IR 05000456/2020004
| ML21027A038 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 01/26/2021 |
| From: | Hironori Peterson Region 3 Branch 3 |
| To: | Rhoades D Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2020001, IR 2020004 | |
| Download: ML21027A038 (30) | |
Text
January 26, 2021
SUBJECT:
BRAIDWOOD STATION - INTEGRATED INSPECTION REPORT 05000456/2020004; 05000457/2020004; AND 07200073/2020001
Dear Mr. Rhoades:
On December 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Braidwood Station. On January 11, 2021, the NRC inspectors discussed the results of this inspection with Mr. J. Keenan, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. One Severity Level IV violation without an associated finding is documented in this report. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Braidwood Generating Station.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Braidwood Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Hironori Peterson, Chief Branch 3 Division of Reactor Projects
Docket Nos. 05000456; 05000457;
07200073 License Nos. NPF-72 and NPF-77
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000456; 05000457; and 07200073
License Numbers:
Report Numbers:
05000456/2020004; 05000457/2020004; and 07200073/2020001
Enterprise Identifier: I-2020-004-0024 and I-2020-001-0161
Licensee:
Exelon Generation Company, LLC
Facility:
Braidwood Station
Location:
Braceville, IL
Inspection Dates:
October 1, 2020 to December 31, 2020
Inspectors:
R. Bowen, Illinois Emergency Management Agency
G. Edwards, Health Physicist
R. Edwards, Senior Health Physicist
M. Garza, Emergency Preparedness Inspector
D. Kimble, Senior Resident Inspector
V. Petrella, Reactor Inspector
P. Smagacz, Resident Inspector
Approved By:
Hironori Peterson, Chief
Branch 3
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Braidwood 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 Follow Established Procedures Results in Incomplete Multi-Purpose Canister Blowdown Cornerstone Significance Cross-Cutting Aspect Report Section Not Applicable NCV 05000456,05000457/2020004-01 Open/Closed Not Applicable 71152 A self-revealed Severity Level IV non-cited violation (NCV) of 10 CFR 72.150, "Instructions,
Procedures and Drawings," occurred for failing to follow procedures for activities that affect quality when setting up the Multi-Purpose Canister (MPC) Forced Helium Dehydration (FHD)system. Specifically, in preparation for removing bulk water from the MPC, hoses were incorrectly connected which resulted in essentially no water being removed prior to commencing drying operations and incorrectly declaring that bulk water boiling was no longer a concern.
Main Steam Safety Valves Lift Pressure Setpoints Not Within Technical Specification Lift Setting Tolerance Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000457/2020004-02 Open/Closed
[P.5] -
Operating Experience 71153 A self-revealed finding of very low safety significance and an associated non-cited violation (NCV) of Technical Specification (TS) 3.7.1, "Main Steam Safety Valves (MSSVs)," were identified when the licensee operated Braidwood Unit 2 with three MSSVs which were found to have lift pressure setpoints that were not within their TS lift setting tolerance. Specifically, just prior to the Braidwood Unit 2 A2R21 refueling outage on April 15 - 16, 2020, MSSVs 2MS014B, 2MS016A, and 2MS016C were found with lift pressure setpoints above the percent tolerance listed in TS 3.7.1 during in-situ testing. A subsequent causal evaluation by the licensee identified that previous procedures and work instructions used to make adjustments to the lift pressure setpoints for the MSSVs did no incorporate applicable guidance for temperature stabilization following very large adjustments or multiple back to back adjustments. This pre-disposed the MSSVs to larger lift pressure setpoint drift levels over their service time.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000457/2020-001-00 LER 2020-001-00 for Braidwood Station, Unit 2,
Three Main Steam Safety Valves Failed Setpoint Testing 71153 Closed
PLANT STATUS
Unit 1 and Unit 2 both began the inspection period operating at full power. With the exception of minor reductions in power to support scheduled testing activities and load changes requested by the transmission system dispatcher, both units remained operating at or near full power for the entire inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the Coronavirus Disease 2019 (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week; conducted plant status activities as described in IMC 2515, Appendix D, Plant Status; observed risk-significant activities; and completed on-site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on-site. The inspections documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures during the weeks ending December 5 through December 19, 2020.
External Flooding Sample (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding during the weeks ending December 5 through December 19, 2020.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)2B Residual Heat Removal (RH) Train during 2A RH Train maintenance activities during the week ending November 7, 2020 (2)1A Essential Service Water (SX) Train during 1B SX Train maintenance activities during the week ending November 21, 2020
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Fire Zone 11.3-0 South; Unit 2 Component Cooling Pumps and Heat Exchanger (HX)during the week ending November 21, 2020
- (2) Fire Zone 11.2A-1; the 1A RH Pump Room during the week ending November 21, 2020
- (3) Fire Zone 11.4A-1; the 1B Auxiliary Feed (AF) Pump Room during the week ending December 19, 2020
71111.06 - Flood Protection Measures
Cable Degradation (IP Section 03.02) (1 Sample)
The inspectors evaluated cable submergence protection during review of the following activity:
- (1) Inspection of the 2J Cable Vault during sump pump replacement as documented in Work Order (WO) 4906557 during the week ending November 21, 2020.
71111.07T - Heat Sink Performance Triennial Review (IP Section 03.02)
(1)1VA02SA - 1A Residual Heat Removal Pump Cubicle Cooler (2)2CC01A - Unit 2 Component Cooling Water Heat Exchanger
- (3) Section 02.02d, Specifically Sections 02.02d2 and 02.02d7 were completed
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
- (1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam administered on October 9, 2020.
The licensee tested all licensed operators required to perform the annual operating test per the licensed operator requalification program under 10 CFR 55.59. The licensee developed remediation plans as appropriate for operators who failed portions of the exam.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the Control Room during various activities involving on-watch operations crews in the main control room during the weeks ending October 24 through October 31, 2020. These activities included, but were not limited to:
- Plant power maneuvers in support of main turbine throttle and governor valve testing on Unit 1 during the week ending October 24, 2020.
- Electrical plant manipulations, including infrequent operation of the emergency diesel generators in support of the opposite unit, during essential electrical Division 1 4160 Vac unit crosstie capability testing during the week ending October 31, 2020.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated/graded a Crew Simulator Casualty Scenario during the week ending November 14, 2020.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Maintenance effectiveness and performance history review of Essential Service Water (SX) Supply Pit Isolation Valves (0SX115 A-F) during the weeks ending October 31 through December 12, 2020.
