IR 05000254/2024011
| ML24317A237 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 11/13/2024 |
| From: | Nestor Feliz-Adorno NRC/RGN-III/DORS/RPB1 |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| Shared Package | |
| NRC-002 | List: |
| References | |
| EPID I-2024-011-0042 IR 2024011 | |
| Download: ML24317A237 (1) | |
Text
SUBJECT:
QUAD CITIES NUCLEAR POWER STATION - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000254/2024011 AND 05000265/2024011
Dear David P. Rhoades:
On October 3, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Quad Cities Nuclear Power Station and discussed the results of this inspection with Douglas Hild, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations problem identification and resolution program to confirm that the station was complying with NRC regulations and licensee standards.
Based on the samples reviewed, the team determined that your program complies with NRC regulations and applicable industry standards such that the Reactor Oversight process can continue to be implemented.
The team also evaluated the stations effectiveness in identifying, prioritizing, evaluating, and correcting problems, reviewed licensee audits and self-assessments, and its use of industry and NRC operating experience information. The results of these evaluations are in the enclosure.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews, the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
Two findings of very low safety significance (Green) are documented in this report.
One of these findings involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation 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, November 13, 2024 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 or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Quad Cities Nuclear Power Station.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Néstor J. Féliz Adorno, 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:
Report Numbers:
05000254/2024011 and 05000265/2024011
Enterprise Identifier:
I-2024-011-0042
Licensee:
Constellation Nuclear
Facility:
Quad Cities Nuclear Power Station
Location:
Cordova, IL
Inspection Dates:
September 09, 2024, to October 03, 2024
Inspectors:
T. Briley, Senior Project Engineer
Z. Coffman, Resident Inspector
A. Dahbur, Senior Reactor Inspector
M. Keefe-Forsyth, Safety Culture Specialist
C. Mathews, Illinois Emergency Management Agency
N. Shah, Senior Project Engineer
R. Sigmon, Senior Reactor Systems 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 a biennial problem identification and resolution 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 Condition Adverse to Quality Following a Corrective Action Program Evaluation of a Reactor Core Isolation Cooling Low Flow Event Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green FIN 05000265/2024011-01 Open/Closed
[P.2] -
Evaluation 71152B The inspectors identified a Green finding when the licensee failed to identify a condition adverse to quality, as defined in licensee procedure PI-AA-125, Corrective Action Program (CAP) Procedure, associated with a reactor core isolation cooling (RCIC) low flow event from June 5, 2024. Specifically, the licensee failed to identify that the condition adverse to quality, as defined by their procedures, was a low flow event with a duration of 4 minutes. As a result, the licensee incorrectly assessed the event as 18 seconds during their operability evaluation.
Failure to Correct Inadequate Jumper Cable Labeling Practices Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000254,05000265/2024011-02 Open/Closed
[P.3] -
Resolution 71152B The inspectors identified a finding of very low safety significance (Green) and an associated non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion XVI, Corrective Actions, for the licensees failure to promptly correct a condition adverse to quality. Specifically, licensee revised a station procedure to include labeling instructions for jumper cables, but the revision did not provide instructions appropriate for the circumstances, despite the licensee identifying this as a necessary corrective action.
Additional Tracking Items
None.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)
- (1) The inspectors performed a biennial assessment of the effectiveness of the licensees Problem Identification and Resolution program, use of operating experience, self-assessments and audits, and safety-conscious work environment.
- Problem Identification and Resolution Effectiveness: The inspectors assessed the effectiveness of the licensees Problem Identification and Resolution program in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a 5-year review of the station blackout diesels.
The corrective actions for selected non-cited violations were evaluated as part of the assessment.
- Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience.
- Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through audits and self-assessments.
- Safety-Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment. The inspectors conducted focus groups and interviews with 179 individuals, about 20 percent of the station, from Operations, Engineering, Radiation Protection, Maintenance, Security, and first-line supervisors, as well as interviews with the department managers for those departments and the Employee Concerns Program manager.
The inspectors also reviewed the actions taken by the station following the IP 93100, Safety Conscious Work Environment Issue of Concern Follow-up, inspection in August 2023. This inspection was documented in Inspection Report 2023011 (ML23262B441).
- The inspectors reviewed the completed corrective actions to prevent recurrence that were opened during IP 95001 Supplemental Inspection (ML23167B172), dated June 16, 2023, associated with a White Notice of Violation (NOV) in the Mitigating Systems Cornerstone. The inspectors verified these corrective actions had been completed as scheduled.
INSPECTION RESULTS
Assessment 71152B Follow-up of Corrective Action to Prevent Recurrence 2023040 2.e - Corrective Actions to Assign Each Electromagnetic Relief Actuator Rebuild as an Outage Support Activity Under the Actuator Installation to Ensure Correct Operational Critical Component Screening per Root Cause No. 2 On May 4, 2023, the NRC completed a supplemental inspection to review the licensees root cause evaluation for a White Finding associated with Unit 1. This supplemental inspection was documented in Inspection Report 05000265/2023040 (ML23167B172).
One of the root causes identified by the licensee was that (Root Cause No. 2)
The stations preventive maintenance (PM) structure does not ensure that all components for Operational Critical Component (OPCC) work are tied to Preventive Maintenance (PM) IDs that facilitate effective OPCC screening. The associated corrective action to prevent recurrence (CAPR) was to review PMIDs for critical components which are not appropriately flagged, and either tie them to a parent PMID or to tie them appropriately, ensuring that they are screened and coded properly. The CAPR was tied to action items 45339936-33 and -34 and had an associated effectiveness review to perform a self-assessment of OPCC screening to determine if all pre-outage and outage PMIDs for critical components were screened for potential OPCC work. At the time of the supplemental inspection, these actions had not yet been completed.
