IR 05000456/2021003

Integrated Inspection Report 05000456/2021003 and 05000457/2021003

ML21299A077
Person / Time
Site:	Braidwood
Issue date:	10/26/2021
From:	Hironori Peterson Region 3 Branch 3
To:	Rhoades D Exelon Generation Co, Exelon Nuclear
References
IR 2021003
Download: ML21299A077 (24)

Text

October 26, 2021

SUBJECT:

BRAIDWOOD STATION - INTEGRATED INSPECTION REPORT 05000456/2021003 AND 05000457/2021003

Dear Mr. Rhoades:

On September 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Braidwood Station. On October 13, 2021, the NRC inspectors discussed the results of this inspection with Mr. J. Keenan, the Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

No findings or violations of more than minor significance were identified during this inspection.

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, Signed by Peterson, Hironori on 10/26/21 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: 05000456/2021003 and 05000457/2021003 Enterprise Identifier: I-2021-003-0059 Licensee: Exelon Generation Company, LLC Facility: Braidwood Station Location: Braceville, IL Inspection Dates: July 01, 2021 to September 30, 2021 Inspectors: B. Bartlett, Senior Operations Engineer G. Edwards, Health Physicist D. Kimble, Senior Resident Inspector J. Nance, Operations Engineer N. Shah, Project Engineer 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

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

PLANT STATUS

Unit 1 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.

Unit 2 began the inspection period operating at full power. On September 16, 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 91 percent power at the end of the 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 (COVID-19), resident and regional 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, increasing the amount of time on-site as local COVID-19 conditions permitted.

As part of their on-site activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution, 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 a portion 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.

71111.04 - 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) 1A Residual Heat Removal (RH) Train during 1B RH Train maintenance during the week ending July 24, 2021.

(2) 1B Safety Injection (SI) Train during 1A SI Train maintenance during the week ending August 28, 2021.

(3) 2A Station Air Compressor during replacement of the Unit 0 Station Air Compressor replacement during the week ending September 4, 2021.

(4) 2A Auxiliary Feedwater (AF) Train during 2B AF Train maintenance during the week ending September 11, 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) Units 1 and 2 Auxiliary Building, 346' Elevation, General Area, during the week ending August 7, 2021.

(2) Units 1 and 2 Auxiliary Building, 330' Elevation, 1A and 2A Essential Service Water (SX) Pump Room, during the week ending August 7, 2021.

(3) Units 1 and 2 Auxiliary Building, 330' Elevation, 1B and 2B SX Pump Room, during the week ending August 7, 2021.

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (2 Samples)

The inspectors evaluated internal flooding mitigation protection features in the following plant areas:

(1) Unit 1 Auxiliary Building, 330', 346', and 364' Elevations, during the week ending August 7, 2021.

(2) Unit 2 Auxiliary Building, 330', 346', and 364' Elevations, during the week ending August 7, 2021.

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 and biennial written examination administered from August 9, 2021 through September 17, 2021.

71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)

(1) Biennial Requalification Written Examinations The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered between August 9, 2021 and September 17, 2021.

Annual Requalification Operating Tests The inspectors evaluated the adequacy of the facility licensees annual requalification operating test.

Administration of an Annual Requalification Operating Test The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.

Requalification Examination Security The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.

Remedial Training and Re-examinations The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.

Operator License Conditions The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.

Control Room Simulator The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.

Problem Identification and Resolution The inspectors evaluated the licensees ability to identify and resolve problems associated with licensed operator performance.

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:

End-of-cycle reactivity maneuvers leading into Unit 2 coast down operations for the A2R22 refuel outage during the week ending September 18, 2021.

4,160 Vac electric plant maneuvers in support of emergency diesel generator testing during the week ending September 18, 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 September 7, 2021.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (3 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 the Direct Current (DC)

Batteries and Distribution System during the weeks ending August 21 through August 28, 2021.

(2) Maintenance effectiveness and performance history review of nuclear instrumentation during the week ending August 28, 2021.

(3) Maintenance effectiveness and performance history review of Overpower Delta Temperature (OPDT) components during the weeks ending September 4 through September 30, 2021.