- (2) Maintenance effectiveness and performance history review of the 0A Control Room Heating, Ventilation, and Air Conditioning (VC) Chiller during the week ending December 12, 2020.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Assessment of risk and emergent repairs for 0VC24Y (0A VC Train Makeup Air Filter Discharge Flow Control Damper) as set forth in Work Order (WO) 5095226 during the week ending November 7, 2020.
- (2) Assessment of risk during actuator replacement for 1SX150B (1B Essential Service Water Strainer Backwash Valve) as set forth in WO 1730745 during the week ending November 21, 2020.
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Assessment of the operability of plant warning beacons in safety-related equipment rooms as documented in Issue Report (IR) 4383947 during the week ending November 14, 2020.
- (2) Assessment of the operability of the Unit 2 Leading Edge Flow Meter (LEFM)following multiple issues with the LEFM computer processor as documented in IR 4375795 and several other IRs during the weeks ending October 24 through December 5, 2020.
- (3) Assessment of the operability of the 1A AF Train and impact on the AF safety function following identification of a failed pump suction pressure instrument (1PT-AF051) as documented in IR 4374128 during the weeks ending October 9 through December 19, 2020.
- (4) Assessment of the operability and functionality of the Unit 1 & 2 Control Rod Drive system following identification of potential issues with the rod drive speed as documented in IRs 4377754 and 4377755 during the weeks ending October 24 through November 4, 2020.
- (5) Assessment of the operability of the 2B SX Pump following discovery of cubicle cooler head degradation as documented in IR 4377920 during the weeks ending October 24 through December 19, 2020.
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
- (1) Functional and operational testing of 1SX150B (1B Essential Service Water Strainer Backwash Valve) following actuator replacement as set forth in WO 1730745 during the week ending November 21, 2020.
- (2) Functional and operational testing of the 2A Reactor Containment Fan Cooler (RCFC) unit following calibration of two fan time delay starting relays as set forth in WOs 4908204 and 4906560 during the week ending December 5, 2020.
- (3) Functional and operational testing of the 2B Emergency Diesel Generator (EDG)following various work accomplished during a 2-year maintenance work window as set forth in WOs 4924112, 4924113, and 5086398 during the week ending December 19, 2020.
- (4) Functional and operational testing of the Unit 1 Station Air Compressor following full replacement of the component with a new, upgraded unit as set for in WO 5014727 during the weeks ending December 19 through December 31, 2020.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
(1)1BwOSR 3.8.1.2-1: Unit 1 1A Diesel Generator Operability Surveillance during the weeks ending October 3 through October 10, 2020 (2)1BwOS TRM 3.3.g.4: Unit 1 Turbine Overspeed Protection Systems Valve Stem Freedom Checks (TV - GV Cycling) during the week ending October 24, 2020 (3)1BwOSR 3.8.1.8-1: SAT 242-1 Crosstie to Bus 141 and EDG 1A Crosstie to Bus 142 Surveillance during the weeks ending October 31 through November 7, 2020
Inservice Testing (IP Section 03.01) (1 Sample)
(1)2BwOSR 5.5.8.SX-3A: Group A Inservice Testing (IST) for 2A Essential Service Water Pump (2SX01PA) during the weeks ending October 31 through November 7, 2020
FLEX Testing (IP Section 03.02) (1 Sample)
(1)0BwOS FX-9: Flex Pump Flow Surveillance during the weeks ending October 17 through October 24, 2020
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
- (1) The inspectors completed an evaluation of submitted emergency action level and emergency plan changes on December 2, 2020. This evaluation does not constitute NRC approval.
RADIATION SAFETY
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (5 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:
- (1) Area Radiation Monitors (ARMs) in auxiliary building.
- (2) Portable ion chambers stored ready for use and/or during use in auxiliary building.
- (3) Portable friskers used at the radiation protection checkpoint area at the auxiliary building exit.
- (4) Portable ion chambers used at the radiation protection checkpoint area at the auxiliary building exit.
- (5) Small Articles Monitor (SAM) at the auxiliary building exit.
Calibration and Testing Program (IP Section 03.02) (4 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection instruments:
- (1) Thermo SAM-12, SN#12102
- (2) Eberline Model 3, SN#0021768
- (3) Ludlum Model 177, SN#0025793
- (4) Ludlum Model 177, SN#0025808
Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (2 Samples)
The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:
- (1) Unit 1 Containment Purge Effluent (1RE-001A)
- (2) Unit 2 Auxiliary Building ventilation system discharge to main plant vent stack (2PR28J)
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10)===
- (1) Unit 1 (August 2019-September 2020)
- (2) Unit 2 (August 2019-September 2020)
BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)
- (1) Unit 1 (October 1, 2019 through September 30, 2020)
- (2) Unit 2 (October 1, 2019 through September 30, 2020)
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) August 2019-September 2020
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) August 2019-September 2020
71152 - Problem Identification and Resolution
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors conducted a semiannual review of the licensees corrective action program (CAP) for potential adverse trends that might be indicative of a more significant safety concern during the weeks ending October 3 through December 26, 2020. A specific trend related to the site's fire protection system and header isolation valve stem/disc separation is documented in the Results Section of this report.
Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)
The inspectors conducted in-depth reviews of the licensees implementation of the CAP related to the following issues:
- (1) Completion of an in-depth review of corrective actions taken following various human performance issues with the summer 2020 dry cask storage (DCS) loading campaign, as documented in IR 4364058, during the weeks ending September 12 through December 31, 2020. This review completed the partial inspection sample documented in Inspection Report 05000456/2020003 and 05000457/2020003 (ADAMS Accession Number ML20315A490). Specific details regarding this review are documented in the Results Section of this report.
- (2) An in-depth review of corrective actions taken following lube oil cooler issues identified during a 2B EDG 2-year maintenance window, as documented in IR 4389711, during the weeks ending December 12 through December 31, 2020.
Specific details regarding this review are documented in the Results Section of this report.
71153 - Follow-up of Events and Notices of Enforcement Discretion Event Follow-up (IP Section 03.01)
- (1) Review and tracking of licensee actions during the COVID-19 National Emergency declaration as set forth by the President of the United States during the weeks ending October 3 through December 26, 2020.
Event Report (IP Section 03.02) (1 Sample)
The inspectors evaluated and closed the following licensee event report (LER):
- (1) Review and closure of LER 05000457/2020-001-00, Three Main Steam Safety Valves Failed Setpoint Testing, (ADAMS Accession Number ML20164A226) during the weeks ending November 7 through December 31, 2020. The inspection conclusions and specific details associated with the closure of this LER are documented in the Results Section of this report.
