1 Sample)

The inspectors evaluated the configuration of the following temporary ventilation systems:

(1) Temporary HEPA unit #1112 used for work activities associated with level control valve in Unit 1 turbine building at location D-20, 595' elevation

Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees use of respiratory protection devices.

Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)

(1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.

71124.04 - Occupational Dose Assessment

Source Term Characterization (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.

External Dosimetry (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee processes, stores, and uses external dosimetry.

Special Dosimetric Situations (IP Section 03.04) (1 Sample)

The inspectors evaluated the following special dosimetric situations:

(1) Declared pregnant worker EID BURREG6719

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10)===

Main article: IP 71151

(1) Unit 1 (May 1, 2022, through April 30, 2023)

(2) Unit 2 (May 1, 2022, through April 30, 2023)

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) May 1, 2022, through April 30, 2023 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)

(1) May 1, 2022, through April 30, 2023

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

Main article: IP 71152

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

(1) The failure to staff the shift technical advisor position documented in AR 4675690, Shift Staffing, on May 15, 2023 71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02) (1 Partial)

(1)

(Partial)

Operations department performance issues on June 21,

INSPECTION RESULTS

Inadequate Work Instructions for High-Pressure Coolant Injection Cooling Water Pressure Control Valve Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000254,05000265/2023002-01 Open/Closed

[H.14] -

Conservative Bias 71111.12 A self-revealed finding of very low safety significance (i.e., Green) and an associated non-cited violation (NCV) of Title 10 Code of Federal Regulations Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified for the licensees failure to perform activities affecting quality in accordance with documented instructions, appropriate for the circumstances, associated with the maintenance and restoration of high-pressure coolant injection (HPCI) cooling water pressure control valve (PCV), 1-2301-46. Specifically, the licensee failed to have acceptance criteria, appropriate for the circumstances, to ensure that the PCV spring setting was set as required per the associated site engineering calculation following maintenance. Additionally, the maintenance work instructions failed to include activities to ensure that the PCV sensing line was properly vented prior to returning the valve to service.

Description:

On April 17, 2023, the licensee was performing an ascent to full power following the Q1R27 refueling outage and attempted to perform QCOS 2300-27, HPCI Pump Comprehensive/Performance Test, per Technical Specification Surveillance Requirement (TSSR) 3.5.1.6, which has the licensee verify that the HPCI pump can develop a flow rate of greater than 5000 gallons per minute (gpm) against a system head corresponding to reactor pressure greater than or equal to 920 pounds per square inch gauge(psig) and less than or equal to 1005 psig. During this surveillance test, technicians in the field reported steam leaks from the flex hose connection between the gland seal exhaust condenser and the gland seal exhaust fan, as well as from the turbine gland seals themselves. As a result, operators tripped the HPCI turbine.

The licensee investigated the cause of the leaks and determined that the 1-2301-46 valve failed to open as expected. PCV 1-2301-46 is a pressure control valve that regulates the flow of cooling water supplied by the HPCI booster pump to the HPCI gland seal exhaust condenser (GSC) as well as the HPCI lube oil cooler. If PCV 1-2301-46 does not open as designed during HPCI operation, the HPCI GSC and lube oil cooler do not receive adequate cooling. The licensee performed a causal evaluation under AR 4670834 and determined that the PCV spring setting was not set to the desired value following maintenance to replace the valve diaphragm. Additionally, the licensee determined that the valve sensing line was not properly vented prior to returning the valve to service.

Specifically, for the HPCI GSC, licensee calculation QDC-2300-M-0433, Quad Cities HPCI Room Thermal Analysis Loss of Gland Seal System, states that the failure to provide cooling water to the GSC, results in the failure of the GSE subsystem. The licensee probabilistic risk assessment (PRA) notebook, QC-PSA-005.06, Quad Cities Probabilistic Risk Assessment High Pressure Coolant Injection System (HPCI) Notebook, revision 7, states that a failure of the GSE subsystem, as modeled in the sites PRA, results in the failure of the HPCI system to meet the success criteria for its credited PRA functions.

Specifically, if the GSE subsystem is not available, steam that would otherwise be condensed in the GSC has the potential to enter the equipment space. This additional heat input is not accounted for in the current licensee calculations for environment qualification of the room.

