IR 05000456/2020004

Integrated Inspection Report 05000456/2020004; 05000457/2020004; and 07200073/2020001

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: NPF-72 and NPF-77 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 Enclosure

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 Report Aspect Section Not Applicable NCV 05000456,05000457/2020004-01 Not Applicable 71152 Open/Closed 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 Report Aspect Section Mitigating Green [P.5] - 71153 Systems NCV 05000457/2020004-02 Operating Open/Closed Experience 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 71153 Closed Braidwood Station, Unit 2,

Three Main Steam Safety Valves Failed Setpoint Testing

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.

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.

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 Report Aspect Section Not Severity Level IV Not 71152 Applicable NCV 05000456,05000457/2020004-01 Applicable Open/Closed 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 Report Aspect Section Mitigating Green [P.5] - 71153 Systems NCV 05000457/2020004-02 Operating Open/Closed Experience 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 Type Designation Description or Title Revision or

Procedure Date

71111.01 Corrective Action 4384749 0SH08PB Motor Hot to the Touch 11/16/2020

Documents 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 12/01/2020

4388090 2TS-SI059X Relay Chattering 12/04/2020

4389193 System Effect on 1SH01PA Vibrations 12/09/2020

4389796 0FX01AF Heater Not Energizing 12/12/2020

Miscellaneous Letter 2021 Winter Readiness Certification 12/15/2020

Procedures 0BwOS XFT-A1 Unit Common Freezing Temperature Equipment Protection 21

Surveillance

0BwOS XFT-A2a Unit Common Station Heat Area Heaters Freezing 9

Temperature Equipment Protection Surveillance

0BwOS XFT-A2b Unit Common Station Heat Area Heaters Freezing 7

Temperature Equipment Protection Surveillance

0BwOS XFT-A3 Unit Common Cold Weather Surveillance 13

0BwOS XFT-A4 Unit Common Freezing Temperature Equipment Protection 13

Inside Surveillance

71111.04 Procedures BwOP RH-E2 Electrical Lineup - Unit 2 Operating 9

BwOP RH-M4 Operating Mechanical Lineup Unit 2 2B Train 8

BwOP SX-E1 Electrical Lineup - Unit 1 Essential Service Water System 11

Operating

BwOP SX-M1 Operating Mechanical Lineup Unit 1 35

71111.05 Fire Plans Pre-Fire Plan No. Fire Zone 11.2A-1; Auxiliary Building 346' Elevation, 2

103 Residual Heater Removal Pump 1A Room

Pre-Fire Plan No. Fire Zone 11.3-0 South; Unit 2 Auxiliary Building General 2

113 Area - (South)

Pre-Fire Plan No. Fire Zone 11.4A-1; Auxiliary Building 383' Elevation, Unit 1 3

137 Auxiliary Feedwater Pump Diesel

Procedures BwAP 1110-1 Fire Protection Program System Requirements 44

BwAP 1110-3 Plant Barrier Impairment Program 39

BwOP PBI-1 Plant Barrier Impairment Program Pre-Evaluated Barrier 4

Matrix

Inspection Type Designation Description or Title Revision or

Procedure Date

CC-AA-201 Plant Barrier Control Program 13

ER-AA-600-1069 High Risk Fire Area Identification 4

ER-BR-600-1069 Braidwood Units 1 and 2 - Site List of High-Risk Fire Areas 0

OP-AA-201-004 Fire Prevention for Hot Work 17

OP-AA-201-007 Fire Protection System Impairment Control 0

OP-AA-201-008 Pre-Fire Plan Manual 4

OP-AA-201-009 Control of Transient Combustible Material 25

OP-AA-201-012- Operations On-Line Fire Risk Management 4

1001

71111.06 Corrective Action 4356572 Cable Vault 1G High Level 07/14/2020

Documents

Drawings 20E-0-1001A Duct Runs Outdoor Plan Plant Area O

20E-0-3594 Electrical Installation Manholes #2J Racks Plan and Z

Sections

M-67A Miscellaneous Drains Electrical Cable Vaults Units 1 and 2 D

Procedures ER-AA-300-150 Cable Condition Monitoring Program 7

Work Orders 4906557 Remove and Replace Cable Vault 2J Sump Pump 11/17/2020

(2DM06P)

