IR 05000456/2021004
| ML22028A195 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 01/28/2022 |
| From: | Hironori Peterson Region 3 Branch 3 |
| To: | Rhoades D Exelon Generation Co |
| References | |
| IR 2021004 | |
| Download: ML22028A195 (36) | |
Text
SUBJECT:
BRAIDWOOD STATION - INTEGRATED INSPECTION REPORT 05000456/2021004 AND 05000457/2021004
Dear Mr. Rhoades:
On December 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Braidwood Station. On January 18, 2022, 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.
January 28, 2022 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, 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:
05000456/2021004 and 05000457/2021004
Enterprise Identifier:
I-2021-004-0065
Licensee:
Constellation Energy Generation, LLC
Facility:
Braidwood Station
Location:
Braceville, IL
Inspection Dates:
October 01, 2021 to December 31, 2021
Inspectors:
R. Bowen, Illinois Emergency Management Agency
J. Bozga, Senior Reactor Inspector
A. Demeter, Reactor Engineer
G. Edwards, Health Physicist
D. Kimble, Senior Resident Inspector
J. Park, Reactor Inspector
P. Smagacz, Resident Inspector
Approved By:
Hironori Peterson, Chief
Branch 3
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Braidwood Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Inadequate Tracking of Equipment Status Required by Plant Technical Specifications Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000456/2021004-02 Open/Closed
[H.4] -
Teamwork 71153 A self-revealed finding of very low safety significance and an associated non-cited violation (NCV) of Technical Specification (TS) 3.3.1, Reactor Trip System (RTS) Instrumentation, were identified when the licensee operated Braidwood Unit 1 with the reactor trip functions for both of the units source range neutron flux channels, N31 and N32, manually bypassed.
Specifically, the units source range neutron flux channels, N31 and N32, are required to be operable:
In Modes 3, 4, and 5 with the rod control system capable of rod withdrawal or with one or more rods not fully inserted; or
In Mode 2 when power is below the source range block permissive interlock.
A review of this event determined that there were several periods between April 21, 2021, and April 23, 2021, when Unit 1 was operated with source range neutron flux channels, N31 and N32, inoperable due to their reactor trip functions being manually bypassed, and in a condition prohibited by TS 3.3.1. Additionally, there were two instances of mode changes during this timeframe, into Mode 4 and again into Mode 2, that were not in accordance with TS LCO
[Limiting Condition for Operation] 3.0.4 requirements.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000456,05000457/
2021004-01 2SI8822B Cold Leg Injection Throttle Valve Cage Failure 71152 Open LER 05000456/2021-001-00 LER 2021-001-00 for Braidwood Station, Unit 1,
Train A and B Source Range Neutron Flux Trip Functions Bypassed During Plant Startup 71153 Closed LER 05000456/2021-002-00 LER 2021-002-00 for Braidwood Station, Unit 1,
Unit Trip on Generator Load Rejection Due to Lightning Strike Within the Unit Switchyard Exceeding the Capabilities of the Switchyard Grounding System 71153 Closed
PLANT STATUS
Unit 1 began the inspection period operating at full power. With the exception of planned 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 approximately 91 percent power and in power coast down for the planned end of the fuel cycle. On October 18, 2021, the unit was shut down for its planned 22nd refueling outage (A2R22). Following completion of refueling and other maintenance activities, the reactor was restarted and taken critical on November 5, 2021, and the main electrical generator was synchronized to the power grid later that same day. The unit reached full power operation on November 8, 2021, and continued operating at or near full power for the remainder 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 performed activities described in IMC 2515, Appendix D, Plant Status, conducted routine reviews using IP 71152, Problem Identification and Resolution, observed risk significant activities, and completed on-site portions of IPs. 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.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors reviewed and evaluated the station's readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures during the week ending December 25, 2021.
External Flooding Sample (IP Section 03.03) (1 Sample)
- (1) The inspectors reviewed and evaluated selected flood protection barriers, mitigation plans, procedures, and equipment to verify that they were consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding during the week ending December 4, 2021.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (2 Samples)
The inspectors reviewed and evaluated selected system configurations during partial physical alignment verifications of the following systems/trains:
- (1) The Unit 2 Residual Heat Removal (RH) system while the system was required for the decay heat removal function as a part of Refuel Outage A2R22 during the week ending October 23, 2021.
- (2) The Unit 2 Spent Fuel Pool Cooling (SFP) system while the Unit 2 reactor core was removed and residing in the SFP as a part of Refuel Outage A2R22 during the week ending October 30, 2021.
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors reviewed and evaluated system configurations during a complete physical alignment verification of the Unit 2 Containment Spray system during the weeks ending October 16 through November 6, 2021.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting physical inspections and performing reviews to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) The Unit 2 Containment, Elevations 377' and 401', Missile Shield Area as part of the A2R22 Refuel Outage during the week ending October 23, 2021.
- (2) The Unit 2 Containment, Elevation 426', Upper Area as part of the A2R22 Refuel Outage during the week ending October 23, 2021.
- (3) The Auxiliary Building, Elevation 383', General Area South during the week ending December 4, 2021.
- (4) The Auxiliary Building, Elevation 383', Unit 1 and Unit 2 Auxiliary Feedwater (AF)
Pump Diesel Rooms during the week ending December 4, 2021.
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)
The inspectors reviewed and evaluated internal flooding mitigation protections for the following areas of the station:
- (1) The Unit 2 Lower Cable Spreading Room Auxiliary Building, 439' Elevation, during the week ending December 11, 2021.
71111.08P - Inservice Inspection Activities (PWR) PWR Inservice Inspection Activities Sample (IP Section 03.01)
- (1) The inspectors verified that the reactor coolant system boundary, steam generator tubes, reactor vessel internals, risk significant piping system boundaries, and containment boundary were appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from October 18, 2021 to November 2, 2021:
03.01.a - Nondestructive Examination and Welding Activities.
Ultrasonic (UT) examination between pressurizer safety nozzle to safe end weld 2PZR-01-SE-02
UT examination between nozzle to safe end (22 degrees) weld 2RV-01-022
UT examination between safe end to nozzle (113 degrees) weld 2RV-01-024
UT examination between pressurizer to relief nozzle weld 2PZR-01-N3
UT examination between elbow to pipe weld 2MS-04-56
UT examination of reactor coolant pump main flange bolts 2RCP-01-RCP-PA-01 to 24
Liquid penetrant examination of bottom head to support skirt weld of 2RHX-01-2RHES-01
Magnetic particle examination of pressurizer support skirt attachment weld 2PZR-01-07
Pressure boundary welds 1, 1A, 2, 3, 4, and 5 fabricated during repair &
replacement of Valve 2RC8042A 03.01.b - Pressurized-Water Reactor Vessel Upper Head Penetration Examination Activities
Bare Metal Visual (BMV) examination of the RPV upper head penetrations 03.01.c - Pressurized-Water Reactor Boric Acid Corrosion Control Activities.
Boric Acid Leakage Evaluation of Component ID 2SI02PB, Issue Report (IR) 04344206
Boric Acid Leakage Evaluation and Corrective Action of Component ID 2CV239, IR 04376331
Boric Acid Leakage Evaluation and Corrective Action of Component ID 2CV8425, IR 04398552 03.01.d - Pressurized-Water Reactor Steam Generator Tube Examination Activities.
Unit 2 A, B, C, D, steam generators were examined by eddy current
There were no tubes subjected to in-situ pressure testing
Unit 2 A, B, C, D steam generators were examined visually on secondary side
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:
Selected portions of the shutdown of Unit 2 for the A2R22 Refuel Outage, during the week ending October 23, 2021.
Selected portions of the cooldown of Unit 2 for the A2R22 Refuel Outage, during the week ending October 23, 2021.