During this biennial PI&R inspection, the inspectors reviewed the status of the above CAPR and the associated self-assessment. The inspectors reviewed the list generated by the licensees system managers for items 45339936-33 and -34, and selectively assessed that the components identified as critical were tied to the relevant PMID to support proper screening. Additionally, the inspectors reviewed the licensees identification of critical components associated with the emergency relief valve rebuild activities and observed that they were coded as OPCC work. The inspectors reviewed the licensees self-assessment performed on February 8, 2024, and did not identify any issues.
No findings or violations were identified.
Assessment 71152B Assessment of Safety-Conscious Work Environment In general, the inspectors heard that most employees at Quad Cities were willing to raise nuclear safety concerns without fear of retaliation. However, the team also heard that while individuals would raise concerns, they were not always confident that anything would be done about the concerns. Perceptions that writing Issue Reports (IRs) will have a positive impact on plant reliability and safety is an essential element in sustaining an effective CAP.
The inspectors specifically asked about how the OR-7 code affected individuals willingness to raise concerns. The OR-7 code, as outline in procedure PI-AA-1012, Safety Culture Monitoring, Revision 4, flags IRs that meet certain criteria, including issues that have been repeatedly raised in the CAP without resolution. During the IP 93100 review, many expressed a perception that this code labeled individuals as too emotional or disgruntled.
Some groups acknowledged that the station had taken actions to clarify that the OR-7 code is meant to highlight unresolved issues and to ensure feedback is provided to those raising concerns. However, this understanding was not widespread. While some individuals recalled station communications on the topic, they remained skeptical; others didnt recall any communications; and some had prior experiences with OR-7-tagged issues, which continued to influence their views more strongly than recent clarifications.
In addition, there was a belief that the technical content of IRs labeled with OR-7 would not receive the attention needed to fix the issue they addressed. The inspectors noted that the station had begun recognizing IRs tagged with OR-7 as good catches, though this had not yet been fully implemented.
Several themes emerged across multiple focus groups and in discussions with individual managers:
- Staffing Concerns: Staffing was the top issue mentioned when participants were asked what they would change if they could.
- Resource Sharing Among Sites: Resource sharing among Constellation sites, particularly for certain groups, was frequently cited as a stressor, adding to the burden on already strained teams working to complete scheduled tasks.
- Training and Qualifications: Staffing shortages impacted perceptions about the ability to complete required training and advanced qualifications, as work groups were challenged to allocate time for individuals to complete training.
- Unaddressed Equipment Deficiencies: Uncorrected equipment deficiencies, including the number of deficiency tags in the main control room, contributed to the perception that writing IRs does not result in getting issues corrected.
- Procedure Over Equipment Repair: There was a perception that, rather than fixing equipment issues, the station would revise procedures to address long-standing deficiencies, sometimes creating additional work and impacted the plants long-term reliability.
- Production-Over-Safety Mentality: This sentiment was frequently mentioned as a characteristic of the stations culture. While no one expressed hesitation about raising safety concerns, especially those affecting personnel or plant Technical Specifications, there was a belief that the station would prioritize additional online time over addressing issues that might lead to more significant unplanned outages in the future.
- Shift in Supervisory Experience: Over the past decade, a shift in the experience level of first-line supervisors was noted. Once seen as a natural progression, moving from craft, to first-line supervisor, to higher management is now perceived as less attractive due to increased workload and reduced quality of life. Retiring, experienced supervisors are being replaced by newer hires who lack the same level of plant knowledge and on-the-job experience.
- Work Planning Frustrations: Frustration with the work planning process was widespread. Participants highlighted issues such as frequent last-minute changes to the work schedule, time wasted preparing resources, inadequate walkdowns, work package deficiencies, difficulty obtaining support for scheduled work, and late identification of plant lineup conflicts.
Many of these individual issues have been noted in previous NRC inspections. Since the 2023 IP 93100 inspection, inspectors noted that while the licensee implemented some corrective actions, challenges remain. The licensees corrective actions included a plan to hire additional staff, though there was skepticism about its short-term impact, as it could take a year or more before these new hires are fully qualified to support operations. Additionally, while main control room deficiency tags are now tracked more visibly, their overall number remains high. The licensee also conducted a trend review on the use of procedure changes to address equipment issues. However, this trend review included only two data points, neither predating the time period when this concern was initially raised by staff.
The inspectors found individuals perceived that the work planning process was not effectively using available resources to address equipment issues in a timely manner. Perceptions included:
- Delayed Involvement of Key Work Groups: Certain work groups felt they were brought in late to review proposed tasks after the scope had supposedly been finalized, only to find the plan incompatible with current plant conditions or Technical Specifications.
- Lack of Support Group Representation: There was a perception that the planning process did not consistently ensure representation from support groups, impacting the availability of necessary staffing for scheduled work.
- Work Package and Walkdown Quality: Individuals felt that the quality of work packages and walkdowns was affected by assumptions in the planning process that supervisors and responsible personnel possessed a level of experience and plant knowledge that many currently lack.
The inspectors noted recent changes to the work planning process aimed at addressing some of these concerns, though it was too early to assess their effectiveness. However, from the perspective of those interviewed, these issues within the work planning process continued to pose substantial challenges.