INSPECTION RESULTS
Failure to Follow Established Procedures Results in Incomplete Multi-Purpose Canister Blowdown Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000456,05000457/2020004-01 Open/Closed
Not Applicable 71152 A self-revealed Severity Level IV non-cited violation (NCV) of 10 CFR 72.150, "Instructions, Procedures and Drawings," occurred for failing to follow procedures for activities that affect quality when setting up the Multi-Purpose Canister (MPC) Forced Helium Dehydration (FHD)system. Specifically, in preparation for removing bulk water from the MPC, hoses were incorrectly connected which resulted in essentially no water being removed prior to commencing drying operations and incorrectly declaring that bulk water boiling was no longer a concern.
Description:
On August 19, 2020, while preparing for processing MPC 409, the vent hose was incorrectly connected to the drain line and the drain hose was connected to the vent line on the MPC.
During bulk water removal from this MC, an evolution known as blowdown, compressed helium should have been applied to the vent line where bulk water is then forced out through the drain line and back to the spent fuel pool. By monitoring a sight glass on the drain line, a worker can determine when blowdown is complete when only gas, and no water, is flowing through the drain line. Because the hoses were swapped, compressed helium was incorrectly put into the drain line and effectively allowed to bubble out of the vent line without removing any water from the MPC. Approximately 10 to 15 minutes following the start of blowdown, a worker noted the blowdown appeared complete since no water was seen flowing through the drain line site glass. Normally, a blowdown is expected to take 45 to 60 minutes. Believing blowdown was complete, the workers declared that bulk water boiling was no longer a concern. The time to boiling is calculated and tracked to ensure that bulk water is removed prior to the time at which bulk boiling would start. As such, the licensee incorrectly exited the time-to-boil (TTB) clock and continued with drying operations, the next evolution in processing an MPC. When the FHD system was started, the workers heard an abnormal noise and stopped to investigate. It was at this point that the licensee identified the incorrect hose lineup and discovered blowdown was incomplete. The hoses were reconfigured, blowdown was completed successfully, the TTB clock was correctly exited. The TTB clock was calculated to expire at 2030 on August 19. Despite the original error in declaring bulk water removed, the licensee was able to correct the configuration and blowdown the canister by 1518 on August 19, well within the calculated TTB expiration time. In addition to a potential hazard to equipment and personnel, bulk boiling inside an MPC has the potential to over pressurize the important-to-safety MPC, which is relied upon as the eventual confinement barrier to fission product release.
The as configured lineup during initial attempts to process MPC 409 was not in accordance with licensee procedure OU-MW-671-300, MPC Processing Forced Helium Dehydration (FHD) for PWRs, Revision 13. Step 4.4.7 of this procedure states, "Connect 2-inch hose, from FDV-2, Manifold Drain Side Inlet Valve, to VD-1, Drain Port RVOA." Step 4.4.10 states, "Connect 2-inch hose, from FVV-2, Manifold Vent Side Outlet Valve, to VV-1, Vent Port RVOA." Furthermore, the condition was not identified beforehand during procedurally required equipment alignment checks or from available indications following completion of the perceived blowdown. Specifically, Step 4.4.19 states, "Perform walkdown of hoses and components to verify configuration." Finally, the personnel involved noted that the duration of the attempted blowdown appeared to be rather short and available survey data indicated no change in radiological conditions following the attempted blowdown; however, this information was not reviewed or used to assess the results of the blowdown.
Corrective Actions: Upon discovery of the incorrect hose configuration, the equipment was placed in a safe condition and lineup corrected, the MPC was blown down, and the canister was safely processed for storage. There was no immediate safety concern because the bulk water was eventually removed prior to exceeding the calculated time to boil. The concern was placed in the corrective action program and additional causal evaluations and corrective actions assigned. Long term corrective actions proposed include modifying components to ensure the configuration is fail-safe and procedural enhancements to further ensure the configuration is correct and conditions as expected. The inspectors did not identify and issues with these licensee corrective actions as part of their in-depth problem identification and resolution inspection sample.
Corrective Action References: IR 04364058; Forced Helium Drying Skid Issue; 08/19/2020
Performance Assessment:
The inspectors determined this violation was associated with a minor performance deficiency.
The inspectors concluded that the licensee failed to follow procedure OU-MW-671-300 when setting up the FHD system to process the important-to-safety MPC, increasing the potential to over pressurize the MPC, damage equipment, and/or injure personnel.
Enforcement:
Severity: The inspectors determined that the violation could be evaluated, using Section 6.5.d.1 of the NRC Enforcement Policy, as a violation of very low safety significance (Severity Level IV) because the licensee failed to meet a regulatory requirement that had a more than minor safety significance.
Violation: Title 10 CFR 72.150, "Instructions, Procedures, and Drawings," states, in part, that the licensee shall prescribe activities affecting quality by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall require that these instructions, procedures, and drawings be followed. The licensee established procedure OU-MW-671-300, MPC Processing Forced Helium Dehydration (FHD) for PWRs, Revision 13, as the implementing procedure for processing an MPC, an activity affecting quality.
Procedure OU-MW-671-300, Step 4.4.7 states, "Connect 2-inch hose, from FDV-2, Manifold Drain Side Inlet Valve, to DV-1, Drain Port RVOA;" Step 4.4.10 dates, "Connect 2-inch hose, from FVV-2, Manifold Side Outlet Valve to VV-1, Vent Port RVOA;" and Step 4.4.19 states, "Perform walkdown of hoses and components to verify configuration."
Contrary to these requirements, on August 19, 2020, the licensee failed to follow procedure OU-MW-671-300 in that the drain hose was incorrectly connected from the Manifold Drain Site Inlet Valve to the Vent Port RVOA and the vent hose was incorrectly connected from the Manifold Vent Side Outlet Valve to the Drain Port RVOA, and the licensee did not identify the incorrect configuration while performing the walkdown of hoses and components when setting up the FHD system to process the important-to-safety MPC.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Observation: Trend in Fire Protection System Header Isolation Valve Issues 71152 The inspectors performed a review of plant issues, particularly those entered into the licensees corrective action program (CAP), associated with fire protection system over the past six months. During their review, the inspectors noted that there had been several recent issues at the station involving the separation of the valve disc from the valve stem in fire protection system header isolation valves. These included, but were not limited to:
-Issues with 0FP297, Auxiliary Building Ring Header to Loop Header Isolation Valve, as documented in the licensees CAP as IR 4382568.
