IR 05000456/2021001
| 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:
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
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 Aspect Report Section Mitigating Systems Green NCV 05000456/2021001-01 Closed
[H.1] -
Resources 71153 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.
REACTOR SAFETY
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,
RADIATION SAFETY
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 Aspect Report Section Mitigating Systems
Green NCV 05000456/2021001-01 Closed
[H.1] -
Resources 71153 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
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
0BwOA ENV-1
Adverse Weather Conditions Unit 0
24
General Area Checks and Operator Field Rounds
OP-AA-108-111-
1001
Severe Weather and Natural Disaster Guidelines
OP-BR-102-102-
1001
Augmented Operator Field Rounds
Seasonal Readiness
Corrective Action
Documents
4362997
1SI01PA, 1A SI Pump Outboard Bearing has Boric Acid
Buildup
08/13/2020
Procedures
BwOP AF-E2
Electrical Lineup Unit 2 Operating
BwOP AF-M2
Operating Mechanical Lineup, Auxiliary Feedwater, Unit 2
BwOP DC-E2
Electrical Lineup Unit 1 Operating 125V DC Division 11
BwOP DC-E3
Electrical Lineup Unit 1 Operating 125V DC Division 12
BwOP DC-E4
Electrical Lineup Unit 1 Operating 250V DC Distribution
BwOP SI-E1
Electrical Lineup Unit 1 Operating
BwOP SI-M1
Operating Mechanical Lineup
Corrective Action
Documents
4405839
4.0 Critique Crew 4 Fire Drill
03/02/2021
Fire Plans
Pre-Fire Plan 112
Fire Zone 11.3-0 North; Auxiliary Building 364' Elevation Unit 1
Auxiliary Building General Area North
Pre-Fire Plan 2
Fire Zone 8.3-1; Turbine Building 401' Elevation, Unit 1
Turbine Building Grade Level Southwest
Pre-Fire Plan 224
Fire Zone 18.12-0; Lake Screen House 602' Elevation
Pre-Fire Plan 60
Fire Zone 8.3-1; Turbine Building 401' Elevation, Unit 1
Turbine Building Grade Level Northwest
Pre-Fire Plan 61
Fire Zone 8.3-1; Turbine Building 401' Elevation, Unit 1
Turbine Building Grade Level Southeast
Pre-Fire Plan No.
134
Fire Zone 11.4-0 South; Auxiliary Building 383' Elevation
Unit 2 Auxiliary Building General Area South
Miscellaneous
Fire Drill Scenario
20.18.09.24
Unit 1 Flammable Liquids Cabinet Fire
09/24/2018
Procedures
BwAP 1100-16
Fire/Hazardous Materials Spill and/or Injury Response
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
BwAP 1100-3
Fire Chief (Designated Field Supervisor) Implementing
Procedure
BwAP 1100-4
Fire Brigade Implementing Procedure
BwAP 1110-1
Fire Protection Program System Requirements
BwAP 1110-3
Plant Barrier Impairment Program
BwAR 0-37-A4
Unit One Are Fire
BwOP FP-100
Fire Response Guidelines
BwOP PBI-1
Plant Barrier Impairment Program Pre-Evaluated Barrier
Matrix
Plant Barrier Control Program
High Risk Fire Area Identification
ER-BR-600-1069
Site List of High Risk Fire Areas Braidwood Unit 1 and
Unit 2
Fire Drill Performance
Fire Prevention for Hot Work
Fire Brigade Qualification
Pre-Fire Plan Manual
Control of Transient Combustible Material
OP-AA-201-012-
1001
Operations On-Line Fire Risk Management
Miscellaneous
Unit 0 Component Cooling Water Heat Exchanger 0CC01A
Eddy Current Examination Final Report
01/2021
Work Orders
4757035-02
0CC01A: Eddy Current Heat Exchanger
01/28/2021
71111.11Q Procedures
OP-AA-101-111-
1001
Operations Standards and Expectations
Operator Fundamentals
Watch-Standing Practices
OP-AA-103-102-
1001
Strategies for Successful Transient Mitigation
Communications
Operating Narrative Logs and Records
Reactivity Management
OP-AA0101-113-
4.0 Crew Critique Guidelines
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
1006
Systematic Approach to Training Process Description
Operator Training Programs
Conduct of Simulator Training and Evaluation
Simulator Management
TQ-BR-201-0113
Braidwood Training Department Simulator Examination
Security Actions
Radiation Surveys OP-AA-103-103
Operation of Plant Equipment
Examination Security and Administration
Corrective Action
Documents
4398561
2A RCP Seal Injection Flow Change
01/28/2021
4404934
50.59 SSC Categorization Lessons Learned
2/26/2021
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