71111.07T Calculations ATD-0063 Heat Load to the Ultimate Heat Sink During a Loss of 5

Coolant Accident

ATD-0109 Thermal Performance of UHS During Postulated Loss of 4

Coolant Accident

BRW-08-0097-M Air to Water Cubicle Cooler Heat Exchanger Tube Plugging 1

Evaluation

BRW-97-1072-M Component Cooling Heat Exchanger Tube Plugging 6

/ BYR97-0467 Evaluation

Corrective Action 04127063 OSP-X L-1 RCFC Cooler Head Degraded Sealing Surface 04/15/2018

Documents 04146327 Lessons Learned from Diesel Freeze 06/12/2018

297169 White Paste Found in 0B VC Suction Elbow and Guide 11/14/2019

Vanes

04338566 08-OSP-A 2C RCFC Degradation Found Cooler Heads 04/26/2020

Corrective Action 04385510 NRC Identified a Gap in Documentation for BwMP 330-095 11/19/2020

Documents 04385659 Non-Conservative Assumptions in Heat Load Calc for the 11/20/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

Resulting from UHS

Inspection 04386129 NRC UHS - Calc Methodology for RH Cubicle Cooler 11/23/2020

Performance

Miscellaneous 1A RHR Cubicle Cooler Heat Exchanger Inspection Report 12/03/2018

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 0 124

0Bw0A ENV-3 Braidwood Cooling Lake Low Level Unit 0 105

0Bw0A ENV-7 Adverse Cooling Lake Conditions Unit 0 10

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 Type Designation Description or Title Revision or

Procedure 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 12/04/2018

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 08/17/2018

1CW03FB

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

SW

71111.11A Procedures OP-AA-101-113 Operator Fundamentals 14

OP-AA-101-113- 4.0 Crew Critique Guidelines 10

1006

OP-AA-103-102 Watch-Standing Practices 20

OP-AA-103-102- Strategies for Successful Transient Mitigation 2

1001

OP-AA-103-103 Operation of Plant Equipment 1

OP-AA-111-101 Operating Narrative Logs and Records 16

TQ-AA-150-F25 Braidwood 2020 LORT Annual Exam Report 10/09/2020

TQ-AA-155 Conduct of Simulator Training and Evaluation 10

TQ-AA-201 Examination Security and Administration 17

TQ-AA-306 Simulator Management 10

TQ-BR-201-0113 Braidwood Training Department Simulator Examination 22

Security Actions

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.11Q Procedures OP-AA-101-111- Operations Standards and Expectations 25

1001

OP-AA-104-101 Communications 5

TQ-AA-10 Systematic Approach to Training Process Description 6

TQ-AA-150 Operator Training Programs 19

71111.12 Corrective Action 4380250 OSX115C Monthly Pit Inspection Results 10/28/2020

Documents 4380250 Conditional Release of New Oil Pump for 0WO01CA Chiller 12/04/2020

4387762 0A VC Chiller Trip 12/02/2020

Procedures ER-AA-310-1002 Maintenance Rule Functions - Safety Significant 3

Classification

ER-AA-320 Maintenance Rule Implementation per NEI 18-10 0

ER-AA-320-1001 Maintenance Rule 18-10 - Scoping 0

ER-AA-320-1003 Maintenance Rule 18-10 - Failure Definitions 0

ER-AA-320-1004 Maintenance Rule 18-10 - Performance Monitoring and 1

Dispositioning Between (a)(1) and (a)(2)

71111.13 Corrective Action 4382073 0VC24Y Appears to Be Failed Open 11/03/2020

Documents 43854326 Rebuild 1SX150B Actuator 11/19/2020

Drawings M-96 Control Room HVAC System AO

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 4

Actuator Removal)