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (3 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 activities and risk associated with emergent troubleshooting and repairs to the 1A Emergency Diesel Generator (EDG), as documented in Issue Report (IR) 4437474 during the week ending July 31, 2021.

(2) Evaluation of the work activities and risk associated with planned maintenance on the 1B SI Recirculation Isolation Valve, 1SI8920, in conjunction with emergent work on 1HD026A, the 12A Feedwater Heater Normal Level Control Valve, during the week ending September 18, 2021.

(3) Evaluation of the work activities and risk associated with several concurrent planned work activities, including acceptance testing for the 1A Station Air Compressor, 1A EDG monthly operability testing, 1A RH Train operability testing, and 2A Containment Spray Train operability testing during the week ending September 30, 2021.

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples 1 Partial)

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

(1) Evaluation of the availability of the 2B Start Up Feedwater Pump due to low oil pressure, as documented in IR 4428965 during the weeks ending July 10 through August 14, 2021.

(2) Evaluation of the operability of the 2B RH system due to boric acid leakage on the 2FIS-0611 Recirculation Valve Controller, as documented in IR 4436953 during the weeks ending July 31 through August 14, 2021.

(3) Evaluation of the operability of the 1A EDG after a failure to start during a monthly surveillance, as documented in IR 4437474 during the weeks ending August 7 through September 18, 2021.

(4) Evaluation of the operability of the 2A EDG following identification of a sheared bolt associated with the 4L cylinder air manifold, as documented in IR 4443522 during the weeks ending September 4 through September 25, 2021.

(5) (Partial)

Continued evaluation of the operability of the source range nuclear instruments with their high flux trips bypassed during reactor startup, as documented in IR 4418688 during the weeks ending July 1 through September 25, 2021.

(6) Review of Unit 1 Core Exit Thermocouple (CETC) operability following several issues, as documented in IRs 4419609, 4420610, and 4423740 during the weeks ending September 25 through September 30, 2021.

(7) Review of the 0B Auxiliary Building Nonaccessible Area (NAC) Exhaust Filter Plenum Ventilation Train operability following identification of testing equipment being left installed since May 2021, as documented in IR 4447805 during the weeks ending July 10 through September 30, 2021.

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (2 Samples)

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

(1) Testing of the 1SI8920 Mini-Flow Recirculation Valve after maintenance, as set forth in Work Order (WO) 4904903 during the week ending September 18, 2021.

(2) Comprehensive functional and operational acceptance testing of the 1A Station Air Compressor following replacement and installation, as documented in station procedure SPP-21-002 during the weeks ending September 25 through September 30, 2021.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) 2BwOSR 3.8.1.2-1, Technical Specification operability surveillance for the 2A EDG, during the weeks ending August 7 through August 14, 2021.

(2) BwIP 2500-070, calibration of the 2B Steam Generator main steam atmospheric relief valve control loop, during the week ending August 14, 2021.

Inservice Testing (IP Section 03.01) (1 Sample)

(1) 2BwOSR 5.5.8.RH, inservice testing for the 2B RH Train, during the weeks ending August 14 through August 21, 2021.

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes.

Eval No. 20-71 Emergency Action Levels for Braidwood Station, EP-AA-1001, Addendum 3 This evaluation does not constitute NRC approval.

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)

(1 Sample)

The inspectors evaluated the following select emergency preparedness (EP) drill:

(1) Observation and evaluation of the station's Emergency Response Organization during the performance of a full-scale site-wide EP drill on August 2, 2021.

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

The inspectors evaluated the following EP drill/training evolution:

(1) Review of the implementation of the site's emergency plan by a crew of licensed operators during an evaluated emergency scenario in the facility's simulator on September 7,

71124.05 - Radiation Monitoring Instrumentation

Calibration and Testing Program (IP Section 03.02) (6 Samples)

The inspectors evaluated the calibration and testing of the following radiation detection instruments:

(1) Thermo Fisher RO20 SN#0013941

(2) Eberline Model 3 SN#0017854

(3) Ludlum 177 SN#0025821

(4) Thermo Fisher RO20 SN#0018388

(5) Eberline Model 3 SN#0014351

(6) Ludlum 3030P SN#0015022

71124.07 - Radiological Environmental Monitoring Program

Environmental Monitoring Equipment and Sampling (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated environmental monitoring equipment and observed collection of environmental samples.

