IR 05000254/2024003
| ML24313A198 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 11/12/2024 |
| From: | Nestor Feliz-Adorno NRC/RGN-III/DORS/RPB1 |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| EPID I-2024-003-0066, EPID I-2024-001-0129 IR 2024003, IR 2024001 | |
| Download: ML24313A198 (1) | |
Text
SUBJECT:
QUAD CITIES NUCLEAR POWER STATION - INTEGRATED INSPECTION REPORT 05000254/2024003; 05000265/2024003 AND 07200053/2024001
Dear David Rhoades:
On September 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Quad Cities Nuclear Power Station. On October 24, 2024, the NRC inspectors discussed the results of this inspection with Doug Hild, 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.
November 12, 2024 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, Néstor J. Féliz Adorno, Chief Reactor Projects Branch 1 Division of Operating Reactor Safety Docket Nos. 05000254; 05000265; 07200053 License Nos. DPR-29 and DPR-30
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000254; 05000265; 07200053
License Numbers:
Report Numbers:
05000254/2024003; 05000265/2024003; 07200053/2024001
Enterprise Identifier:
I-2024-003-0066 and I-2024-001-0129
Licensee:
Constellation Nuclear
Facility:
Quad Cities Nuclear Power Station
Location:
Cordova, IL
Inspection Dates:
July 01, 2024, to September 30, 2024
Inspectors:
N. Audia, Reactor Inspector
Z. Coffman, Resident Inspector
C. Hunt, Senior Resident Inspector
M. Learn, Acting Branch Chief
J. Meszaros, Resident Inspector
T. Okamoto, Project Engineer
N. Shah, Senior Project Engineer
Approved By:
Néstor J. Féliz Adorno, 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
Failure to Identify a Negative Low Safety Significant Trend in 10 CFR 50.65(a)(3)
Periodic Assessment Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000254,05000265/2024003-01 Open/Closed
[H.14] -
Conservative Bias 71111.12 The inspectors identified a Green finding and associated Non-Cited Violation (NCV) of 10 CFR 50.65(a)(3) for the licensees failure to evaluate performance and condition monitoring activities and associated goals and preventative maintenance activities for the emergency core cooling system (ECCS) keep fill system for the assessment period of May 1, 2022, through May 1, 2024. Specifically, the licensee did not recognize a low safety significance (LSS) negative trend. As a result, the licensee failed to adjust the associated maintenance strategy.
Inadvertent Operation of Reactor Core Isolation Cooling System in an Unanalyzed Low-Flow Condition Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000254,05000265/2024003-02 Open/Closed
[H.12] - Avoid Complacency 71152A A self-revealed Green finding and associated Non-Cited Violation (NCV) of Technical Specification (TS) 5.4.1.a, Procedures, was identified for the licensees failure to establish a procedure for calibrating the Unit 2 reactor core isolation cooling (RCIC) turbine governor.
As a result, equipment operators incorrectly shut valve 2-1301-53 while setting up conditions to perform the calibration, isolating the discharge path for the RCIC pump, and inadvertently inducing an unanalyzed low-flow condition.
Additional Tracking Items
None.
PLANT STATUS
Unit 1 Unit 1 began the inspection period at full-rated thermal power, 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 for the entire inspection period.
Unit 2 Unit 2 began the inspection period at full-rated thermal power. On July 3, 2024, the unit was down powered to approximately 60 percent by the control room operators due to flooding underneath the hotwell, initiated by a broken ventilation pipe from the main condenser waterbox. After repairs were complete, the unit was returned to full-rated thermal power on July 3, 2024. On September 26, 2024, the Unit 2B recirculation pump tripped, and the unit was down powered to approximately 30 percent by the control room operators. The unit was returned to full power on September 28, 2024, 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 for the remainder of the inspection period.
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 onsite 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) (1 Sample)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 1 emergency diesel generator cooling water system during planned work on the 1/2 emergency diesel generator cooling water system on July 29, 2024 Complete Walkdown Sample (IP Section 03.02) (1 Partial)
(1)
(Partial)
The inspectors evaluated system configurations during a complete walkdown of the Unit 2 reactor core isolation cooling (RCIC) system on August 22, 2024.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (2 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 1.1.1.2, Unit 1, elevation 595', ground floor on July 2, 2024
- (2) Fire Zone 9.1, Unit 1, elevation 595', diesel generator room on September 4, 2024
71111.06 - Flood Protection Measures
Flooding Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated internal flooding penetrations in the Unit 2 high pressure coolant injection room on August 27, 2024.