Selected portions of the Unit 2 reactor coolant system drain to reduced inventory in support of A2R22 Refuel Outage reactor vessel head lift, during the week ending October 23, 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 December 3, 2021.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure that selected structures, systems, and components (SSCs) remain capable of performing their intended functions. The following SSCs and/or maintenance activities were reviewed:
- (1) Engineering Change (EC) 632665, which is in the process of being installed on all four
- (4) of the station's EDGs to replace existing Kilovac relays with a Struthers-Dunn model for improved reliability, during the week ending December 4, 2021.
- (2) A review of the effectiveness of maintenance activities planned and performed on the Unit 2 Control Rod Drive (RD) power supplies, during the week ending December 31, 2021.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (5 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 work activities and risk associated with emergent troubleshooting and repairs to Unit 2 RD Power Cabinet 2BD, as documented in Work Order (WO)
===5195634 and IR 4452605 during the week ending October 16, 2021.
- (2) Evaluation of the work activities and risk associated with emergent troubleshooting and repairs to the Unit 2 Safety Injection (SI) system following full flow testing performance issues, as documented in IR 4454447 during the weeks ending October 23 through October 30, 2021.
- (3) Evaluation of the work activities and risk associated with Unit 2 Essential Service Water (SX) work (2A SX Strainer, as documented in WO 1752367, and 2SX002A Check Valve replacement, as documented in WO 5023104) during the week ending October 30, 2021.
- (4) Evaluation of the work activities and risk associated with emergent repairs to the Penetration 55 RD funnel on the Unit 2 reactor vessel head during Refuel Outage A2R22, as documented in WO 5199832 during the week ending October 30, 2021.
- (5) Evaluation of the work activities and risk associated with unplanned maintenance on the 2A Emergency Diesel Generator (EDG) during Refuel Outage A2R22, as documented in WO 5200200 during the week ending November 6, 2021.
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01)===
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Evaluation of the operability of Unit 2 Source Range Nuclear Instrument (SRNI) N32 following a decision to postpone a planned detector replacement activity during the A2R22 Refuel Outage, as documented in IRs 4452229 and 4448954 during the weeks ending October 23 through October 30, 2021.
- (2) Evaluation of the operability of the Unit 1 SRNIs with their high flux trips bypassed during reactor startup, as documented in IR 4418688 during the weeks ending July 1 through November 20, 2021.
- (3) Evaluation of the operability of the 1C Overpower Delta Temperature (OPDT)instrumentation channel following a spurious trip of the channel, as documented in IR 4465938 during the week ending December 18, 2021.
- (4) Evaluation of the functionality and operability of the Unit 2 Flex to AF connection isolation valves, as documented in IR 4466073 during the week ending December 18, 2021.
- (5) Evaluation of the operability of the Unit 2 RD system after receiving a non-urgent rod control failure alarm, as documented in IR 4467108 during the week ending December 25, 2021.
- (6) Evaluation of the operability of the Unit 2 SI system following issues identified as a part of full flow testing during the A2R22 Refuel Outage, as documented in IRs
===4454443 and 4454447 during the weeks ending October 23 through December 31, 2021.
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)
=
The inspectors reviewed and evaluated the following permanent changes to the facility:
- (1) EC 633170: Units 1 and 2 rod speed demand scaling correction during the weeks ending October 30 through November 6, 2021.
- (2) EC 634332: A weld overlay on the 2B Feedwater Pump discharge nozzle as a part of the A2R22 Refuel Outage during the weeks ending October 30 through November 6, 2021.
- (3) ECs 378130, 388910, 393104, and 412478: Replacement of the 2SX002A Check Valve as a part of the A2R22 Refuel Outage during the week ending November 6, 2021.
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (8 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
- (1) Functional testing of the Unit 2 RD system after emergent maintenance involving Unit 2 RD Cabinet 1BD, as documented in WO 5195634 and IR 4452605 during the week ending October 16, 2021.
- (2) Functional and operational testing of the Unit 2 AF system after maintenance during Refuel Outage A2R22, as documented in WO 1767441 during the week ending November 6, 2021.
- (3) Functional and operational testing of Unit 2 control rods after maintenance during Refuel Outage A2R22, as documented in WOs 5106805 and 5201996 during the week ending November 6, 2021.
- (4) Functional testing of the 2A EDG following work during Refuel Outage A2R22, as documented in WO 4868293 during the week ending October 30, 2021.
- (5) Low power core physics testing following reactor refueling, as documented in WOs
===5058689 and 5039073 during the week ending November 6, 2021.
- (6) Functional and operational testing of the 2A EDG following work to replace the EDG's emergency regulating circuit, as documented in WO 5200200 during the week ending November 6, 2021.
- (7) Functional and operational testing of the main steam isolation valves after maintenance activities during Refuel Outage A2R22, as documented in WO 5044103 during the week ending November 6, 2021.
- (8) Functional and operational testing of the AF system after maintenance during Refuel Outage A2R22, as documented in WOs 5044103, 5085932, 4868517, and 1737030 during the week ending November 6, 2021.
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01)===
- (1) The inspectors reviewed licensee activities and evaluated licensee performance associated with Unit 2 Refuel Outage A2R22, during the weeks ending October 17 through November 13, 2021.
71111.22 - Surveillance Testing
The inspectors reviewed and evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
(1)2BwOSR 5.5.8.AF-4A(B): Unit 2 Comprehensive Inservice Testing Requirements for 2A(B) AF Pump during the weeks ending October 16 through October 23, 2021.
(2)1/2BwOSR 3.3.2.3: Undervoltage Simulated Start of AF Pump surveillances for the 1A and 2A AF Pumps during the weeks ending December 18 through December 25, 2021.
(3)2BwOSR 3.8.1.2-2: 2B EDG Operability surveillance during the week ending December 25, 2021.
Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)
(1)2BwOSR 3.6.3.7-2: Primary Containment Type C Local Leakage Rate Tests of Containment Purge Exhaust Isolation Valves during the weeks ending October 23 through October 30, 2021.
FLEX Testing (IP Section 03.02) (1 Sample)
(1)0BwOS FX-9: Flex Pump Flow surveillance during the week ending December 11,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated instructions to workers including radiation work permits used to access high radiation areas and labeling of radioactive material in containers.
Contamination and Radioactive Material Control (IP Section 03.03) (3 Samples)
The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:
- (1) The inspectors observed workers exiting the radiological controlled area at Unit 2 during a refueling outage.
- (2) The inspectors observed licensee surveys of potentially contaminated material leaving the radiological controlled area.
- (3) The inspectors observed work area staging for inspections of steam generators in Unit 2.
Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)
The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:
- (1) The inspectors observed steam generator bowl installation and removal during the fall 2021 outage (Radiation Work Permit BW-02-21-00701 and associated ALARA documentation).
- (2) The inspectors observed seal table maintenance activities during the fall 2021 outage (Radiation Work Permit BW-02-21-00649 and associated ALARA documentation).
- (3) The inspectors observed reactor vessel head removal activities during the fall 2021 outage (Radiation Work Permit BW-02-21-00614 and associated ALARA documentation).
High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (2 Samples)
The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:
- (1) Unit 2 steam generator platforms.
- (2) Unit 2 reactor vessel head removal activities.
Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
- (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors reviewed and verified selected portions of the licensee's performance indicator submittals listed below:
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10)===
- (1) Unit 1 (August 1, 2020 through September 30, 2021)
- (2) Unit 2 (August 1, 2020 through September 30, 2021)
BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)
- (1) Unit 1 (August 1, 2020 through September 30, 2021)
- (2) Unit 2 (August 1, 2020 through September 30, 2021)
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
(1)
(August 1, 2020 through September 30, 2021)
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
(1)
(August 1, 2020 through September 30, 2021)
71152 - Problem Identification and Resolution (PI&R)
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors conducted a semiannual review of the licensees corrective action program (CAP) for potential adverse trends that might be indicative of a more significant safety concern during the weeks ending December 18 through December 31, 2021. A specific trend related to Delta T instrumentation and protection channels on Unit 1 is documented in the Results Section of this report.