ER-AA-330-009 ASME Section XI Repair/Replacement Program 17

ER-AA-600 Risk Management 17

ER-AA-600-1042 On-Line Risk Management 12

ER-AA-600-1052 Risk Management Support of RICT 1

ER-AA-600-1053 Calculation of RMAT and RICT for Risk Informed Completion 0

Time Program

ER-BW-600-2001 Braidwood RICT System Guidelines 0

MA-AA-716-004 Conduct of Troubleshooting 17

MA-AA-734-451 Limitorque (SMB-000) Operator Maintenance 8

OP-AA-108-117 Protected Equipment Program 5

WC-AA-101-1006 On-Line Risk Management and Assessment 4

Work Orders 1730745 Rebuild/Replace Actuator for 1B SX Pump Strainer 11/17/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

Backwash Valve (1SX150B)

71111.15 Corrective Action 4321734 Unit 2 LEFM Error Message 02/26/2020

Documents 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 10 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 10/20/2020

Repair

4383947 Beacon Repair Needed and Their Requirements 11/12/2020

Engineering 373557 Evaluate the Impact of the as Found 2VA01SA SX Cubicle 12/31/2008

Changes Cooler Degraded with Loss of One Cubicle Cooler Fan to

Determine the Cubicle Cooler's Design Capability

25908 Temporary Condition Related to the Cubicle Cooler 10/29/2018

(2VA01SA) for the 2A Essential Service Water (SX) Pump

Procedures BwMP 3100-099 SX Cubicle Cooler Inspection 0

BwOP FW-35 Obtaining LEFM Event Log Information and A/C Unit Alarm 3

Resetting

BwOP FW-38 LEFM Data Retrieval 3

EP-AA-1000 Exelon Nuclear Standardized Radiological Emergency Plan 33

ER-AA-600-1012 Risk Management Documentation 17

MA-BR-723-141 Test of the Beacon System 2

OP-AA-106-101- Operational Decision-Making Process 22

1006

OP-AA-108-111 Adverse Condition Monitoring and Contingency Planning 14

OP-AA-108-115 Operability Determinations (CM-1) 23

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.18 Work Orders 4906560 2AP10E REF1 Time Delay Relay Calibration 12/02/2020

71111.19 Corrective Action 4363448 Unexpected Annunciator 2-21-C8, Diesel Generator 2A 08/16/2020

Documents Trouble/Fail to Start

4370636 Unexpected Alarm 2-22-C8, 2B Diesel Generator Control 09/19/2020

Power Failure

4387564 Time Delay Relays Out-of-Tolerance 12/02/2020

4391523 Multiple Oil Leaks on 1B Station Aire Compressor 12/21/2020

4391524 Multiple Leaks on 1B Station Air Compressor 12/21/2020

4391893 1B & 2A Station Air Compressors Not Sharing SA/IA Load 12/23/2020

4391895 1B Station Air Compressor Failure to Start While Aux Oil 12/23/2020

Pump Initially Secured

Engineering 630880 Replacement of Unit 1 Station Air Compressor 1

Changes 632665 Diesel Generator KILOVAC Relay Replacement with 12/04/2020

Struthers-Dunn Model (Units 1 and 2)

Procedures 1BwOSR Essential Service Water System Valve Stroke Surveillance 4

5.5.8.SX-7

2BwOS DG-2B 2B Diesel Generator Overspeed Trip Test 4

2BwOSR 3.3.2.8- Unit 2: ESFAS [Emergency Safety Features Actuation 13

611B System] Instrumentation Slave Relay Surveillance (B Train

Automatic Safety Injection - K611)