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 a Unit 2 2B recirculation pump trip on September 26, 2024.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator requalification training on July 8, 2024.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (4 Samples 1 Partial)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
(1)control room heating, ventilation, and air conditioning (HVAC) train A maintenance rule monitoring plan on July 23, 2024
- (2) Action Request (AR) 4699810, HPCI [high pressure coolant injection] Condensate Pump Did Not Auto Start, on July 29, 2024
- (3) Maintenance Rule 10CFR 50.65(a)(3) evaluation for May 2022 through May 2024, on August 7, 2024
- (4) AR 4784746, 902-7 D-10 Condenser Pit Low Level, on August 29, 2024 (5)
(Partial)
AR 4680534, Safe Shutdown Makeup Pump Room Cooling Circuit 1, on August 13, 2024
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (3 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)fire risk equipment walkdown during Unit 2 station blackout diesel work window on August 14, 2024 (2)risk management for work week 09/16/2024 on September 16, 2024 (3)risk management for work week 09/23/2024 on September 23, 2024
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)
The inspectors evaluated the licensees justifications and actions associated with the following operability determinations and functionality assessments:
- (1) AR 4761088, Change in U2 250 VDC [Volts direct current] Battery Discharge Test Performance, on July 10, 2024
- (2) AR 4760456, OSP 2-1301-49 Local Control Station Did Not Work, on July 23, 2024
- (3) Engineering Change 641961, Reactor Core Isolation Cooling Operability Evaluation Following Greater Than 10 Seconds with Low Flow, on August 1, 2024
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 Partial)
- (1) PMT associated with the Unit 1 station blackout diesel generator following a planned work window on July 24, 2024
- (2) PMT associated with the Unit 2 station blackout diesel generator following a planned work window on August 16, 2024
- (3) PMT associated with the Unit 1/2 emergency diesel generator following a planned work window on September 18, 2024
- (5) PMT associated with Unit 1 core spray Agastat timing relay maintenance on September 11, 2024 (6)
(Partial)
PMT associated with the Unit 1 250 Vdc battery cell 76 replacement on September 23, 2024
Surveillance Testing (IP Section 03.01) (5 Samples)
- (1) QCOS 6600-42, Unit 2 Emergency Diesel Generator Monthly Load Test, on July 2, 2024 (2)calibration of the Unit 2 RCIC flow switch, 2-1360-7, on July 24, 2024
- (3) QCOS 5750-02, Control Room Emergency Filtration System Test, and QCOS 5750-04, Quarterly Testing of Control Room HVAC System Valves and Dampers, on August 14, 2024
- (4) QCOS 1400-15, Unit 1 Division I Core Spray Logic Functional Test, on September 11, 2024
- (5) QCOS 1300-05, RCIC Pump Operability Test, on September 19, 2024
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
71114.06 - Drill Evaluation
Additional Drill and/or Training Evolution (1 Sample)
The inspectors evaluated:
- (1) emergency preparedness performance indicator/focused drill on August 1,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS07: High Pressure Injection Systems (IP Section 02.06)===
- (1) Unit 1 (October 1, 2023, through June 30, 2024)
- (2) Unit 2 (October 1, 2023, through June 30, 2024)
MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)
- (1) Unit 1 (October 1, 2023, through June 30, 2024)
- (2) Unit 2 (October 1, 2023, through June 30, 2024)
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) AR 4778839, QCAN 902-4 E-16 Received During QCOS 1300-05, June 27, 2024
===71153 - Follow-Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02) (1 Partial)
The inspectors evaluated the following licensees event reporting determinations to ensure it complied with reporting requirements.
(1)
(Partial)
Licensee Event Report 05000265/2024-001-00, Automatic Actuation of Reactor Protection System During Scram Discharge Volume Leak Rate Testing (Agencywide Documents and Management System [ADAMS] Accession No. ML24131A015)
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 60855 - Operation of an ISFSI Operation of an ISFSI===
- (1) The inspectors evaluated the licensees independent spent fuel storage installation (ISFSI) cask loading activities from July 8 through July 12, 2024.
Specifically, the inspectors observed the following activities during the loading of Multi-Purpose Canister (MPC) No. 830:
- closure welding and non-destructive evaluations
- forced helium dehydration
- heavy load lift into stack-up configuration
- downloading loaded MPC into overpack
- radiological field surveys The inspectors performed walkdowns of the ISFSI pad, which also included performing independent radiation surveys and walkdowns of the ISFSI haul path.
The inspectors evaluated the following:
- spent fuel selected for loading into dry cask storage during this loading campaign
- selected corrective action program documents
- selected 72.48 screenings and evaluations
- changes to the sites 10 CFR 72.212 report since the previous inspection
INSPECTION RESULTS
Failure to Identify a Negative Low Safety Significant Trend in 10 CFR 50.65(a)(3)
Periodic Assessment Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000254,05000265/2024003-01 Open/Closed
[H.14] -
Conservative Bias 71111.12 The inspectors identified a Green finding and associated Non-Cited Violation (NCV) of 10 CFR 50.65(a)(3) for the licensees failure to evaluate performance and condition monitoring activities and associated goals and preventative maintenance activities for the emergency core cooling system (ECCS) keep fill system for the assessment period of May 1, 2022, through May 1, 2024. Specifically, the licensee did not recognize a low safety significance (LSS) negative trend. As a result, the licensee failed to adjust the associated maintenance strategy.
Description:
The ECCS keep fill system includes a jockey pump that draws water from the suction line of the core spray pump and discharges it to the discharge piping downstream of the core spray pump discharge check valves. This configuration ensures that the discharge piping of both the core spray and the residual heat removal systems remains full of water. If an ECCS initiation signal were to occur while the piping was not full, it could lead to system damage due to water hammer upon pump startup.
