IR 05000456/2012009

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IR 05000457-12-009; 11/26/12 - 11/30/12; Braidwood Station, Unit 2; Supplemental Inspection - Inspection Procedure 95001
ML12362A257
Person / Time
Site: Braidwood Constellation icon.png
Issue date: 12/27/2012
From: Duncan E R
Region 3 Branch 3
To: Pacilio M J
Exelon Generation Co
References
IR-12-009
Download: ML12362A257 (21)


Text

December 27, 2012

Mr. Michael Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO), Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT: BRAIDWOOD STATION, UNIT 2, SUPPLEMENTAL INSPECTION REPORT 05000457/2012009 AND ASSESSMENT FOLLOW-UP LETTER

Dear Mr. Pacilio:

On November 30, 2012, the U. S. Nuclear Regulatory Commission (NRC) completed a supplemental inspection pursuant to Inspection Procedure 95001, "Supplemental Inspection for One or Two White Inputs in a Strategic Performance Area," at your Braidwood Station, Unit 2. The enclosed report documents the inspection results, which were discussed during a Regulatory Performance Meeting on November 30, 2012, with Mr. D. Enright and other members of your staff. In accordance with the NRC Reactor Oversight Process (ROP) Action Matrix, this supplemental inspection was performed to follow up on the White Mitigating System Performance Index (MSPI) for the Cooling Water Systems Performance Indicator (PI) which crossed the threshold from Green to White in the second quarter of 2012. We documented this issue in our Assessment Follow-Up Letter (ML12220A393) to you on August 6, 2012. The NRC staff was informed by your letter (ML12305A423) dated October 30, 2012, of your readiness for this inspection. The objective of this supplemental inspection was to provide assurance that the root causes and contributing causes resulting in the White MSPI were understood, the extent of condition and extent of cause were identified, and that the corrective actions were sufficient to address the root causes and contributing causes and to prevent recurrence. The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspector reviewed selected procedures and records and interviewed personnel. Based on the results of this inspection, no findings were identified. We determined that your root cause evaluation was conducted to a level of detail commensurate with the significance of the problem and reached reasonable conclusions as to the root and contributing causes of the event. We also concluded that you identified the extent of condition and extent of cause of the issue, that you identified appropriate corrective actions for each root and contributing cause, and that you appropriately prioritized these actions. As a result of our quarterly review of plant performance, which was completed on October 31, 2012, the NRC updated its assessment of Braidwood Station Unit 2. The NRC's evaluation consisted of a review of PIs and inspection results. The NRC's review of Braidwood Unit 2 identified that the MSPI for the Cooling Water Systems returned to the Green performance band in the third quarter of 2012. In accordance with NRC Inspection Manual Chapter 0305, "Operating Reactor Assessment Program," the MSPI for the Cooling Water Systems is considered a Green Action Matrix input as of July 1, 2012. Therefore, as a result of the successful completion of the supplemental inspection and a Green MSPI for the Cooling Water Systems, the NRC determined the performance at Braidwood Station, Unit 2 to be within the Licensee Response column of the ROP Action Matrix as of the date of this letter. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any), will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/ Eric R. Duncan, Chief Branch 3 Division of Reactor Projects Docket No. 50-457 License No. NPF-77

Enclosure:

Inspection Report 05000457/2012009

w/Attachment:

Supplemental Information cc w/encl: Distribution via ListServ Enclosure U. S. NUCLEAR REGULATORY COMMISSION REGION III Docket No: 50-457 License No: NPF-77 Report No: 05000457/2012009 Licensee: Exelon Generation Company, LLC Facility: Braidwood Station, Unit 2 Location: Braceville, Illinois Dates: November 26, 2012, through November 30, 2012 Inspector: D. Passehl, Senior Reactor Analyst, Region III Approved by: E. Duncan, Chief Branch 3 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

......................................................................................................... 1

REPORT DETAILS

OTHER ACTIVITIES

...................................................................................................... 3

4OA4 Supplemental Inspection

.............................................................. 3

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

.................................................................................................. 1

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED ........................................................ 1

LIST OF DOCUMENTS REVIEWED

...................................................................................... 2

LIST OF ACRONYMS

US [[]]