In summary, the inspectors determined that there was an adequate safety-conscious work environment at Quad Cities. The inspectors observed that Quad Cities had taken steps to address findings from the 93100 inspection conducted last summer. Feedback indicated that some actions, especially those related to the OR-7 code for IRs, had begun to have a positive impact. However, many of the recent actions, particularly those affecting the work management process, had been implemented too recently to assess their effectiveness.
The licensee documented the safety culture assessment observations in IR 4807458.
No violations or findings were identified.
Assessment 71152B Assessment of the use of Self-Assessments and Audits The inspectors reviewed several audits and self-assessments and deemed those sampled as thorough and intrusive with regards to following up with the issues that were identified.
No findings or violations were identified.
Assessment 71152B Assessment of the Corrective Action Program The inspectors performed an assessment of the licensees implementation of the corrective action program, specifically, in the areas of identification, prioritization and evaluation, and corrective actions.
Effectiveness of Problem Identification Overall, the station was generally effective at identifying issues at a low threshold and entering them into the corrective action program (CAP) as required by station procedures. During interviews, workers were familiar with how to enter issues into the CAP and stated that they were encouraged to use it to document issues. During plant walkdowns, the inspectors observed that issues were being identified in the field and that they were being properly addressed in the CAP. The inspectors determined that the station was generally effective at identifying negative trends that could potentially impact nuclear safety.
The inspectors noted several examples where concerns were not being properly identified even if previously documented in the CAP. These examples were similar to those observed in the 2022 PI&R inspection (Inspection Report 2022013; ML22319A156). Some examples included:
- The licensees evaluation for the June 5, 2024, low flow event during Unit 2 reactor core cooling isolation (RCIC) surveillance testing (IR 4786391), failed to recognize that the issue had occurred for 4 minutes versus the 18 seconds evaluated. This was identified by the NRC resident inspectors during their review of event. One Green finding with an associated non-cited violation was identified, which is documented in the inspection results below.
- The licensee failed to identify that the resistance measurement between cells 25-26 exceeded 120 percent of the baseline, during planned work on the Unit 1 Station Blackout Diesel 125 Vdc Battery. This was determined to be a minor performance deficiency and is documented in the inspection results below.
- During a May 30, 2024, walkdown of the station blackout diesel jacket water system, a licensee system engineer failed to document obvious indications of corrosion of the jacket water piping. This was determined to be a minor performance deficiency and is documented in the inspection results below.
- In the stations 2024 nuclear oversight audit report (NOSA-QDC-24-05 (IR 4781214))
the station identified that non-licensed operators were not always capturing observed housekeeping deficiencies in the CAP during station rounds. This was a repeat issue from the prior audit.
Based on these observations, the inspectors concluded that continued efforts were needed to further address this gap in problem identification.
Effectiveness of Prioritization and Evaluation of Issues The inspectors noted that issues were properly screened with most either classified as Conditions Adverse to Quality (CAQ) or Non-Corrective Action Program (NCAP) items.
Through a selective review of CAP and NCAP items, the inspectors did not identify any issues of concern with the assigned level of evaluation. Except for the RCIC low flow issue noted above, issues having potential operability concerns were properly addressed through the screening process.
Issue evaluations were generally sound and of good quality. Most issues were screened through the stations CAP screening process as low significance and were assigned a work group evaluation (WGE; the lowest level of review); more significant issues were assigned a Corrective Action Program Evaluation (CAPE) or if highly significant, a root cause evaluation. While most evaluations were generally thorough and consistent with the expectations in station procedures, the inspectors noted a negative trend with the quality of the documentation in the evaluations.
Specifically, from 2022-2024, NRC inspectors have identified numerous quality issues with CAP products resulting from insufficient evaluation or understanding of the issue; most of these issues had associated findings and/or violations. For example, during performance of the baseline inspection, the resident inspectors identified:
- CAPE 04464185 Unit 1 HPCI Manually Isolated in Response to a Trip of the Gland Seal Exhauster, incorrectly stated under the Cause section: The limit switch was determined to be approximately 20 years old with calibration/inspections performed on an O2 frequency (PMID 35689-01). The last inspection was completed satisfactorily 3/29/2019 under work order (WO) 4613965. The resident inspectors identified that calibrations were not being performed as credited under PMID 35689-01 and only visual inspections of the outside of the switch were being performed. In short, there was no preventive maintenance being performed on the switches even though the switches were known to have aging-related degradation associated with them and the licensee failed to recognize that. This resulted in a Green finding and NCV, as documented in Inspection Report 2022001 (ML22130A771,) and was documented in the licensees CAP as IR 4482225.
- The CAPE (IR 4486294) for the 3B electromagnetic relief valve (ERV) failure references CAPE 04330737 for a previous failure of the 3D ERV discovered in 2020.
CAPE 04330737 incorrectly states that the 3B ERV was identified prior to being placed into service for having a bent upper guide bracket and was replaced under WO 04804706. CAPE 04330737 used this example to highlight that the procedure is robust enough to catch such equipment deficiencies and was credited with mitigating future events. However, the 3B ERV was not replaced by WO 04804706 which resulted in a subsequent failure in 2022 of the 3B ERV. The licensee generated IR 04498778 to address the resident office concerns. This was associated with a White Finding and NCV as documented in Inspection Report 2022091 (ML22313A150).
- A WGE under IR 04730133 contained incorrect information concerning the last time maintenance was performed on the U1 EDG amphenol. Specifically, the licensee failed to recognize that the amphenol was last evaluated for tightness on October 9, 2023, versus October 11, 2021, as credited in the WGE. IR 04768752 was documented as the result of resident offices observation.