Maintenance rule function CS1400-04 requires that the keep fill system keep the discharge piping of the core spray and residual heat removal systems full of water. This function is classified as an LSS function according to licensees procedure ER-AA-320, Maintenance Rule Implementation Per NEI 18-10, Revision 00. An LSS event under CS1400-04 is indicated if the jockey pump fails such that it is unable to maintain system pressure.
On August 3, 2024, during their review of the licensees most recent maintenance rule (a)(3)periodic assessment for the period of May 1, 2022, through May 1, 2024, inspectors identified that the licensee did not recognize three LSS events associated with maintenance rule function CS1400-04. These events were documented in issue reports [ARs] ARs 4687703, 4727804, and 4755803. Following an event on June 29, 2023, documented in AR 4687703, inspectors questioned the evaluation criterion for function CS1400-04, as it only classified events as LSS if the jockey pump itself failed, not if other conditions prevented the keep fill system from maintaining pressure. As documented in AR 4687703, a degraded check valve in the discharge path of the jockey pump caused a loss of the CS1400-04 function without a failure of the pump, highlighting a gap in the evaluation process.
These concerns were documented in AR 4710599, which prompted the licensee to benchmark other sites evaluation criteria. Although the original due date for these actions was January 19, 2024, it was extended multiple times and ultimately completed on September 18, 2024. During this extended period, the licensee did not identify and evaluate two additional LSS events documented in ARs 4727804 and 4755803, both of which involved a loss of pressure. The event in AR 4755803 resulted in the core spray system becoming unavailable due to the pressure in the associated discharge piping dropping below the minimum calculated pressure requirements. In both AR 4727804 and AR 4755803, the licensee documented degraded conditions where the discharge check valve of the associated core spray pump failed to reseat following surveillance testing, leading to the loss of function CS1400-04 while the keep fill system jockey pump was still running.
Since the licensee did not recognize these events under ARs 4687703, 4727804, and 4755803 as LSS events during the assessment period, a necessary change to the maintenance strategy was not considered.
Corrective Actions: The licensee reevaluated maintenance rule function CS1400-04 under AR 4801016 and determined that an LSS trend existed. The function was subsequently taken to (a)(1) status.
Corrective Action References: AR 4801016, Required Actions for Maintenance Rule Core Spray Function
Performance Assessment:
Performance Deficiency: The inspectors determined that the failure to evaluate performance and condition monitoring activities and associated goals and preventative maintenance activities for maintenance rule function CS1400-04 for the assessment period of May 1, 2022, through May 1, 2024, was contrary to 10 CFR 50.65(a)(3) and was a performance deficiency.
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, adjustments to the maintenance program were warranted but not completed due to the failure to perform the periodic 50.65(a)(3) evaluation.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.
The inspectors screened the finding in accordance with IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, Section A, and answered No to all of the screening questions. Therefore, the finding screens to very low safety significance (Green).
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 licensee extended the completion date for benchmarking other sites evaluation criteria after the inspectors raised concerns about its adequacy beyond the closure date of the maintenance rule assessment period, neglecting to consider how these delays compromised compliance to the maintenance rule. In addition, under ARs 4687703 and 4755803, the licensee rationalized their assumptions, claiming that because the system was inoperable during surveillance testing when the loss of function occurred, subsequent satisfactory test results meant no LSS event had occurred. This nonconservative approach led to the failure to identify LSS events during the periodic maintenance rule assessment.
Enforcement:
Violation: 10 CFR 50.65 (a)(3) requires, in part, that performance and condition monitoring activities and associated goals and preventive maintenance activities shall be evaluated at least every refueling cycle provided the interval between evaluations does not exceed 24 months. Adjustments shall be made where necessary to ensure that the objective of preventing failures of structures, systems, and components through maintenance is appropriately balanced against the objective of minimizing unavailability of structures, systems, and components due to monitoring or preventive maintenance.
Licensee procedure ER-AA-320, Maintenance Rule Implementation Per NEI 18-10, Revision 00, and the associated sub procedures describe how the licensee implements the requirements of 10 CFR 50.65. Licensee procedure ER-AA-320-1007, Maintenance Rule 18-10 - Periodic (a)(3) Assessment, Revision 1, provides the requirements to complete the Maintenance Rule periodic (a)(3) assessment specified in ER-AA-320. ER-AA-320-1007, Step 4.10.3.2, states, in part, EVALUATE and DOCUMENT that Engineering evaluated the need to place an SSC in (a)(1) status during the assessment period; was each LSS SSC event evaluated to determine if a LSS trend had occurred Step 4.10.3.3, states, in part, REVIEW this list of events AND IDENTIFY negative trends in the SSCs performance, that were not previously identified, that indicate a change to the maintenance strategy may be required Contrary to the above, from May 1, 2022 to August 1, 2024, the licensee failed to evaluate performance and condition monitoring activities and associated goals and preventative maintenance activities for maintenance rule function CS1400-04 for the assessment period of May 1 2022, through May 1, 2024. Specifically, the licensee did not recognize three LSS events involving loss of the ECCS keep fill function, documented in ARs 4687703, 4727804, and 4755803. As a result, the licensee did not identify a negative trend in the performance of the ECCS keep fill system and failed to make necessary adjustments to ensure that the objective of preventing failures of SSCs through maintenance was appropriately balanced against the objective of minimizing unavailability of SSCs due to monitoring or preventive maintenance.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Inadvertent Operation of Reactor Core Isolation Cooling System in an Unanalyzed Low-Flow Condition Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000254,05000265/2024003-02 Open/Closed
[H.12] - Avoid Complacency 71152A A self-revealed Green finding and associated non-cited violation (NCV) of Technical Specification (TS) 5.4.1.a, Procedures, was identified for the licensees failure to establish a procedure for calibrating the Unit 2 reactor core isolation cooling (RCIC) turbine governor.