The HPCI room has a temperature sensor that is designed to trip the turbine at 155 degrees Fahrenheit. Therefore, the additional heat input from the failed GSE subsystem has the potential to cause an unwanted automatic trip of the HPCI turbine during an actual event.

Licensee calculation QDC-2300-M-0487, Determination of Pressure Setpoint for PCV 1(2)-2301-46, states that the correct setpoint for PCV 1-2301-46 is 46 psig in order to ensure a cooling flow of greater than 200 gpm to the GSC and greater than 170 gpm to the lube oil cooler. This value is also indicated on licensee drawing M-46, sheet 1, Diagram of High-Pressure Coolant Injection - HPCI Piping, which is a critical control room diagram of the HPCI system piping and a quality document. Earlier in the refueling outage on April 8, 2023, the licensee replaced the diaphragm on PCV 1-2301-46 under work order (WO) 5224911. The WO directed technicians to check the setpoint of 1-2301-46 such that the valve should be fully closed at no greater than 46 psig, after replacing the diaphragm. The technician performing the work noted that the as-found set point of the valve was 38 psig. After the diaphragm was replaced, the technician returned the valve to 38 psig and documented the as-left setting in the work package. The inspectors noted that although 38 psig was less than the required 46 psig per QDC-2300-M-0487, it was within the requirements of WO 5224911, and therefore met the acceptance criterion of the work package. During the causal evaluation, the licensee was not able to determine when the set point of 1-2301-46 changed to the as-found value of 38 psig noted by the technician prior to replacing the diaphragm.

As a part of maintenance activities to replace the diaphragm on 1-2301-46, the sensing line on the PCV must be disconnected and drained to gain access to the diaphragm and then reconnected after the diaphragm is replaced. The licensee identified in a separate issue report, AR 4673441, that air trapped in the sensing line following the diaphragm replacement of 1-2301-46 contributed to the valve being unable to control pressure as designed. Licensee procedure QCOP 2300-15, Unit 1 HPCI Preparation for Standby Operation, includes steps for filling and venting the HPCI system in preparation for return to service. QCOP 2300-15 did not direct operators to vent the sensing line for 1-2301-46. Additionally, there was no maintenance activity to fill and vent the sensing line following the diaphragm replacement in WO 5224911. As such, air was allowed to accumulate in the sensing line which prevented the valve from operating as designed.

The inspectors reviewed the licensees causal evaluation and the circumstances surrounding this issue. The inspectors noted that the work instructions for replacing the diaphragm for 1-2301-46 failed to provide adequate acceptance criteria to ensure that the PCV was set to 46 psig as required by QDC-2300-M-0487. Additionally, neither the work instruction for replacing the PCV diaphragm, nor licensee procedure for preparing the HPCI system for standby operation, contained direction to fill and vent the sensing line of 1-2301-46 prior to returning it to service. As a result, the availability, reliability, and capability of the HPCI system was adversely affected when the licensee attempted to perform surveillance testing per TSSR 3.5.1.6 to demonstrate operability of the system.

Corrective Actions: The licensee took manual actions to locally vent PCV 1-2301-46 and manually control the valve in order to restore cooling water to the GSC and lube oil cooler which allowed the completion of surveillance testing per TSSR 3.5.1.6. On April 18, 2023, the licensees readjusted the spring setting of 1-2301-46 to 46 psig per WO 5356414-01.

The licensee performed a causal evaluation under AR 4670834.

Corrective Action References:

AR 4670834, HPCI High Pressure Run Aborted AR 4673441, HPCI GSC Valve Replacement WO 5356414, Check and Adjust Setpoint Pressure 1-2301-46

Performance Assessment:

Performance Deficiency: The inspectors determined the failure to perform activities affecting quality in accordance with documented instructions, appropriate for the circumstances, associated with the maintenance and restoration of PCV 1-2301-46 following a diaphragm replacement was a performance deficiency. Specifically, the inspectors determined that the licensee failed to include adequate acceptance criteria to ensure that PCV 1-2301-46 was set to 46 psig per engineering calculation QDC-2300-M-0487. In addition, the licensee failed to include venting activities for the PCV sensing line following maintenance.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance 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. Specifically, PCV 1-2301-46 did not operate as designed during surveillance testing because of degraded conditions introduced during diaphragm replacement. These degraded conditions required additional maintenance activities to correct to restore the valve to full function.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.