- The operability basis for IR 04698645, U2 EDG Starting Air Header PCV Reads High Out of Band, incorrectly stated that all components in the air start system were rated up to 250 psig. Subsequent review by the resident office identified in EC 392108, as well as on the label plate on the air start motors, that maximum pressure the air start motors are rated to is 200 psig. The licensee documented this concern in IR 639697 and performed an operability evaluation to disposition the issue.
- Resident office identified that flow switch FIS 2-1360-7 did not actuate as expected during RCIC low flow event on June 5, 2024. CAPE 04778839 failed to identify this.
The licensee performed an operability evaluation based on the resident offices concerns, to provide reasonable assurance of operability because the original operability basis documented in IR 04778839 only assumed 18 seconds, versus the 4 minutes of actual low flow time. This issue is a finding for this report.
During the age-related degradation inspection documented in Inspection Report 2024010 (ML24296A089), the inspectors identified:
- The licensees corporate office generated CAP item AR 04670087, Gaps in EDG System Performance Noted, to prompt sites in the fleet to review PCM templates for the EDG and SBO diesel and address any gaps in the PM program identified. Quad completed the review, and generated an Excel spreadsheet along with IR 04740841, PM Review of EDG System Requires Action, and identified several discrepancies between the PCM templates and the actual maintenance being performed under the site PM program. The action item was closed on February 1, 2024, under IR 04670087-09. However, in August 2024, during the age-related degradation inspection, the NRC identified that the SBO jacket water flexible hoses were not being changed out in accordance with the PCM template recommendations.
A non-cited violation was identified for this issue in Inspection Report 2024010.
- The licensee failed to identify additional conditions adverse to quality during extent-of-conditions reviews related to IR 04711264 identified by inspectors during a previous NRC Component Engineering Team Inspection. Specifically, IR 04711264-2 was a task for engineering to walk down all the safety-related batteries and identify any additional cable bend issues. The task was completed with no additional issues identified. Later, during the NRC age-related degradation inspection, the NRC identified several issues on the Unit 2 250 Vdc battery that were within the scope of IR 04711264-2. This was documented as a violation in Inspection Report 2024010.
- The licensee performed a causal evaluation under IR 04746848 to address the NCV from the Component Engineering Team Inspection under IR 04711264. The causal evaluation failed to identify that the condition adverse to quality did not have any actions in either CAP or work control to correct it. As a result, all actions associated with the CAQ were closed out and the CAQ remained. This issue was documented as a violation in Inspection Report 2024010.
These examples were particularly noteworthy given that the screening usually consists of multi-disciplinary and multi-managerial reviews as part of the approval process. The licensee captured this observation as IR 4806789.
While these examples were primarily associated with NRC findings and observations, the inspectors concluded that the issue was more an example of attention to detail in the licensees overall screening and evaluation process then a lack of attention towards NRC issues.
Corrective Actions The inspectors concluded that the licensee was generally effective in corrective action implementation, but identified some examples where ineffective corrective actions were taken for identified issues, and several observations where certain actions may adversely affect the efficacy of the program.
- For AR 04722018, Issues Putting in Unit 1 125-volt battery and chargers, a Corrective Action to revise the procedure to correctly label short and long cables was ineffective, as the procedure generated still had incorrect guidance for the proper labeling.
- For AR 4704780, Tritium Troubleshooting Results, A minor performance deficiency was identified for the failure to assign a Corrective Action (CA) in lieu of an Action Tracking Item to address a condition adverse to quality associated with the clogged drains on the main chimney basement drain line.
Both issues were documented below as minor performance deficiencies.
Additionally, the inspectors had the following observations:
- The practice of assigning Action Tracking Items (ACITS) to capture sub assignments associated with CAs or Corrective Actions to Prevent Recurrence (CAPRs) may introduce some unanticipated vulnerabilities, which may result in items not being corrected. Specifically, procedure PI-AA-125, defined an ACIT as being used to address enhancements or items of minor significance and not CAQs. Therefore, these sub assignments can be perceived as unnecessary. Since the oversight of ACITs were less restrictive than /CAPRs, some sub assignments critical to the implementation of a CA/CAPR may not be reviewed consistent with the CA/CAPR classification.
- Step 2.9 of PA-AA-125, defines a CA or CAPR as an action taken or planned that restores a CAQ. However, the stations practice is to define only the final action as the CA or CAPR, overlooking the importance of intermediate steps, even when they are critical to the final outcome. For instance, if a root cause evaluation identifies a CAPR that involves conducting a system walkdown to identify deficiencies, the subsequent action of entering those deficiencies into the work control process for correction is documented as the CAPR. In contrast, the walkdown and other essential subtasks related to the repairs are categorized as ACITs. As a result, these subtasks, which are vital for executing the CAPR, do not receive the same procedural controls as the CAs or CAPRs.