-Issues with 0FP252, Auxiliary Building Ring Header Sectionalizing Valve, as documented in the licensees CAP as IR 4382571.
-Issues with 0FP251, Auxiliary Building Ring Header Sectionalizing Valve, as documented in the licensees CAP as IR 4366302.
In addition to being installed in the same raw water system, the inspectors noted that all of these fire protection system header isolation valves were of a similar design (Anchor-Darling 150 pound class manual gate valves, of either 10-inch or 6-inch size), and had been installed around the same time as part of the plants initial construction.
While the inspectors noted that these issues documented in the CAP had occurred as part of the licensees actions to conduct extensive full flow testing of their fire protection system header in response to industry operating experience, coincidental issues with multiple header isolation valves featuring so many common denominators represented a potential concern warranting a more in-depth analysis. Following discussions with the inspectors, the licensee entered the trend into their CAP as IR 4393999.
The inspectors did not identify any findings or violations of NRC requirements in the course of their review.
Observation: 2B Emergency Diesel Generator (EDG) Cooler Quad Rings 71152 The inspectors performed a detailed review of IR 4389711, 2B DG - 2DG01KB-Y1/Y2 - Quad Ring Gasket Material Found. The issue involved the identification of quad ring gasket material in both the upper and lower 2B EDG lube oil coolers during a 6-year lube oil cooler inspection performed on the 2B EDG in December 2020. The inspectors chose this issue for an in-depth review of the licensee's actions within their corrective action program (CAP) due to previous history on the 2B EDG where quad ring gasket material had been degraded and potentially become a foreign material issue. Consequently, for this detailed Problem Identification and Resolution inspection sample, the inspectors focused on assessment of the licensee's corrective actions taken both in the past and for this present condition.
The inspectors did not identify any issues with the licensee's CAP actions taken for past historical issues involving quad rings on either the 2B EDG lube oil jacket water coolers.
These CAP actions were largely focused on preventing the quad rings from becoming extruded or otherwise damaged to the extent that they might become a foreign material issue.
Similarly, the inspectors' review of the licensee's current corrective actions also did not result in the identification of any issues of note. The most recent CAP actions included, but were not limited to, retrieval of all of the most recently identified gasket material from December 2020 and analysis of 2B EDG lube oil temperatures since the last 6-year lube oil cooler inspection had been performed in 2016. The latter action verified that no abnormal temperature conditions had been recorded during 2B EDG operation during the period.
No findings or violations of NRC requirements were identified by the inspectors in the course of this review.
Main Steam Safety Valves Lift Pressure Setpoints Not Within Technical Specification Lift Setting Tolerance Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000457/2020004-02 Open/Closed
[P.5] -
Operating Experience 71153 A self-revealed finding of very low safety significance and an associated non-cited violation (NCV) of Technical Specification (TS) 3.7.1, "Main Steam Safety Valves (MSSVs)," were identified when the licensee operated Braidwood Unit 2 with three MSSVs which were found to have lift pressure setpoints that were not within their TS lift setting tolerance. Specifically, just prior to the Braidwood Unit 2 A2R21 refueling outage on April 15 - 16, 2020, MSSVs 2MS014B, 2MS016A, and 2MS016C were found with lift pressure setpoints above the 3 percent tolerance listed in TS 3.7.1 during in-situ testing. A subsequent causal evaluation by the licensee identified that previous procedures and work instructions used to make adjustments to the lift pressure setpoints for the MSSVs did no incorporate applicable guidance for temperature stabilization following very large adjustments or multiple back to back adjustments. This pre-disposed the MSSVs to larger lift pressure setpoint drift levels over their service time.
Description:
On April 15 - 16, 2020, the licensee was conducting pre-outage lift pressure setpoint testing for Unit 2 MSSVs as required by TX 3.7.1 prior to shutting the unit down for its scheduled A2R21 refueling outage. During testing, the as-found set points for MSSVs 2MS014B, 2MS016A, and 2MS016C failed to meet the as-found set pressure acceptance criteria set forth in TS 3.7.1 of +/- 3 percent. The specific as-found values were +4.18 percent for 2MS016A, +3.9 percent for 2MS014B, and +3.13 percent for 2MS016C.
The licensee determined that the apparent cause of the failed as-found lift pressure setpoint testing on the MSSVs was setpoint drift. This setpoint drift had been exacerbated by the lack of incorporation of known industry and internal company experience into the formal work instructions and/or procedural guidance governing testing and setpoint adjustments for the MSSVs. This lack of formal guidance led to insufficient temperature stabilization lifts in between multiple back to back adjustments of the MSSV setpoints or following very large adjustments to the setpoints. Ultimately, without allowing the MSSV temperature to appropriately stabilize as a part of the lift pressure setpoint adjustment process, the valves were susceptible to larger drift levels over their subsequent service periods.
Typically, issues found during TS surveillance tests are considered to have occurred at the time of the test unless there is substantive evidence to the contrary. Multiple MSSVs found to lift with setpoints outside of TS limits was an indication that the condition had arisen over a period of time, and that the unit had been operated at power in excess of TS 3.7.1 required action completion times. As a result, the licensee reported this event in accordance with 10 CFR 50.73(a)(2)(i)(B) as an operation or condition prohibited by the plant's TS.
Additionally, because the issue impacted multiple MSSVs and led to their being inoperable, the event was also considered to be reportable under 10 CFR 50.73(a)(2)(vii) as an event where a single cause or condition caused two independent trains or channels to become inoperable in a single system designed to mitigate the consequences of an accident. The licensee reported this event to the NRC as LER 2020-001-00, Three Main Steam Safety Valves Failed Setpoint Testing, on June 12, 2020, (ADAMS Accession Number ML20164A226).
Corrective Actions: The entire population of 20 Unit 2 MSSVs were subjected to lift pressure setpoint testing, and all 20 MSSVs were returned to the required lift pressure setpoint range of +/- 1 percent as set forth in TS 3.7.1 at the conclusion of testing evolution. Further, the licensee's causal evaluation confirmed that all 20 installed MSSVs on Unit 2 had not been subjected to multiple adjustments without sufficient lifts to stabilize the valves' springs in between adjustments during pre-outage A2R21 testing, and enhancements were made to existing MSSV testing procedures and work instructions to incorporate appropriate guidance for temperature stabilization. Finally, 2MS014B and 2MS016C were conservatively scheduled for lift pressure setpoint testing in the licensee's A2R22 refueling outage planned for October 2021.