2BwOSR 3.6.6.7 Containment Cooling Fan Automatic Actuation Test 4

2BwOSR 2B Diesel Generator Bypass of Automatic Trips Surveillance 17

3.8.1.13-2

2BwOSR 3.8.1.2- Unit 2: 2B Diesel Generator Operability Surveillance 48

BwMP 3100-022 Diesel Generator 2-Year Inspection 39

MA-AA-723-300 Diagnostic Testing of Motor-Operated Valves 13

MA-BR-722-210 Calibration of Time Delay Relays 14

MA-BR-EM-4- Diesel Generator Electrical Inspection 18

09070

SPP 20-003 Special Procedure - Modification Test for 1SA01CB Station 0

Air Compressor

WC-AA-101 On-Line Work Control Process 29

Work Orders 4907204 Perform Time Delay Relay Calibration Check of 1-RCFL at 12/01/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

2AP10E

24112 2DG01KB - Perform 2-Year Inspection of Diesel Generator 12/08/2020

24113 2DG01EB - Diesel Generator Exciter Inspection (2B EDG) 12/07/2020

5014727 1SA01CB - Replacement of Unit 1 Station Air Compressor 10/26/2020

per EC 630880

5086398 2PL08J - Replace Diesel Generator Local Control Panel 12/08/2020

KILOVAC Relays

71111.20 Corrective Action 4380316 1A DG Lower Oil Cooler East End Bell Leak 10/28/2020

Documents

71111.22 Corrective Action 4380237 Unexpected Annunciator 1-21-E8 10/28/2020

Documents

Procedures 0BwOS FX-9 FLEX Pump Flow Surveillance 6

1BwOS TRM Unit 1 Turbine Overspeed Protection Systems Valve Stem 21

3.3.g.4 Freedom Checks (TV-GV Cycling)

1BwOSR 3.8.1.2- Unit One 1A Diesel Generator Operability Surveillance 48

1BwOSR 3.8.1.8- SAT 242-1 Crosstie to Bus 141 and DG `1A Crosstie to Bus 8

241 Surveillance

2BwOSR Group A IST Requirements for 2A Essential Service Water 18

5.5.8.SX-3A Pump (2SX01PA)

OP-BR-FX-1003 High Head FLEX Pump Operating Guideline 1

OP-BR-FX-1004 Medium Head FLEX Pump Operating Guideline 0

OP-BR-FX-1005 Low Head FLEX Pump Operating Guideline 1

Work Orders 4928410 18-Month Surveillance: SAT 242-1 Crosstie to Bus 141 and 10/28/2020

DG 1A Crosstie to Bus 241

4963041 0FX01PB - Medium Head FLEX Pump Component 10/14/2020

Operational Inspection

4964162 0FX02PB - High Head FLEX Pump Component Operational 10/14/2020

Inspection

4965111 0FX03PB - Low Head FLEX Pump Component Operational 10/14/2020

Inspection

5052445 Unit 1 TV-GV Surveillance 10/17/2020

71114.04 Corrective Action IR 4325295 Perform Impact Review of EAL Revisions 03/10/2020

Documents IR 4328154 EP FAQ EAL Change License Amendment Implementation 03/20/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

Actions

IR 4329864 NOS ID: Revise Standard Emergency Plan 03/26/2020

IR 4334253 Emergency Plan: CDAM 50.54(q) Potential Deficiencies 04/09/2020

Miscellaneous Eval 19-29 Evaluation of EP-AA-1000; Exelon Nuclear Standardized 09/04/2019

Radiation Emergency Plan

Eval 19-65 Evaluation of EP-AA-1000; Exelon Nuclear Standardized 09/06/2019

Radiation Emergency Plan

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

71124.05 Calibration Exelon Powerlabs AMS-4 02794 Calibration Record 05/16/2020

Records Calibration

Record

Exelon Powerlabs DMC-3000 Calibration Summary Report 03/27/2020

Calibration

Summary Report

RP-AA-232-1001 Fastscan 13007133 Calibration Report 03/12/2020

RP-AA-700-1235 PM-12 12060 Calibration Data Sheet 05/13/2019

RP-AA-700-1240 ARGOS-5 1011-279 Calibration Data Sheet 02/02/2020

Corrective Action AR 04231595 RP Instrumentation Calibration Out of Tolerance Data 03/21/2019

Documents AR 04337693 04-OSP-A Elevated BKGB Radiation Impacting RCA Exit 04/22/2020