- In RCE 4539936 for the 3B ERV failure, one identified root cause was the prevalence of improper human performance behaviors, such as a lack of questioning attitude and imprecise communication, during the ERV rebuild. However, a CAPR was not assigned, with the rationale being that due to human fallibility, the station will not be able to completely eliminate the possibility of a human performance error and therefore cannot guarantee prevention of future occurrences. This perspective suggests a limited understanding of the issue, as it appears to be a common belief regarding events attributed to human performance. Consequently, previous station corrective actions primarily consisted of one-shot interventions, such as refresher training followed by a brief period of increased in-field monitoring. These actions resulted in short-term improvements but failed to yield lasting change. For example, prior to the ERV event, the licensee had conducted training and monitoring from November 2022 to February 2023 to address the same behaviors observed during the ERV failure. Following this, one of the corrective actions was to conduct a second training and monitoring session from late 2023 to 2024. However, based on recent observations by the resident inspectors, this training also did not effectively curb the trend of negative human performance behaviors. Although the licensee has recently implemented a site-wide human performance plan, most actions are still pending, preventing the inspectors from evaluating its potential effectiveness compared to previous efforts.
By letter dated February 28, 2024 (ML24059A007), the NRC identified a cross-cutting theme associated with H.14, Conservative Bias. While the inspectors noted that some near-term corrective actions had been taken, the long-term actions expected to have the most impact were included into the site-wide human performance improvement plan. Since most of these actions were still pending, the inspectors could not assess whether these actions were effective to address the H.14 cross-cutting theme.
Assessment 71152B Assessment of Operating Experience Based on the samples reviewed, the inspectors determined that the licensees performance in using operating experience was generally effective. The licensee screened industry and NRC operating experience information for applicability to the site. When applicable, the licensee wrote condition reports and developed and implemented actions to prevent similar issues. The licensee generally communicated operating experience lessons learned and incorporated them into plant operations.
No violations or findings were identified.
Failure to Identify Condition Adverse to Quality Following a Corrective Action Program Evaluation of a Reactor Core Isolation Cooling Low Flow Event Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green FIN 05000265/2024011-01 Open/Closed
[P.2] -
Evaluation 71152B The inspectors identified a Green finding when the licensee failed to identify a condition adverse to quality, as defined in licensee procedure PI-AA-125, Corrective Action Program (CAP) Procedure, associated with a reactor core isolation cooling (RCIC) low flow event from June 5, 2024. Specifically, the licensee failed to identify that the condition adverse to quality, as defined by their procedures, was a low flow event with a duration of 4 minutes. As a result, the licensee incorrectly assessed the event as 18 seconds during their operability evaluation.
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, field 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 vessel, in the case of a loss of normal feedwater, and maintain water level above the top of the core. The licensee does not credit the RCIC system as an emergency core cooling subsystem, therefore it is not safety related. However, the reactor vessel level and pressure control functions performed by RCIC during an event is of high safety significance in the licensees maintenance rule program under 10 CFR part 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. The RCIC system is a system that is credited in the licensees fire protection report under 10 CFR part 50, Appendix R, Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979. The operability of the RCIC system is required by the licensees Technical Specifications (TS).
On July 11, 2024, during their review of the licensees corrective action program evaluation (CAPE) under IR 4778839, the inspectors identified that the plant process computer data for RCIC flow during the event indicated that the low flow condition spanned approximately 4 minutes versus the 18 seconds assumed by the control room operators. The inspectors discussed the issue with the licensee and the concern was captured in the corrective action program under IR 04786391. Further troubleshooting by the licensee identified that flow switch FIS 2-1360-7, which drives the annunciator for 901(2)-4-E-16, did not actuate as expected when system flow fell below 40 gpm. As a result, the operability basis documented in IR 4778839, which assumed that the low flow condition only existed for 18 seconds, was invalid. The licensee performed an operability evaluation under IR 04789755 to provide reasonable assurance that the RCIC system could continue to meet its required TS functions.
Licensee procedure PI-AA-125, Corrective Action Program (CAP) Procedure, revision 9, defines a condition adverse to quality as An all-inclusive term used in reference to any of the following: failures, malfunctions, deficiencies, defective items, and non-conformances. The inspectors determined that the failure of flow switch FIS 2-1360-7 to actuate as designed on low flow was considered a condition adverse to quality per PI-AA-125.
Licensee procedure PI-AA-125-1003, Corrective Action Program Evaluation Manual, revision 7, contains guidance on the process for conducting a CAPE and preparing the associated report. Under Section 4.2, Preparation, step 4.2.3 directs the licensee to determine a problem statement. Section 4.3, Information Gathering, step 4.3.5, directs the evaluators to gather information and data relating to the event or problem. Information includes physical evidence, interviews, records, and documents needed to support the apparent cause analysis. The step goes on to identify plant parameter readings as one such source of information. Under Section 4.1, Precautions, step 4.1.2 states that if at any time a condition adverse to quality, a new issue, or any question of either current or past operability or reportability arises or is identified, then an issue report should be initiated in accordance with PI-AA-120, Issue Identification and Screening Process, revision 13.
The inspectors noted in their review of the CAPE that the licensees identified problem statement was, U2 RCIC was mis-operated for 18 seconds during performance of QCOS 1300-05 in conjunction with QCIPM 1300-04 resulting in RCIC being operated in a short duration no flow condition. Additionally, inspectors determined that during information gathering under PI-AA-125-1003, step 4.3.5, the licensee failed to identify the condition adverse to quality associated with FIS 2-1360-7 during a review of the plant parameters relating to the event. Specifically, the actual low flow condition lasted for approximately 4 minutes versus 18 seconds and directly called into question the conclusion of the operability basis documented in IR 4778839. This issue should have prompted the licensee to initiate an issue report per PI-AA-125-1003, step 4.1.2. Because the licensee failed to identify the condition adverse to quality, no new issue report was generated, prompting an updated operability determination. Therefore, the inspectors determined that the failure to identify this condition adverse to quality was a performance deficiency.