Radiological Environmental Monitoring Program (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the implementation of the licensees radiological environmental monitoring program.

GPI Implementation (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees implementation of the Groundwater Protection Initiative program to identify incomplete or discontinued program elements.

71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage,

& Transportation

Radioactive Material Storage (IP Section 03.01)

(1) Inspectors evaluated the licensees performance in controlling, labeling, and securing radioactive materials. This included the radioactive waste storage portion of the facility.

Radioactive Waste System Walkdown (IP Section 03.02) (1 Sample)

(1) Inspectors walked down accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality.

Waste Characterization and Classification (IP Section 03.03) (2 Samples)

(1) The inspectors evaluated the licensees characterization and classification of radioactive waste. This included the resin waste streams at the facility.

(2) The inspectors evaluated the licensees characterization and classification of radioactive waste. This included the dry activated waste (DAW) stream at the facility.

Shipment Preparation (IP Section 03.04) (1 Sample)

(1) The inspectors observed that a shipment containing radioactive material is prepared according to requirements. The shipment identification number was RWS21-015 for seven B-25 Boxes of Condensate Polish Resin shipped on August 17, 2021.

Shipping Records (IP Section 03.05) (3 Samples)

The inspectors evaluated the following non-excepted radioactive material shipments through a record review:

(1) Shipment RWS21-001 UN3321 LSA-II; Resin Liner P0695283-14 in Cask 14-215.

(2) Shipment RWS20-015 UN3321 LSA-II; 14 DAW Legacy Waste in Cask 14-210.

(3) Shipment RWS20-018 UN2916 Type (B) Package; Resin Liner PO 692200-4.

OTHER ACTIVITIES - BASELINE

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

MS08: Heat Removal Systems (IP Section 02.07) ===

(1) Unit 1 (July 1, 2020 through June 30, 2021)

(2) Unit 2 (July 1, 2020 through June 30, 2021)

MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)

(1) Unit 1 (July 1, 2020 through June 30, 2021)

(2) Unit 2 (July 1, 2020 through June 30, 2021)

MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)

(1) Unit 1 (July 1, 2020 through June 30, 2021)

(2) Unit 2 (July 1, 2020 through June 30, 2021)

71152 - Problem Identification and Resolution

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) Review and assessment of the corrective actions for the spent fuel dry cask storage (DCS) system forced helium drying errors, as documented in IR 4364058 during the weeks ending August 7 through August 14, 2021.

(2) Review and assessment of the corrective actions for the 1/2CC202B wrong unit valve operation, as documented in IR 4434922 during the weeks ending July 17 through September 30,

INSPECTION RESULTS

Observation: Forced Helium Drying Skid Issue During Dry Cask Processing 71152 The inspectors performed a detailed review of IR 4364058, Forced Helium Drying Skid Issue. Specifically, on August 19, 2020, a reactor services crew connected hoses incorrectly in preparation for Multi-Purpose Cannister (MPC) blowdown, resulting in an increased risk of the cask being over-pressurized due to bulk water boiling inside the cask. The inspectors chose this issue for an in-depth review of the licensee's actions within their corrective action program (CAP) due to the potential of cask failure and damage to the integrity of the fuel stored within the cask. Consequently, for this detailed Problem Identification and Resolution inspection sample, the inspectors focused on assessment of the licensee's corrective actions taken to address this condition.

The licensees evaluation concluded that the direct cause was the failure by the fuel handlers to verify that the correct hoses were properly attached to the MPC prior to starting work.

Contributing to this were inappropriate actions taken by supervision overseeing the work activities, in part, due to a culture of not reinforcing expectations for using human performance tools during previous work activities and workers not effectively challenging supervision when faced with potential issues.

Corrective actions included, but were not limited to, revising procedures to use color coded hoses to ensure correct connections and requiring that supervisors sign off on specific, key steps to ensure proper system setup. Additionally, coaching/training was provided to ensure fuel handling supervision understood the expectations for performing work observations and in how to identify and correct key behaviors. Further, fuel handling management verified the efficacy of these actions by holding monthly meetings to evaluate the observations performed and proffer feedback on their effectiveness.

