IR 05000456/2021001

Integrated Inspection Report 05000456/2021001 and 05000457/2021001

ML21106A208
Person / Time
Site:	Braidwood
Issue date:	04/16/2021
From:	Hironori Peterson Division Reactor Projects III
To:	Rhoades D Exelon Generation Co, Exelon Nuclear
References
IR 2021001
Download: ML21106A208 (25)

Text

April 16, 2021

SUBJECT:

BRAIDWOOD STATION - INTEGRATED INSPECTION REPORT 05000456/2021001 AND 05000457/2021001

Dear Mr. Rhoades:

On March 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Braidwood Station. On April 1, 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. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, 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 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 and 05000457 License Nos. NPF-72 and NPF-77

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000456 and 05000457 License Numbers: NPF-72 and NPF-77 Report Numbers: 05000456/2021001 and 05000457/2021001 Enterprise Identifier: I-2021-001-0019 Licensee: Exelon Generation Company, LLC Facility: Braidwood Station Location: Braceville, IL Inspection Dates: January 01, 2021 to March 31, 2021 Inspectors: R. Bowen, Illinois Emergency Management Agency J. Bozga, Senior Reactor Inspector G. Edwards, Health Physicist M. Garza, Emergency Preparedness Inspector D. Kimble, Senior Resident 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

LER 2020-001-00 for Braidwood Station, Unit 1, Train A Auxiliary Feedwater Pump was Inoperable Due to a Failed Suction Pressure Lead/Lag Card Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.1] - 71153 Systems NCV 05000456/2021001-01 Resources Closed A self-revealed finding of very low safety significance and an associated non-cited violation (NCV) of Technical Specification (TS) 3.7.5, Auxiliary Feedwater (AF) System, were identified when the licensee operated Braidwood Unit 1 with the 1 A AF Pump and its associated suction pressure instrument, 1PT-AF051, in an inoperable condition for longer period of time than allowed by the stations Technical Specifications. Specifically, on October 3, 2020, a shiftly channel check identified that the deviation between the 1A and 1B AF Pump suction pressures exceeded the deviation for the channel check acceptance criteria.

Further investigation by the licensee revealed that the 1A AF suction pressure indication had failed at a constant value on September 17, 2020.

Additional Tracking Items

None.

PLANT STATUS

Unit 1 began the inspection period operating at full power. On March 12, 2021, the unit reached the end of the fuel cycle and power coast down operations commenced in preparation for a planned refuel outage. The unit continued to reduce power in accordance with the licensees approved reactivity management plan, and was operating at approximately 89 percent power at the end of the inspection period.

Unit 2 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, the unit 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

Impending Severe Weather Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from an impending winter storm moving through northeast Illinois on January 25 and 26, 2021.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated system configurations during partial physical alignment verifications of the following systems/trains:

(1) The 1B Safety Injection (SI) Train while the 1A SI Train was out of service for maintenance during the week ending January 9, 2021.

(2) The 1A SI Train while the 1B SI Train was out of service for maintenance during the week ending January 23, 2021.

(3) The 2A AF Train while the U0 Component Cooling (CC) Heat Exchanger (HX) was undergoing a planned risk-significant maintenance window during the week ending January 30, 2021.

(4) The Unit 1, Division 11 and 12 125 Vdc safety-related batteries while the U0 CC HX was undergoing a planned risk-significant maintenance window during the weeks ending February 6 through February 13, 2021.

Complete Walkdown Sample (IP Section 03.02) (1 Partial)

The inspectors evaluated system configuration during a full system physical alignment verification of the following system/trains:

(1) (Partial)

The inspectors performed the first part of a full system physical alignment verification of the Unit 1 Residual Heat Removal (RH) System during the weeks ending March 27 through March 31, 2021.

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 physical inspections and reviews to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) The Auxiliary Building 383' Elevation, General Area South while the fire protection system was undergoing maintenance during the week ending January 16, 2021.

(2) The Auxiliary Building 364' Elevation, General Area North while the U0 CC HX was out of service for a risk-significant maintenance window during the week ending February 6, 2021.

(3) The Lake Screen House while welding activities on essential service water (SX)components were underway during the week ending March 31, 2021.

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

The inspectors evaluated the performance and training of the on-site fire brigade during observation of the following drill activity:

(1) An unannounced fire drill during the week ending February 27, 2021.

71111.07A - Heat Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors conducted a review that evaluated readiness and performance of the following safety-related HX:

(1) The Unit 0 CC HX as set forth in Work Order (WO) 4757035 during the weeks ending January 30 through February 20, 2021.