Cross-Cutting Aspect: H.14 - Conservative Bias: Individuals use decision making-practices that emphasize prudent choices over those that are simply allowable. A proposed action is determined to be safe in order to proceed, rather than unsafe in order to stop. Specifically, the work instructions for the 1-2301-46 diaphragm replacement contained non-conservative acceptance criteria which allowed the PCV spring to be set at a value below that which was required by engineering calculation QDC-2300-M-0487 but still meet the acceptance criteria of the work order.

Enforcement:

Violation: Appendix B to 10 CFR Part 50, Criterion V, Instructions, Procedures, and Drawings, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, 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.

Contrary to the above, on April 8, 2023, the licensee performed maintenance on PCV 1-2301-46, a safety-related component within the High-Pressure Coolant Injection system, using written instructions in WO 5224911 that did not contain acceptance criteria appropriate for the circumstances to ensure that the valves spring tension was set as documented in engineering calculation QDC-2300-M-0487. Additionally, maintenance work instructions failed to include activities for filling and venting of PCV 1-2301-46 sensing line after the diaphragm was replaced.

As a result, on April 17, 2023, PCV 1-2301-46 failed to operate as required during surveillance testing.

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

Unresolved Item (Open)

Clarification of the Dew Point Specification for the MSA Firehawk M7XT SCBA System URI 05000254,05000265/2023002-02 71124.03

Description:

In Subpart H of 10 CFR Part 20, the USNRC established oversight of respiratory protection programs used for radiation protection purposes by NRC licensees. Nuclear Regulatory Commission regulations require that NRC licensees use NIOSH approved equipment in their respiratory protection programs, or that they obtain approval from the USNRC to use equipment that has not been approved by NIOSH. NIOSH regulations and guidance state that user instructions are included as part of the NIOSH approval.

The inspectors identified that the FireHawk M7XT cylinders were filled with Grade D air with a dew point of -50 F. Upon review of the user instructions that pertain to the FireHawk M7XT SCBA system, the inspectors identified several inconsistencies regarding the specification that applies to dew point. In general, the user instructions direct users to use Grade D quality air, as defined by the Compressed Gas Association, Commodity Specification for Air, (or better); however, in certain locations a further specification is added that the dew point of the supplied air be -65 F.

The specification of a dew point value in the user instructions that differs from the dew point guidance that applies to Grade D air implies that it is an additional restriction that is required to satisfy the NIOSH certification requirements that pertain to the equipment. However, the licensee has obtained guidance from an MSA sales representative that supplied air with a dew point of -50 F is of sufficient quality to operate the FireHawk M7XT SCBA in accordance with the NIOSH approval (the -50 F dew point would align with the guidance that applies to Grade D air). This is problematic because vendors are not allowed to authorize use of their equipment outside of the bounds of the NIOSH approval. At this point, it is not clear if the NIOSH approval is contingent upon the dew point guidance that applies to Grade D air, or a dew point of -65 F. It does not appear that there is an immediate safety concern with the continued use of these SCBAs based on their environment of use. However, continued long-term use without clarification of this issue does not seem tenable because the user instructions are not clear on the specifications that apply to certified safe use of the equipment and might be in violation of NRC regulations for the use of respiratory protection.

Planned Closure Actions: NRC Program office (NRR/DRA/ARCB) will work with the FireHawk M7XT vendor, MSA, and, potentially, NIOSH to clarify the dew point requirement for the FireHawk M7XT SCBA system and assess the impact of the differing air quality descriptions in the user instructions for the FireHawk M7XT SCBA system on compliance with NRC requirements.

Licensee Actions: No action is required at this time.

Corrective Action References: AR 4683815 Shift Staffing Below Minimum Technical Specifications Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness Green NCV 05000254,05000265/2023002-03 Open/Closed

[H.8] -

Procedure Adherence 71152A A self-revealed finding of very low safety significance (Green) and an associated non-cited violation (NCV) of both Technical Specification 5.2.2, Unit Staff, as well as Title 10 Code of Federal Regulations (CFR) 50.47, Emergency Plans, was identified when the licensee failed to staff the shift technical advisor (STA) position for greater than 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months on May 4, 2023.