Annual Follow-Up of Selected Issues (IP Section 02.03) (2 Samples)
The inspectors conducted in-depth reviews of the licensees implementation of the CAP related to the following issues:
- (1) Review and assessment of the corrective actions from Unit 2 SI full flow testing issues during Refuel Outage A2R22, as documented in IRs 445443 and 445447 during the weeks ending October 30 through December 31, 2021.
- (2) Review and assessment of the results of the Unit 2 Refuel Outage A2R22 reactor vessel head thermal sleeve measurements and ongoing licensee actions to monitor and address the condition, as documented in IR 4455790 during the weeks ending October 30 through November 6, 2021.
71153 - Follow-Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors reviewed, evaluated, and closed the following licensee event reports (LERs):
- (1) Unit 1 LER 05000456/2021-002-00, Unit Trip on Generator Load Rejection Due to Lightning Strike Within the Unit Switchyard Grounding System. (ADAMS Accession No. ML21230A030) The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER therefore no performance deficiency was identified. The inspectors reviewed the LER during the weeks ending November 20 through December 4, 2021, and determined there were no associated findings or violations.
- (2) Unit 1 LER 05000456/2021-001-00, Train A and B Source Range Neutron Flux Trip Functions Bypassed During Plant Startup. (ADAMS Accession No.
ML21172A153) The inspectors reviewed the LER during the week ending December 25, 2021. A finding of very low safety significance (Green) and an associated NCV are documented in the Results Section of this report.
INSPECTION RESULTS
Unresolved Item (Open)2SI8822B Cold Leg Injection Throttle Valve Cage Failure URI 05000456,05000457/2021004-01 71152
Description:
The inspectors performed a detailed review and assessment of the licensees corrective actions for several issues that were identified during full flow surveillance testing of the Unit 2 safety injection (SI) system during the A2R22 Refuel Outage in the fall of 2021. The inspectors reviews included, but were not limited to, the following IRs:
4454447: Failed Acceptance Criteria for 2BwOSR 5.5.8.SI-11 F.1
4454443: 03-OSP-A Evaluate Flow Balance for Unit 2 SI Cold Leg Injection
4455415: Foreign Material Recovered from 2SI8822B/C/D Throttle Valves
4183402: 2SI8810D Inspection Results FME
4455569: 2SI8822B As-Found Inspection Unsatisfactory
4455416: Foreign Material Recovered from 2CV8369A/D Throttle Valves The inspectors chose this issue for an in-depth review of the licensees actions within their CAP because of the inherent safety significance of issues involving the operability, availability, and capability of the units SI system. Consequently, for this detailed Problem Identification and Resolution inspection sample, the inspectors focused on assessment of the licensees corrective actions taken to restore the system to its full capabilities.
On October 21, 2021, as part of scheduled testing activities for the Unit 2 A2R22 Refuel Outage, the licensee performed 2BwOSR 5.5.8.SI-11, Comprehensive Inservice Testing (IST) Requirements for Unit 2 Safety Injection Pumps and Safety Injection System Check Valve Stroke Test. As discussed in IR 4454447, The total flow acceptance criteria for the test of 140 gpm was not met, with the measured value being 139.6 gpm. Additionally, criterion within 2BwOSR 5.5.8.SI-11 requires the licensee to evaluate the need for SI system flow balancing if the three lowest line flows are less than 439 gpm, and/or the difference between the highest and lowest line flows is greater than 10 gpm. In this instance, the value obtained for the three lowest line flows was 437.6 gpm, and the value obtained for the difference between the highest and lowest line flows was 13 gpm.
Due to past issues with foreign material having been introduced into the Unit 2 SI system, the licensee developed a comprehensive plan to disassemble and inspect several throttle valves within the system where tight clearances might trap foreign material in the flow stream. As discussed in IR 4455415, small amounts of foreign material were identified within the 2SI8822B, 2SI8822C, and 2SI8822D Cold Leg Injection SI Throttle Valves. As part of their corrective actions, the licensee removed the materials that were found and sent them out for laboratory analysis off site. The licensee also flushed the system thoroughly and conducted flow balancing to restore each cold leg injection flow path to its optimum value. The licensee was able to show by calculation that the small amount by which the SI system flow was found out-of-tolerance was within the existing margin for the system and did not impact the system function. The inspectors did not identify any issues with the licensees CAP actions taken for these aspects of the issue.
During disassembly and inspection of the 2SI8822B Cold Leg Injection Throttle Valve, the licensee identified that the throttle valve cage had cracked and failed. The licensee replaced the valve internals and successfully rebalanced the SI cold leg injection flows as noted above. However, the licensees follow-on analysis was not able to identify a cause or adequately explain the reasons behind the failure. Laboratory analysis of the failed internal components suggested that the valve seat ring was most probably the first component to fail, and the fracture surfaces were consistent with intergranular stress corrosion cracking and inconsistent with an overload failure.
Near the end of the inspection period, the licensee decided to commission a formal CAP causal evaluation to further look into the 2SI8822B Cold Leg Injection SI Throttle Valve cage failure.
Planned Closure Actions: The failure of the 2SI8822B Cold Leg Injection SI Throttle Valve cage is considered unresolved pending the inspectors receipt and review of the licensees formal causal evaluation. At the end of the inspection period, the licensee planned to complete this evaluation during the 1st Quarter of 2022.
Licensee Actions: No additional licensee actions are necessary at this time.
Corrective Action References:
IR 4455415: Foreign Material Recovered from 2SI8822B/C/D Throttle Valves
IR 4455569: 2SI8822B As-Found Inspection Unsatisfactory Observation: Trend in Unit 1 Overpower Delta T Issues 71152 The inspectors performed a review of plant issues, particularly those entered into the licensees CAP over the past several months. During their review, the inspectors noted an adverse trend on Unit 1 involving the performance of the units Overpower Delta T (OPDT)protection channels. Specific CAP entries reviewed by the inspectors included, but were not limited to:
- IR 4421778; Unexpected Alarms 1-10-A5 and 1-14-A1 for OPDT.
- IR 4441987; Unexpected Alarms 1-10-A5 and 1-14-A1 for 1C OPDT.
- IR 4465938; 1C OPDT Setpoint Spiked Low. Unexpected Alarms and Half-Trip.
In the first instance, documented under IR 4421778 on May 5, 2021, the 1B OPDT Channel was involved. The subsequent cases, documented under IR 4441987 on August 22, 2021, and IR 4465938 on December 10, 2021, involved the 1C OPDT Channel. In each case, a momentary downward spike in the OPDT setpoint resulted in a spurious half-trip condition within the Unit 1 solid state protection system (SSPS). Following each instance, the licensee replaced one or more cards within the Unit 1 SSPS and successfully retested and restored the affected channel to service.
The inspectors noted that while these spurious half-trip signals had not resulted in an actual plant transient to date, their continuing presence was problematic with respect to event free unit operations. The inspectors further noted that the licensee was placing an appropriate level of emphasis on this issue; shortly after the conclusion of the inspection period the licensee generated IR 4470640, Proactive Replacement of Unit 1 7300 NSA Cards, within the stations CAP to drive the replacement of certain Unit 1 SSPS cards that been identified as suspect during the extent-of-condition reviews for this issue.
The inspectors did not identify any findings or violations of NRC requirements in the course of their review.