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)

The inspectors observed and evaluated the following licensed operator activities in the control room:

(1) Various activities involving on-watch operations crews. These activities included, but were not limited to:

• Restoration of Unit 2 letdown system pressure/temperature to automatic control from local-manual control during the week ending March 13, 2021.

• Realignment of Unit 2 heater drains following maintenance activities during the week ending March 27, 2021.

• Performance of the 2B Emergency Diesel Generator (EDG) 24-hour endurance surveillance load manipulations during the week ending March 27, 2021.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

The inspectors observed and evaluated the following licensed operator training activity:

(1) A complex casualty graded scenario involving a crew of licensed operators was observed in facility's simulator on March 16, 2021.

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 chemical and volume control system (CVCS) filters during the weeks ending January 30 through March 20, 2021.

(2) Maintenance effectiveness and performance history review of the 0SX115C valve and associated piping following the categorization of the station's essential service water (SX) system under 10 CFR 50.69 during the weeks ending March 6 through March 31, 2021.

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (4 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) Evaluation of the planned work associated with new fuel receipt, as set forth in Work Order (WO) 4988286 during the weeks ending January 23 through February 6, 2021.

(2) Evaluation of the planned work and the risk-informed completion time (RICT)associated with repairs to the Unit 0 CC HX, as set forth in WO 4757035 during the weeks ending January 23 through January 30, 2021.

(3) Evaluation of the work activities and risk associated with emergent repairs to the Reactor Coolant (RC) Filter and associated valves in the Unit 2 letdown line, as set forth in WOs 5120762 and 5120805 during the week ending January 30, 2021.

(4) Evaluation of the planned work and the RICT associated with repairs to the Unit 1 CC HX, as set forth in WO 1478802 during the weeks ending February 6 through February 20, 2021.

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (2 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Evaluation of the operability of the 1B EDG following identification of a degraded hydraulic lifter on the 10L engine cylinder, as documented in Issue Report (IR)

===4395932 during the weeks ending January 23 through January 30, 2021.

(2) Evaluation of the operability of AF system components following ultrasonic testing issues on the safety-related SX supply piping to AF, as documented in IR 446038 during the weeks ending March 6 through March 13, 2021.

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

(1 Partial)

The inspectors reviewed and evaluated the following permanent change to the facility that was enacted on the Unit 1 and Unit 2 SX system. The inspectors reviews included an in-depth examination of the licensees use of 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors, as it was applied to the SX system:

(1) (Partial)

Engineering Change (EC) 632945: 0SX115C Valve and Piping Carbon Fiber Wrap, during the weeks ending March 3 through March 31, 2021.

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) ===

The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:

(1) Functional and operational testing of the 2B EDG following corrective maintenance on the air starting system, as set forth in WOs 5126451 and 5120934 during the week ending February 20, 2021.

(2) Functional and operational testing of the 2A EDG following replacement of kilovac relays, as set forth in WOs 5086399 and 5127218 during the weeks ending February 27 through March 6, 2021.

(3) Replacement and testing of Ovation' logic controllers for the CVCS, as set forth in WO 5130977 during the week ending March 13, 2021.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) 1BwOSR 3.8.1.2-2: Unit One - 1B Diesel Generator (DG) Operability Surveillance, during the weeks ending January 16 through January 23, 2021.

Inservice Testing (IP Section 03.01) (1 Sample)

(1) 2BwOSR 5.5.8.RH-5B: Group A Inservice Testing (IST) Requirements for the 2B RH Pump (2RH01PB), during the week ending January 16, 2021.

RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)

(1) Assessment of unidentified Reactor Coolant System (RCS) leakage rate on Unit 1, as documented in IRs 4344110, 4344858, 4345453, and 4345579, during the weeks ending January 9 through February 6, 2021.

71114.02 - Alert and Notification System Testing

Inspection Review (IP Section 02.01-02.04) (1 Sample)

(1) The inspectors evaluated the following maintenance and testing of the alert and notification system:

• 2019 PNS System Maintenance Report

• 2020 PNS System Maintenance Report

71114.03 - Emergency Response Organization Staffing and Augmentation System

Inspection Review (IP Section 02.01-02.02) (1 Sample)

(1) The inspectors evaluated the readiness of the Emergency Preparedness Organization.

71114.05 - Maintenance of Emergency Preparedness

Inspection Review (IP Section 02.01 - 02.11) (1 Sample)

(1) The inspectors evaluated the maintenance of the emergency preparedness program.