Corrective Action References: 4335846; 2MS016A - Pre-A2R21 Testing As-Found Outside of Acceptance Range; 04/15/2020. 4336005; 2MS016C - Pre-A2R21 Testing As-Found Outside of Acceptance Range; 04/16/2020. 4335997; 2MS014B - Pre-A2R21 Testing As-Found Outside of Acceptance Range; 04/16/2020.
Performance Assessment:
Performance Deficiency: The inspectors concluded that the licensee's failure to incorporate industry guidance for stabilizing valve temperatures during the testing and adjusting of the lift set pressure of their MSSVs into applicable work instruction and procedures constituted a performance deficiency. Further, because some of the licensee's corporate subject matter experts were keenly aware of this guidance, the inspectors determined that the performance deficiency was within the licensee's ability to have foreseen and should have been prevented.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. This finding was associated with the Mitigating Systems Cornerstone of Reactor Safety and was determined to be of more than minor significance because it was associated with cornerstone attributes of design control and procedure quality, and adversely affected the cornerstone objective: "To ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage)." Specifically, the inspectors determined that the licensee's failure to have incorporated known industry guidance for stabilizing valve temperatures during the testing and adjusting of the lift set pressure of their MSSVs into applicable work instructions and procedures contributed to the degradation of the valves with respect to lift pressure setpoint drift and contributed to the ultimate inoperability of MSSVs 2MS016A, 2MS014B, and 2MS016C. The inspectors also compared the finding with the examples listed in IMC 0612, "Power Reactor Inspection Reports," Appendix E, "Examples of Minor Issues," Example 3.I was found to be similar in that a failure to incorporate available industry operating experience into the licensee's processes for MSSV lift pressure setpoint testing and adjustments ultimately resulted in increased MSSV lift pressure setpoint drift and valve inoperability.
Cross-Cutting Aspect: P.5 - Operating Experience: The organization systematically and effectively collects, evaluates, and implements relevant internal and external operating experience in a timely manner. Specifically, licensee subject matter experts were aware of industry experience regarding MSSV temperature stabilization during lift pressure setpoint adjustment activities, yet this information was not effectively implemented by incorporating it into applicable procedures and work instructions until after Unit 2 MSSV lift pressure setpoint testing activities on April 15 - 16, 2020, as corrective action for this event.
Enforcement:
Violation: Technical Specification (TS) 3.7.1 requires that the five MSSVs associated with each steam generator (SG) are operable whenever the unit is operating above 56 percent of rated thermal power. Contrary to this requirement, on April 15 - 16, 2020, planned lift pressure setpoint testing identified that MSSV 2MS016A for the 2A SG, MSSV 2MS014B for the 2B SG, and MSSV 2MS016C for the 2C SG failed to meet the as-found set pressure acceptance criteria set forth in TS 3.7.1 of +/- 3 percent and were, therefore, inoperable. A causal evaluation performed by the licensee determined that the failures had occurred over time during the previous Unit 2 operating cycle, and that the unit had been operated in a condition prohibited by TS 3.7.1 during that cycle.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On January 11, 2021, the inspectors presented the integrated inspection results to Mr. J. Keenan, Site Vice President, and other members of the licensee staff.
- On October 9, 2020, the inspectors presented the annual licensed operator requalification examination results inspection results to Mr. J. Taff, Operations Training Manager, and other members of the licensee staff.
- On November 24, 2020, the inspectors presented the triennial heat sink inspection results to Mr. G. Gugle, Plant Manager, and other members of the licensee staff.
- On December 2, 2020, the inspectors presented the emergency action level and emergency plan inspection results to Mr. D. Moore, Senior Manager - Emergency Preparedness, and other members of the licensee staff.
- On December 16, 2020, the inspectors presented the radiation protection inspection results to Ms. M. Holba, Acting Radiation Protection Manager, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
4384749
0SH08PB Motor Hot to the Touch
11/16/2020
4386474
2TS-SI-059X Chattering
11/25/2020
4386776
1HT86EA Low Current and Circuit Fault Alarms In
11/28/2020
4387383
Potential Leakby of 0FP941
2/01/2020
4388090
2TS-SI059X Relay Chattering
2/04/2020
4389193
System Effect on 1SH01PA Vibrations
2/09/2020
4389796
0FX01AF Heater Not Energizing
2/12/2020
Miscellaneous
Letter
21 Winter Readiness Certification
2/15/2020
Procedures
0BwOS XFT-A1
Unit Common Freezing Temperature Equipment Protection
Surveillance
0BwOS XFT-A2a
Unit Common Station Heat Area Heaters Freezing
Temperature Equipment Protection Surveillance
0BwOS XFT-A2b
Unit Common Station Heat Area Heaters Freezing
Temperature Equipment Protection Surveillance
0BwOS XFT-A3
Unit Common Cold Weather Surveillance
0BwOS XFT-A4
Unit Common Freezing Temperature Equipment Protection
Inside Surveillance
Procedures
BwOP RH-E2
Electrical Lineup - Unit 2 Operating
BwOP RH-M4
Operating Mechanical Lineup Unit 2 2B Train
BwOP SX-E1
Electrical Lineup - Unit 1 Essential Service Water System
Operating
BwOP SX-M1
Operating Mechanical Lineup Unit 1
Fire Plans
Pre-Fire Plan No.
103
Fire Zone 11.2A-1; Auxiliary Building 346' Elevation,
Residual Heater Removal Pump 1A Room
Pre-Fire Plan No.
113
Fire Zone 11.3-0 South; Unit 2 Auxiliary Building General
Area - (South)
Pre-Fire Plan No.