Observation: Control Rod Drive Mechanism Thermal Sleeves 71152 The inspectors performed a detailed review of IR 4455790, A2R22 CRDM Thermal Sleeve Metrology VT-1 Exam Results.
The sample selected was associated with a 10 CFR Part 21 notification to the NRC (Westinghouse LTR-NRC-19-79, dated December 12, 2019; ADAMS Accession No.
ML19346H873) and additional information on the 10 CFR Part 21 in Nuclear Safety Advisory Letter (NSAL) NSAL-20-1, Reactor Vessel Head Control Rod Drive Mechanism Penetration Thermal Sleeve Cross-Sectional Failure, dated February 14, 2020 (ADAMS Accession No.
ML20063J583). The specific issue was associated with mechanical fatigue and fracture that leads to flange separation of thermal sleeves in the control rod drive mechanism (CRDM)penetration tubes which could have a safety consequence that was not previously considered. In addition, the sample was associated with NSAL-18-1, Thermal Sleeve Flange Wear Leads to Stuck Control Rod, dated July 9, 2018 (ADAMS Accession No.
ML18198A275). The specific issue was associated with thermal sleeve flange wear that leads to complete flange separation of the thermal sleeves which may prevent control rod insertion. PWROG-16003-P, Evaluation of Potential Thermal Sleeve Flange Wear, Revision 2, provides acceptance criteria for evaluation of thermal sleeve flange wear associated with NSAL 18-1.
The licensee performed an evaluation of the actual thermal sleeve wear measurements taken at thermal sleeve penetrations during the fall Unit 2 2021 refuel outage (A2R22). Penetration No. 55 appeared to contain a measurement discrepancy. The licensee performed a follow-up inspection on thermal sleeve Penetration No. 55 using a telescoping camera, and that inspection revealed that the funnel on the thermal sleeve had partially unscrewed by approximately 5 full revolutions. This accounted for the unusual drop measurement found during the thermal sleeve measurement inspections. Following reattachment of the funnel and reperformance of the thermal sleeve measurements on Penetration No. 55, thermal sleeve measurements taken for all penetrations were less than the NSAL-20-1 lowering criteria and the PWROG-16003-P, Revision 2, acceptance criteria. VT-1 visual examinations were performed on Penetration Nos. 8, 36, 60, 40, and 67. No recordable or relevant indications (i.e., cracking) were identified. The inspectors reviewed the evaluations and consulted with technical staff from the NRC Office of Nuclear Reactor Regulation (NRR). Based on this review, the inspectors concluded that the licensee was taking appropriate actions to monitor and address this issue. No findings or violations were identified.
Inadequate Tracking of Equipment Status Required by Plant Technical Specifications Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000456/2021004-02 Open/Closed
[H.4] -
Teamwork 71153 A self-revealed finding of very low safety significance and an associated non-cited violation (NCV) of Technical Specification (TS) 3.3.1, Reactor Trip System (RTS) Instrumentation, were identified when the licensee operated Braidwood Unit 1 with the reactor trip functions for both of the units source range neutron flux channels, N31 and N32, manually bypassed. Specifically, the units source range neutron flux channels, N31 and N32, are required to be operable:
In Modes 3, 4, and 5 with the rod control system capable of rod withdrawal or with one or more rods not fully inserted; or
In Mode 2 when power is below the source range block permissive interlock.
A review of this event determined that there were several periods between April 21, 2021, and April 23, 2021, when Unit 1 was operated with source range neutron flux channels, N31 and N32, inoperable due to their reactor trip functions being manually bypassed, and in a condition prohibited by TS 3.3.1. Additionally, there were two instances of mode changes during this timeframe, into Mode 4 and again into Mode 2, that were not in accordance with TS LCO [Limiting Condition for Operation] 3.0.4 requirements.
Description:
Unit 1 entered Refuel Outage A1R22 on April 5, 2021. Part of the scheduled outage work activities included transmission system work within the stations 345 KV switchyard, some of which had been known to cause electrical interference with a units nuclear instruments and other sensitive instrumentation. Station procedure BwOP RP-9, Disabling and Restoring Source Range Nuclear Instruments, provides procedural guidance to disable and restore source range nuclear instrument (SRNI) reactor trips and high flux at shutdown alarms, and was created, in part, to specifically address this known vulnerability.
The licensee had affixed a placard on main control room (MCR) panel 0PM03J for the 345 KV switchyard controls that read, Refer to BwOP RP-9 Prior to Switchyard Operations.
At approximately 7:24 a.m. on April 21, 2021, with Unit 1 in cold shutdown (Mode 5) and control rods not capable of being withdrawn, plant operators in the MCR received communications from the transmission system operator directing them to perform switching operations in the 345 KV switchyard. Without performing an adequate pre-job briefing or establishing clear roles and responsibilities for the activity, including responsibilities for tracking and subsequent restoration, plant operators performed the initial steps of BwOP RP-9 to defeat SRNI automatic actuations for both N31 and N32. The in-progress procedure was then returned to the Unit 1 Supervisors desk in the MCR. No formal tracking mechanism was used for the in-progress procedure, and no entries were made in the Unit 1 narrative log or degraded equipment log regarding the status of the units SRNIs.
Switching operations in the stations 345 KV switchyard were performed as directed by the transmission system operator, but BwOP RP-9 steps to restore the N31 and N32 SRNI trips and alarms were subsequently not performed due to the lack of proper formal tracking of the instruments status and the fact that no formal ownership for the completion of the BwOP RP-9 procedure had been established by the MCR crew. Later during the same shift in the MCR, the crew reached the point in their preparations for unit startup from the refueling outage where the Unit 1 rod drive system was required for scheduled surveillances to verify operability of the digital rod position indication and to perform control rod drive mechanism timing testing. At approximately 3:09 p.m. on April 21, 2021, lift disconnects for control and shutdown bank rod groups and reactor trip breakers were closed enabling control rod withdrawal. These actions met the entry conditions for TS LCO 3.3.1, Table 3.3.1-1, Function 5, which is applicable in Modes 3, 4, and 5 with control rods capable of withdrawal. With both N31 and N32 SRNI high flux reactor trip functions bypassed, TS 3.3.1, Required Action I.1, directs operators to immediately open the reactor trip breakers. This action was not completed because the MCR operations crew had lost track of the actual status of N31 and N32 and because they incorrectly assumed that the SRNIs were operable based on expected visual and audible indications.
In the evening on April 21, 2021, MCR operator turnover from dayshift to nightshift occurred with the rod control surveillance tests still in-progress. Operators conducting turnover activities failed to recognize main control board alarm annunciators on Unit 1 that indicated that the SRNI reactor trips were bypassed, as well as the SRNI level trip bypass switch positions and status lights located on the N31 and N32 instrument drawers. The rod control surveillances were completed at approximately 7:30 p.m., but the Unit 1 reactor trip breakers remained closed and control rods capable of withdrawal as the second control rod drive motor-generator set was being returned to service following emergent maintenance.
At approximately 10:21 p.m. on April 21, 2021, Unit 1 entered hot shutdown (Mode 4). With both of the units source range neutron flux channels, N31 and N32, manually bypassed and, therefore, inoperable and control rods capable of being withdrawn, this change in reactor operating mode failed to meet the requirements of TS LCO 3.0.4. Later in the same shift at approximately 1:24 a.m. on April 22, 2021, the units reactor trip breakers were opened, and control rods were no longer capable of being withdrawn. At this point, SRNI reactor trip functions were no longer required for compliance with TS 3.3.1. At approximately 3:24 a.m.
on April 22, 2021, Unit 1 entered hot standby (Mode 3). Fortuitously, since the units reactor trip breakers were open and control rods were not capable of being withdrawn, this change in reactor operating modes did meet the requirements of TS LCO 3.0.4.