ED .................................................................................................. 3

Enclosure

SUMMAR Y
OF [[]]
FINDIN [[]]
GS Inspection Report (IR) 05000457/2012009; 11/26/12 - 11/30/12; Braidwood Station, Unit 2; Supplemental Inspection - Inspection Procedure 95001. This supplemental inspection was performed by a Region
III Senior Reactor Analyst. No findings were identified. The
NRC 's program for overseeing the safe operation of commercial nuclear power reactors is described in
NUREG -1649, "Reactor Oversight Process," Revision 4, dated December 2006. A. Cornerstone: Mitigating Systems
NRC [[-Identified and Self-Revealed Findings This supplemental inspection was performed in accordance with Inspection Procedure 95001, "Supplemental Inspection for One or Two White Inputs in a Strategic Performance Area," to assess the licensee's root cause evaluation, extent of condition and extent of cause determination, and corrective actions related to the identification of a White performance indicator (PI) with the Cooling Water Systems element of the Mitigating Systems Performance Index (MSPI). Specifically, this Cooling Water Systems]]
MSPI was reported as White in the licensee's second quarter 2012
PI data submitted to the
NRC. This
MSPI was subsequently reported as Green in the third quarter
2012 PI submittal. In preparation for the inspection, the licensee performed Root Cause Evaluation (
RCE ) 1390319, "Root Cause Report for 2Q2012
MSPI White Index in
CWS [[[Cooling Water Systems]," to identify the root and contributing causes for this White]]
MSPI. This
RCE determined that the White Cooling Water Systems
MSPI was due to probabilistic risk assessment model change errors, operating restrictions on the cooling water systems, and equipment failures; and that these problems were due to organizational weaknesses with
MSPI margin management, and weak organizational understanding, ownership, and challenging of the
MS [[]]
PI. The inspector reviewed the licensee's
RCE in addition to other evaluations conducted in support and as a result of the

RCE. The inspector reviewed corrective actions that were taken or planned to address the identified causes. The inspector also held discussions with licensee personnel to ensure that the root and contributing causes and the contribution of safety culture components were understood, and corrective actions taken or planned were appropriate to address the causes and preclude repetition. During this inspection, the inspector determined that the licensee's root cause evaluation was conducted to a level of detail commensurate with the significance of the problem and reached reasonable conclusions as to the root and contributing causes of the event. The inspector also concluded that the licensee identified appropriate corrective actions for each root and contributing cause and that these actions were appropriately

prioritized. Consistent with

NRC Inspection Manual Chapter (
IMC ) 0305, "Operating Reactor Assessment Program," the White Cooling Water Systems
MSPI is considered a Green

NRC Action Matrix input as of July 1, 2012. Therefore, since all other NRC Action Matrix

Enclosure inputs are currently Green, Braidwood Station, Unit 2 has transitioned from the Regulatory Response column back to the Licensee Response column of the Reactor Oversight Process (ROP) Action Matrix as of the date of this supplemental inspection report and assessment follow-up letter. B. None. Licensee-Identified Violations

Enclosure

REPORT [[]]
DETAIL S 1. 4.
OTHER [[]]
ACTIVI TIES
4OA [[4 Supplemental Inspection (95001) .01 Inspection Scope This inspection was conducted in accordance with Inspection Procedure 95001, "Supplemental Inspection for One or Two White Inputs in a Strategic Performance Area," to assess the licensee's evaluation associated with unreliability and unavailability reporting in the Cooling Water Systems element of the Mitigating Systems Performance Index (]]
MSPI ). The Cooling Water Systems
MSPI was reported as White in the licensee's second quarter 2012 Performance Indicator (
PI ) data submitted to the
NRC. The Cooling Water Systems
MSPI was subsequently reported as Green in the third quarter
PI [[submittal. The inspection objectives were to: Provide assurance that the root causes and contributing causes of risk-significant performance issues were understood; Provide assurance that the extent of condition and extent of cause of risk-significant issues were identified; and Provide assurance that the licensee's corrective actions for risk-significant performance issues were or will be sufficient to address the root causes and contributing causes, and to prevent recurrence. By letter dated August 6, 2012, the]]
NRC communicated the results of its quarterly evaluation of plant performance, which was completed on July 31, 2012. The evaluation included an overall review of performance indicators and inspection results. The
NRC 's review of Braidwood Unit 2 identified that the Cooling Water Systems
MSPI crossed the Green-to-White threshold in the second quarter of 2012. This was due to probabilistic risk assessment model change errors, operating restrictions on the cooling water system, and equipment failures. The
NRC determined the performance at Braidwood Station Unit 2 to be in the Regulatory Response column of the
ROP Action Matrix beginning in the second quarter of 2012 based on the
PI data reported to the
NRC. On October 30, 2012, the licensee notified the
NRC that a root cause investigation had been completed and that it was ready for the
NRC to conduct this supplemental inspection to review their evaluation of the causes and the actions taken to address the White Cooling Water Systems
MSPI. In preparation for the inspection, the licensee performed Root Cause Evaluation (
RCE ) 1390319, "Root Cause Report for 2Q2012
MSPI White Index in
CWS [[[Cooling Water Systems]," to identify the root and contributing causes for the White Cooling Water System]]
MSPI. The inspector reviewed the licensee's