Description:

On May 4, 2023 at 9:38 p.m., the relieving operating crew arrived to take the shift and discovered that there had been no one stationed as the STA for greater than 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months at the site. The licensee performed a causal evaluation of this issue under AR 4675690.

NUREG-0737, Clarification of TMI Action Plan Requirements, states that certain deficiencies may exist in the level of technical expertise generally available to the shift operating staff prior to, during, and immediately after an accident or severe plant transient. As such, NUREG-0737 establishes the role of the STA as the position at a nuclear power plant established to evaluate plant conditions and provide advice to the shift supervisor during plant transients and accidents. Inherent in the STA function is the detection and reporting of potential safety problems. Accordingly, licensee TS 5.2.2.f states that the STA shall provide advisory technical support to the shift manager in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit.

Additionally, licensee procedure EP-AA-1000, Standardized Radiological Emergency Plan, states that during an abnormal condition, the shift manager assumes direct supervision of personnel and all activities in the control room while a qualified individual steps back and assumes an overview role as an STA with the specific responsibility of monitoring the maintenance of core cooling and containment integrity. An individual assigned the duty as the STA shall be available to the control room at all times.

Licensee procedure OP-AA-112-101, Shift Turnover and Relief, states that STA turnover responsibilities include initiating a turnover sheet, performing a turnover in the main control room, ensuring the STA position is filled by a qualified individual, and announcing the completion of the turnover to the unit supervisors and shift manager, to include how the STA can be contacted.

The inspectors reviewed the circumstances around the event, and the licensee's causal evaluation, and determined that there were several examples of individuals failing to perform watch turnover in accordance with licensee procedure OP-AA-112-101. Specifically, on May 4, 2023, the off-going STA failed to meet the requirements of OP-AA-112-101 when the individual turned over the responsibilities of the work execution center supervisor to another individual qualified senior reactor operator, but not qualified STA, and then inadvertently logged in the stations electronic log a different individual as the relieving STA with whom a turnover was not performed.

After realizing the error, the off-going STA attempted to perform a verbal turnover with the Unit 2 supervisor, who was qualified STA, but again failed to meet the requirements of OP-AA-112-101. As a result, the STA responsibilities were never formally transferred between the off-going and on-coming shifts and the logging error was never corrected. In addition, the shift manager was not made aware of whom, if anyone, was filling the STA position. The last remaining STA-qualified individual left the site at 5:29 p.m., unaware that there were no other qualified individuals on site to fill the position. This error was not caught by any of the remaining on-shift personnel until the next STA-qualified individual arrived on site at 9:38 p.m.

for shift turnover. As such, the inspectors determined that the STA position not being stationed for greater than 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months was a performance deficiency.

Corrective Actions: The licensee performed a causal evaluation under AR 4675690.

Corrective Action References: AR 4675690, Shift Staffing

Performance Assessment:

Performance Deficiency: The inspectors determined that the failure to meet the minimum staffing requirements for on-shift personnel for greater than 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the ERO Readiness attribute of the Emergency Preparedness cornerstone and adversely affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix B, Emergency Preparedness SDP. The inspectors screened the issue using IMC 0609, Appendix B, Section 5.2, 10 CFR 50.47(b)(2), Onsite Emergency Organization, and determined that this finding was of very low safety significance (Green).

Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions. Specifically, the off-going STA erroneously logged an individual qualified STA as having assumed the STA position but having never actually received a turnover per the licensee's turnover procedure. Once the error was identified, the off-going STA attempted a verbal turnover with the Unit 2 supervisor but again failed to turn over the STA responsibilities as outlined by the licensees turnover procedure.

Enforcement:

Violation: Title 10 CFR 50.47(b)(2) states that on-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified. Licensee procedure EP-AA-1000, Standardized Radiological Emergency Plan, is the governing document for how the site meets the requirements of 10 CFR 50.47, to include 10 CFR 50.47(b)(2). EP-AA-1000, section B, part 1, lists the required personnel for the emergency response organization, and states in part, that an individual assigned the duty as the STA shall be available to the control room at all times.

Technical Specification 5.2.2.b. states that shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and Specifications 5.2.2.a and 5.2.2.f for a period of time not to exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.