The inspectors review did not identify any issues of note with the corrective actions taken; however, their effectiveness could not be confirmed as the licensee had not performed any cask handling activities since implementation.

No findings or violations of NRC requirements were identified by the inspectors in the course of this review.

Observation: 1/2CC202B Wrong Unit Error 71152 The inspectors performed a detailed review of IR 4434922, Level 4 Configuration Control -

Received Unexpected Alarm 1-2-E3. The issue involved the mistaken operation of 1CC202B, Motor-Operated Valve (MOV) 1B SX to CC Makeup Downstream Isolation, during what was planned to have been a post-maintenance stroke test of 2CC202B, MOV 2B SX to CC Makeup Downstream Isolation, on July 14, 2021. The inspectors determined that the mistaken operation of 1CC202B instead of the planned and briefed 2CC202B had constituted a violation of the requirements of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings. However, because the SX to Component Cooling (CC)emergency makeup line on each unit is protected from the effects of inadvertent valve operation by the use of two MOVs in series, the mistaken operation of the 1CC202B valve instead of the intended 2CC202B valve did not result in any adverse consequences.

Subsequently, the inspectors concluded that the violation had not adversely impacted the Reactor Safety Mitigating Systems Cornerstone objective and, therefore, constituted a violation of minor significance that was not subject to formal actions per Section 2.3.1 of the NRC Enforcement Policy.

The inspectors chose this issue for an in-depth review of the licensees actions within their CAP because of the inherent risk associated with wrong unit/wrong component operational errors. Consequently, for this detailed Problem Identification and Resolution inspection sample, the inspectors focused on assessment of the licensees corrective actions taken both for this specific error, as well as those targeted at the more generic issue of preventing wrong unit/wrong component operational errors.

The inspectors did not identify any issues with the licensees CAP actions taken. Actions targeting the more generic issue of wrong unit/wrong component operational errors were focused on reinforcing existing human performance tool use and appreciation by the workforce. Actions targeting this specific event included painting the control panels for the MOV hand switches involved in this event with the appropriate unit-specific color scheme - yellow for Unit 1 and green for Unit 2. At the time of the event, all of the control panels involved, all of which are located in the same physical area of the station, were painted with a non-distinct color.

No findings or violations of NRC requirements of more than minor safety significance were identified by the inspectors in the course of this review.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On October 13, 2021, the inspectors presented the integrated inspection results to Mr. J. Keenan, Site Vice President, and other members of the licensee staff.

On July 15, 2021, the inspectors presented the radiation protection inspection results to Mr. J. Keenan, Site Vice President, and other members of the licensee staff.

On August 20, 2021, the inspectors presented the radiation protection inspection results to Mr. J. Keenan, Site Vice President, and other members of the licensee staff.

On August 20, 2021, the inspectors presented the biennial requalification inspection results inspection results to Mr. J. Keenan, Site Vice President, and other members of the licensee staff.

On October 1, 2021, the inspectors presented the EPlan and EAL Change Inspection Exit inspection results to Mr. D. Moore, Senior Manager, Emergency Preparedness, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.04 Corrective Action 4429000 SA SAC (2SA02C) Oil Temperature High 06/12/2021

Documents 4436087 1RH8729A Lock Issues 07/20/2021

4436735 2SA02C Oil Temperature High 07/23/2021

4437788 2SA02C Margin Improvement Initiative 07/29/2021

4443172 2SA01C FNL I/S Temperature is High 08/28/2021

BwOP RH-M1 Operating Mechanical Lineup Unit 1 1A RH Train 14

Procedures BwOP AF-E2 Electrical Lineup Unit 2 Operating 11

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

BwOP RH-E1 Electrical Lineup Unit 1 Operating 10

BwOP SA-E2 Electrical Lineup Unit 2 Station Air System Operating 5

BwOP SA-M2 Operating Mechanical Lineup Unit 2 15

BwOP SI-E1 Electrical Lineup Unit 1 Operating 12

BwOP SI-M1 Operating Mechanical Lineup Unit 1 27

71111.05 Fire Plans Pre-Fire Plan No. Fire Zone 11.2-0; Auxiliary Building 346' Elevation, 3

101 Auxiliary Building General Area South

Pre-Fire Plan No. Fire Zone 11.1A-0; Auxiliary Building 330' Elevation, Unit 1 2

Auxiliary Building Basement (1A/2A SX)