As a result, equipment operators incorrectly shut valve 2-1301-53 while setting up conditions to perform the calibration, isolating the discharge path for the RCIC pump, and inadvertently inducing an unanalyzed low-flow condition.
Description:
On June 5, 2024, while performing QCOS 1300-05, RCIC Operability Test, revision 65, in conjunction with QCIPM 1300-04, RCIC Woodward Governor EG-M Control Box and Ramp Generator/Signal Converter (RG/SC) In Field Calibration, revision 7, on the Unit 2 RCIC system, main control room annunciators 902-4 A-14, RCIC High Suction Pressure, and 902-4 E-16, RCIC Pump Low Flow, unexpectedly alarmed. Control room operators contacted equipment operators in the field and determined that while attempting to establish the conditions to perform the governor calibration, equipment operators inadvertently shut RCIC test bypass valve 2-1301-53, which isolated the discharge path of the RCIC pump, and resulted in a low-flow condition. The alarms cleared after 2-1301-53 was reopened. Control room operators noted on the sequence of event recorder that the low-flow condition existed for approximately 18 seconds. The control room operators decided to back out of QCIPM 1300-04 but continue with QCOS 1300-05 to support making an operability determination of the RCIC pump following the event. Upon successful completion of QCOS 1300-05, the licensee shutdown the RCIC system and documented the condition in the corrective action program under issue report AR 4778839.
The RCIC system is designed to operate either automatically or manually following a reactor pressure vessel isolation to provide makeup water to the reactor pressure vessel in the case of a loss of normal feedwater, and maintain water level in the reactor pressure vessel above the top of the core. The RCIC system injects water with a steam driven turbine pump using steam from the reactor through the RCIC steam supply line upstream of the main steam isolation valves. Included in the RCIC system is a minimum flow valve, MO 2-1301-60, that establishes a discharge flow path to the torus to ensure minimum flow and preclude damage to the pump, should the normal discharge paths become obstructed or the normal discharge valves inadvertently go closed during system operation. A design characteristic of the system is that the minimum flow valve will only automatically open on low flow if a RCIC initiation signal is present. It is not designed to provide minimum flow protection during testing or when the flow controller for the system is in manual.
In 2004, the NRC identified that, if the operators reduced RCIC flow, as allowed by operating procedures at the time, to prevent overfilling of the reactor vessel during a transient, the RCIC control logic would not provide automatic minimum flow protection. This could potentially result in pump inoperability from damage caused by the pump deadheading. The NRC issued a finding for this issue, as documented in NRC Safety System Design and Performance Capability Inspection Report 05000254/2004004; 05000265/2004004 (ADAMS Accession No. ML041810189), dated July 29, 2004. As a corrective action, the licensee strengthened procedural controls to prevent operation of the pump under low-flow conditions. Low flow limits, including zero flow conditions, were communicated to the site by the pump vendor which were incorporated into the sites procedures. Specifically, regarding surveillance testing, the licensee established a threshold of 10 seconds to trip the RCIC pump during a low-flow condition because if the pump was operated against closed discharge valves for longer than 10 seconds there would be a risk of thermal shock to system components once a discharge valve was reopened.
Following the event on June 5, 2024, the licensee discussed a different degradation mechanism with the vendor than what was originally evaluated. Specifically, operation of the RCIC pump with restricted flow would cause a loss of internal cooling to the pump and result in thermal expansion of the pump case and rotating elements due to elevated temperatures, which could damage the pump. As documented in the operability section of AR 4778839, under this scenario, the time to reach elevated temperatures would take 3 to 5 minutes, depending on the flow restriction. Since the low-flow condition only existed for 18 seconds, the licensee concluded that there were no immediate concerns with the pump. The licensee maintained the presumption of system operability immediately following the event by verifying the pump could produce the required flow at the required discharge pressure in accordance with surveillance procedure QCOS 1300-05.