RCE in addition to other evaluations conducted in support and as a result of the RCE. The inspector reviewed

Enclosure corrective actions that were taken or planned to address the identified causes. The inspector also held discussions with licensee personnel to ensure that the root and contributing causes and the contribution of safety culture components were understood and corrective actions taken or planned were appropriate to address the causes and preclude repetition. .02 Evaluation of the Inspection Requirements 02.01 Problem Identification a. Determine that the evaluation documented who identified the issue (i.e., license-identified, self-revealed, or

NRC -identified) and under what conditions the issue was identified. The inspector determined that the licensee's
RCE [[adequately described the conditions through which this self-revealed issue was identified. During the entry of Cooling Water Systems data into the Consolidated Data Entry (CDE) reporting software for the second quarter 2012, it was self-revealed to the component cooling water and essential service water system managers that the Unit 2 Cooling Water Systems]]
MSPI value had exceeded the Green-to-White threshold of 1.0E-6 with a reported

MSPI value of 1.1E-06.

In the subsequent

RCE , the licensee identified that organizational weaknesses with
MSPI margin management, and weak organizational understanding, ownership, and challenging of the
MSPI contributed to the identified White
MSPI. Regarding the second quarter 2012 Cooling Water Systems
MSPI , there were five key contributors that led to the Green-to-White threshold being exceeded. The licensee determined that had any one of the five contributors not occurred, the Cooling Water Systems
MSPI would have remained Green. The inspector noted that from largest to smallest, the White
MSPI [[contributors were as follows: Component Cooling Water Pump Pressure Switch Failures; Probabilistic Risk Assessment Model Changes; Component Cooling Water System Split Train Operation; Essential Service Water System Unavailability Above Baseline; and Removal of Credit and Use of the Auxiliary Feedwater (]]
AF ) System Cross-Tie. b. Determine that the evaluation documented how long the issue existed and prior opportunities for identification. The inspector determined that the licensee's
RCE adequately documented how long the issues leading to the second quarter 2012 Cooling Water Systems

MSPI data exceeding 1.0E-6 existed and prior opportunities for identification. Component Cooling Water Pump Pressure Switch Failures

Braidwood had two Component Cooling Water (CC) pump failures early in the 12 quarter

MSPI monitoring period attributable to failures of the pump discharge pressure switches. The first occurred in July 2009 with the 2B

CC pump and the second occurred in

Enclosure January 2010 with the 2A

CC pump. These switches were considered nonsafety-related and provide for an automatic start of the standby
CC pump on low discharge header pressure (85 pounds per square inch gauge decreasing). These switches also provide a "CC Pump Discharge Pressure Low" alarm in the Main Control Room. These pressure switch failures were classified as
MSPI failures because actuation on low discharge pressure had not been explicitly excluded from the monitored scope in the Cooling Water Systems
MSPI Basis Document. In March 2010, the licensee determined that the switch failures should not have been classified as
MSPI failures because the switches were not part of the engineered safety feature start circuitry and had no impact on the safety function of the
CC pumps. Even though the switches were later reclassified, the licensee could not exclude the failures from past consideration because
MS [[]]

PI is a forward-looking indicator.

The inspector observed that the

CC pump pressure switch failures contributed the most to the second quarter 2012 Cooling Water Systems
MSPI value, yet in hindsight was the easiest of the five contributors to address. Had the licensee performed a risk evaluation and removed the switches from the
MSPI scope following the initial switch failure in July 2009, then the second pressure switch failure in January 2010 would not have been counted and the Cooling Water Systems
MSPI would have remained Green for the second quarter of 2012. Probabilistic Risk Assessment (PRA) Model Changes The licensee determined that the process for
PRA model changes did not include adequate controls to ensure that an impact to the Cooling Water Systems

MSPI margin was recognized and understood in advance of these changes. Margin refers to the change in Core Damager Frequency (CDF) required for delta-CDF to exceed 1.0E-6/year. Probabilistic Risk Assessment Model Change 6F in September 2011 resulted from CC split train operation (discussed below). Probabilistic Risk Assessment periodic

update

BB 011a in March 2012 included removal of the

AF cross-tie (also discussed below). The licensee had not recognized the impact of these PRA model changes

sufficiently in advance of the

MSPI reporting period to identify and evaluate potential conservative assumptions in the model that could have been re-examined and possibly modified to allow the
MSPI to remain Green. Component Cooling Water Pump Split Train Operation For most of the life of the plant the
CC system was operated as a shared train system and a semi-shared system between units. This included post-
LOCA [[[Loss-of-Coolant-Accident] operation, during which time the system would not be split into its individual trains unless there was a leak detected in the system. In late 2008, the licensee found that this practice was not in compliance with the operating license and subsequently required the]]
CC system to be split with the trains operated independently for emergency core cooling system recirculation during post-
LOCA conditions. Related to this was an issue identified in 2010 associated with the common or "0"
CC pump. The licensee found that the 0
CC pump was not a fully qualified functional spare pump for it to be aligned to replace the Unit 1 or Unit 2 'B'
CC pumps due to it being isolated from the