In the morning on April 22, 2021, MCR operator turnover from nightshift to dayshift took place without operators noting the main control board alarm annunciators on Unit 1 that indicated that the SRNI reactor trips were bypassed, or the SRNI level trip bypass switch positions and status lights located on the N31 and N32 instrument drawers. Control rods were made capable of withdrawal at approximately 1:54 p.m. on April 22, 2021, for control rod drive system relay trip checks. This resulted in a second example of the same noncompliance with the requirements of TS 3.3.1. Unit 1 reactor trip breakers were opened at approximately 4:21 p.m. on April 22, 2021.
In the evening on April 22, 2021, MCR operator turnover from dayshift to nightshift occurred again without operators noting the main control board alarm annunciators on Unit 1 that indicated that the SRNI reactor trips were bypassed, or the SRNI level trip bypass switch positions and status lights located on the N31 and N32 instrument drawers. At approximately, 6:29 p.m. on April 22, 2021, Unit 1 reactor trip breakers were closed in order to perform rod drop time testing, leading to a third example of the same noncompliance with the requirements of TS 3.3.1. The testing concluded at approximately 10:07 p.m. on April 22, 2021, and the Unit 1 reactor trip breakers were once again opened.
In preparation for the Unit 1 reactor startup from Refuel Outage A1R22, reactor trip breakers were closed at approximately 1:22 a.m. on April 23, 2021, leading to a fourth example of the same noncompliance with the requirements of TS 3.3.1. At approximately 11:54 a.m. on April 23, 2021, Unit 1 entered startup (Mode 2). With both of the units source range neutron flux channels, N31 and N32, manually bypassed and, therefore, inoperable and control rods capable of being withdrawn, this change in reactor operating mode failed to meet the requirements of TS LCO 3.0.4. At approximately 12:16 p.m. on April 23,2021, the condition was identified by MCR personnel. Upon identification, the SRNI high neutron flux trips were immediately restored and N31 and N32 made operable.
The licensee reported this event in accordance with 10 CFR 50.73(a)(2)(v)(A), as an event or condition that could have prevented the fulfillment of the safety function of structures or systems that are needed to shut down the reactor and maintain it in a safe shutdown condition, and 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 2021-001-00, Train A and B Source Range Neutron Flux Trip Functions Bypassed During Plant Startup, on June 21, 2021, (ADAMS Accession Number ML21172A153).
Corrective Actions: Immediately following the identification of the condition, the licensee completed station procedure BwOP RP-9 to restore SRNIs N31 and N32 to an operable status. Detailed extent-of-condition physical walkdowns in the MCR and reviews for in-progress plant procedures were performed to identify any other similar issues. The licensee commissioned a full root cause investigation for the event, which prompted changes to in-progress procedure tracking, MCR shiftly and daily operator rounds, and mode change checklists. Additionally, the licensee developed and implemented a comprehensive plan to improve MCR operator standards.
Corrective Action References: 4418688; Source Range High Flux Reactor Trip Bypassed When Required; 04/24/2021.
Performance Assessment:
Performance Deficiency: Station procedure BwOP RP-9, Disabling and Restoring Source Range Nuclear Instruments, provides procedural guidance to disable and restore SRNI reactor trips and high flux at shutdown alarms. Section F.1 of this procedure provides the actions necessary to disable the disable the SRNI reactor trips and high flux at shutdown alarms, while Section F.2 provides the actions necessary to restore the SRNI reactor trips and high flux at shutdown alarms. On April 21, 2021, the MCR crew performed Section F.1, but lost track of the status of the in-progress procedure and never performed Section F.2 prior to the SRNIs being required per TS 3.3.1. The inspectors concluded that the licensees failure to have completed station procedure BwOP RP-9 as written and in a timely manner 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 Configuration Control and Human Performance attributes 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. Specifically, the inspectors determined that the licensees failure to have restored the reactor trips and high flux at shutdown alarms for SRNIs N31 and N32 in a timely manner led to multiple examples where the TS 3.3.1 Required Actions were not met or an LCO was not met prior to a mode change in accordance with TS LCO 3.0.4. The inspectors also compared the finding with the examples listed in IMC 0612, Power Reactor Inspection Reports, Appendix E, Example of Minor Issues. Example 4.k was found to be similar in that the performance deficiency adversely affected Mitigating Systems Cornerstone of Reactor Safety objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power, and IMC 0609, Appendix G, Shutdown Operations Significance Determination Process. This event began on April 21, 2021, with Unit 1 in cold shutdown (Mode 5). It concluded on April 23, 2021, when Unit 1 was in startup (Mode 2). As a result, the inspectors determined that both IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, and IMC 0609, Appendix G, Shutdown Operations Significance Determination Process, were applicable for parts of the event, and that assistance from the NRC Region III Senior Reactor Analyst (SRA) was required in order to properly characterize the findings significance.
Starting with the portion of the event that occurred with Unit 1 in startup (Mode 2), the inspectors using IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, were able to answer no to all questions and determined that the significance of the finding was indicative of being of very low safety significance (Green). More specifically, the inspectors, in consultation with the NRC Region III SRA, concluded that probabilistic risk assessment (PRA) functionality of the Unit 1 reactor protection system had not been lost with Unit 1 in Mode 2 because the power range high neutron flux reactor trip (low setting) was available and provided redundant protection to that afforded by the N31 and N32 SRNI high flux reactor trip function.
For the portions of the event that occurred with Unit 1 in Modes 3 through 5, however, the inspectors found that there was a loss of PRA functionality of the Unit 1 reactor protection system, as the power range nuclear instruments (PRNIs) are incapable of detecting neutron power levels in this range. Using IMC 0609, Appendix G, Shutdown Operations Significance Determination Process, the inspectors and the NRC Region III SRA subsequently concluded that the event was of very low safety significance (Green) based on the following:
For the uncontrolled rod withdrawal casualty, despite the fact that the SRNI high flux reactor trip functions from N31 and N32 are credited in the stations updated final safety analysis report (UFSAR) for providing protection for the event, the probability of such an event remained highly unlikely. A review by the inspectors of the required and actual reactor coolant system (RCS) boron concentration for the time in question (from 2:00 a.m. on April 21, 2021, to noon on April 23, 2021) confirmed that RCS boron concentration remain above the minimum required to prevent criticality, even with a full bank of control rods being fully withdrawn.
For the inadvertent boron dilution event, which is a slower reactivity addition event than the uncontrolled rod withdrawal event, operator action is credited for responding to and mitigating the event. A review by the inspectors concluded that there were multiple redundant indications that remained available to alert plant operators to such a potential dilution, and thus, initiate the required operator response.
Cross-Cutting Aspect: H.4 - Teamwork: Individuals and work groups communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety is maintained. Specifically, this event illustrated multiple missed opportunities (e.g.,
crew turnovers, MCR board walkdowns, log reviews, etc.) for operators in the MCR to have more rapidly identified the error responsible for the event.
Enforcement:
Violation: Technical Specification (TS) 3.3.1, Reactor Trip System (RTS) Instrumentation, requires that a units source range neutron flux channels, N31 and N32, are operable:
In Modes 3, 4, and 5 with the rod control system capable of rod withdrawal or with one or more rods not fully inserted; or
In Mode 2 when power is below the source range block permissive interlock.