On July 11, 2024, the inspectors reviewed the licensees causal evaluation, and the circumstance surrounding the event, and determined that the licensee failed to establish a procedure to allow operators to perform the calibration of the RCIC system. Specifically, QCIPM 1300-04 requires specific conditions to set up for the calibration of the RCIC governor, however, it failed to provide direction to the equipment operators on how to achieve the initial turbine speed required for the calibration. In addition, QCOS 1300-05 did not provide direction to the equipment operators on how to achieve the desired turbine speed when performed in conjunction with QCIPM 1300-04. As a result, equipment operators did not recognize that actions taken in the field to adjust the speed of the RCIC turbine by throttling closed 2-1301-53 would not have accomplished the desired result with the system flow controller in manual. The licensee personnel involved with the activity failed to identify that using both procedures in conjunction to perform the calibration was a first-time evolution at full power and failed to recognize that the evolution was considered high-risk per site procedures, requiring additional supervisory oversight. Following additional discussions with the inspectors concerning the justification of operability, the licensee performed an operability evaluation under AR 4789755 along with a RCIC comprehensive run on August 15, 2024, to provide reasonable assurance of RCIC system operability.
In addition to the performance deficiency above, the inspectors identified two other issues of concern associated with the low flow event on June 5, 2024, that are also dispositioned in the Results section of this report. An additional issue concerning the licensees causal evaluation quality following the event was dispositioned during the Biennial Problem Identification and Resolution Inspection under NRC Inspection Report 05000254/2024011 and 05000265/2024011, and resulted in a finding of very low significance (Green).
Corrective Actions: Immediate actions directed by control room operators restored a discharge path to the RCIC pump by reopening 2-1301-53, which subsequently cleared the unexpected annunciators. The licensee performed an operability evaluation under AR 4789755 along with a RCIC comprehensive run on August 15, 2024, to provide reasonable assurance of RCIC system operability.
Corrective Action References: AR 4778839, QCAN 902-4 E-16 Received during QCOS 1300-05, and AR 4786391, Troubleshoot U2 RCIC SER vs. PPC Discrepancy
Performance Assessment:
Performance Deficiency: The inspectors determined that the failure to establish a procedure for the calibration of the Unit 2 RCIC governor was contrary to TS 5.4.1.a, Procedures, and was a performance deficiency.
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. Specifically, the licensee relied on a different assumption for what constituted the bounding time for how long the pump could be run with low flow before damage took place. The inspectors reviewed IMC 0612, Appendix E, Example 4.m, and determined that the licensees use of different assumptions to justify no system degradation (e.g., revised assumptions solely to obtain favorable results) met the not minor if condition. Consequently, the inspectors determined that the performance deficiency was a finding of more-than-minor safety significance.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.
The inspectors screened the finding in accordance with IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, Section A, and answered No to all of the screening questions. Therefore, the finding screens to very low safety significance (Green).
Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Specifically, the licensee did not account for potential errors, and implement appropriate error reduction tools, when deciding to use QCIMP 1300-04 in conjunction with QCOS 1300-05, a first-time evolution, to perform a calibration the RCIC governor at full power. This resulted in missed opportunities to identify the lack of instructions on how to achieve the desired initial conditions for the calibration.
Enforcement:
Violation: TS 5.4.1.a, Procedures, states that written procedures shall be established, implemented, and maintained, covering the applicable procedures recommended in Regulatory Guide 1.33, revision 2, Appendix A, dated February 1978. Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), Appendix A, Section 8, Procedures for Control of Measuring and Test Equipment and for Surveillance Tests, Procedures, and Calibrations, states, in part, that specific procedures for calibrations should be written for RCIC tests (Section 8b.(2)(r)).
The licensee established revision 7 of procedure QCIPM 1300-04, RCIC Woodward Governor EG-M Control Box and Ramp Generator/Signal Convertor (RG/SC) in Field Calibration, intended to provide guidance for calibrating the RCIC turbine electronic governor control system.
Contrary to the above, on June 5, 2024, the licensee failed to establish a written procedure covered in Regulatory Guide 1.33, revision 2, Appendix A, dated February 1978.
Specifically, while performing QCOS 1300-05 in conjunction with QCIPM 1300-04 to calibrate the governor, QCIPM 1300-04 did not provide direction to the equipment operators on achieving the initial turbine speed required for calibration. In addition, QCOS 1300-05 did not provide direction to the equipment operators on how to achieve the needed turbine speed when performed with QCIPM 1300-04. As a result, operators incorrectly closed valve 2-1301-53, which isolated the RCIC pump discharge path, and inadvertently induced an unanalyzed low-flow condition in the RCIC system.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Minor Violation 71152A Failure to Follow Annunciator Response Procedures Minor Violation: TS 5.4.1.a, Procedures, states that written procedures shall be established, implemented, and maintained, covering the applicable procedures recommended in Regulatory Guide 1.33, revision 2, Appendix A, dated February 1978. Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), Appendix A, Section 5, Procedures for Abnormal, Off-normal, or Alarm Conditions, covers annunciator response procedures.
The licensee established QCAN 901(2)-4 E-16, RCIC Pump Low Flow, Revision 2, as the annunciator response procedure for RCIC pump low flow. Step B.3, states, in part, IF a test is in progress, THEN immediately trip RCIC per QCOP 1300-05 and determine cause of low flow.
Contrary to the above, on June 5, 2024, the licensee failed to implement written procedures covered in Regulatory Guide 1.33, revision 2, Appendix A, dated February 1978.
Specifically, control room operators failed to trip RCIC during a low-flow condition per QCAN 901(2)-4 E-16, Step B.3, after the low flow annunciator was received in the control room during surveillance testing.