CC surge tank during post-LOCA operation. This situation increased the unreliability of the individual CC trains and core damage frequency. This issue of spilt train operation was

Enclosure initially identified by the licensee as early as 2008 at the Byron Station during preparation for an

NRC Component Design Basis Inspection. Essential Service Water System Unavailability Greater Than Baseline Braidwood essential service water (
SX ) system planned unavailability had been greater than its predicted baseline unavailability during the 12-quarter
MSPI monitoring period. This directly contributed to a loss of
MSPI margin. For the 2A
SX [[Train, for example, the actual planned unavailability from July 2009 through June 2012 was higher than baseline with 236 hours of actual unavailability as compared to a planned unavailability of 135 hours. This was primarily due to normal preventive maintenance work, system upgrades, and degraded component repairs. At the beginning of the second quarter 2012, when the Cooling Water Systems]]
MSPI became White, the unavailability contribution to
MSPI from
SX was 5E-07; half of the contribution to exceeding the Green-to-White Cooling Water Systems
MSPI threshold of 1E-06. Baseline unavailability data used in
MSPI was based on Braidwood data from 2002 through 2004. The licensee evaluated and revised some
SX [[maintenance practices over the last 3 years such that activities previously counted towards system unavailability would not be considered as such going forward. Removal of Credit and Use of the Auxiliary Feedwater System Cross-Tie In October 2009 the licensee installed a cross-tie between the Unit 1 and 2 'A' (motor-driven)]]
AF pumps. Subsequently, in October 2011 the
NRC identified a finding and an associated Severity Level
IV non-cited violation (NCV) of
10 CFR 50.59, "Changes, Tests, and Experiments," associated with installation of the cross-tie. Specifically, licensee personnel failed to obtain a required license amendment prior to installing the cross-tie. This issue was documented in
NRC Inspection Report 05000456/2011004; 05000457/2011004. In response, the licensee removed the reference to the use of the cross-tie in the emergency operating procedures and its credit in the
PRA , which increased the importance of the
CC system and caused an increase in the significance of the previous
CC pump pressure switch failures. c. Determine that the evaluation documented the plant-specific risk consequences, as applicable, and compliance concerns associated with the issue. The inspector determined that the

RCE adequately documented the plant-specific risk consequences and compliance concerns associated with the event. Component Cooling Water Pump Pressure Switch Failures

The

CC pump pressure switch failures that were identified in July 2009 and January 2010 increased the unreliability of the
CC pumps. Starting in the third quarter
2012 MSPI monitoring period, the first pressure switch failure in July 2009 would no longer be considered in the reporting of Cooling Water Systems

MSPI data since this failure was outside of the 3-year monitoring period. As discussed earlier, following the second pressure switch failure, the licensee reclassified the pressure switch failures as being of low safety significance. The inspector agreed with the licensee's actions and conclusions regarding reclassification of future pressure switch

Enclosure failures. Therefore, any future

CC pressure switch failure would not be considered in
MSPI data reporting. Probabilistic Risk Assessment Model Changes The licensee's
RCE identified no
PRA modeling errors (i.e. modeling mistakes that caused the model to not adequately represent the as-built and as-operated plant). However, the
RCE identified weaknesses with the
PRA model revision process, including an absence of station reviews of pending model changes to identify losses of
MSPI margin. Besides
MSPI applications, the site-specific
PRA was also used to support other applications, such as online work risk assessments, maintenance rule applications, risk-informed in-service inspections, and risk-informed license amendment requests. All
PRA application models, except
MSPI , permitted interim changes if minor modeling assumptions or logic inputs needed to be revised. For
MSPI , however, a
PRA model used at the start of a quarter must be used throughout the quarter so any necessary
PRA adjustments affecting
MSPI cannot be made effective until the following quarter after a
PRA model change has been approved. The
RCE identified that there was no process to perform additional
PRA model reviews or revisions sufficiently in advance to address unanticipated reductions of
MSPI margin. Further, the
MSPI [[margin management process was not well defined and relied on a single corporate expert. The corporate knowledge was not adequately captured in processes and procedures. Component Cooling Water System Split Train Operation As discussed above, the licensee revised the operation of]]
CC during post-
LOCA conditions to require the system to be split. Loss-of-Coolant-Accident events are low likelihood, passive system failure events. The impact of a
CC system failure given a
LOCA [[is of greater risk in the split train configuration due to the loss of redundancy and cross-train power supplies. Administrative controls were implemented by the licensee as short-term corrective actions until a license amendment request (LAR) was submitted and approved. These short-term actions included reducing the]]
CC system Technical Specification (
TS ) Allowed Outage Time (AOT) from 7 days to 72 hours and prohibiting the
0 CC pump from being aligned to replace either unit's "B" pump. Longer-term corrective actions included modifications to restore compliance with the current licensing basis (
CLB ). Because this condition applied to Byron Station due to similar
CC [[system configurations, Byron and Braidwood were working together on a common resolution. At the end of this inspection, the issue had been entered into the licensee's corrective action program and was identified in the root cause report as Corrective Action Item 1, "Submit a]]
LAR to not preemptively split
CC trains post-
LOCA in order to regain
CWS [[[Cooling Water Systems]]]
MSPI margin." This issue was also discussed in
NRC Inspection Report 05000454/2011004; 05000455/2011004 for the Byron Station. Essential Service Water System Unavailability Above Baseline Although Braidwood