Further, TS LCO 3.0.4 states, in part, that:
When an LCO is not met, entry into a Mode or other specified condition in the Applicability shall only be made:
1. When the associated ACTIONS to be entered permit continued operation in the
MODE or other specified condition in the Applicability for an unlimited period of time;
2. After performance of a risk assessment addressing inoperable systems and
components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate (exceptions to this Specification are stated in the individual Specifications); or
3. When an allowance is stated in the individual value, parameter, or other Specification.
Contrary to these requirements, from April 21, 2021, through April 23, 2021, there were multiple instances where the licensee operated Unit 1 in Mode 2 with power below the source range block permissive interlock, and in Modes 3, 4, and 5 with the rod control system capable of rod withdrawal, while the units source range neutron flux channels, N31 and N32, were inoperable; and there were two instances where Mode changes were performed by the licensee under these conditions.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Observation: LER 05000456/2021-002-00: Unit Trip on Generator Load Rejection Due to Lightning Strike Within the Unit Switchyard Exceeding the Capabilities of the Switchyard Grounding System 71153 The inspectors performed a detailed review of the licensees root cause evaluation associated with IR 4430441, Braidwood Unit 1 Reactor Trip on Generator Load Rejection.
On June 21, 2021, at 12:51 a.m., Braidwood Unit 1 experienced turbine and reactor trips preceded by a main electrical generator load reject. The cause of the main generator load reject was not initially known by plant operators, who successfully completed the Unit 1 shut down in accordance with plant procedures. Following the event, plant personnel began an investigation into the cause of the event. Through a review of various data recorded on both station recorders and the equipment of the transmission system owner (ComEd), plant technical personnel were able to determine the cause of the event.
A thunderstorm in the area produced a lightning strike within the stations switchyard at the exact time of the main electrical generator load reject. The root cause of the load rejection was determined to have been this lightning strike within the stations switchyard, which exceeded the capabilities of the switchyard grounding system. The lightning strike resulted in and induced voltage on the 125 Volts - direct current (Vdc) load rejection circuit for the Unit 1 generator output breakers, which resulted in both breakers opening.
The licensee determined that station equipment operated as designed to prevent a nuclear safety impact and/or equipment damage from the lightning strike. Licensee inspections of the switchyard grounding system confirmed that it was not degraded. However, the system was not designed to be able to fully handle a direct lightning strike of the magnitude that was seen. The national average magnitude for a lightning strike is approximately 30 kiloamps (kA); the lightning strike during this event was approximately 98 kA, or over three times the national average, as measured by the switchyard data recording systems.
The inspectors did not identify any issues with the licensees actions taken in response to this event. No findings or violations of NRC requirements 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 January 18, 2022, the inspectors presented the integrated inspection results to Mr. J. Keenan, Site Vice President, and other members of the licensee staff.
On October 22, 2021, the inspectors presented the radiation protection inspection results to Mr. J. Keenan, Site Vice President, and other members of the licensee staff.
On November 2, 2021, the inspectors presented the Braidwood Unit 2 ISI inspection results to Mr. J. Keenan, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
4467447
FLEX Building Unavailable >72 Hours Due to Offsite Power
2/18/2021
Miscellaneous
Letter from Mr. John Keenan to Mr. Shane Marik; 2022
Winter Readiness Certification
11/15/2021
0BwOS XFT-A1
Unit Common Freezing Temperature Equipment Protection
Surveillance
0BwOS XFT-A2a
Unit Common Station Heat Area Heaters Freezing
Temperature Equipment Protection Surveillance
0BwOS XFT-A2b
Unit Common Station Heat Area Heaters Freezing
Temperature Equipment Protection Surveillance
0BwOS XFT-A3
Unit Common Cold Weather Surveillance
0BwOS XFT-A4
Unit Common Freezing Temperature Equipment Protection
Inside Surveillance
BwOP SI-10
RWST Heating Pump and Heater Operations
Procedures
CC-BR-118-1001
Site Implementation of Diverse and Flexible Coping
Strategies (FLEX) and Spent Fuel Pool Instrumentation
Program
212516
0FC8754 is Broken and Will not Operate
01/20/2019
284038
0FC8754 Handwheel Degraded Due to Vibration
10/01/2019
4353919
2CS01PA ASME Lost Surveillance Paperwork
06/30/2020
4361554
2A CS Pump DP Tracking EDG Uncertainties
08/06/2020
4364030
2A CS Pump Seal and Shaft Coupling has Boric Acid
Buildup
08/19/2020
4418729
0FC8754 High Vibrations in Area
04/24/2021
Corrective Action
Documents
4436483
0FC8754 Valve Handwheel Operator Detached
07/22/2021
M-129 Sheet 1A
Diagram of Containment Spray
M-129 Sheet 1B
Diagram of Containment Spray
AX
M-129 Sheet 1C
Diagram of Containment Spray
M-2129 Sheet 1
P&ID/D&I Diagrams Containment Spray System
L
M-2129 Sheet 2
P&ID/C&I Diagrams Containment Spray System
L
M-2129 Sheet 4
P&ID/C&I Diagrams Containment Spray System
D
Drawings
M-2129 Sheet 5
P&ID/C&I Diagrams Containment Spray System
C
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Bw-OP FC-M2
Operating Mechanical Lineup Unit 2
BwOP CS-E2
Electrical Lineup Unit 2
BwOP CS-M2
Operating Mechanical Lineup Unit 2
BwOP FC-E1
Electrical Lineup Unit 1
BwOP FC-E2
Electrical Lineup Unit 2
BwOP FC-M1
Operating Mechanical Lineup Unit 1
BwOP RH-6
Placing the RH System in Shutdown Cooling
Procedures
BwOP RH-M3
Operating Mechanical Lineup Unit 2 2A RH Train
BwAP 1110-1
Fire Protection Program System Requirements
BwAP 1110-3
Plant Barrier Impairment Program
BwOP PBI-1
Plant Barrier Impairment Program Pre-Evaluated Barrier
Matrix
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
Control of Transient Combustible Material
Procedures
OP-AA-201-012-
1001
Operations On-Line Fire Risk Management
Auxiliary Building Flood Level Calculation
Calculations
Confirmation of Safe Shutdown Capability After Auxiliary
Building Flooding
Corrective Action
Documents
4447598
Floor Drain Overflowing in Unit 2 Cable Spreading Room
09/20/2021
Miscellaneous
BB-PRA-012
Byron and Braidwood Probabilistic Risk Assessment,
Internal Flood Evaluation Summary Notebook
0BwOA PRI-8
Auxiliary Building Flooding Unit 0
Procedures
Structures Monitoring
4344206
2SI01PB Active Leakage from Gasket
05/18/2020