Line
03/11/2021
Procedures
Maintenance Rule Functions - Safety Significant Classification
Maintenance Rule Implementation per NEI 18-10
Maintenance Rule 18-10 - Scooping
Maintenance Rule 18-10 - Failure Definitions
Maintenance Rule 18-10 - Performance Monitoring and
Dispositioning Between (a)(1) and (a)(2)
Corrective Action
Documents
4396911
Foreign Material Found During New Fuel Inspection
01/20/2021
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
2/01/2021
Miscellaneous
Final RICT Record for Unit0 CC HX Window
2/02/2021
Final RICT Record for Unit 1 CC HX Window
2/11/2021
Procedures
BwMP 3305-009
Disassembly - Reassembly of ITT Grinnell Manually Operated
Diaphragm Valves
Risk Management
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
PARAGON Model Capability
On-Line Risk Management
Risk Management Support of RICT
Calculation of RMAT and RICT for Risk Informed Completion
Time Program
ER-BW-600-2001
Braidwood RICT System Guidelines
MA-AA0716-004
Conduct of Troubleshooting
Protected Equipment Program
Risk Informed Completion Time
Administrative Controls During Fuel Handling Activities for
Byron and Braidwood
New Fuel Receipt and Inspection for Byron, Braidwood, and
Ginna
Operation of the New Fuel Elevator for Byron and Braidwood
Fuel Movement in the Spent Fuel Pool for Byron and
Braidwood
On-Line Risk Management and Assessment
Work Orders
1478802
1CC01A - Repair of Corroded Unit 1 Component Cooling
Water Heat Exchanger Inlet Flanges
2/03/2021
4757035
0CC01A - Repair of Corroded Unit 0 Component Cooling
Water Heat Exchanger Inlet Flanges
01/28/2021
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
Corrective Action
Documents
4395932
Abnormal Noise Identified 1B Emergency Diesel Generator
01/14/2021
4406038
1AF006A & 1AF017A Water Solid UT NDE Exam Issues
03/02/2021
Drawings
M-37
Diagram of Auxiliary Feedwater Unit 1 (Critical Control Room
Drawing)
BK
Procedures
Risk Management Documentation
OP-AA-106-101-
1006
Operational Decision-Making Process
Adverse Condition Monitoring and Contingency Planning
Operability Determinations (CM-1)
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Work Orders
4990811
IST-FSE-1AF006A/017A/013A-D Train A Auxiliary Feedwater
Valves Full Stroke Exercise
03/01/2021
Calculations
BRW-02-0030-M
Min Wall Evaluation for Lines 0SX01CA/B/C/D/E/F-30",
0WS02C-60" and 1(2)CW01AA(C)-108"
Corrective Action
Documents
4408293
Missed Implementation Action on SX 50.69
03/11/2021
4410194
NOS ID: UFSAR Change for Recategorized System not
Approved
03/19/2021
Engineering
Changes
2945
0SX115C Valve and Piping Carbon Fiber Wrap
Miscellaneous
BR-5069-SX-003
CFR 50.69 System Categorization Document - Essential
Service Water (SX) System
& 1
BR-5069-SX-20-
001
50.69 Integrated Decision-Making Panel (IDP) Meeting
Minutes
07/28/2020
BR-5069-SX-20-
2
50.69 Integrated Decision-Making Panel (IDP) Meeting
Minutes
08/12/2020
BW-5069-SX-002
Essential Service Water (SX) Passive Consequence
Development in Support of 50.69 Passive Categorization
DIT-BRW-2020-
23
Transmittal of Design Information (TODI) for EC 632945
Procedures
CFR 50.69 Program
CFR 50.69 Passive Component Categorization
CFR 50.69 Risk Informed Categorization for Structures,
Systems, and Components
CFR 50.69 Alternative Treatment Implementation Process
Integrated Decision Decision-Making Panel for Risk Informed
SSC Categorization Duties and Responsibilities
Requirements for Immediate, Interim and Periodic
Performance Monitoring Reviews
IP-ENG-001
Standard Design Process (EB-17-06)
Corrective Action
Documents
4402970
2B Emergency Diesel Generator Trip on Incomplete Sequence 02/17/2021
Procedures
2BwOSR 3.8.1.2-
2A Diesel Generator Operability Surveillance
2BwOSR 3.8.1.2-
2B Diesel Generator Operability Surveillance
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2BwOSR 3.8/1.2-
2A Diesel Generator Operability Surveillance
Work Orders
5086399
Replace Diesel Generator Local Control Panel Kilovac Relays
2/23/2021
25461
Replace 2PS-DG110B
2/17/2021
27218
2A Emergency Diesel Generator Operability Monthly
2/23/2021
2934
2B Emergency Diesel Generator Operability Monthly
2/17/2021
5130977
Letdown Heat Exchanger Component Cooling Controller