71114.06 - Drill Evaluation

Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

The inspectors evaluated site's emergency plan by observing the following activity:

(1) Implementation of the site's emergency plan by a crew of licensed operators during an evaluated emergency scenario in the facility's simulator on March 16,

71124.02 - Occupational ALARA Planning and Controls

Radiological Work Planning (IP Section 03.01) (4 Samples)

The inspectors evaluated the licensees radiological work planning.

(1) Reactor Disassembly and Reassembly during the spring 2020 refueling outage (A2R21).

(2) Reactor Head/Upper Internal Moves during A2R21.

(3) Nuclear Instrumentation Under-Vessel Activities during A2R21.

(4) 2 Alpha Reactor Coolant Pump Motor/Pump Replacement during A2R21.

Verification of Dose Estimates and Exposure Tracking Systems (IP Section 03.02) (4 Samples)

The inspectors evaluated dose estimates and exposure tracking.

(1) Radiation Work Permit BW-02-20-00613 and Associated ALARA Documentation for Reactor Disassembly and Reassembly during the spring 2020 refueling Outage (A2R21).

(2) Radiation Work Permit BW-02-20-00614 and Associated ALARA Documentation for Reactor Head/Upper Internal Moves during A2R21.

(3) Radiation Work Permit BW-02-20-00619 and Associated ALARA Documentation for Nuclear Instrumentation Under-Vessel Activities during A2R21.

(4) Radiation Work Permit BW-02-20-00645 and Associated ALARA Documentation for 2 Alpha Reactor Coolant Pump Motor/Pump Replacement during A2R21.

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors reviewed and verified selected portions of the licensee's performance indicator submittals listed below:

EP01: Drill/Exercise Performance (IP Section 03.12) ===

(1) Unit 1 (January 1, 2020 through December 31, 2020)

Unit 2 (January 1, 2020 through December 31, 2020)

IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 03.01) (2 Samples)

(1) Unit 1 (January 1, 2020 - December 31, 2020)

(2) Unit 2 (January 1, 2020 - December 31, 2020)

EP02: ERO Drill Participation (IP Section 03.13) (1 Sample)

(1) Unit 1 (January 1, 2020 through December 31, 2020)

Unit 2 (January 1, 2020 through December 31, 2020)

IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 03.02)

(2 Samples)

(1) Unit 1 (January 1, 2020 - December 31, 2020)

(2) Unit 2 (January 1, 2020 - December 31, 2020)

EP03: Alert & Notification System Reliability (IP Section 03.14) (1 Sample)

(1) Unit 1 (January 1, 2020 through December 31, 2020) Unit 2 (January 1, 2020 through December 31, 2020)

IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 03.03) (2 Samples)

(1) Unit 1 (January 1, 2020 - December 31, 2020)

(2) Unit 2 (January 1, 2020 - December 31, 2020)

71153 - Follow-up of Events and Notices of Enforcement Discretion Event Follow-up (IP Section 03.01)

The inspectors assessed licensee performance related to the following events:

(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 February 13 through March 31, 2021.

Event Report (IP Section 03.02) (1 Sample)

The inspectors evaluated and closed the following licensee event report (LER):

(1) LER 05000456/2020-001-00, Train A Auxiliary Feedwater Pump was Inoperable Due to a Failed Suction Pressure Lead/Lag Card (ADAMS Accession No. ML20330A155).

The inspection conclusions and specific details associated with the closure of this LER are documented in the Results Section of this report.

INSPECTION RESULTS

LER 2020-001-00 for Braidwood Station, Unit 1, Train A Auxiliary Feedwater Pump was Inoperable Due to a Failed Suction Pressure Lead/Lag Card Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.1] - 71153 Systems NCV 05000456/2021001-01 Resources Closed A self-revealed finding of very low safety significance and an associated non-cited violation (NCV) of Technical Specification (TS) 3.7.5, Auxiliary Feedwater (AF) System, were identified when the licensee operated Braidwood Unit 1 with the 1A AF Pump and its associated suction pressure instrument, 1PT-AF051, in an inoperable condition for longer period of time than allowed by the stations Technical Specifications. Specifically, on October 3, 2020, a shiftly channel check identified that the deviation between the 1A and 1B AF Pump suction pressures exceeded the deviation for the channel check acceptance criteria. Further investigation by the licensee revealed that the 1A AF suction pressure indication had failed at a constant value on September 17, 2020.