137
Fire Zone 11.4A-1; Auxiliary Building 383' Elevation, Unit 1
Auxiliary Feedwater Pump Diesel
Procedures
BwAP 1110-1
Fire Protection Program System Requirements
BwAP 1110-3
Plant Barrier Impairment Program
BwOP PBI-1
Plant Barrier Impairment Program Pre-Evaluated Barrier
Matrix
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Plant Barrier Control Program
High Risk Fire Area Identification
ER-BR-600-1069
Braidwood Units 1 and 2 - Site List of High-Risk Fire Areas
Fire Prevention for Hot Work
Fire Protection System Impairment Control
Pre-Fire Plan Manual
Control of Transient Combustible Material
OP-AA-201-012-
1001
Operations On-Line Fire Risk Management
Corrective Action
Documents
4356572
Cable Vault 1G High Level
07/14/2020
Drawings
Duct Runs Outdoor Plan Plant Area
O
Electrical Installation Manholes #2J Racks Plan and
Sections
Z
M-67A
Miscellaneous Drains Electrical Cable Vaults Units 1 and 2
D
Procedures
Cable Condition Monitoring Program
Work Orders
4906557
Remove and Replace Cable Vault 2J Sump Pump
(2DM06P)
11/17/2020
Calculations
ATD-0063
Heat Load to the Ultimate Heat Sink During a Loss of
Coolant Accident
ATD-0109
Thermal Performance of UHS During Postulated Loss of
Coolant Accident
BRW-08-0097-M
Air to Water Cubicle Cooler Heat Exchanger Tube Plugging
Evaluation
BRW-97-1072-M
/ BYR97-0467
Component Cooling Heat Exchanger Tube Plugging
Evaluation
Corrective Action
Documents
04127063
OSP-X L-1 RCFC Cooler Head Degraded Sealing Surface
04/15/2018
04146327
Lessons Learned from Diesel Freeze
06/12/2018
297169
White Paste Found in 0B VC Suction Elbow and Guide
Vanes
11/14/2019
04338566
08-OSP-A 2C RCFC Degradation Found Cooler Heads
04/26/2020
Corrective Action
Documents
04385510
NRC Identified a Gap in Documentation for BwMP 330-095
11/19/2020
04385659
Non-Conservative Assumptions in Heat Load Calc for the
11/20/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Resulting from
Inspection
04386129
NRC UHS - Calc Methodology for RH Cubicle Cooler
Performance
11/23/2020
Miscellaneous
1A RHR Cubicle Cooler Heat Exchanger Inspection Report
2/03/2018
Unit Two - Modes 1, 2, and 3 Shiftly and Daily Operating
Surveillance Data Sheet from 10-1-2020 to 10-31-2020
Unit Two - Modes 1, 2, and 3 Shiftly and Daily Operating
Surveillance Data Sheet From 11-12-2020 to 11-18-2020
Unit Two - Modes 1, 2, and 3 Shiftly and Daily Operating
Surveillance Data Sheet From 11-1-2020 to 11-11-2020
Unit One - Modes 1, 2, and 3 Shiftly and Daily Operating
Surveillance Data Sheet From 10-1-2020 to 10-31-2020
Unit One - Modes 1, 2, and 3 Shiftly and Daily Operating
Surveillance Data Sheet From 11-12-2020 to 11-18-2020
Unit One - Modes 1, 2, and 3 Shiftly and Daily Operating
Surveillance Data Sheet From 11-1-2020 to 11-11-2020
Unit Common All Modes / At All Times Shiftly and Daily
Operating Surveillance Data Sheet From 10-1-2020 to
10-31-2020
Unit Common All Modes / At All Times Shiftly and Daily
Operating Surveillance Data Sheet From 11-1-2020 to
11-11-2020
Unit Common All Modes / At All Times Shiftly and Daily
Operating Surveillance Data Sheet From 11-12-2020 to
11-18-2020
Unit 2 CC Heat Exchanger Inspection Report
01/09/2018
NDE Reports
Unit 2 CC Heat Exchanger Eddy Current Examination
01/11/2018
Procedures
0Bw0A ENV-1
Adverse Weather Conditions Unit 0
24
0Bw0A ENV-3
Braidwood Cooling Lake Low Level Unit 0
105
0Bw0A ENV-7
Adverse Cooling Lake Conditions Unit 0
Work Orders
01528250-01
0L-CW041 Circulating Water Intake Bay Level Control Loop
08/11/2015
01790489
2C Forebay - August Diver Inspection and Screen ADJ
09/11/2015
01790490
2A Forebay - August Diver Inspection and Screen ADJ
10/23/2015
01825273
1C Forebay - August Diver Inspection and Screen ADJ
10/19/2016
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
01828057
1A Forebay - August Diver Inspection and Screen ADJ
10/23/2016
01886280
LR-2C Forebay - August Diver Inspection and Screen ADJ
10/10/2018
01889551
Gauge(s) out of Calibration
03/22/2016
01891178-01
Unexpected Annunciator - SX STRN DP High (19)
01/12/2016
01912566
LR-2A Forebay - August Diver Inspection and Screen ADJ
10/19/2018
01932930
LR-1VA02SA Eddy Current Testing/Trend
2/04/2018
04584734
LR-2B Forebay - August Diver Inspection and Screen ADJ
10/20/2018
04720132
LR-Braidwood Cooling Lake Hydrographic SRVEY
03/18/2019
04751457-01
LR-1B Forebay - August Diver Inspection and Screen ADJ
10/18/2019
04751459-01
LR-1A Forebay - August Diver Inspection and Screen ADJ
10/09/2019
04751460-01
LR-1C Forebay - August Diver Inspection and Screen ADJ
10/15/2019
04798572-01
0CW05F Leak Found on Traversing Gearbox
04/22/2019
04807644-01
2B SX Strainer Stuck in Continuous Backwash
07/17/2018
04817927-01
Potential Environmental Risk - 3DPM Oil Leak From
1CW03FB
08/17/2018
04908394-01
LSH Traveling Screen 2F Will Not Run in Slow
04/15/2019
04954865-01
1A SX PP Strainer Is Backwashing Excessively
08/29/2019
05044675-01
FNI 1PDS-SX021 Calibrate/Replace 1A SX PP Strainer DP
05/28/2020
Procedures
Operator Fundamentals
OP-AA-101-113-
1006
4.0 Crew Critique Guidelines
Watch-Standing Practices
OP-AA-103-102-
1001
Strategies for Successful Transient Mitigation
Operation of Plant Equipment
Operating Narrative Logs and Records
TQ-AA-150-F25
Braidwood 2020 LORT Annual Exam Report
10/09/2020
Conduct of Simulator Training and Evaluation
Examination Security and Administration
Simulator Management
TQ-BR-201-0113
Braidwood Training Department Simulator Examination
Security Actions