SX maintenance unavailability had historically exceeded its baseline unavailability value, the overall risk significance was low. In Braidwood Unit 1

Enclosure

PRA model
BB 011a, the maintenance term for the 1A (normal standby)
SX pump contributed approximately 1.5 percent to the plant core damage frequency, and for the 1B (normally running)
SX pump the maintenance term was approximately 0.17 percent. Removal of Credit and Use of the Auxiliary Feedwater System Cross-Tie The compliance issues and risk significance were discussed in a previous
NRC inspection report. Specifically, a violation of very low safety significance was documented in

NRC Inspection Report 05000456/2011004; 05000457/2011004. d. Findings No findings were identified. 02.02 Root Cause, Extent of Condition, and Extent of Cause Evaluation a. Determine that the problem was evaluated using a systematic methodology to identify the root and contributing causes. The inspector determined that the root cause evaluation adequately applied systematic methods in evaluating the issue in order to identify root causes and contributing causes.

In the root cause evaluation, the licensee utilized Event and Causal Factor Charting, the TapRooT system, Barrier Analysis, Interviewing, and Why Staircase root cause methodologies. The root cause investigation was conducted by a team of eight investigators. The systematic methodology was applied to the evaluation of plant history, operational changes, and process issues (margin assessment and

PRA model changes) that led to exceeding the Cooling Water Systems
MSPI [[Green-to-White threshold. b. Determine that the root cause evaluation was conducted to a level of detail commensurate with the significance of the problem. The inspector determined that the root cause evaluation was conducted to a level of detail commensurate with the significance of the problem and reached reasonable conclusions as to the root and contributing causes of the event. As a result of the investigation into these issues the licensee identified two root causes (RCs) and five contributing causes (CCs). The identified root causes were as follows:]]
RC -1: Inadequate process controls for
MSPI margin management with respect to revising
PRA models; and
RC -2: Inadequate process controls for identifying, managing and communicating
MS [[]]

PI margin. The identified contributing causes were as follows:

Enclosure

CC -1: Component Cooling Water system alignment post-
LOCA did not meet
GDC [[[General Design Criteria] 44;]]
CC -2: The process barriers in procedure
ER -
AA [[-600-1015, "FPIE [Full Power Internal Events]]]
PRA Model Update," for review of
PRA model revisions for impact on
MSPI margin were not robust;
CC -3: Failure to recognize the need for a license amendment request prior to implementing the
AF cross-tie modification;
CC -4:
SX pump train unavailability was managed relative to the margin remaining in Green in the
CDE margin report as opposed to unavailability over baseline; and
CC -5: Less reliable replacement switches for the component cooling water pumps caused increased failures. The licensee's root cause evaluation found the overall process for managing
MSPI to lack robustness and allowed for a loss of
MS [[]]

PI margin over time. A key factor that

impacted all of the identified root and contributing causes was management of the site

PRA in relation to
MSPI. Given the importance of the
PRA model in relation to
MSPI , the licensee found that more robust
PRA model reviews were necessary to ensure that the status of

MSPI margin is known and understood prior to model approval, and that the margin status is precisely communicated to station management. c. Determine that the root cause evaluation included a consideration of prior occurrences

of the problem and knowledge of prior operating experience. The inspector determined that the root cause evaluation included consideration of prior occurrences of the problem and knowledge of prior operating experience. The root cause evaluation included a search for prior occurrences and operating experience within internal and external databases, including the Exelon Corrective Action Program database.