Screening: The inspectors determined the performance deficiency was minor. Specifically, due to the nature of the low-flow condition, a RCIC pump trip as outlined in the procedure would have not prevented the pump from operating outside of its analyzed limits.
Enforcement:
This failure to comply with TS 5.4.1 constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
Minor Violation 71152A Failure to Log Unexpected Alarms Minor Violation: TS 5.4.1.a, Procedures, states that written procedures shall be established, implemented, and maintained, covering the applicable procedures recommended in Regulatory Guide 1.33, revision 2, Appendix A, dated February 1978. Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), Appendix A, Section 1, Administrative Procedures, covers procedures for log entries, record retention, and review procedures. Section 1 also covers procedures for authorities and responsibilities for safe operation and shutdown.
The licensee established OP-AA-111-101, Operating Narrative Logs and Records, revision 19, as the governing procedure for log entries. Section 4.3, Narrative Logs, step 4.3.2, contains examples of information to be recorded in operations logs as applicable.
Step 4.3.2.17, Receipt of unexpected alarms, is an example of information to be recorded.
The licensee established procedure OP-AA-101-111, Roles and Responsibilities of On-Shift Personnel, revision 15, as the administrative procedure for authorities and responsibilities for safe operation and shutdown. Section 3, Responsibilities, Step 3.3 states, The Unified Control Room Log (UCRL) shall be MAINTAINED as applicable by the Shift Manager, Unit Supervisor, Field Supervisor, each Unit Reactor Operator, and the Non-licensed Operators.
Contrary to the above, on June 5, 2024, the licensee failed to implement written procedures covered in Regulatory Guide 1.33, revision 2, Appendix A, dated February 1978.
Specifically, control room operators failed to log the unexpected receipt of control room annunciators 902-4 E-16, RCIC Pump Low Flow, and 902-4 A-14, RCIC High Suction Pressure, when a low-flow condition was inadvertently induced on the RCIC system while performing an infield calibration of the RCIC governor. Following discussions with the inspectors, the licensee made a late entry into the control room logs on July 31, 2024, to reflect the receipt of the two unexpected annunciators.
Screening: The inspectors determined the performance deficiency was minor. Specifically, the failure to log the receipt of the annunciators was not viewed as a precursor to a significant event, did not have the potential to lead to a more significant safety issue, and did not adversely affect a cornerstone objective.
Enforcement:
This failure to comply with TS 5.4.1 constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 24, 2024, the inspectors presented the integrated inspection results to Doug Hild, Site Vice President, and other members of the licensee staff.
- On July 12, 2024, the inspectors presented the ISFSI cask loading inspection results to Doug Hild, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
24 Spent Fuel Dry Cask Storage
05/10/2024
Calibration
Records
0011455038
Certificate of Calibration
09/28/2023
ISFSI Inspection Results, HI-STORM Vent Screens
05/03/2022
MPC Vent Port RVOA Operating Rod Issue
08/31/2022
Forced Helium Dehydration (FHD) Skid Tripped on
VFD Alarm
08/31/2022
Blower Motor Replacement
06/26/2023
ISFSI Inspection Results General Walkdown
10/24/2023
Corrective Action
Documents
NRC Exemption Letter to Use CBS MPCs in
24 ISFSI Campaign
05/14/2024
Holtec CoC Amendment 8 Revision 1 MPC-68M
Cask Model for Quad Cities NPS - ISFSI
Engineering
Changes
Quad Cities Fuel Selection Packages and
Alternate Assembly Listing for the 2024
Spent Fuel Loading Campaign - ISFSI
Job #2211268
23 Annual Inspection RX Crane
07/10/2024
QC-72.48-S-22-
0002
Exelon 72.48 Review - QCNPS 10 CFR 72.212 Evaluation
Report 72.212 Change Request 22-02
QC-72.48-S-22-
0005
Exelon 72.48 Review - Review of PCI/CES and Leak Testing
Services Vendor Supplied Welding Procedures for
QC-72.48-S-23-
0002
Constellation 72.48 Review - MPC Processing Forced
Helium Dehydration (FHD) for BWRS
QC-72.48-S-24-
0006