Corrective Actions: The licensee performed an Operability Evaluation under IR 04789755 and performed a RCIC pump comprehensive run to evaluate the issue and to provide reasonable assurance of the RCIC system operability.
Corrective Action References: IR 04789755, Follow up to IR 4786391, IR 04786391, Troubleshoot U2 RCIC SER VS PPC Discrepancy
Performance Assessment:
Performance Deficiency: The inspectors determined that the licensees failure to identify the condition adverse to quality associated with FIS 2-1360-7 during a review of the plant parameters relating to the event was contrary to step 4.3.5 of PA-AA-125-1003 and was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more-than-minor because it was associated with the Human 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, the performance deficiency challenged the documented operability basis of the RCIC system. As a result, it did not ensure the availability, capability, and reliability of this mitigating system.
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: P.2 - Evaluation: The organization thoroughly evaluates issues to ensure that resolutions address causes and extent-of-conditions commensurate with their safety significance. Specifically, the licensee did not thoroughly evaluate readily available information to completely characterize the problem, resulting in the missed identification of the condition adverse to quality associated with flow switch FIS 2-1360-7.
Enforcement:
Inspectors did not identify a violation of regulatory requirements associated with this finding.
Failure to Correct Inadequate Jumper Cable Labeling Practices Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000254,05000265/2024011-02 Open/Closed
[P.3] -
Resolution 71152B The inspectors identified a finding of very low safety significance (Green) and an associated non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion XVI, Corrective Actions, for the licensees failure to promptly correct a condition adverse to quality. Specifically, the licensee revised a station procedure to include labeling instructions for jumper cables, but the revision did not provide instructions appropriate for the circumstances, despite the licensee identifying this as a necessary corrective action.
Description:
On December 6, 2023, the Division 1 125Vdc battery was disconnected to perform the U1 Normal 125 VOC Battery Modification Performance Test. During the test, electrical maintenance was using QCOP 6900-25, Transfer of Unit 1 125 Vdc bus between Normal and Alternate Battery, Revision 28, to put the batteries onto charge. The procedure instructed the removal of insulation and connection of long jumper to the terminal plate.
The electrician disconnected the wrong jumper that was going to the U1 125 Vdc alternate batteries to the bus. This resulted in disconnection of the alternate 125 Vdc batteries from the bus.
With both the Unit 1 Division 1 and the alternate 125Vdc batteries being disconnected, the licensee entered Technical Specification 3.8.4, DC SourcesOperating, Conditions D and E. Condition D states, in part, that with the Division 1 or 2 125 Vdc electrical power subsystem inoperable for reasons other than maintenance, you must restore the affected 125 Vdc electrical subsystem within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or within the Risk Informed Completion Time (RICT) Program, or place the alternate 125 Vdc electrical subsystem in service within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Condition E states, in part, that if the opposite Unit 125 Vdc electrical power subsystem is inoperable, to restore the opposite Unit 125 Vdc electrical power subsystem within 7 days or in accordance with the RICT program. The licensee documented this event in AR 04722018, Issue Putting Unit 1 125 Vdc Battery on Charger, and determined that a contributing cause of this event was the jumper cables not being labeled. The corrective action was to generate Action Item 35 of AR 04722018 to implement a revision to procedure QCOP 6900-25, to provide detailed labeling for these jumper cables.
The inspectors reviewed the revised copy of procedure QCOP 6900-25 (i.e., Revision 29)and noticed that Steps F.3.a, F.3.b, F4.a.(1) and F.4.a.(2) incorrectly directed the technician/operator to label the long jumper cable as short. The inspectors determined that the licensee failed to implement the corrective action as required per Action Item 35 of AR 04722018.
Corrective Actions: The licensee entered the condition into the CAP under IR 4687356 and initiated a procedure change request to correct the jumper cables labeling.
Corrective Action References: AR 04801036, Incorrect Step in QCOP 6900-25
Performance Assessment:
Performance Deficiency: The inspectors determined that the licensees failure to promptly correct the lack of instructions for labeling jumper cables that were appropriate to the circumstances was contrary to 10 CFR 50, Appendix B, Criterion XVI, Corrective Actions, and was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more-than-minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, the licensees failure to provide correct instruction for labeling the jumper cables has the potential to result in a similar event as described in AR 04722018. Specifically, in that event, both the normal and alternate 125 Vdc batteries were unavailable to the DC bus since they were both disconnected, in part, due to the cables not being properly labeled. This resulted in the Unit 1 125Vdc battery being inoperable.
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, Section A, and answered No to all of the screening questions.
Therefore, the finding screens to very low safety significance (Green).
Cross-Cutting Aspect: P.3 - Resolution: The organization takes effective corrective actions to address issues in a timely manner commensurate with their safety significance. Specifically, the licensee revised procedure QCOP 6900-25, but did not verify the revision addressed the issue described in IR 4722718.
Enforcement:
Violation: Title 10 CFR Part 50, appendix B, criterion XVI, Corrective Action, requires, in part, that measures be established to ensure conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are corrected.