Failure
03/09/2021
Corrective Action
Documents
4303972
1B DG 5L Cylinder Temperature TC not Functional
2/15/2019
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
Surveillance
1BwOSR 3.8.1.2-
1B Diesel Generator Operability Surveillance
2BwOSR
5.5.8.RH.5B
Group A IST Requirements for Residual Heat Removal Pump
2RH01PB
BwOP DG-1
Diesel Generator Alignment to Standby Condition
BwOP DG-11
Diesel Generator Startup and Operation
BwOP DG-12
Diesel Generator Shutdown
Administrative Requirements for Inservice Testing
Corrective Action
Documents
04333398
EP-Siren Failure (BW06)
04/07/2020
04343467
EP-Siren Failure BW28
05/15/2020
04363003
Siren AC Power Outages (BW16, BW20, BW28)
08/13/2020
Corrective Action
Documents
238680
NOS ID: Use EP Qualifications as Designed
04/11/2019
29942
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
Procedure
Type
Designation
Description or Title
Revision or
Date
20
Corrective Action
Documents
04324463
BRW-EP-2020-NRC-CORP-EOF-Failed Objectives
03/06/2020
04332184
NOS ID: EP to Evaluate ORO Comments
04/02/2020
04387891
Annual EP Medical Emergency Drill
2/03/2020
Miscellaneous
Drills and Exercises Reports
2019-2020
21 NRC Emergency Preparedness Graded Exercise
Baseline Inspection
2/11/2021
20 NRC Emergency Preparedness Graded Exercise
Baseline Inspection
01/30/2020
236364
Braidwood EP OYE Additional Comments for the CR and EOF
04/04/2019
EP-AA-124-1001-
F-07
Alternative Facility/ Liaison Kit Inventory
01/01/2019 -
2/31/2020
EP-MW-124-
1001-F-02
CR/Simulator/TSC/OSC Equipment Test - TSC Software and
Reference Document Inventory
01/01/2019 -
2/31/2020
EP-MW-124-
1001-F-03
Technical Support Center Inventory
01/01/2019 -
2/31/2020
EP-MW-124-
1001-F-04
Operations Support Center Inventory
01/01/2019 -
2/31/2020
NOSA-BRW-19-
EP Audit Report
04/17/2019
NOSA-BRW-20-
EP Audit Report
04/08/2020
Procedures
Standardized Radiological Emergency Plan
Radiological Emergency Plan Annex for Braidwood Station
Corrective Action
Documents
Dose Excellence Plan of Action
2/17/2019
MMD Individual Receives Unplanned Dose Alarm
04/20/2020
Loss of LDBP May Lead to Higher Dose Rates for A2R21
04/21/2020
RP-AA-400-1002 Dose Equalization Actions
06/13/2020
Radiation Work
Permits (RWPs)
BW-02-20-00613
Radiation Work Permit BW-02-20-00613 and Associated
ALARA Documentation for Reactor Disassembly and
Reassembly
Multiple
Dates
BW-02-20-00614
Radiation Work Permit BW-02-20-00614 and Associated
ALARA Documentation for Reactor Head/Upper Internal
Moves
Multiple
Dates
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
BW-02-20-00619
Radiation Work Permit BW-02-20-00619 and Associated
ALARA Documentation for Nuclear Instrumentation Under-
Vessel Activities
Multiple
Dates
BW-02-20-00645
Radiation Work Permit BW-02-20-00645 and Associated
ALARA Documentation for 2 Alpha Reactor Coolant Pump
Motor/Pump Replacement
Multiple
Dates
71151
Corrective Action
Documents
04396237
NRC Participation PI Corrections
01/15/2021
Corrective Action
Documents
Resulting from
Inspection
4403396
NRC Observations During Review of LS-AA-2010 and 2030
2/19/2021
Miscellaneous
NRC Performance Indicator Data; Initiating Events -
Unit/Reactor Shutdown Occurrences
01/01/2020 -
2/31/2020
NRC Performance Indicator Data; Initiating Events -
Unplanned Power Changes per 7000 Critical Hours
01/01/2020 -
2/31/2020
NRC Performance Indicator Data; Emergency Preparedness -
Alert and Notification System
01/01/2020 -
2/31/2020
NRC Performance Indicator Data; Emergency Preparedness -
ERO Participation Drill
01/01/2020 -
2/31/2020
NRC Performance Indicator Data; Emergency Preparedness -
Drill/Exercise Performance
01/01/2020 -
2/31/2020
Procedures
Collecting and Reporting of NRC Performance Indicator Data
Monthly Data Elements for NRC/WANO Unit/Reactor
Shutdown Occurrences
- 6
Monthly Data Elements for NRC Unplanned Power Changes
per 7000 Critical Hours
- 6
Procedures
Quality Assurance Topical Report (QATR)
Issue Identification and Screening Process
Corrective Action Program (CAP) Procedure
Corrective Action
Documents
4374128
P2301 Indication Suspect
10/03/2020
Procedures
BwMP 3305-003
Main Steam Safety Valve Testing Using Setpoint Verification
Device
- 5