Quad Cities procedure QAP 0300-03, Operations Shift Staffing, covers the requirements of Technical Specification 5.2.2 as well as 10 CFR 50.47(b)(2). QAP 0300-03, section C.9, states, in part, that the STA is to be within 10 minutes of the control room.

Contrary to the above, on May 4, 2023, from 5:29 p.m. to 9:38 p.m. there was no qualified STA on site for greater than 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

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

EXIT MEETINGS AND DEBRIEFS

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

On July 25, 2023, the inspectors presented the integrated inspection results to Brian Wake, Site Vice President, and other members of the licensee staff.

On April 6, 2023, the inspectors presented the radiation protection inspection results to W. K. Akre, Sr. Manager Site Radiation Protection, and other members of the licensee staff.

On April 6, 2023, the inspectors presented the inservice inspection results to Adnan Ali, Engineering Director, and other members of the licensee staff.

On July 7, 2023, the inspectors presented the radiation protection inspection results to W. K. Akre, Sr. Manager Site Radiation Protection, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

QCOS 0005-08

Unit 1 Electrical Distribution Breaker and Voltage Verification

QCOS 0005-09

Unit Two Electrical Distribution Breaker and Voltage

Verification

QCOS 1400-01

Core Spray System Flow Rate Test

Procedures

QCOS 6600-43

Unit 1/2 Emergency Diesel Generator Load Test

WO 5324924

Core Spray Pump A Flow Rate Test (IST)

03/27/2023

WO 5345621

Diesel Generator Load Test (IST)