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71111.11Q Procedures
OP-AA-101-111-
1001
Operations Standards and Expectations
Communications
Systematic Approach to Training Process Description
Operator Training Programs
Corrective Action
Documents
4380250
OSX115C Monthly Pit Inspection Results
10/28/2020
4380250
Conditional Release of New Oil Pump for 0WO01CA Chiller
2/04/2020
4387762
0A VC Chiller Trip
2/02/2020
Procedures
Maintenance Rule Functions - Safety Significant
Classification
Maintenance Rule Implementation per NEI 18-10
Maintenance Rule 18-10 - Scoping
Maintenance Rule 18-10 - Failure Definitions
Maintenance Rule 18-10 - Performance Monitoring and
Dispositioning Between (a)(1) and (a)(2)
Corrective Action
Documents
4382073
0VC24Y Appears to Be Failed Open
11/03/2020
43854326
Rebuild 1SX150B Actuator
11/19/2020
Drawings
M-96
Control Room HVAC System
Procedures
BwMP 3305-092
Limitorque Operator Maintenance (Type HBC-0 Thru HBC-3) 4
BwMP 3305-102
Limitorque Operator Maintenance (Type SMB Stem Nut and
Actuator Removal)
ASME Section XI Repair/Replacement Program
Risk Management
On-Line Risk Management
Risk Management Support of RICT
Calculation of RMAT and RICT for Risk Informed Completion
Time Program
ER-BW-600-2001
Braidwood RICT System Guidelines
Conduct of Troubleshooting
Limitorque (SMB-000) Operator Maintenance
Protected Equipment Program
On-Line Risk Management and Assessment
Work Orders
1730745
Rebuild/Replace Actuator for 1B SX Pump Strainer
11/17/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Backwash Valve (1SX150B)
Corrective Action
Documents
21734
Unit 2 LEFM Error Message
2/26/2020
4335813
Unit 2 LEFM Trouble Alarm
04/15/2020
4363654
Unexpected Alarm, LEFM Trouble
08/17/2020
4367655
Unexpected Annunciator, LEFM Trouble
09/05/2020
4369921
Unexpected Annunciator, LEFM Trouble
09/16/2020
4370232
of 15 Group 3 Station Beacons Inoperable
09/18/2020
4373452
Unit 2 LEFM Swapped to Method 2
10/01/2020
4373471
Unit 2 LEFM Swapped to Method 2
10/01/2020
4374128
P2301 Indication Suspect
10/03/2020
4375795
Unit 2 LEFM Swapped to Method 2
10/10/2020
4377376
Rod Control Scaling Incorrect
10/17/2020
4377754
EOC - Unit 1 Rod Control Scaling Incorrect
10/19/2020
4377755
EOC - Unit 2 Rod Control Scaling Incorrect
10/19/2020
4377920
2B SX Cubicle Cooler Divider Plate on Upper Cooler Needs
Repair
10/20/2020
4383947
Beacon Repair Needed and Their Requirements
11/12/2020
Engineering
Changes
373557
Evaluate the Impact of the as Found 2VA01SA SX Cubicle
Cooler Degraded with Loss of One Cubicle Cooler Fan to
Determine the Cubicle Cooler's Design Capability
2/31/2008
25908
Temporary Condition Related to the Cubicle Cooler
(2VA01SA) for the 2A Essential Service Water (SX) Pump
10/29/2018
Procedures
BwMP 3100-099
SX Cubicle Cooler Inspection
BwOP FW-35
Obtaining LEFM Event Log Information and A/C Unit Alarm
Resetting
BwOP FW-38
LEFM Data Retrieval
Exelon Nuclear Standardized Radiological Emergency Plan
Risk Management Documentation
MA-BR-723-141
Test of the Beacon System
OP-AA-106-101-
1006
Operational Decision-Making Process
Adverse Condition Monitoring and Contingency Planning
Operability Determinations (CM-1)
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Work Orders
4906560
2AP10E REF1 Time Delay Relay Calibration
2/02/2020
Corrective Action
Documents
4363448
Unexpected Annunciator 2-21-C8, Diesel Generator 2A
Trouble/Fail to Start
08/16/2020
4370636
Unexpected Alarm 2-22-C8, 2B Diesel Generator Control
Power Failure
09/19/2020
4387564
Time Delay Relays Out-of-Tolerance
2/02/2020
4391523
Multiple Oil Leaks on 1B Station Aire Compressor
2/21/2020
4391524
Multiple Leaks on 1B Station Air Compressor
2/21/2020
4391893
1B & 2A Station Air Compressors Not Sharing SA/IA Load
2/23/2020
4391895
1B Station Air Compressor Failure to Start While Aux Oil
Pump Initially Secured
2/23/2020
Engineering
Changes
630880
Replacement of Unit 1 Station Air Compressor
2665
Diesel Generator KILOVAC Relay Replacement with
Struthers-Dunn Model (Units 1 and 2)
2/04/2020
Procedures
1BwOSR
5.5.8.SX-7
Essential Service Water System Valve Stroke Surveillance
2BwOS DG-2B
2B Diesel Generator Overspeed Trip Test
2BwOSR 3.3.2.8-
611B
Unit 2: ESFAS [Emergency Safety Features Actuation
System] Instrumentation Slave Relay Surveillance (B Train
Automatic Safety Injection - K611)
2BwOSR 3.6.6.7
Containment Cooling Fan Automatic Actuation Test
2BwOSR
3.8.1.13-2
2B Diesel Generator Bypass of Automatic Trips Surveillance
2BwOSR 3.8.1.2-
Unit 2: 2B Diesel Generator Operability Surveillance
BwMP 3100-022
Diesel Generator 2-Year Inspection
Diagnostic Testing of Motor-Operated Valves
MA-BR-722-210
Calibration of Time Delay Relays
MA-BR-EM-4-
09070
Diesel Generator Electrical Inspection
SPP 20-003
Special Procedure - Modification Test for 1SA01CB Station
Air Compressor
On-Line Work Control Process
Work Orders
4907204
Perform Time Delay Relay Calibration Check of 1-RCFL at
2/01/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2AP10E
24112
2DG01KB - Perform 2-Year Inspection of Diesel Generator
2/08/2020
24113
2DG01EB - Diesel Generator Exciter Inspection (2B EDG)
2/07/2020
5014727
1SA01CB - Replacement of Unit 1 Station Air Compressor
per EC 630880
10/26/2020
5086398
2PL08J - Replace Diesel Generator Local Control Panel
KILOVAC Relays
2/08/2020
Corrective Action
Documents
4380316
1A DG Lower Oil Cooler East End Bell Leak
10/28/2020
Corrective Action
Documents
4380237
Unexpected Annunciator 1-21-E8
10/28/2020
Procedures
0BwOS FX-9