With regard to prior occurrences, the root cause evaluation included a search of corrective action documents to identify previous events related to

MSPI and
PRA. This search identified several issue reports (IRs) that discussed
MSPI margin management issues. However, those
IR s only focused on margin recovery methods, not needed improvements in
MSPI processes as identified in the licensee's root cause evaluation report. Regarding
PRA , there were several human performance-related
IR s in the corrective action program related to licensee personnel failing to follow established
PRA -related processes and procedures. The
PRA -related issues in the licensee's root cause evaluation report related to inadequate
PRA -related processes and procedures, which were adequately captured in
IR [[s. With regard to operating experience, the root cause evaluation report discussed ten operating experience issues external to Exelon. The licensee performed an adequate review of these issues. No new corrective action documents were written as a result of the operating experience reviews since either relevant issues were already captured as part of the licensee's own root cause investigation, or the issues did not impact]]
MSPI. [[Enclosure d. Determine that the root cause evaluation addressed the extent of condition and the extent of cause of the problem. The inspector concluded that the licensee adequately addressed the extent of condition and extent of cause of the problem. The inspector's review of the extent of condition for which the root and contributing causes were identified found that each problem was evaluated against other systems or programs that may be affected. The extent of condition included assignments to review the root and contributing causes at other plants in the Exelon fleet and to implement additional reviews for Low Margin and "At-Risk"]]
MSPI [[systems. The licensee's extent of cause effort included a review of each of the seven root and contributing causes and either described how the causes were being reviewed (including a reference to an action tracking item) or statements on acceptability. e. Determine that the root cause, extent of condition, and extent of cause evaluations appropriately considered the safety culture components as described in Inspection Manual Chapter (]]

IMC) 0305. The inspector determined that the root cause, extent of condition, and extent of cause evaluations appropriately considered the safety culture components as described in IMC 0305.

The inspector reviewed the

RCE and validated the licensee had systematically considered each of the safety culture components. The safety culture components, as identified in

NRC Regulatory Issue Summary 2006-13, "Information on the Changes Made to the Reactor Oversight Process to More Fully Address Safety Culture," were assessed as part of this root cause. Issues were identified in the areas of decision-making, work control, work practices, corrective action program, and continuous learning

environment. Recommended actions to address these issues were properly identified in the RCE report. f. Findings No findings were identified. 02.03 Corrective Actions a. Determine that appropriate corrective actions are specified for each root and contributing cause or that the licensee has an adequate evaluation for why no corrective actions are necessary.

The inspector reviewed applicable corrective actions (CAs) and corrective actions to prevent recurrence (CAPRs) and determined that the licensee specified reasonable and

appropriate corrective actions for each root and contributing cause. The root cause evaluation report identified

2 CAPR s, 13
CA s, and 12 action items (ACITs). There were also pre-existing corrective action items for the specific key factors discussed earlier. The inspector confirmed that each
CAPR and

CA were entered into the licensee's computerized tracking system, and sampled the other corrective action

Enclosure program assignments. In those instances when it was determined that no corrective actions were necessary, the basis for those decisions were clearly documented in the RCE. b. Determine that corrective actions have been prioritized with consideration of risk

significance and regulatory compliance. The inspector concluded that the licensee adequately prioritized the corrective actions with consideration of the risk significance and regulatory compliance. Overall, the corrective action implementation deadlines appeared reasonable and commensurate with risk significance. The licensee's immediate corrective actions appeared effective in preventing similar events until the long-term

CA s and
CAPR s could be completed. Time frames for actions to address the root causes and contributing causes were established commensurate with their safety significance and contribution to the event. There were two regulatory issues referenced related to the
AF cross-tie modification and splitting of the
CC trains. The corrective actions identified involved submittal of
LAR s. For the
AF cross-tie modification, the
LAR had been submitted and was awaiting
NRC approval. For the
CC split train issue, the licensee established a due date of March 1, 2013 for submitting the

LAR. c. Determine that a schedule has been established for implementing and completing the corrective actions. The inspector determined that the licensee adequately established a schedule for implementing and completing the corrective actions. The licensee assigned completion due dates that were commensurate with the safety significance of the issues being addressed as well as the level of effort required to complete the actions. Completion dates were being tracked in the corrective action program. d. Determine that quantitative or qualitative measures of success have been developed for determining the effectiveness of the corrective actions to prevent recurrence. The inspector determined that the licensee adequately developed quantitative or qualitative measures of success for determining effectiveness of the corrective actions

to prevent recurrence.

Each root cause had an associated effectiveness review scheduled in the corrective action program. The effectiveness reviews were all scheduled to be completed 1 year after the associated

CAPR [[s had been completed to allow an adequate basis to assess effectiveness. The inspector determined that the effectiveness review criteria established for the issues were appropriate. e. Determine that the corrective actions planned or taken adequately address a]]

NOV that was the basis for the supplemental inspection, if applicable.