Description:

On October 3, 2020, control room operators conducting a shiftly channel check of Unit 1 AF suction pressure instruments identified that the difference between the Train A and Train B pump suction pressures exceeded the channel check acceptance criteria. The 1A AF Pump suction pressure indicated 37.9 psia, while the 1B AF Pump suction pressure indicated 40.3 psia. The 2.4 psia difference exceeded the specified acceptance criteria for the surveillance of 4 percent, or 2 psia. As part of the investigation that followed, the licensee examined historical data for the suction pressure instruments recorded on the plant process computer. This examination revealed that computer point P2301 for the 1A AF Pump suction pressure instrument had failed at a constant value back on September 17, 2020. Based on this information, at 10 a.m. on October 3, 2020, the licensee entered TS 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation, Limiting Condition for Operation (LCO) Conditions A and J. Condition J required the associated 1A AF Pump to be declared inoperable immediately, resulting in entry into TS LCO 3.7.5, Auxiliary Feedwater (AF)

System, Condition A for one AF train inoperable.

Troubleshooting conducted by the licensee determined the 1A AF Pump and its associated suction pressure instrument, 1PT-AF051, were inoperable as of 7:31 p.m. on September 17, 2020, due to failed suction pressure lead/lag card (1PYAF051C). Because of the failed card, the 1A AF Pump was incapable of automatically transferring to its safety-related essential service water (SX) suction source if the normal suction source was lost. This transfer capability was, however, always available with operator action from the control room and the manual transfer of the AF pumps suction source is a proceduralized action that licensed operators are trained to accomplish if the automatic transfer should fail when called upon. The failed lead/lag card was replaced and the 1A AF Pump and its associated suction pressure instrument were restored to operable status. All applicable TS LCO required actions were exited at 1:11 a.m. on October 4, 2020.

The licensee determined that the failed lead/lag card not being identified from the time of failure at 7:31 p.m. on September 17, 2020, until discovery at 10 a.m. on October 3, 2020, constituted a missed opportunity due to the manner in which the channel check surveillance was being performed. Ultimately, because the 1A AF Pump suction pressure instrument failed in a manner that continued to place its output in close proximity to the nominal value seen by both the 1A and 1B AF Pump suction pressure instruments, the simple comparison of output values was insufficient to permit timely identification of the failure.

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. Given that data from the plant process computer was able to trace the failure of the 1PYAF051C suction pressure lead/lag card to precisely 7:31 p.m. on September 17, 2020, there was clear indication that the unit had been operated at power in excess of the TS 3.7.5 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. The licensee reported this event to the NRC as LER 2020-001-00, The Unit 1 Train A Auxiliary Feedwater Pump was Inoperable Due to a Failed Suction Pressure Lead/Lag Card, on November 25, 2020, (ADAMS Accession Number ML20330A155).

Corrective Actions: The failed 1PYAF051C suction pressure lead/lag card for the 1A AF Pump was successfully replaced and the automatic transfer capability for the 1A AF suction source was restored. Additionally, the licensee added requirements to check the historical trends associated with the AF pump suction pressure instruments during channel check surveillances.

Corrective Action References: 4374128; P2301 Indication Suspect; 10/03/2020

Performance Assessment:

Performance Deficiency: The Bases for TS Surveillance Requirement (SR) 3.3.2.1 stipulates that the channel check surveillance ensures that a gross failure of instrumentation has not occurred. Further, the Bases stipulates that the channel check surveillance will detect gross channel failure, and thus, is key to verifying instrumentation continues to operate properly between required channel calibrations. The inspectors concluded that the licensees failure to have performed a routine, shiftly channel check on the Unit 1 AF pump suction pressure instruments that was capable of detecting a gross failure of the 1A AF Pump suction pressure instrument constituted a performance deficiency that was within the licensees ability to have foreseen and that 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. 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 attribute of 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 licensees failure to have implemented and performed a channel check on the Unit 1 AF pump suction pressure instruments that met the intent of the TS SR 3.3.2.1 Bases contributed to the missed opportunity to have identified the failure of the 1PYAF051C suction pressure lead/lag card in a timely manner. The inspectors also compared the finding with the examples listed in IMC 0612, Power Reactor Inspection Reports, Appendix E, Example of Minor Issues. Example 3.d was found to be similar in that a failure to have adequately executed a required TS SR adversely impacted the cornerstone objective and ultimately resulted in the 1A AF Pump being rendered inoperable for a period in excess of the TS 3.7.5 allowed required action completion time.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 2, Mitigating Systems Screening Questions, the inspectors were able to answer no to all questions and determined the finding to be of very low safety significance (Green). More specifically, the inspectors concluded that probabilistic risk assessment (PRA) functionality of the Unit 1 AF system had not been lost during the time in question from September 17, 2020, to October 4, 2020, because:

• The redundant 1B AF Train was always available;

• Despite being incapable of automatically transferring to its safety-related essential service water (SX) suction source if the normal suction source was lost, the 1A AF Pump was fully capable of automatically starting and supplying AF from its normal source, the condensate storage tanks (CSTs), if demanded by any starting signal; and

• The 1A AF Pump could have been transferred to its safety-related SX suction source, if necessary, by plant operators using approved procedures and response actions to which they were trained.

Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety.

Specifically, existing procedures used to perform the Unit 1 AF pump suction pressure instrument TS channel check surveillance were ineffective at detecting a gross failure of the instrumentation, as discussed in the TS SR Bases

Enforcement:

Violation: TS 3.7.5 requires that two AF trains be operable whenever a unit is operating in Modes 1, 2, or 3. Further, with one AF train inoperable, the inoperable train must be restored within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or in accordance with an approved Risk Informed Completion Time (RICT),or the unit place into Mode 4 where TS 3.7.5 no longer applies. Contrary to this requirement, the licensee operated Unit 1 at power in Mode 1 from September 17, 2020, at 7:31 p.m. to October 4, 2020, at 1:11 a.m. with the 1A AF Train inoperable due to a failed 1PYAF051C suction pressure lead/lag card for the 1A AF Pump.

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 April 1, 2021, the inspectors presented the integrated inspection results to Mr. J. Keenan, Site Vice President, and other members of the licensee staff.

• On February 19, 2021, the inspectors presented the Radiation Protection Inspection results to Mr. J. Keenan, Site Vice President, and other members of the licensee staff.

• On March 5, 2021, the inspectors presented the Emergency Preparedness Program Inspection Exit Meeting inspection results to Ms. M. Spillie, Emergency Preparedness Manager, and other members of the licensee staff.

THIRD PARTY REVIEWS As discussed in IMC 0611, Section 13.01, the inspectors completed a review of the January 13, 2021, report issued by the Institute of Nuclear Power Operations (INPO) National Academy for Nuclear Training (NANT) for their most recent evaluation of maintenance, technical, and engineering training programs at Braidwood Station.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Procedures 0BwOA ENV-1 Adverse Weather Conditions Unit 0 124

OP-AA-102-102 General Area Checks and Operator Field Rounds 18

OP-AA-108-111- Severe Weather and Natural Disaster Guidelines 22

1001

OP-BR-102-102- Augmented Operator Field Rounds 4

1001

WC-AA-107 Seasonal Readiness 22

71111.04 Corrective Action 4362997 1SI01PA, 1A SI Pump Outboard Bearing has Boric Acid 08/13/2020

Documents Buildup

Procedures BwOP AF-E2 Electrical Lineup Unit 2 Operating 11

BwOP AF-M2 Operating Mechanical Lineup, Auxiliary Feedwater, Unit 2 18

BwOP DC-E2 Electrical Lineup Unit 1 Operating 125V DC Division 11 9

BwOP DC-E3 Electrical Lineup Unit 1 Operating 125V DC Division 12 8

BwOP DC-E4 Electrical Lineup Unit 1 Operating 250V DC Distribution 2

BwOP SI-E1 Electrical Lineup Unit 1 Operating 12

BwOP SI-M1 Operating Mechanical Lineup 27

71111.05 Corrective Action 4405839 4.0 Critique Crew 4 Fire Drill 03/02/2021

Documents

Fire Plans Pre-Fire Plan 112 Fire Zone 11.3-0 North; Auxiliary Building 364' Elevation Unit 1 2

Auxiliary Building General Area North

Pre-Fire Plan 2 Fire Zone 8.3-1; Turbine Building 401' Elevation, Unit 1 3

Turbine Building Grade Level Southwest

Pre-Fire Plan 224 Fire Zone 18.12-0; Lake Screen House 602' Elevation 4

Pre-Fire Plan 60 Fire Zone 8.3-1; Turbine Building 401' Elevation, Unit 1 4

Turbine Building Grade Level Northwest

Pre-Fire Plan 61 Fire Zone 8.3-1; Turbine Building 401' Elevation, Unit 1 3

Turbine Building Grade Level Southeast

Pre-Fire Plan No. Fire Zone 11.4-0 South; Auxiliary Building 383' Elevation 3

134 Unit 2 Auxiliary Building General Area South

Miscellaneous Fire Drill Scenario Unit 1 Flammable Liquids Cabinet Fire 09/24/2018