03/28/2023

71111.04

Work Orders

WO 5349048

Diesel Generator Load Test

04/26/2023

FZ 1.1.2.3

Unit 2 RB 623'-0" Elev. Mezzanine Level

08/01/2022

FZ 3.0

SB 609' Elev. Cable Spreading Room

08/01/2022

FZ 4.0

SB 595' Elev. Computer Room in Auxiliary Electric Room

08/01/2022

FZ 6.3

SB 595' Elev. Auxiliary Electric Room

08/01/2022

FZ 8.2.5

Unit 1/2 TB 580' Elev. U-2 Cable Tunnel

08/01/2022

FZ 8.2.6.E

Unit 2 TB 595' Elev 4KV Switchgear & Trackway Area

11/01/2022

FZ 8.2.7.D

Unit 2 TB 615' Low Pressure Heater Bay East / D Heater

Bay

08/01/2022

FZ 8.2.7.D

Unit 2 TB 608'-6" Elev. Low Pressure Heater Bay West

08/01/2022

FZ 8.2.8.B

Unit 1/2 Tb 639'-0" Elev. 480V SG

R. 18/19, 4KV SWGR. 13-

MG Set 1A

08/2022

Fire Plans

FZ 8.2.8.C

Unit 1/2 Tb 639'-0" Elev. 480V SG

R. 28/29, 4KV SWGR. 24-

MG Set 2B

08/2022

Miscellaneous

23-2-#2

Fire Drill Scenario No. 2023 #2

06/01/2023

71111.05

Procedures

OP-QC-012-1001

Quad Cities On-Line Fire Risk Management

Corrective Action

Documents

AR 4666387

Q1R27: U1 EDGCW Piping to HX Weld Buildup Required

03/31/2023

Engineering

Changes

EC 362215

Diesel Generator Heat Exchanger Fouling Limit

001

WO 4921308

Open/Inspect Diesel Generator HX

03/31/2023

71111.07A

Work Orders

WO 4921310

Open/Inspect Diesel Generator HX

03/31/2023

Q1R27-MT-004

Core Spray Room B Pump-Base Plate MT

03/30/2023

71111.08G

NDE Reports

Q1R27-UT-026

REGEN HX Elbow-Pipe Weld UT

03/30/2023

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Q1R27-VEN-009

RPV-THMS-60 Weld UT

04/03/2023

Q1R27-VEN-012

RPV-THMS-240 Weld UT

04/03/2023

ER-AA-335-002

Liquid Penetrant Examination

2

ER-AA-335-003

Magnetic Particle Examination

010

GEH-PDI-UT-1

PDI GENERIC PROCEDURE FOR THE ULTRASONIC

EXAMINATION OF FERRITIC WELDS

2.1

GEH-PDI-UT-2

PDI GENERIC PROCEDURE FOR THE ULTRASONIC

EXAMINATION OF AUSTENITIC PIPE

WELDS

Procedures

WPS-8.8 GTSM

ASME Welding Procedure Specification Record

CLP Quad Cities

Quad Cities Unit 2 Cycle 27 Core Loading Plan

NF-AB-720

Control Rod Sequence Package Preparation, Review,

Revision, and Implementation

NF-AB-720-1000

Startup, Shutdown, and Target Rod Pattern Sequence

Package Development

71111.11Q

Procedures

NF-QC-721

Control Rod Sequences and Forms

Corrective Action

Documents

AR 4670834

HPCI High Pressure Run Aborted

04/17/2023

Drawings

M-46

Unit 1 Diagram of High-Pressure Coolant Injection - HPCI

Piping

05/05/1998

ER-AA-2008

MSPI Failure Determination

ER-AA-320-1004

Maintenance Rule 18-10 - Performance Monitoring and

Dispositioning between (a)(1) and (a)(2)

Procedures

TIC 3712

Unit 1 HPCI Preparation for Standby Operation

17a

WO 5224911

MM Replace 1-2301-46 Valve Actuator Diaphragm

04/08/2023

71111.12

Work Orders

WO 536414

MM Check and Adjust Setpoint Pressure 1-2301-46

04/18/2023

EC 638380

Q1R27 Decay Heat Related Calculations

Engineering

Changes

QC-MISC-046

Technical Specification Limiting Condition for Operation

3.0.10 Risk Evaluation for Removal of Watertight/Bulkhead

Door 1-0030-245

Procedures

QCOP 1000-44

Alternate Decay Heat Removal

71111.13

Self-Assessments Q1R27 Shutdown

Safety Plan

Shutdown Safety Plan for Unit 1 Refueling Outage

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Q2M30 Shutdown

Safety

Management

Plan

Shutdown Safety Plan for the maintenance outage.

05/03/2023

Work Orders

WO 5308155

DG Cooling Water Pump Group B Flow (IST)

2/03/2023

AR 4665789

U1 HPCI Control Valve Seat NDE Indications

03/29/2023

AR 4666631

PSU: OPS ID: MCC 1B BREAKER M02 ISSUES

03/31/2023

AR 4667418

PSU:Q1R27 HPCI MO 1-2399-41 Exceeded Required Action

Limit

04/04/2023

AR 4668259

PSU: Q1R27 MOV 1-2399-41 Overthrust during IR4666631

03/31/2023

AR 4668661

FME MO 1-2399-41 Found Nut in Seat of Valve

04/09/2023

AR 4669438

PSU Action Required to Determine Source of FM in IR

04668661

04/12/2023

AR 4670429

FME from 1-2399-67 Check Valve

04/16/2023

AR 4670834

HPCI High Pressure Run Aborted

04/17/2023

AR 4680683

Control Room Double Door 0-0075-89 Seal Leaks

05/25/2023

AR 4680684

Control Room Back Door 0-0075-92 Seal Leaks

05/25/2023

Corrective Action

Documents

AR 4680687

Cable Spreading Room Door 0-0075-80 Seal Leaks

05/25/2023

Drawings

M-46, Sheet 1

Diagram of High-Pressure Coolant Injection - HPCI Piping

05/05/1998

EC 392888

Indications on U1 HPCI turbine control valve disks and

seats.

EC 638782

Cumulative Effects Review of Lost Parts in Q1R27 IAW ER-

AA-2006

Engineering

Changes

ECR 457457

Engineering review NDE acceptance criteria for HPCI control

valve seats and disc and determine criteria when

replacement is required.

Miscellaneous

STN 22-017

Distinction Between Operability & Availability

MA-AA-716-012

Post Maintenance Testing

QCGP 1-1 T01

Startup Path Flowchart

Procedures

QCTS 0440-05

Control Room HVAC Component Inspection

WO 1529815

PCV 1-2301-46 Found Full Closed

2/10/2022

71111.15

Work Orders

WO 5224911

Replace 1-2301-46 Diaphragm

2/16/2022

71111.18

Engineering

EC 633550

MSIV Room Camera Cable Installation (Unit 1)