Enclosure The White Cooling Water Systems

MSPI that was the subject of this inspection was not associated with an
NOV. [[Therefore, this inspection aspect was not applicable and, as a result, was not reviewed. f. Findings No findings were identified. 02.04 Evaluation of Inspection Manual Chapter 0305 Criteria for Treatment of Old Design Issues The licensee did not request credit for self-identification of an old design issue; therefore, the White Cooling Water Systems]]
MSPI was not evaluated against the
IMC 0305 criteria for treatment of an old design issue.
4OA [[6 Management Meetings .01 Exit Meeting Summary The inspector presented the inspection results to Mr. D. Enright and other members of the licensee management on November 30, 2012. Proprietary material received during the inspection was returned to the licensee and was not included in this report. .02 Regulatory Performance Meeting On November 30, 2012, the]]
NRC met with the licensee to discuss its performance in accordance with Section 10.02.b.4 of
IMC 0305. During this meeting, the
NRC and licensee discussed the issues related to the White Cooling Water Systems
MSPI that resulted in Braidwood Station, Unit 2, being placed in the Regulatory Response column of the
NRC 's
ROP Action Matrix. This discussion included the causes, corrective actions, extent of condition, extent of cause, and other planned licensee actions.
ATTACH MENT:
SUPPLE [[]]
MENTAL [[]]
INFORM [[]]
ATION Attachment
SUPPLE [[]]
MENTAL [[]]
INFORM [[]]
ATION [[]]
KEY [[]]
POINTS [[]]
OF [[]]
CONTAC T
D. [[Enright, Site Vice President M. Kanavos, Plant Manager Licensee M. Marchionda-Palmer, Director, Site Operations G. Krueger, Director, Probabilistic Risk Assessment P. Boyle, Director, Site Work Management F. Gogliotti, Senior Manager, Plant Engineering P. Raush, Senior Manager, Design Engineering R. Radulovich, Manager, Site Nuclear Oversight J. Kijowski, Manager,]]
NSSS Systems C. VanDenburgh, Manager, Site Regulatory Assurance J. Odeen, Manager, Site Projects J. Nedza, Supervisor, Security Operations C. Xydis, Supervisor, Radwaste/Environmental D. Gullott, Corporate Licensing
J. Bashor, Special Projects R. Linthicum, Risk Engineer H. Addis, Risk Management S. Falvo, Risk Management J. Zoeller, Nuclear Oversight M. Abbas,
NRC Coordinator
G. Shear, Deputy Division Director, Division of Reactor Projects Nuclear Regulatory Commission E. Duncan, Chief, Reactor Projects Branch 3 D. Passehl, Senior Reactor Analyst J. Benjamin, Senior Resident Inspector C. Sanders, Reactor Operations Engineer
LIST [[]]
OF [[]]
ITEMS [[]]
OPENED ,
CLOSED [[]]
AND [[]]

DISCUSSED Opened None. Closed None. Discussed None.

Attachment

LIST [[]]
OF [[]]
DOCUME [[]]
NTS [[]]
REVIEW [[]]
ED The following is a list of documents reviewed during the inspection. Inclusion on this list does not imply that the
NRC inspector reviewed the documents in their entirety, but rather, that selected sections of portions of the documents were evaluated as part of the overall inspection effort. Inclusion of a document on this list does not imply
NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report. Documents Reviewed
BW -
MSPI -001,
MSPI Basis Document, Rev. 8
AR 1390319, Braidwood Unit 2 Confirmed
MSPI White Cooling Water System
AR 1258017, 1A/2A
AF Pump Discharge Crosstie Regulatory Concern
AR 1420632, Corporate Root Cause Report Rejected by Braidwood
MRC [[[Management Review Committee]]]
AR 1391877, Unit 1 Cooling Water System
MSPI is White for April 2012
AR 1319046,
BYR /
BRD [[]]
MSPI Lessons Learned
AR 0841395,
CDBI [[[Component Design Bases Inspection]]]
FASA [[]]
CC System Post-
LOCA [[[Loss-of-Coolant-Accident] Passive Failures (Byron)]]
AR 1043006,
MSPI Basis Document - Enhancement Opportunity
AR 1071578, 2
PS -0673A
EACE [[[Equipment Apparent Cause Evaluation] - Extent Of Condition Review]]
AR 1412759,
IP 95001 Readiness Self-Assessment
ER -AA-600-1011, Risk Management Program, Rev.
11 ER -
AA -600-1012, Risk Management Documentation, Rev.
9 ER -
AA -600-1015,
FPIE [[]]
PRA Model Update, Rev.
13 ER -
AA -600-1047, Mitigating Systems Performance Index Basis Document, Rev.
7 LS -
AA -120, Issue Identification and Screening Process, Rev.
14 LS -
AA -125, Corrective Action Program (CAP) Procedure, Rev.
17 LS -
AA -126, Self-Assessment and Benchmark (SAB)
PROG , Rev. 7
LS -AA-2001, Collecting and Reporting of
NRC Performance Indicators, Rev. 14
LS -AA-2200, Mitigating System Performance Index Data Acquisition and Reporting, Rev.
5 LS -
AA -125-1001, Root Cause Analysis Manual, Rev.
10 LS -
AA -125-1002, Common Cause Analysis Manual, Rev.
7 LS -
AA -125-1003, Apparent Cause Evaluation Manual, Rev.
10 LS -
AA -125-1004, Effectiveness Review Manual, Rev.
5 LS -
AA -125-1005, Coding and Analysis Manual Rev.
8 LS -
AA -126-1001, Focused Area Self-Assessments, Rev.
7 LS -
AA -126-1005, Check-In Self-Assessments, Rev. 5 N-BR-ENG-11C03-MSPI,
MSPI Lesson Plan, Rev. 1
RCE 1390319, Root Cause Report for 2Q2012
MSPI White Index in