20.18.09.24

Procedures BwAP 1100-16 Fire/Hazardous Materials Spill and/or Injury Response 36

Inspection Type Designation Description or Title Revision or

Procedure Date

BwAP 1100-3 Fire Chief (Designated Field Supervisor) Implementing 4

Procedure

BwAP 1100-4 Fire Brigade Implementing Procedure 5

BwAP 1110-1 Fire Protection Program System Requirements 44

BwAP 1110-3 Plant Barrier Impairment Program 39

BwAR 0-37-A4 Unit One Are Fire 18

BwOP FP-100 Fire Response Guidelines 25

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

Matrix

CC-AA-201 Plant Barrier Control Program 13

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

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

Unit 2

OP-AA-201-003 Fire Drill Performance 18

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

OP-AA-201-005 Fire Brigade Qualification 11

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

71111.07A Miscellaneous Unit 0 Component Cooling Water Heat Exchanger 0CC01A 01/2021

Eddy Current Examination Final Report

Work Orders 4757035-02 0CC01A: Eddy Current Heat Exchanger 01/28/2021

71111.11Q Procedures OP-AA-101-111- Operations Standards and Expectations 26

1001

OP-AA-101-113 Operator Fundamentals 14

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

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

1001

OP-AA-104-101 Communications 5

OP-AA-111-101 Operating Narrative Logs and Records 17

OP-AA-300 Reactivity Management 14

OP-AA0101-113- 4.0 Crew Critique Guidelines 11

Inspection Type Designation Description or Title Revision or

Procedure Date

1006

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

TQ-AA-150 Operator Training Programs 19

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

TQ-AA-306 Simulator Management 10

TQ-BR-201-0113 Braidwood Training Department Simulator Examination 23

Security Actions

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

TQ-AA-201 Examination Security and Administration 18

71111.12 Corrective Action 4398561 2A RCP Seal Injection Flow Change 01/28/2021

Documents 4404934 50.59 SSC Categorization Lessons Learned 02/26/2021

4405894 0SX205A 1/4-Inch Line 30 dpm Leak, 0SX115C Valve Pit 03/02/2021

4408016 0SX115C Leak Identified During Sandblasting 03/10/2021

4408296 Joint Leak Where 0SX115C 30-inch Line Meets 2-Inch YMCI 03/11/2021

Line

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

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

ER-AA-320-1001 Maintenance Rule 18-10 - Scooping 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 4396911 Foreign Material Found During New Fuel Inspection 01/20/2021

Documents 4397021 Paragon Model Conservatism Impacting U-1 CC HX RICT 01/20/2021

4398474 Foreign Material Found in U0 CC HX Drain Line 01/28/2021

4398552 2CV8425 Diaphragm Leak 01/28/2021

4398601 2CV8421 Suspected to be Degraded 01/28/2021

4398967 Lessons Learned U0 CC HX (0CC1A) Clean and Inspect 01/29/2021

4399523 Elevated Dose Rate Identified for U0/1 CC HX Window 02/01/2021

Miscellaneous Final RICT Record for Unit0 CC HX Window 02/02/2021

Final RICT Record for Unit 1 CC HX Window 02/11/2021

Procedures BwMP 3305-009 Disassembly - Reassembly of ITT Grinnell Manually Operated 12

Diaphragm Valves

ER-AA-600 Risk Management 7

Inspection Type Designation Description or Title Revision or

Procedure Date

ER-AA-600-1023 PARAGON Model Capability 10

ER-AA-600-1042 On-Line Risk Management 13

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-AA0716-004 Conduct of Troubleshooting 17

OP-AA-108-117 Protected Equipment Program 5

OP-AA-108-118 Risk Informed Completion Time 2

OU-AP-200 Administrative Controls During Fuel Handling Activities for 24

Byron and Braidwood

OU-AP-201 New Fuel Receipt and Inspection for Byron, Braidwood, and 17

Ginna

OU-AP-203 Operation of the New Fuel Elevator for Byron and Braidwood 7

OU-AP-204 Fuel Movement in the Spent Fuel Pool for Byron and 16

Braidwood

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

Work Orders 1478802 1CC01A - Repair of Corroded Unit 1 Component Cooling 02/03/2021

Water Heat Exchanger Inlet Flanges

4757035 0CC01A - Repair of Corroded Unit 0 Component Cooling 01/28/2021

Water Heat Exchanger Inlet Flanges

4988286 Reactor Services - New Fuel Receipt 01/12/2021

20762 Repair 2CV8425 Diaphragm Leak 01/29/2021

20805 Repair 2CV8421 Suspected to be Degraded 01/29/2021

71111.15 Corrective Action 4395932 Abnormal Noise Identified 1B Emergency Diesel Generator 01/14/2021

Documents 4406038 1AF006A & 1AF017A Water Solid UT NDE Exam Issues 03/02/2021

Drawings M-37 Diagram of Auxiliary Feedwater Unit 1 (Critical Control Room BK

Drawing)