Pre-Fire Plan No. Fire Zone 11.1B-0; Auxiliary Building 330' Elevation, Unit 2 3

Auxiliary Building Basement (1B/2B SX)

Pre-Fire Plan No. Fire Zone 11.2-0; Auxiliary Building 346' Elevation, 3

Auxiliary Building General Area Center

Pre-Fire Plan No. Fire Zone 11.2-0; Auxiliary Building 346' Elevation, 3

Auxiliary Building General Area North

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

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

Inspection Type Designation Description or Title Revision or

Procedure Date

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

OP-AA-201-009 Control of Transient Combustible Material 26

OP-AA-201-1001 Operations On-Line Fire Risk Management 4

71111.06 Calculations 3C8-0685-002 Auxiliary Building Flood Level Calculation 16

3C8-0787-001 Confirmation of Safe Shutdown Capability After Auxiliary 4

Building Flooding

3C8-1281-001 Auxiliary Building Flood Level Calculations 4

Corrective Action 4355236 The Plug for the 0TR19P (Lime Sludge West Lagoon Sump 08/07/2020

Documents Pump) is Damaged and Needs to be Replaced

4366140 Unexpected Alarm 1-1-A2 Containment Drain Leak 08/29/2020

Detection Flow High

4391353 0TR19P WWT West Lime Sludge Lagoon #2 Sump Pump is 12/20/2020

Degraded

4405498 SD-191 Discrepancy During Watertight Door Surveillance 03/01/2021

4418893 WO 01785089-09 Stud Missing for Re-Installation of Flood 04/25/2021

Seal

22795 Procedural Guidance for Setting Cable Vault Sump Pumps 05/11/2021

27580 IAM for Sump Pump 0CP05P WO 5157026-01 06/04/2021

28760 Received the Unit 1 SX Sump Level High High Alarm 06/11/2021

4438648 Door Operator Loose on Unit 2 SX Pump Room 08/03/2021

Miscellaneous BB-PRA-012 Byron and Braidwood Probabilistic Risk Assessment, 9

Internal Flood Evaluation Summary Notebook

NEI 12-07 Guidelines for Performing Verification Walkdowns of Plant 0

Flood Protection Features

Procedures 0BwOA PRI-8 Auxiliary Building Flooding Unit 0 9

ER-AA-450 Structures Monitoring 10

Work Orders 1860257 1DSFO06/08 Outage Flood Seals Surveillance 03/03/2017

1915060 2DSFSO06/08 Outage Flood Seals Surveillance 10/18/2017

4838070 Remove/Replace Flood Seal Covers 03/25/2020

1DSFSO07 & 09 Auxiliary Feedwater Tunnel Outage

5079981 Watertight Door Inspection 03/18/2021

71111.11B Corrective Action 4340246 4.0 Critique for Recent and Ramps 05/012020

Documents 4398670 4.0 Critique U0 CC Heat Exchanger Side Drain Down 01/28/2021

Inspection Type Designation Description or Title Revision or

Procedure Date

4418688 Level 3 Configuration Control SRNI's Required Function 04/24/2021

Bypassed

4430586 4.0 Critique U1 Reactor Trip Due to Generator Load Reject 06/21/2021

Corrective Action 4441641 NRC Identified Unattended Exam Material 08/19/2021

Documents

Resulting from

Inspection

Fire Plans Simulator Post 1A MFP Start (PMT) 03/05/2020

Event Testing

Miscellaneous Simulator Post 1A MFP Start 11/06/2019

Event Testing

Simulator Post 2CC130 Issues / Drop 7 failure 07/23/2021

Event Testing

Simulator Post 2CV131 - Securing Letdown Evolution 07/14/2021

Event Testing

Simulator Post Unit 2A MFP Start 12/7/2020 02/10/2021

Event Testing

TQ-AA-306 ATT 10 PWR Moderator Temperature Coefficient of 04/29/2021

Reactivity, Cycle 23 Compare to Plant Startup Data

TQ-AA-306 ATT 10 PWR Moderator Temperature Coefficient of 04/27/2021

Reactivity Cycle 23 New Core Test

TQ-AA-306 ATT 11 PWR Rod Worth Coefficient of Reactivity Cycle 23 04/27/2021

New Core Test

TQ-AA-306 ATT 12 PWR Boron Coefficient of Reactivity Cycle 23, 04/27/2021

New Core Test

TQ-AA-306 ATT 13 PWR Xenon Worths Cycle 23, New Core Test 04/27/2021

TQ-AA-306 ATT 16 PWR Approach to Criticality Using Boric Acid 04/29/2021

Cycle 23, Comparison to Plant Data

TQ-AA-306 ATT 16 PWR Approach to Criticality Using Boric Acid 04/27/2021

Cycle 23, New Core Test

TQ-AA-306 ATT 17 PWR Approach to Criticality Using Rods Cycle 23, 04/27/2021

New Core Test

TQ-BR-0115 Transient 10, Slow Primary Depressurization Due to Open 03/22/2021

PORV w/o Charging Pumps

Inspection Type Designation Description or Title Revision or

Procedure Date

TQ-BR-302-0103 Braidwood Steady State Testing 100% and 75% 03/05/2020

TQ-BR-302-0103 FW/CV Letdown System Tuning 49% 03/05/2020

TQ-BR-302-0106 Transient Test - 1, Manual Reactor Trip 03/22/2021

TQ-BR-302-0107 Transient Test 2, Simultaneous Trip of All Main Feedwater 03/22/2021

Pumps

TQ-BR-302-0108 Transient Test 3, Simultaneous Closure of All Main Steam 03/22/2021

Isolation Valves

TQ-BR-302-0109 Transient Test 4, Simultaneous Trip of All Reactor Coolant 03/22/2021

Pumps

TQ-BR-302-0110 Transient Test 5, Trip of Any Single Reactor Coolant Pump 03/22/2021