Constellation 72.48 Review - Field Change Request for
Closure Welding of Holtec Multi-Purpose Canisters at
Constellation Facilities
Miscellaneous
QC-72.48-S-24-
0008
Constellation 72.48 Review - 10 CFR 72.212 Evaluation
Report Change Request 24-04
NDE Reports
20421-830-01
GQP-9.2 Liquid Penetrant Examination Report
07/08/2024
Constellation 72.48 Review Process ISFSI
60855
Procedures
Constellation 72.48 Resource Manual
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Fuel Selection and Documentation for Dry Cask Loading
OU-MW-671-200
MPC Processing Forced Helium Dehydration (FHD)
for BWRs
QCFHP 0800-69
HI-TRAC Movement Within the Reactor Building
21A
QCFHP 0800-70
HI-TRAC Loading Operations
QCGM 0303-01
Crane Operator Daily Visual Crane Inspection
Holtec Independent Spent Fuel Storage Installation (ISFSI)
Radiation Survey
22-120271
ISFSI Pad
03/20/2022
23-192068
ISFSI Pad
04/18/2023
Radiation
Surveys
24-217608
ISFSI Pad
05/13/2024
Sample RX BLDG Crane MN Hoist N Gear Set Oil
08/08/2023
MM RX BLDG Overhead Crane Annual Inspection/NDE
08/18/2023
EM Reactor BLDG Overhead Crane Annual Inspection
07/07/2023
ISFSI HI-TRAC Trunnion Inspection
2/27/2023
ISFSI MPC Lift Cleat Inspection
2/21/2023
04/29/2024
Perform an Integrity Inspection of the ISFSI IAW
05/23/2024
Work Orders
MM EWP Monthly Reactor Building Overhead Crane
Inspection
05/20/2024
Calculations
QDC-1300-M-
0800
Pressure Drop Through RCIC Discharge Piping to
Reactor Vessel
03/11/1999
Corrective Action
Documents
IST Unfavorable Trend:
1-3903 DGCW Pump dP Low Margin
06/20/2024
QCOS 0020-02
Safety System Monthly Manual Valve Position Verification
Procedures
QCOS-1300-01
Periodic RCIC Pump Operability Test
RCIC Flow Rate Comprehensive Test (IST)
03/12/2020
RCIC Flow Rate Test Comprehensive Test (IST)
2/14/2021
RCIC Flow Rate Test Comprehensive Test (IST)
05/03/2022
Work Orders
RCIC Valve Position Indication (IST)
06/07/2024
Drawings
M-27, Sheet 2
Diagram of Fire Protection Piping
09/10/1999
Fire Plans
FZ 1.1.1.2
Unit 1 RB 595' Elev. Ground Floor
08/2022
Corrective Action
IEMA U2 HPCI Flood Penetration Concern
11/05/2014
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
U2 HPCI Flood Penetration Degraded
08/08/2024
Engineering
Changes
Evaluate Potential Impact from Internal Flood Barrier on
Procedures
QCOA 1600-05
Leak in Torus
Work Orders
00034311-01, COM, (LR) RX BLDG Flood Barriers
Inspection (Flood Protection)
07/14/2022
Corrective Action
Documents
2B Reactor Recirc Pump Trip
09/26/2024
Drawings
Relay and Metering Diagram Recirculating Pump Asd 2b
03/13/2004
Calculations
QDC-1400-M-
0585
Pressure Requirements for Ess Fill System
001
Unexpected 2B Core Spray Header Low Pressure Alarm
06/11/2020
ECCS Keep Fill Check Valve Stuck Closed
06/11/2020
1-1402-8B Failed to Reseat During QCOS 1400-07
2/14/2022
1-1402-8B Failed to Reseat During QCOS 1400-01
2/13/2023
PSU NE Condenser Water Box Relief Valve
Maintenance Rule
04/16/2024
Received 902-3 B-16 CS DISCH HDR HI/LO PRESSURE
06/29/2023
HPCI Condensate Pump Did Not Auto Start
08/31/2023
Core Spray ECCS Keep Fill MRule Benchmarking
10/18/2023
Received U2 CS HDR Hi/Lo Pressure Alarm (A Loop)
01/01/2024
Unexpected 2B Core Spray Header Low Pressure Alarm
03/05/2024
CR Train A AHU 0-5797-361 Trip
05/17/2024
CR Train A AHU Tripped Unexpectedly
05/18/2024
CR Train A AHU Tripped Unexpectedly
05/21/2024
2B Core Spray Loop Not Holding Pressure
06/03/2024
HPCI GSC Level Switch Obsolete
06/26/2024
CR Train A AHU Tripped Unexpectedly
06/27/2024
2-7 D-10 Condenser Pit Low Level
07/03/2024
Maintenance Rule A3 Assessment Identified Deficiencies
08/01/2024
Corrective Action
Documents
NRC ID: Maintenance Rule (a)(1) Plan Not Updated
08/07/2024
Corrective Action
Documents
Required Actions for Maintenance Rule Core Spray Function
09/11/2024
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Resulting from
Inspection
Engineering
Evaluations
CFR 50.65(a)(3) Periodic Evaluation
08/01/2024
FAS Control Room Terminal Not Responding to Inputs
09/12/2024
U1 250V Battery Pilot Cell Voltage
09/18/2024
Corrective Action
Documents
2B Reactor Recirc Pump Trip
09/26/2024
Procedures
QCOA 4100-11
Fire Alarm System (FAS) Alarm/Trouble
OSP 2-1301-49 Local Control Station Did Not Work
03/23/2024
Corrective Action
Documents