CWS [Cooling Water Systems]

Attachment

LIST [[]]
OF [[]]
ACRONY [[]]
MS [[]]
USED [[]]
ACIT Action Item
ADAMS Agencywide Documents Access and Management System
AF Auxiliary Feedwater
AOT Allowed Outage Time
CA Corrective Action
CAPR Corrective Action to Prevent Recurrence
CC Component Cooling
CC Contributing Cause
CDE Consolidated Data Entry
CDF Core Damage Frequency
CLB Current Licensing Basis
CWS Cooling Water Systems
FPIE Full Power Internal Events
GDC General Design Criteria
IMC Inspection Manual Chapter
IP Inspection Procedure
IR Issue Report
LAR License Amendment Request
LOCA Loss-of-Coolant-Accident
MSPI Mitigating Systems Performance Index
NCV Non-Cited Violation
NOV Notice of Violation
NRC Nuclear Regulatory Commission
PARS Publically Available Records System
PI Performance Indicator
PRA Probabilistic Risk Assessment
RC Root Cause
RCE Root Cause Evaluation
ROP Reactor Oversight Process
SX Essential Service Water
TS Technical Specification
M. [[Pacilio -2- We determined that your root cause evaluation was conducted to a level of detail commensurate with the significance of the problem and reached reasonable conclusions as to the root and contributing causes of the event. We also concluded that you identified the extent of condition and extent of cause of the issue, that you identified appropriate corrective actions for each root and contributing cause, and that you appropriately prioritized these actions. As a result of our quarterly review of plant performance, which was completed on October 31, 2012, the]]
NRC updated its assessment of Braidwood Station Unit 2. The
NRC 's evaluation consisted of a review of
PI s and inspection results. The
NRC 's review of Braidwood Unit 2 identified that the
MSPI for the Cooling Water Systems returned to the Green performance band in the third quarter of 2012. In accordance with
NRC Inspection Manual Chapter 0305, "Operating Reactor Assessment Program," the
MSPI for the Cooling Water Systems is considered a Green Action Matrix input as of July 1, 2012. Therefore, as a result of the successful completion of the supplemental inspection and a Green
MS [[]]

PI for the Cooling

Water Systems, the

NRC determined the performance at Braidwood Station, Unit 2 to be within the Licensee Response column of the
ROP Action Matrix as of the date of this letter. In accordance with
10 CFR 2.390 of the
NRC 's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any), will be available electronically for public inspection in the
NRC Public Document Room or from the Publicly Available Records System (

PARS)

component of

NRC 's Agencywide Documents Access and Management System (
ADAMS ).
ADAMS is accessible from the

NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Sincerely,

/RA/ Eric

R. Duncan, Chief Branch 3 Division of Reactor Projects Docket No. 50-457 License No.
NPF -77 Enclosure: Inspection Report 05000457/2012009 w/Attachment: Supplemental Information cc w/encl: Distribution via ListServ
DOCUME [[]]
NT [[]]
NAME G:\
DRPIII \BRAI\Braidwood
IP 95001 White
MSPI. docx Publicly Available Non-Publicly Available Sensitive Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy
OFFICE [[]]
RIII [[]]
RIII [[]]
RIII [[]]
NAME [[]]
RN g:dtp
DP assehl
ED uncan
DATE 12/19/12 12/20/12 12/27/12
OFFICI AL
RECORD [[]]
COPY Letter to
M. Pacilio from E. Duncan dated December 27, 2012.
SUBJEC T:
BRAIDW [[]]
OOD [[]]
STATIO N,
UNIT 2,
SUPPLE [[]]
MENTAL [[]]
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TION [[]]
REPORT 05000457/2012009
AND [[]]
ASSESS [[]]
MENT [[]]
FOLLOW -
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ER [[]]