TQ-BR-302-0111 Transient Test 6, Turbine Trip
<P-8 03/22/2021

TQ-BR-302-0112 Transient 7, Maximum Ramp Rate (100% to 75% to 100%) 03/22/2021

TQ-BR-302-0113 Transient 8, LBLOCA with LOOP 03/22/2021

TQ-BR-302-0114 Transient 9, Maximum Size Main Steam Line Rupture 03/22/2021

TQ-BR-302-0116 Maximum Design Load Reject 03/22/2021

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

TQ-AA-150 Operator Training Programs 20

TQ-AA-155 Conduct of Simulator Training and Evaluation 11

TQ-AA-201 Examination Security and Administration 18

TQ-AA-306 Simulator Management 10

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

Security Actions

Self-Assessments Differences Between Braidwood Simulator and Braidwood SRB 21-2

Unit 1

Work Orders Open Service Work Requests 08/16/2021

71111.11Q Procedures OP-AA-101-111- Operations Standards and Expectations 27

1001

OP-AA-101-113 Operator Fundamentals 15

OP-AA-101-113- 4.0 Crew Critique Guidelines 11

1006

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

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

1001

Inspection Type Designation Description or Title Revision or

Procedure Date

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

OP-AA-104-101 Communications 5

OP-AA-111-101 Operating Narrative Logs and Records 18

OP-AA-300 Reactivity Management 14

71111.12 Corrective Action 1451512 Unit 2 Core Exit Thermocouple Nozzle 77 Connections 12/12/2012

Documents Swapped Affecting Indications

4370362 Recurring Equipment Reliability Issue Unit 1 D 09/18/2020

Incore Detector

4393580 Hairline Cracks in Tops of Battery Cells (1DC02E) 01/03/2021

4402276 Battery 211 Terminal Voltage High Out of Admin Limit 02/14/2021

4402279 Battery 112 Quarterly Temp Deviation High Out of Admin 02/14/2021

Limit

4403966 1D Incore Detector Issues 02/22/2021

4411770 Failed Post-Maintenance Test 1D Incore 03/26/2021

4413950 Battery 211 Has Cap Broken on Cell 56 04/04/2021

4418835 1BwOS TRM 3.3.H.1 Failed Symmetric Core Exit 04/25/2021

Thermocouple Temperature Limits

4419609 Unit 1 Core Exit Thermocouple Nozzle 74 Connections 04/28/2021

Swapped Affecting Indications

21778 Unexpected Alarms 1-10-A5 and 1-114-A1 for OPDT 05/05/2021

23740 Unit 1 Core Exit Thermocouples Exceed Allowed Maximum 05/15/2021

Deviation

25470 DC111 Cracked Battery Cells 05/25/2021

4436872 Pilot Cell for Battery 112 Specific Gravity Found Low 07/25/2021

4439676 Summary of Findings from Braidwood Unit 1 Source Range 08/09/2021

Nuclear Instrument Cable Testing

4440617 Unexpected BwAR 1-10-C3 Poer Range Flux Rate Trip Alert 08/13/2021

for N41

4440747 Battery 111 Average Cell Temp High 08/15/2021

4441987 Unexpected Alarms 1-10-A5 and 1-14-A1 for 1C OPDT 08/22/2021

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