4376331
2CV239, Pen 41 377'+14' Unit 2 CNMT
10/13/2020
4397547
Previous IWL Sample Sizes not IAW ASME IWL Code
Requirements
01/22/2021
Corrective Action
Documents
4398552
2CV8425 Diaphragm Leak
01/28/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
4454677
Action Plan to Address Unit 2 Rx Head Residues
10/21/2021
4455474
Change in 2B SG Steam Drum Degradation (A2R22)
10/25/2021
4455917
Eddy Current Indication in SG B During A2R22
10/26/2021
4456449
Foreign Object Found In 2D SG Secondary Side - A2R22
10/28/2021
4456561
FME: Foreign Object Found In 2B SG Secondary Side -
A2R22
10/28/2021
618744
A2R19 Condition Monitoring and Operational Assessment
(CMOA) (Including the Foreign Object Evaluation) Unit 2
634787
A2R22 Steam Generator Degradation Assessment
Engineering
Changes
635377
2RC01R Upper Head Primer Coating Delamination
Resulting in Spotting on Surface
1-51A
Procedure Qualification Record
2/28/1983
4-51A
Procedure Qualification Record
09/12/1986
Procedure Qualification Record
2/08/2000
Procedure Qualification Record
2/08/2000
AIM 200310778-
2-2
Braidwood Unit 2 Operational Assessment Addressing
Deferment of A2R21 Steam Generator Tube Examination to
A2R22, October 2021
04/15/2020
LTR-CDMP-21-
Evaluation of Condition Monitoring and in Situ Screening of
PWSCC Located in SG-B at R1C25 U-Bend at Braidwood
Unit 2
MRS-TRC-2374
Site Validation of EPRI Appendix H / Appendix I Techniques
10/21/2021
QR-20-164-04
Certified Material Test Report for Tube Plugs
10/06/2021
Miscellaneous
SGP-PLG-RIB-
Mechanical Ribbed Plugging of Steam Generator Tubes
4.1
Pressurizer Support Skirt Attachment Weld 2PZR-01-07
10/25/2021
Pressurizer to Relief Nozzle Weld 2PZR-01-N3
10/24/2021
2PZR-01-SE-02 (Pressurizer Safety Nozzle - Safe End
Weld)
10/23/2021
Bare Metal Visual Examination of Reactor Pressure Vessel
Head
10/28/2021
NDE Reports
WN22-01
2RV-01-022 Nozzle to Safe End (22 Degrees) Weld
10/25/2021
Procedures
Magnetic Particle (MT) Examination
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Ultrasonic Examination of Weld Overlaid Similar and
Bare Metal Visual Examination for Nickel Alloy Materials
Byron/Braidwood Unit 2: Steam Generator Eddy Current
Activities
Conduct of Steam Generator Management Program
Activities
PDI-UT-8
Generic Procedure for the Ultrasonic Examination of Weld
Overlaid Similar and Dissimilar Metal Welds
I
SGP-PLG-RIB-
PS-GEN
Steam Generator Tube Plugging Procedure Specification for
Expanded Ribbed Mechanical Plugs
WDI-STD-1165
Automated Ultrasonic Examination of the Remote Inservice
Inspection of Reactor Vessel Nozzle to Safe End, Nozzle to
Pipe, and Safe End to Pipe Welds Using the Athena Phased
Array System
WPS 8-8-GTSM
ASME Welding Procedure Specification Record
05032066-01
CM - 2RC8042A Replace Valve
04/28/2020
Work Orders
05120762-01
FNM Repair 2CV8425 Diaphragm Leak
01/29/2021
Procedures
TQ-BR-201-0113
Braidwood Training Department Simulator Examination
Security Actions
OP-AA-101-111-
1001
Operations Standards and Expectations
Operator Fundamentals
OP-AA-101-113-
1006
4.0 Crew Critique Guidelines
Watch-Standing Practices
OP-AA-103-102-
1001
Strategies for Successful Transient Mitigation
Operation of Plant Equipment
Communications
Operating Narrative Logs and Records
Reactivity Management
Systematic Approach to Training Process Description
Procedures
Operator Training Programs
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Conduct of Simulator Training and Evaluation
Examination Security and Administration
Simulator Management
4467108
Unexpected Annunciator 2-10-D6 Rod Control Non-Urgent
Failure
2/16/2021
Corrective Action
Documents
4468189
Reflash of Unit 2 Rod Control Non-Urgent Failure Alarm
2-10-D6
2/23/2021
Engineering
Changes
2665
Diesel Generator (DG) Kilovac Relay Replacement with
Struthers-Dunn Model (Units 1 and 2)
Maintenance Rule Functions Safety Significant
Classification
Maintenance Rule Implementation per NEI 18-10
Maintenance Rule 18-10 Scoping
Maintenance Rule 18-10 Failure Definitions
Procedures
Maintenance Rule 18-10 Performance Monitoring and
Dispositioning Between (a)(1) and (a)(2)
4452605
Received Unexpected Alarm 2-10-C6 Rod Control Urgent
Failure
10/13/2021
4454443
03-OSP-A Evaluate Flow Balance for U2 Cold Leg Injection
11/20/2021
4454447
Failed Acceptance Criteria for 2BwOSR 5.5.8.SI-11 F.1
10/21/2021
4455090
A2R22 Expanded Scope on 2SX216A
10/23/2021
4455696
2SX174 Dis/Insp PM Requires Additional Isolation
10/26/2021
4456393
10-OSP-A: 2A Diesel Generator Suspected Relay Failure
4EX3
10/28/2021
4456459
11-OSP-R: 2A EDG No PI Parameters
10/28/2021
4456705
11-OSP-A: 2A Diesel Generator Relay 4EX1 Not Making Full
Contact
10/28/2021
Corrective Action
Documents
4456769
11-OSP-A: 2A Diesel Generator Manually Tripped During
Testing
10/29/2021
Engineering
Changes
619607
Alternative Weld Detail for CRDM Guide Funnel
BwAR 2-10-C6
Rod Control Urgent Failure
Procedures
Fuse Control
Revision 11
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CC-BR-206-1000
Fuse Replacement
Risk Management
On-Line Risk Management
Conduct of Troubleshooting
Integrated Risk Management
Protected Equipment Program
Outage Risk Management
On-Line Risk Management and Assessment
1752367
Overhaul SX Strainer
10/22/2021
23104
Replace 36" Check Valve 2SX002A With a Replacement
Valve
10/22/2021
5195634
FNE Replace Fuse 1BD in Panel 2RD05J
10/13/2021
Work Orders
5199832
Control Rod Drive System Funnel at Penetration No. 55
Almost Disengaged from Head
10/28/2021
4448954
Work Request Needed for Source Range Unit 2 N32
09/27/2021
4452229
As-Found Condition of 2N-NR08032 Replacement Detector
10/11/2021
44544443
03-OSP-A Evaluate Flow Balance for U2 SI Cold Leg
Injection
11/20/2021
4454447
Failed Acceptance Criteria for 2BwOSR 5.5.8SI-11 F.1
10/21/2021
Corrective Action
Documents
4467108
Unexpected Annunciator 2-10-D6 Rod Control Non-Urgent
Failure
2/16/2021
25953
Evaluation of A2R20 SI and CV Flow Balance Results in
Support of TRM TSR 2.5.C.2 and TSR 2.5.C.3
Engineering
Changes
631476
ECCS Performance Analysis of SI Hot Leg Flow Deviation in
A2R21 Documentation of Review of Potentially Affected
Analyses
2BwOSR
5.5.8.SI-11
Comprehensive Testing (IST) Requirements for Unit 2
Safety Injection Pumps and Safety Injection System Check
Valve Stroke Test
Engineering Technical Evaluations
Risk Management Documentation
Procedures
OP-AA-106-101-
1006
Operational Decision-Making Process
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Adverse Condition Monitoring and Contingency Planning
Operability Determinations (CM-1)
4649122
OP Safety Injection Cold Leg Check Valve Test
2BwOSR 5.5.8.SI-11
10/10/2021
Work Orders
4840548
Flow Change During 2BwOSR 5.5.8.SI-11
10/13/2018
633170
Unit 1 & 2 Rod Speed Demand Scaling Correction
Engineering
Changes
634332
Perform Weld Overlay for 2B FW Pump Discharge Nozzle
Pup
5106805
Install EC 633170 Unit 2 Rod Speed Demand Scaling