Procedures ER-AA-600-1012 Risk Management Documentation 14

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

1006

OP-AA-108-111 Adverse Condition Monitoring and Contingency Planning 15

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

Inspection Type Designation Description or Title Revision or

Procedure Date

Work Orders 4990811 IST-FSE-1AF006A/017A/013A-D Train A Auxiliary Feedwater 03/01/2021

Valves Full Stroke Exercise

71111.18 Calculations BRW-02-0030-M Min Wall Evaluation for Lines 0SX01CA/B/C/D/E/F-30", 0

0WS02C-60" and 1(2)CW01AA(C)-108"

Corrective Action 4408293 Missed Implementation Action on SX 50.69 03/11/2021

Documents 4410194 NOS ID: UFSAR Change for Recategorized System not 03/19/2021

Approved

Engineering 632945 0SX115C Valve and Piping Carbon Fiber Wrap 0

Changes

Miscellaneous BR-5069-SX-003 10 CFR 50.69 System Categorization Document - Essential 0&1

Service Water (SX) System

BR-5069-SX-20- 50.69 Integrated Decision-Making Panel (IDP) Meeting 07/28/2020

001 Minutes

BR-5069-SX-20- 50.69 Integrated Decision-Making Panel (IDP) Meeting 08/12/2020

2 Minutes

BW-5069-SX-002 Essential Service Water (SX) Passive Consequence 0

Development in Support of 50.69 Passive Categorization

DIT-BRW-2020- Transmittal of Design Information (TODI) for EC 632945 0

23

Procedures ER-AA-569 10 CFR 50.69 Program 4

ER-AA-569-1002 10 CFR 50.69 Passive Component Categorization 3

ER-AA-569-1003 10 CFR 50.69 Risk Informed Categorization for Structures, 6

Systems, and Components

ER-AA-569-1004 10 CFR 50.69 Alternative Treatment Implementation Process 4

ER-AA-569-1005 Integrated Decision Decision-Making Panel for Risk Informed 6

SSC Categorization Duties and Responsibilities

ER-AA-569-1006 Requirements for Immediate, Interim and Periodic 3

Performance Monitoring Reviews

IP-ENG-001 Standard Design Process (EB-17-06) 1

71111.19 Corrective Action 4402970 2B Emergency Diesel Generator Trip on Incomplete Sequence 02/17/2021

Documents

Procedures 2BwOSR 3.8.1.2- 2A Diesel Generator Operability Surveillance 50

2BwOSR 3.8.1.2- 2B Diesel Generator Operability Surveillance 49

Inspection Type Designation Description or Title Revision or

Procedure Date

2BwOSR 3.8/1.2- 2A Diesel Generator Operability Surveillance 50

Work Orders 5086399 Replace Diesel Generator Local Control Panel Kilovac Relays 02/23/2021

25461 Replace 2PS-DG110B 02/17/2021

27218 2A Emergency Diesel Generator Operability Monthly 02/23/2021

2934 2B Emergency Diesel Generator Operability Monthly 02/17/2021

5130977 Letdown Heat Exchanger Component Cooling Controller 03/09/2021

Failure

71111.22 Corrective Action 4303972 1B DG 5L Cylinder Temperature TC not Functional 12/15/2019

Documents 4344110 Unit 1 RCS Leak Rate Deviation Action Level I 06/17/2020

4344858 Unit 1 RCS Leak Rate Action Level Two Deviation 05/21/2020

4345453 Unit 1 RCS Leak Rate Deviation Action Level III 05/24/2020

4345579 Unit 1 RCS Leak Rate Exceeds Deviation Action Level III 05/25/2020

4395932 Abnormal Noise Identified 1B EDG 01/14/2021

Procedures 1BwOSR 3.4.13.1 Unit One Reactor Coolant System Water Inventory Balance 39

Surveillance

1BwOSR 3.8.1.2- 1B Diesel Generator Operability Surveillance 47

2BwOSR Group A IST Requirements for Residual Heat Removal Pump 22

5.5.8.RH.5B 2RH01PB

BwOP DG-1 Diesel Generator Alignment to Standby Condition 31

BwOP DG-11 Diesel Generator Startup and Operation 53

BwOP DG-12 Diesel Generator Shutdown 30

ER-AA-321 Administrative Requirements for Inservice Testing 13

71114.02 Corrective Action 04333398 EP-Siren Failure (BW06) 04/07/2020

Documents 04343467 EP-Siren Failure BW28 05/15/2020

04363003 Siren AC Power Outages (BW16, BW20, BW28) 08/13/2020

71114.03 Corrective Action 04238680 NOS ID: Use EP Qualifications as Designed 04/11/2019

Documents 0429942 Braidwood EP Unannounced 4TH Q Call-In Drill Results 11/22/2019