Evaluations

Procedures ER-AA-312-1002 Maintenance Rule Functions Safety Significant 3

Inspection Type Designation Description or Title Revision or

Procedure Date

Classification

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

ER-AA-320-1001 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 4446169 Unexpected MRC Alarm; 12A HTR LO 09/14/2021

Documents 4446232 1HD054A Continuous Operation Evaluation Required 09/14/2021

Miscellaneous 1SI8920 Work Window Protected Equipment List 09/13/2021

Procedures ER-AA-600 Risk Management 7

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

MA-AA-716-004 Conduct of Troubleshooting 19

OP-AA-108-117 Protected Equipment Program 7

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

71111.15 Corrective Action 1213984 A2R15LL: S/U FW PP Press Switch Isolation Leak-By 05/10/2011

Documents 320432 2PS-FW282A Isolation Valve Leaks-By 04/02/2005

4419609 Unit 1 Core Exit Thermocouple Nozzle 74 - Connections 04/28/2021

Swapped Affecting Indications

20610 B Train Core Exit Thermocouples Not Communicating with 05/01/2021

Plant Process Computer

23740 Unit 1 Core Exit Thermocouples Exceed Allowed Maximum 05/15/2021

Deviation

28965 U-2 Startup Feedwater Pump Oil Pressure Low 06/12/2021

4436953 2FIS-0611 is Weeping Boric Acid 07/26/2021

4437474 1SX169A Failed to Open on Slow Local Start of 1A DG 07/28/2021

4443522 2A DG Bolt on 4L Cylinder Sheared During Scheduled Run 08/30/2021

4447805 0B Non-Accessible Plenum Delay 09/21/2021

Procedures BwOP FW-24 Filling and Venting an Isolated Feedwater Pump 14

ER-AA-600-1012 Risk Management Documentation 14

OP-AA-106-101- Operational Decision-Making Process 23

1006

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

OP-AA-108-115 Operability Determinations (CM-1) 24

71111.19 Procedures 1BwOSR Group A IST Requirements for 1B Safety Injection Pump 12

Inspection Type Designation Description or Title Revision or

Procedure Date

5.5.8.SI-10B (1SI01PB)

1BwOSR Train B Safety Injection System Valve Stroke Surveillance 14

5.5.8.SI-1B

1BwOSR Train B Safety Injection System Isolation Valve Indication 12

5.5.8.SI-2B Surveillance

SPP-21-002 Modification Test of 1SA01CA Station Air Compressor 0

Work Orders 4762173 1SI8920 Motor Operated Valve Diagnostic Test 09/14/2021

5092650 Electrical Replacement of U0 SAC EC 630879 10/06/2021

5175731 IST for 1SI8919A/B/8922B/8926 ASME Surveillance 09/14/2021

Requirements for 1SI01PM

71111.22 Corrective Action 4438884 2A DG Lower Lube Oil Cooler Oil Leak When Running 08/04/2021

Documents

Miscellaneous Calibration of Steam Generator 2B Main Steam Atmospheric 3

Relief Valve Control Loop Test Report Package

2P-MS042 BwIP 2500-070

Procedures 2BwOSR 3.8.1.2- Unit Two 2A Diesel Generator Operability Surveillance 51