FLEX Pump Flow Surveillance
1BwOS TRM
3.3.g.4
Unit 1 Turbine Overspeed Protection Systems Valve Stem
Freedom Checks (TV-GV Cycling)
1BwOSR 3.8.1.2-
Unit One 1A Diesel Generator Operability Surveillance
1BwOSR 3.8.1.8-
SAT 242-1 Crosstie to Bus 141 and DG `1A Crosstie to Bus
241 Surveillance
2BwOSR
5.5.8.SX-3A
Group A IST Requirements for 2A Essential Service Water
Pump (2SX01PA)
OP-BR-FX-1003
High Head FLEX Pump Operating Guideline
OP-BR-FX-1004
Medium Head FLEX Pump Operating Guideline
OP-BR-FX-1005
Low Head FLEX Pump Operating Guideline
Work Orders
28410
18-Month Surveillance: SAT 242-1 Crosstie to Bus 141 and
DG 1A Crosstie to Bus 241
10/28/2020
4963041
0FX01PB - Medium Head FLEX Pump Component
Operational Inspection
10/14/2020
4964162
0FX02PB - High Head FLEX Pump Component Operational
Inspection
10/14/2020
4965111
0FX03PB - Low Head FLEX Pump Component Operational
Inspection
10/14/2020
5052445
Unit 1 TV-GV Surveillance
10/17/2020
Corrective Action
Documents
Perform Impact Review of EAL Revisions
03/10/2020
EP FAQ EAL Change License Amendment Implementation
03/20/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Actions
NOS ID: Revise Standard Emergency Plan
03/26/2020
Emergency Plan: CDAM 50.54(q) Potential Deficiencies
04/09/2020
Miscellaneous
Eval 19-29
Evaluation of EP-AA-1000; Exelon Nuclear Standardized
Radiation Emergency Plan
09/04/2019
Eval 19-65
Evaluation of EP-AA-1000; Exelon Nuclear Standardized
Radiation Emergency Plan
09/06/2019
Eval 19-79
Various Station Emergency Plan Annexes
11/08/2019
Eval 19-80
On-Shift Staffing Assessments
11/08/2019
Eval 20-38
EALs for Braidwood Station
06/22/2020
Calibration
Records
Exelon Powerlabs
Calibration
Record
AMS-4 02794 Calibration Record
05/16/2020
Exelon Powerlabs
Calibration
Summary Report
DMC-3000 Calibration Summary Report
03/27/2020
Fastscan 13007133 Calibration Report
03/12/2020
PM-12 12060 Calibration Data Sheet
05/13/2019
ARGOS-5 1011-279 Calibration Data Sheet
2/02/2020
Corrective Action
Documents
RP Instrumentation Calibration Out of Tolerance Data
03/21/2019
04-OSP-A Elevated BKGB Radiation Impacting RCA Exit
04/22/2020
Potential AR/PRM Setpoint Changes Needed
09/01/2020
Procedures
BwIP 2505-008
Calibration of GA Technologies Area Radiation Monitors
Operation and Calibration of the PM-12 Gamma Portal
Monitors
Operation and Calibration of the Canberra ARGOS-5
Personnel Contamination Monitor
71151
Miscellaneous
NRC Performance Indicator Data; Barrier Integrity - RCS
Identified Leakage
10/01/2019 -
09/30/2020
Monthly Data Elements for NRC Reactor Coolant System
Specific Activity
08/2019 -
09/2020
Monthly Data Elements for NRC Occupational Exposure
Control Effectiveness
08/2019 -
09/2020
Monthly Data Elements for RETS/ODCM Radiological
08/2019 -
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Effluent Occurrences
09/2020
Procedures
Collecting and Reporting of NRC Performance Indicator
Data
Monthly Data Elements for NRC Reactor Coolant System
(RCS) Leakage
Corrective Action
Documents
1500855
2B Diesel Generator Lube Oil FME Integrity Lost Due to
Extruded Quad Ring
04/11/2013
219915
FME: Extruded Quad Ring Matl Found Inside 2B Upper
Jacket Water Cooler
2/14/2019
219927
FME: Extruded Quad Ring Found Inside 2B Lower Jacket
Water Cooler
2/14/2019
4364058
Forced Helium Drying Skid Issue
08/19/2020
4364205
Decontamination May Be Needed Under 426' Fuel Handling
Building Aluminum Decking
08/19/2020
4366302
0FP251 Suspected Stem - Disc Separation
08/30/2020
4374821
0FP252 Suspected Stem is Separated from Disc
10/06/2020
4382568
0FP297 Valve Stem Separated
11/05/2020
4382571
0FP252 Valve Stem Separated from Disc
11/05/2020
4389711
2B Diesel Generator - 2DG01KB-Y1 / Y2 - Quad Ring
Gasket Material Found
2/11/2020
4393999
Adverse Trend if Fire Protection Valve Health
01/05/2021
Procedures
BwFP FH-34
Water Transfers of the Spent Fuel Pool, Wet Cask Pit, or
Transfer Canal
BwFP FH-64
Transporter Operations
BwFP FH-65
Spent Fuel Cask Site Transportation
BwFP FH-67
Trackmobile Operations
BwFP FH-68
HI-TRAC Preparation
BwFP FH-69
HI-TRAC Movement Within the Fuel Building
25-26
BwFP FH-70
HI-TRAC Loading Operations
21-22
BwFP FH-72
HI-STORM Processing
BwFP FH-74
MPC Reflood
BwFP FH-83
Spent Fuel Cask Contingency Actions
Quality Assurance Topical Report (QATR)
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
OU-MW-671-300
MPC Processing Forced Helium Dehydration (FHD) for
13-15
OU-MW-679-300
MPC Alternate Cooling for PWRs
Issue Identification and Screening Process
Corrective Action Program (CAP) Procedure
Root Cause Analysis Manual
Corrective Action Program Evaluation Manual
Work Orders
5074225
0FP251 Suspected Stem - Disc Separation
10/05/2020
5092586
0FP252 Suspected Stem is Separated from Disc
11/05/2020
Corrective Action
Documents
4335846
2MS016A - Pre-A2R21 Testing As-Found Outside of
Acceptance Range
04/15/2020
4335997
2MS014B - Pre-A2R21 Testing As-Found Outside of
Acceptance Range
04/16/2020
Engineering
Changes
631400
Unit 2 Main Steam Safety Valves As-Found Lift Setpoint
Evaluation for Pre-A2R21 Testing
Procedures
BwMP 3305-003
Main Steam Safety Valve Testing Using Setpoint Verification
Device
- 5
Work Orders
4867041
Inservice Testing/Operability Test for 2MS016C, Steam
Generator 2C 1190 psig Relief
04/15/2020
4867041-06
Inservice Testing/Operability Test for 2MS014B, Steam
Generator 2B 1220 psig Relief
04/15/2020
4867041-13
Inservice Testing/Operability Test for 2MS016A, Steam
Generator 2A 1190 psig Relief
04/15/2020