Change in U2 250 VDC Battery Discharge Test Performance
03/26/2024
Engineering
Changes
Evaluation of Battery Test Results for Q2R27 250 VDC
Modified Performance Test
Operability
Evaluations
641961
Reactor Core Isolation Cooling Operability Evaluation
Following Greater than 10 Seconds with Low Flow
QCARP 0030-04
TB-II Unit 2 Injection with RCIC and Bringing the Unit to Cold
Shutdown
QCARP 0050-02
SB-1-2 Injection with RCIC and Bringing the Unit to Cold
Shutdown
QCOP 1300-09
RCIC Local Manual Operation
QCOS 0040-01
Operating Cycle Local Motor Operated Valve Operation
Procedures
QCOS 1300-13
RCIC Motor Operated Valve Local Controller Test
Motor Operated Valve Local Operation Test QCOS 0040-01
04/08/2024
Work Orders
00022919-03, TS, 250 VDC Battery Modified Performance
Service Test, E: 2-8350, B ATA, B04
03/24/2024
Cal Record
4452661
Calibration for Flowmeter for Unit 2 RCIC
Comprehensive Run
07/18/2024
Calibration
Record 3124352
Cal record for Vibration Analysis for Unit 2 RCIC Run
Comprehensive IST
10/25/2023
Calibration
Records
Calibration
Record 989315
Test Gauge 0-2000# for Unit 2 RCIC Comprehensive Run
07/18/2024
4.0 Critique for U1 EDG 18 Yr PM Work Window
10/15/2024
IST Unfavorable Trend: FCV 0-5741-333 Slowing Stroke
Time
01/06/2023
Corrective Action
Documents
U2 EDG #5 Cylinder Exhaust Temp Low
01/30/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
EO ID: Update to IR 4721055 for Packing Leak on 2-3999-83
2/20/2023
PI 0-5795-358, B HVAC Ref Unit SW Inlet Reads D/S
04/11/2024
U2 HPCI Will Not Reach High Speed Stop
06/12/2024
U2 HPCI Condensate Pump Found with No Packing
Leakage
06/13/2024
FIS 2-1360-7 OOT
07/24/2024
FCO 0-5741-333 Failed IST Criteria During QCOS 5750-04
08/12/2024
EOID: U-2 SBO Injector Control Shaft Lip Seal Degraded
08/15/2024
Annunciator A6 Did Not Alarm During SBO Functional
08/16/2024
08/15/2024
Could Not Meet Step in QCOS 2300-05 (TIC 3844)
09/10/2024
HPCI Gland Seal Hotwell Pump Did Not Autostart on High
Level
09/10/2024
Check Valve Failed as Found Inspection
09/16/2024
1/2 SAC Oil Pressure Jumping Up and Down
09/17/2024
Engineering
Changes
Quad Cities Station Discussion on Preconditioning
Engineering
Evaluations
IST-QDC-BDOC-
V-28
0-5741-333 FCV IST Basis Document
03/01/2019
Equipment Classification
Administrative Requirements for Inservice Testing
MA-QC-773-303
Quad Cities Nuclear Operational Analysis 1/2 Emergency
Diesel Generator Relay Calibration and Testing
QCOS 1300-05
RCIC Pump Operability Test
QCOS 1300-26
RCIC Pump Comprehensive/Performance Test
QCOS 6600-02
Diesel Generator Air Compressor Operability
QCOS 6600-03
Diesel Generator Fuel Oil Transfer Pump Monthly Operability
QCOS 6600-42
Unit 2 Emergency Diesel Generator Monthly Load Test
QCOS 6600-46
Unit 1/2 Diesel Generator Timed Start Test
Procedures
QCOS 6620-05
SBO DG 1(2) Fuel Oil Transfer Pump Quarterly Test
EM Replace Agastat Relay
09/12/2024
OP U1 Div 1 Core Spray Logic Test, QCOS 1400-15
09/12/2024
Work Orders
Diesel Generator Load Test
04/23/2024
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
U2 EDG Load Test
05/15/2024
Control Room HVAC System Check Vlv Test (IST)
08/12/2024
Diesel Generator Load Test
06/01/2024
OP QCOS 2300-5 HPCI Pump Flow Rate
09/10/2024
FNI Calibrate FIS 2-1360-7
07/24/2024
Control Room Emergency Filtration Sys Test (IST)
08/12/2024
Corrective Action
Documents
ERO Drill Performance August 1, 2024
08/02/2024
QCAN 902-4 E-16 Received during QCOS 1300-05
06/05/2024
Troubleshoot U2 RCIC SER VS PPC Discrepancy
07/11/2024
Follow Up to IR 4786391
07/25/2024
Corrective Action
Documents
AR 233268-02
Inadequate RCIC Min Flow Protection
06/29/2004
Engineering
Evaluations
U2 RCIC Deadheading Operability Evaluation
QCAN 901(2)-4
E-16
RCIC Pump Low Flow
QCIPM 1300-04
RCIC Woodward Governor EG-M Control Box and Ramper
Generator/Signal Converter (RG/SC) In Field Calibration
Procedures
QCOS 1300-05
RCIC Operability Test
Corrective Action
Documents
SCRAM Signal Received during QCOS 0300-30
03/27/2024
Miscellaneous
LER 265/2024-
001-00
Automatic Actuation of Reactor Protection System During
Scram Discharge Volume Leak Rate Testing
05/10/2024
Procedures
QCOS 0300-30
Scram Discharge Volume Vent and Drain Valve Seat
Leakage Test AO 1(2)-0302-21A/B/C/D and
AO 1(2)-0302-22A/B/C/D
2