04353434 Braidwood EP 6/26/20 Call-In Drill 06/29/2020

Miscellaneous ERO Augmentation Drill Reports March 2019 -

December

Inspection Type Designation Description or Title Revision or

Procedure Date

20

71114.05 Corrective Action 04324463 BRW-EP-2020-NRC-CORP-EOF-Failed Objectives 03/06/2020

Documents 04332184 NOS ID: EP to Evaluate ORO Comments 04/02/2020

04387891 Annual EP Medical Emergency Drill 12/03/2020

Miscellaneous Drills and Exercises Reports 2019-2020

21 NRC Emergency Preparedness Graded Exercise 02/11/2021

Baseline Inspection

20 NRC Emergency Preparedness Graded Exercise 01/30/2020

Baseline Inspection

236364 Braidwood EP OYE Additional Comments for the CR and EOF 04/04/2019

EP-AA-124-1001- Alternative Facility/ Liaison Kit Inventory 01/01/2019 -

F-07 12/31/2020

EP-MW-124- CR/Simulator/TSC/OSC Equipment Test - TSC Software and 01/01/2019 -

1001-F-02 Reference Document Inventory 12/31/2020

EP-MW-124- Technical Support Center Inventory 01/01/2019 -

1001-F-03 12/31/2020

EP-MW-124- Operations Support Center Inventory 01/01/2019 -

1001-F-04 12/31/2020

NOSA-BRW-19- EP Audit Report 04/17/2019

NOSA-BRW-20- EP Audit Report 04/08/2020

71114.06 Procedures EP-AA-1000 Standardized Radiological Emergency Plan 33

EP-AA-1001 Radiological Emergency Plan Annex for Braidwood Station 35

71124.02 Corrective Action AR 04304548 Dose Excellence Plan of Action 12/17/2019

Documents AR 04337024 MMD Individual Receives Unplanned Dose Alarm 04/20/2020

AR 04337390 Loss of LDBP May Lead to Higher Dose Rates for A2R21 04/21/2020

AR 04350103 RP-AA-400-1002 Dose Equalization Actions 06/13/2020

Radiation Work BW-02-20-00613 Radiation Work Permit BW-02-20-00613 and Associated Multiple

Permits (RWPs) ALARA Documentation for Reactor Disassembly and Dates

Reassembly

BW-02-20-00614 Radiation Work Permit BW-02-20-00614 and Associated Multiple

ALARA Documentation for Reactor Head/Upper Internal Dates

Moves

Inspection Type Designation Description or Title Revision or

Procedure Date

BW-02-20-00619 Radiation Work Permit BW-02-20-00619 and Associated Multiple

ALARA Documentation for Nuclear Instrumentation Under- Dates

Vessel Activities

BW-02-20-00645 Radiation Work Permit BW-02-20-00645 and Associated Multiple

ALARA Documentation for 2 Alpha Reactor Coolant Pump Dates

Motor/Pump Replacement

71151 Corrective Action 04396237 NRC Participation PI Corrections 01/15/2021

Documents

Corrective Action 4403396 NRC Observations During Review of LS-AA-2010 and 2030 02/19/2021

Documents

Resulting from

Inspection

Miscellaneous NRC Performance Indicator Data; Initiating Events - 01/01/2020 -

Unit/Reactor Shutdown Occurrences 12/31/2020

NRC Performance Indicator Data; Initiating Events - 01/01/2020 -

Unplanned Power Changes per 7000 Critical Hours 12/31/2020

NRC Performance Indicator Data; Emergency Preparedness - 01/01/2020 -

Alert and Notification System 12/31/2020

NRC Performance Indicator Data; Emergency Preparedness - 01/01/2020 -

ERO Participation Drill 12/31/2020

NRC Performance Indicator Data; Emergency Preparedness - 01/01/2020 -

Drill/Exercise Performance 12/31/2020

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

LS-AA-2010 Monthly Data Elements for NRC/WANO Unit/Reactor 5-6

Shutdown Occurrences

LS-AA-2030 Monthly Data Elements for NRC Unplanned Power Changes 5-6

per 7000 Critical Hours

71152 Procedures NO-AA-10 Quality Assurance Topical Report (QATR) 96

PI-AA-120 Issue Identification and Screening Process 11

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

71153 Corrective Action 4374128 P2301 Indication Suspect 10/03/2020

Documents

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

Device

2