Contrary to the above, from December 6, 2023, until at least September 11, 2024, the licensee failed to promptly correct a condition adverse to quality. Specifically, on December 6, 2023, the licensee identified that incorrect jumper cable labeling contributed to the Unit 1 125Vdc battery becoming inoperable while implementing revision 28 of QCOP 6900-25. While the licensee revised this procedure intending to correct the inadequate labeling practice under Action Item 25 of AR 04722018, the revision incorrectly directed long jumper cables to be labeled as short. Action Item 35 was closed on August 28, 2024, crediting the incorrect revision. As a result, the licensee failed to correct the condition adverse to quality.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Minor Performance Deficiency 71152B Failure to Identify a Condition Adverse to Quality Associated with the Unit 1 Station Blackout Diesel 125 Vdc Battery Minor Performance Deficiency: Inspectors identified that the licensee failed to identify a condition adverse to quality, as defined by PI-AA-125, Corrective Action Program (CAP)
Procedure, revision 8, associated with intercell resistance measurements on the Unit 1 station blackout (SBO) diesel 125 Vdc battery. Specifically, QCEPM 0100-01, Station Battery Systems Preventive Maintenance, revision 55, step 4.4.3.2, directed technicians to evaluate intercell resistance readings to determine if they are below the acceptance criteria of 120 percent of the baseline resistance readings. If an intercell resistance reading does not meet acceptance criteria, the procedure directed technicians to generate an issue report in the corrective action program, clean the affected cells, and re-torque the cells in accordance with step 4.5 of the procedure.
Contrary to the above, on October 21, 2022, while performing work under work order 04730645, the licensee failed to identify that the resistance measurement between cells 25-26 exceeded 120 percent of the baseline. As a result, an issue report was not generated, and no further procedural actions were taken to address the condition. Subsequently, under work order 05466769 performed on April 26, 2024, the licensee again recorded values for the intercell resistance between cells 25-26 being greater than acceptance criteria. At the conclusion of this maintenance, the licensee generated issue report 04769124 documenting the condition.
The licensee documented this issue in the CAP as IR 4792004.
Screening: The inspectors determined the performance deficiency was minor. Specifically, the performance deficiency was not viewed as being a precursor to a significant event, the performance deficiency did not have the potential to lead to a more significant safety concern if left uncorrected, and the performance deficiency did not adversely affect any cornerstone attributes listed in the procedure.
Minor Performance Deficiency 71152B Failure to Identify a Condition Adverse to Quality Associated with Station Blackout Diesel Jacket Water Piping Corrosion Minor Performance Deficiency: Licensee document, NO-AA-10, Quality Assurance Topical Report, revision 98, states that the licensee is committed to appendix A and B of Regulatory Guide (RG) 1.155, Station Blackout. RG 1.155, appendix A, Section 8, Corrective Action, states that measures should be established to ensure that failures, malfunctions, deficiencies, deviations, defective components, and nonconformances are promptly identified, reported, and corrected. NO-AA-10, Section A.2, Requirements, states deficiencies are addressed in accordance with the corrective action program for augmented quality systems such as the station blackout diesels.
Additionally, ER-AA-2030, Conduct of Equipment Reliability Manual, revision 30, 7, License Renewal Commitments & Performance Monitoring Commitments, states that there should be no evidence of corrosion on external surfaces of systems being walked down for license renewal. If a condition is applicable and present, ER-AA-2030, 7, directs the individual performing the walk down to either document the condition in an issue report in the corrective action program if it is new, identify if the issue has changed by referencing a previous issue report, or identify if additional actions are needed if the condition has worsened since a previous issue report was generated.
Contrary to the above, on May 30, 2024, the licensee performed a walk down of the station blackout diesel jacket water system and failed to identify and document obvious indications of corrosion of the jacket water piping on top of the station blackout building. The inspectors determined that the failure to write an issue report for the corrosion on the jacket water piping was a performance deficiency.
The licensee captured this item in the CAP as IR 4795822.
Screening: The inspectors determined the performance deficiency was minor. Specifically, the performance deficiency was not viewed as being a precursor to a significant event, the performance deficiency did not have the potential to lead to a more significant safety concern if left uncorrected, and the performance deficiency did not adversely affect any cornerstone attributes listed in the procedure.
Minor Performance Deficiency 71152B Failure to Assign a Corrective Action to Address Blocked Floor Drains in the Main Chimney Basement Drain Lines Leading to a Release of Tritium to the Groundwater Minor Performance Deficiency: During a review of the CAPE associated with IR 4704780, Tritium Troubleshooting Results, the inspectors noted that the failure to clear floor drains was identified as one of the two potential causes for a release of tritium to the groundwater from the main chimney basement drain lines. To correct this issue, the licensee assigned an ACIT in lieu of a Corrective Action to clear the drains and develop a preventive maintenance (PM) activity to ensure they remain cleared. Since the licensee had documented the tritium release as a condition adverse to quality in the IR, the inspectors identified that an ACIT was inappropriate to track the corrective action.
Licensee document, NO-AA-10, Quality Assurance Topical Report, revision 98, Section 5.1, states, in part, that Activities governed by the Companys Quality Assurance Program shall be performed as required by documented instructions, procedures, and drawings appropriate to the activity. Section 16.2 states, in part, that the Company implements a Corrective Action Program to promptly identify and correct items or occurrences that are adverse to quality or might adversely affect the safe operations of a nuclear power station.
Section 16.2.2 states, in part, that measures are established to ensure that conditions adverse to quality are identified and corrected. Station Procedure PI-AA-125, Corrective Action Program Procedure, revision 9, implements the Corrective Action Program, including addressing conditions adverse to quality.
Step 2.1 of PI-AA-125 states, in part, that Action Tracking Items are completed to correct minor problems that are not considered conditions adverse to quality. Step 2.9, states that a Corrective Action is an action taken or planned that restores a condition adverse to quality to an acceptable condition or capability.