AR 04366845 Potential AR/PRM Setpoint Changes Needed 09/01/2020

Procedures BwIP 2505-008 Calibration of GA Technologies Area Radiation Monitors 14

RP-AA-700-1235 Operation and Calibration of the PM-12 Gamma Portal 5

Monitors

RP-AA-700-1240 Operation and Calibration of the Canberra ARGOS-5 6

Personnel Contamination Monitor

71151 Miscellaneous NRC Performance Indicator Data; Barrier Integrity - RCS 10/01/2019 -

Identified Leakage 09/30/2020

LS-AA-2090 Monthly Data Elements for NRC Reactor Coolant System 08/2019 -

Specific Activity 09/2020

LS-AA-2140 Monthly Data Elements for NRC Occupational Exposure 08/2019 -

Control Effectiveness 09/2020

LS-AA-2150 Monthly Data Elements for RETS/ODCM Radiological 08/2019 -

Inspection Type Designation Description or Title Revision or

Procedure Date

Effluent Occurrences 09/2020

Procedures LS-AA-2001 Collecting and Reporting of NRC Performance Indicator 16

Data

LS-AA-2100 Monthly Data Elements for NRC Reactor Coolant System 6

(RCS) Leakage

71152 Corrective Action 1500855 2B Diesel Generator Lube Oil FME Integrity Lost Due to 04/11/2013

Documents Extruded Quad Ring

219915 FME: Extruded Quad Ring Matl Found Inside 2B Upper 02/14/2019

Jacket Water Cooler

219927 FME: Extruded Quad Ring Found Inside 2B Lower Jacket 02/14/2019

Water Cooler

4364058 Forced Helium Drying Skid Issue 08/19/2020

4364205 Decontamination May Be Needed Under 426' Fuel Handling 08/19/2020

Building Aluminum Decking

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 12/11/2020

Gasket Material Found

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 2

Transfer Canal

BwFP FH-64 Transporter Operations 10

BwFP FH-65 Spent Fuel Cask Site Transportation 16

BwFP FH-67 Trackmobile Operations 0

BwFP FH-68 HI-TRAC Preparation 12

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 4

BwFP FH-74 MPC Reflood 6

BwFP FH-83 Spent Fuel Cask Contingency Actions 15

NO-AA-10 Quality Assurance Topical Report (QATR) 95

Inspection Type Designation Description or Title Revision or

Procedure Date

OU-MW-671-300 MPC Processing Forced Helium Dehydration (FHD) for 13-15

PWRs (ISFSI)

OU-MW-679-300 MPC Alternate Cooling for PWRs 1

PI-AA-120 Issue Identification and Screening Process 11

PI-AA-125 Corrective Action Program (CAP) Procedure 7

PI-AA-125-1001 Root Cause Analysis Manual 6

PI-AA-125-1003 Corrective Action Program Evaluation Manual 6

Work Orders 5074225 0FP251 Suspected Stem - Disc Separation 10/05/2020

5092586 0FP252 Suspected Stem is Separated from Disc 11/05/2020

71153 Corrective Action 4335846 2MS016A - Pre-A2R21 Testing As-Found Outside of 04/15/2020

Documents Acceptance Range

4335997 2MS014B - Pre-A2R21 Testing As-Found Outside of 04/16/2020

Acceptance Range

Engineering 631400 Unit 2 Main Steam Safety Valves As-Found Lift Setpoint 0

Changes Evaluation for Pre-A2R21 Testing

Procedures BwMP 3305-003 Main Steam Safety Valve Testing Using Setpoint Verification 3-5

Device

Work Orders 4867041 Inservice Testing/Operability Test for 2MS016C, Steam 04/15/2020

Generator 2C 1190 psig Relief

4867041-06 Inservice Testing/Operability Test for 2MS014B, Steam 04/15/2020

Generator 2B 1220 psig Relief

4867041-13 Inservice Testing/Operability Test for 2MS016A, Steam 04/15/2020

Generator 2A 1190 psig Relief

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