Correction
11/03/2021
Work Orders
5111397
2FW78AB-20" A2R22 Capital FAC Piping Replacement
10/23/2021
4458162
2B AF Pump Air Box did not Trip When Expected
11/02/2021
4458258
2AF01PB Diesel Engine
11/03/2021
Corrective Action
Documents
4458282
AF Diesel Air Box Solenoid Replacement PM Testing
UNSAT
10/22/2021
2BwOSR 3.1.6.1
Unit Two ECC Above Control Rod Insertion Limit Startup
Surveillance
2BwOSR
3.6.3.5.AF-1A
Unit Two Train A Auxiliary Feedwater Valve Stroke
Surveillance
2BwOSR 3.7.2.1
Main Steam Isolation Valve Full Stroke Surveillance
2BwOSR
5.5.8.AF-3B
Group A IST Requirements for Unit Two Diesel Driven
Auxiliary Feedwater Pump
BwHS 900-35
Diesel Generator Governor Set-Up Following Governor
Replacement
BwMP 3305-003
Main Steam Safety Valve Testing Using Setpoint Verification
Device
BwOP DG-11
Diesel Generator Startup and Operation
BwOS DG-2
2A Diesel Generator Overspeed Trip Test
BwVS 500-6
Low Power Physics Test Program
Procedures
ER-AA-335-025-
2013
VT-2 Visual Examination in Accordance with ASME 2013
Edition
1737030
Replace Manual Setpoint Control Station
11/03/2021
Work Orders
176441
Very Low Flow Identified in 2A AB Tell-Tale Drain Sightglass
11/01/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
4635735
2AF006A Replace Actuator with Rebuilt Spare
10/24/2021
4868517
OP PMT - 2AF-14E - 2BwOSR 3.7.5.7-2 (Flow) and Leak
Check
11/02/2021
5039073
Low Power Physics Test Program with Dynamic Rod Worth
Measurement
11/04/2021
5044103
OP Train B AF Flowpath Operability Following Cold
Shutdown
11/02/2021
5044113
IST-2MS001A-D-MSIV Full Stroke
10/18/2021
5058689
Reload Startup Physics Testing Following Refueling
10/20/2021
5085932
LR - OP PMT - 2B AF Pump - Functional Run (ASME)
11/02/2021
5106805
Install EC 633170 Unit 2 Rod Speed Demand Scaling
Correction
11/03/2021
2BwGP 100-1
Plant Heat up
2BwGP 100-2
Plant Startup
2BwGP 100-3
Power Ascension 5% to 100%
2BwGP 100-4
Power Descension
2BwGP 100-5
Plant Shutdown and Cooldown
2BwGP 100-6
Refueling Outage
2BwOS TRM
2.5.b.1
Unit Two - Containment Loose Debris Inspection
BwAP 1450-1
Access to Containment
BwVS TRM
3.1.h.1
Core Reload Sequence and Verification
Shutdown Risk Management
Pre-Job Briefings
Fatigue Management and Work Hour Rules
MA-AA-716-008-
1008
Reactor Services: Refuel Floor FME Plan
Unit Restart Review
OP-AA-108-108-
1001
Drywell/Containment Closeout
Evaluation of Special Tests or Evolutions
Procedures
Reactivity Management - Fuel Handling, Storage, and
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Refueling
Shutdown Safety Management Program
Shutdown Safety Plan Independent Review
2BwOSR 3.6.3.7-
Primary Containment Type C Local Leakage Rate Tests of
Containment Purge Exhaust Isolation Valves (VQ)
2BwOSR
5.5.8.AG-4A
Unit Two Comprehensive Inservice Testing (IST)
Requirements for 2A Auxiliary Feedwater Pump
Procedures
BwOP PC-1
Local Leak Rate Flowmeter Monitor Operation
5034477
IST-US Full Flow Test and Equipment Response Time of
Aux FW Pumps
10/15/2021
Work Orders
5036717
IST-LT 2VQ002A/B-PRI Containment Type C LLRT of
Containment Purge
10/07/2021
04439827
Radwaste ARGOS Needs Repair
08/10/2021
Corrective Action
Documents
Plant Shadow Shield Extensions Late
09/22/2021
Procedures
Access Control
for High Radiation
Areas
NISP-RP-005
BW-02-21-00614
Remove/Reinstall Reactor Head/Upper Internals/Flange
Inspection
BW-02-21-00649
Seal Table Room Work
Radiation Work
Permits (RWPs)
BW-02-21-00701
S/G Bowl Drain Installation Removal
AR 04291875-01
Control of Radioactive Material
11/30/2020
Self-Assessments
AR 4291877-01
Contamination Control Self-Assessment
11/30/2020
Monthly Data Elements for NRC Radiological Effluent
Technical Specifications/Offsite Dose Calculation Manual
Radiological Effluent Occurrences (RETS/ODCM)
Radiological Effluent Occurrences Sample (08/01/2020 -
09/31/2021)
08/01/2020 -
09/31/2021
Monthly Data Elements for NRC Reactor Coolant System
(RCS) Specific Activity (08/01/2020 - 09/31/2021)
08/01/2020 -
09/31/2021
Miscellaneous
Monthly Data Elements for NRC Occupational Exposure
Control Effectiveness Sample (08/01/2020 - 09/31/2021)
08/01/2020 -
09/31/2021
71151
Procedures
2BwOSR
5.5.8.AF-4B
Unit Two Comprehensive Inservice Testing (IST)
Requirements for 2B Auxiliary Feedwater Pump
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Collecting and Reporting of NRC Performance Indicator
Data
Monthly Data Elements for NRC Reactor Coolant System
(RCS) Leakage
4183402
2SI8810D Inspection Results FME
10/14/2018
21778
Unexpected Alarms 1-10-A5 and 1-14-A1 for OPDT
05/05/2021
4441987
Unexpected Alarms 1-10-A5 and 1-14-A1 for 1C OPDT
08/22/2021
4455415
Foreign Material Recovered from 2SI8822B/C/D Throttle
Valves
10/25/2021
4455569
2SI8822B As-Found Inspection Unsatisfactory
10/25/2021
4455790
10-OSP-A A2R22 CRDM Thermal Sleeve Metrology VT-1
Exam Results
10/26/2021
4455790
A2R22 CRDM Thermal Sleeve Metrology and VT-1 Exam
Results
10/23/2021
4465938
1C OPDT Setpoint Spiked Low; Unexpected Alarms and
Half-Trip
2/10/2021
Corrective Action
Documents
4470640
Proactive Replacement of Unit 1 7300 NSA Cards
01/07/2022
Corrective Action
Documents
Resulting from
Inspection
4455416
Foreign Material Recovered from 2CV8369A/D Throttle
Valves
10/25/2021
Miscellaneous
Document No.
2-9338475-000
Braidwood Unit 2 CRDM Thermal Sleeve As-Found
Dimensional Report
NDE Reports
180-9338670-000
Braidwood Unit 2 2R22 Thermal Sleeve ID Examination
Quality Assurance Topical Report (QATR)
Issue Identification and Screening Process
Corrective Action Program (CAP) Procedure
Root Cause Analysis Manual
Corrective Action Program Evaluation Manual
Procedures
Effectiveness Review Manual
4418688
Source Range Nuclear Instruments Bypassed
04/24/2021
21307
4.0 Critique for A1R22 Start-Up
05/04/2021
Corrective Action
Documents
4430406
Multiple MCR Alarms Received Due to Adverse Weather
06/20/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
4430440
Indication Lost for 1MS-147A Following Unit 1 Reactor Trip
06/21/2021
4430441
Unit 1 Reactor Trip - Load Reject
06/21/2021
4430442
Unexpected Annunciator: 1-4-D5
06/21/2021
4430444
1A/D MSIV Room Fire Alarm Following Reactor Trip
06/21/2021
4430446
N35 and N36 Appear to be Undercompensated
06/21/2021
4430586
4.0 Critique Unit 1 Reactor Trip Due to Generator Load
Reject
06/21/2021
4430895
Need WO Generated for Testing Station Site Grounding
System
06/22/2021
4432865
Braidwood Site Ground Testing
07/01/2021
Engineering
Changes
DIT-BRW-2021-
0009
A1R22 Reactor Coolant System Boron Samples
06/07/2021
Operations
Standing Order
No.21-002
Actions to Ensure Operational Excellence Following A1R22
04/23/2021
Miscellaneous
Operations
Standing Order
No.21-003
Actions to Refocus on Operating Fundamentals
04/24/2021
BwAR 1-10-D1
Source Range Trip Bypassed
51E1
BwOP RP-9
Disabling and Restoring Source Range Nuclear Instruments
Procedures
Pre-Job Briefings
14