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Changes

CC-AA-302

Control of the Cable Management Database

Procedures

ER-AA-300-150

Cable Condition Monitoring Program

NSWP-S-04,

Appendix II

Approved Air-Seals and Fire Stop Details for Dresden, Quad

Cities, and Zion Stations

WO 5129054

U1 - MSIV Room Camera Cable Penetration Per EC 633550

08/18/2022

Work Orders

WO 5273151

U1 Upgrade FRV 5100 Electronic Control Sys EC 635736

Corrective Action

Documents

AR 4678109

Indications Discovered on Sealing Surface of RPV Flange

05/14/2023

Preliminary Summary Report for Torus Immersion Area

Work Activities - Rev -1

WO 05147231-1 and 05194931-02

04/07/2023

01-RI-

MECHWRK-003D

Unit 1 RCIC Tagout for Mechanical Work

04/08/2023

Miscellaneous

N-AN-AA-

FATIGUE-

ASSESSOR

Qualification Tracker for Staff that can do Fatigue

Assessments

LS-AA-119

Fatigue Management and Work Hour Limits

OU-QC-104

Shutdown Safety Management Program Quad Cities Annex

OU-QC-104,

Risk Factor Chart - Mode 4, 5, and Defueled

05/12/2023

QCAP 0260-03

Screening For Reactor Pressure Vessel Water Inventory

Control

QCOP 1000-17

Shutdown Cooling, Reactor Temperature Trending

Procedures

QCOP 1000-43

Bypassing Reactor Shutdown Cooling Isolation

Q2M30 Daily

Shutdown Safety

Report for

05/13/2023

Daily Shutdown Safety Report for the Unit 2 Maintenance

Outage

05/13/2023

Self-Assessments

Q2M30 Shutdown

Safety

Management

Plan

Shutdown Safety Plan for Quad Unit 2 Maintenance Outage

for May, 2023

05/08/2023

71111.20

Work Orders

WO 1937782

Rx Vessel Temperature Recorder

2/30/2019

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

WO 4836181

Reactor High Pressure Recorder Alarm

03/22/2020

WO 5308737

CRD SCRAM Timing in Hot Condition (IST)

05/16/2023

AR 4666834

PSU Q1R27 1-0220-62A Exceeded Required Action

Leakage

04/01/2023

Corrective Action

Documents

AR 4669047

PSU Q1R27 RCPB Class 1 Extended Boundary System

Leakage Test

04/11/2023

Engineering

Changes

ECR 418127

FW CV LLRT Application of EC 384872

03/21/2015

Miscellaneous

ILRT Interim

Report

Quad Cities ILRT Interim Report

04/16/2023

AD-AA-101-F-10

Unit 1 ILRT Pre-Test Procedure

2

QCOS 0100-05

Main Steam Isolation Valve Local Leak Rate Test

QCOS 0100-07

Feedwater Check Valve Local Leak Rate Test CK 1(2)-0220-

58A/B, CK 1(2)-0220-62A/B

QCOS 4100-36

Emergency Portable Pump (EPP) Surveillance

QCTP 0130-01

Primary Containment Leak Rate Testing Program

QCTS 0500-11

Unit 1 Primary Containment Integrated Leak Rate Test

(ILRT)

QCTS 0500-13

Unit 1 ILRT Pre Test Procedure

QCTS 0500-14

Unit 1 ILRT Engineering Pre-Test Procedure

Procedures

QCTS 0500-15

Operations Department Unit 1 ILRT Post Test Procedure

5356547

RCIC LP Flow Rate Test

04/16/2023

WO 5140017

Reactivity Margin (Shutdown Margin)

04/16/2023

WO 5149307

Reactor Vessel and Class One Piping Leak Test (ISI)

04/10/2023

71111.24

Work Orders

WO 5217428

RCIC Flow Rate Test Comprehensive Test (IST)

04/17/2023

AR 4565406

Unplanned Spread of Contamination - RB 595'

03/28/2023

Corrective Action

Documents

AR 4667833

INPO ID: Fallen RP Boundary

04/05/2023

Corrective Action

Documents

Resulting from

Inspection

AR 4668312

NRC ID: RWP Discrepancies

04/07/2023

71124.01

Miscellaneous

QC-01-23-00541

Associated ALARA Files for DW Inboard MSIV Overhaul

Q1R27

Multiple

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

23-190372