Contrary to the above, the licensee assigned an ACIT in lieu of a Corrective Action to address a condition adverse to quality associated with increased levels of tritium in ground water in onsite monitoring wells, observed from June 16-23, 2023. Specifically, the licensee identified that one of the sources of tritium was a leak in the main chimney basement drain line that due to a blocked drain, was allowed to accumulate and flow out through a penetration into the groundwater. Although the licensee initiated a corrective action to repair the leak, they only assigned an ACIT to address the issue of the blocked drain, a condition they documented as adverse to quality. This was contrary to PI-AA-125 which, as documented above, states that a corrective action, and not an ACIT, was required to correct a condition adverse to quality. The inspectors determined that the failure to assign a corrective action to address the blocked drain for the main chimney basement drain line was a performance deficiency.
The inspectors noted that the licensee had completed actions to clean the drains and developed a PM to ensure they were cleaned. The inspectors reviewed selective work history records to verify that the drains were being cleaned in accordance with the PM frequency.
This issue was documented in the CAP as IR 4804752.
Screening: The inspectors determined the performance deficiency was minor. The inspectors screened the performance deficiency in accordance with the more-than-minor screening questions under Inspection Manual Chapter 0612, Appendix B, Issue Screening Directions, block 4, and determined that the performance deficiency was minor. Specifically, the performance deficiency was not viewed as being a precursor to a significant event, the performance deficiency did not have the potential to lead to a more significant safety concern if left uncorrected, and the performance deficiency did not adversely affect any cornerstone attributes listed in the procedure.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 3, 2024, the inspectors presented the biennial problem identification and resolution inspection results to Douglas Hild, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2A SBO Fuel Injector Control Linkage
01/24/2017
Received 902-5 G-1 (24/48 Batt Charger 2A/2B Circuit Fail)
09/22/2020
ERV 2-0203-3B Relief Valve Failed to Actuate
03/21/2022
Part 21 Framatome Circuit Breakers
05/24/2022
2A FRV Failed Close
08/17/2022
2A FRN Failed Close, U2 Manual SCRAM
Inserted on Low Rx Level
07/04/2022
U1 SBO Failed to Start
07/30/2022
Unit 2 HPCI Room Cooler Insulation Missing or Degraded
Unit 2 LPRM 68-48-49 Drift Alarm Received Multiple Times
Torque Wrench Calibration Exceeded
NRC PI&R ID: Caulk Missing Between B CCST and
Foundation
09/22/2022
NRC PI&R ID: Insufficient Detail to AMP B.1.20 Walkdown
09/16/2022
Change Scope of PMRQ 166690-03 and 166691-03
09/27/2022
NRC PI&R ID: Walkdown Data Not Recorded in Entirety
09/29/2022
Safety Culture Assessments not in Passport
09/30/2022
Did Not Receive Rod Block as Expected
NRC PI&R ID: Issue Report 4432559 Operability Basis
10/05/2022
NRC NOV 2022-090-01 3B ERV White Finding and
Column 2
11/30/2022
NRC NOV Finding 2022-003-02 FLEX TSA Procedure
2/06/2022
MRC Requested Review for Potential Trends in PI&R IDs
2/08/2022
Potential Trend in Questioning Attitude
01/11/2023
Steps in EMD Procedures May Conflict With MA-AA-716-008
01/28/2023
Rod Position Indication System Issues Identified
with Unit 1 Control Rod
U1 SBO not Able to Obtain Full Load
04/27/2023
Indication Discovered on Sealing Surface of RPV Flange
05/14/2023
Lost Light Indication for 2A Core Spray
06/28/2023
Corrective Action
Documents
Lost Light Indication for 2A Core Spray
06/28/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Unit 2 Turbine Trip and SCRAM Due to High Moisture
Separator Drain Tank Level
08/11/2023
NRC ID: Missed OPEX Review on Historical Part 21
08/14/2023
Summer Readiness Lessons Learned
2A RHRSW Sump Pump Not Working
1/2 EDG Load Test Abort
Tritium Troubleshooting Results
09/25/2023
Issue Putting U1 125 VDC Battery on Charger
2/07/2023
U1 EDG Failed During Performance QCOS 6600-41
2/11/2023
2B Recirculation Pump Trip
2/15/2023
NRC FIN 2023-003-02 SBO Full Load Failure
01/12/2024
Unit 1 SBO Exhaust Fan #1 Drive Failed
2/29/2024
2B Feedwater Regulating Valve Drifted Open
After Power Ascension
Unit 2 250 VDC Battery Charger
Work Group Evaluation (WGE) 04795822 Rejected by MRC
09/19/2024
AR 048112751
NRC PI&R OBS--ACITs in Support of CA or CAPRs
QCOP 6900-25 Procedure Error
09/11/2024
Incorrect Outage Coding for WO 5283770-01
09/24/2024
Bus 13 Cub 13 Breaker Swap be Scope Into Q1R28
09/25/2024
Corrective Action
Documents
Resulting from
Inspection
Bus 14 Cub 11 Breaker Swap be Scope Into Q1R28
09/25/2024
Corrective Action Program
Revision 9
Root Cause Analysis Manual
Revision 8
Procedures
QCOP 6900-25
Transfer of Unit 1 125 VDC Bus Between Normal and
Alternate Battery
4668655
Off Year NRC PI&R Assessment of the CAP
2/19/2023
NOSA-QDC-21-
Corrective Action Program Audit
09/22/2021
Self-Assessments
NOSA-QDC-24-
Corrective Action Program Audit Report
08/14/2024