2BwOSR Group A IST Requirements for Residual Heat Removal 23

5.5.8.RH-5B Pump 2RH01PB

BwIP 2500-070 Calibration of Steam Generator Main Steam Atmospheric 13

Relief Valve Control Loop

Work Orders 4718820 2P-MS042 S/G 2B Steam Outlet Pressure Loop 08/23/2021

71114.04 Miscellaneous Eval No. 20-71 Emergency Action Levels for Braidwood Station, 09/08/2020

EP-AA-1001, Addendum 3

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

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

71124.05 Procedures RP-AA-700 Controls for Radiation Protection Instrumentation 8

71124.07 Corrective Action AR 04359867 1st and 2nd Quarter REMP Samples to Document in 07/30/2020

Documents 2020 AREOR

AR 04398177 BD-22 01/26/2021

AR 04398679 3rd and 4th Quarter REMP Samples to Document in 01/28/2021

20 AREOR

Miscellaneous Braidwood Station Unit 1 and 2 Annual Radiological 05/2020

Environmental Operating Report 2019

Inspection Type Designation Description or Title Revision or

Procedure Date

Meteorological Tower Inspection Report 06/2019

Meteorological Tower Inspection Report 06/2020

Braidwood Nuclear Power Station Annual Radioactive 05/2021

Effluent Release Report (ARERR) 2020

Braidwood Station Unit 1 and 2 Annual Radiological 05/2021

Environmental Operating Report 2020

71124.08 Corrective Action AR 04364522 0B RW Demin Inlet Pressure High Out of Band 08/21/2020

Documents AR 04375152 0PL01J, Liquid RW Control Panel, Alarm Check 10/07/2020

Unsatisfactory

AR 04403327 Lesson Learned: Dose Received During RW Resin Liner 02/18/2021

Survey

Miscellaneous 10 CFR 61 Analysis for Primary Resin Filters 04/16/2021

Procedures RP-AA-600 Radioactive Material/Waste Shipments 18

Shipping Records RWS20-015 UN3321 LSA-II; 14 DAW Legacy Waste in Cask 14-210 08/27/2020

RWS20-018 UN2916 Type (B) Package; Resin Liner PO 692200-4 11/12/2020

RWS21-001 UN3321 LSA-II; Resin Liner P0695283-14 in Cask 14-215 01/12/2021

RWS21-015 UN2910 Limited Quantity of Material; Seven B-25 Boxes of 08/17/2021

CP Resin

71151 Miscellaneous NRC Performance Indicator Data; Mitigating 07/01/2020 -

Systems Mitigating System Performance Index for Heat 06/30/2021

Removal Systems

NRC Performance Indicator Data; Mitigating 07/01/2020 -

Systems Mitigating System Performance Index for 06/30/2021

Residual Heat Removal Systems

NRC Performance Indicator Data; Mitigating 07/01/2020 -

Systems Mitigating System Performance Index for 06/30/2021

Cooling Water Systems

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

LS-AA-2200 Mitigating System Performance Index Data Acquisition and 7

Reporting

71152 Corrective Action 4364058 Forced Helium Drying Skid Issue 08/19/2021

Documents 4433954 It Was Identified That Corrective Action 04364058-22 Had 07/08/2021

Been Extended Twice, In Reviewing the CA Template, the

Extensions and Their Approvals Were Not Documented

Inspection Type Designation Description or Title Revision or

Procedure Date

4434922 Level 4 Configuration Control - Received Unexpected Alarm 07/14/2021

1-2-Ec

Drawings M-66, Sheet 3A Diagram of Component Cooling Water, Units 1 and 2 AW

Miscellaneous Gap Analysis for Braidwood DCS Human Performance Error 08/18/2020

Procedures 2BwOSR Common Train Component Cooling Isolation Valve Stroke 10

5.5.8.CC-3 Surveillance

NO-AA-10 Quality Assurance Topical Report (QATR) 97

OU-MW-671-300 MPC Processing Forced Helium Dehydration (FHD) for 16

PWRS (ISFSI)

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

PI-AA-125-1004 Effectiveness Review Manual 2

2