IR 05000456/2022001

Integrated Inspection Report 05000456/2022001 and 05000457/2022001

ML22119A206
Person / Time
Site:	Braidwood
Issue date:	05/03/2022
From:	Hironori Peterson Region 3 Branch 3
To:	Rhoades D Constellation Energy Generation
References
IR 2022001
Download: ML22119A206 (22)

Text

May 3, 2022

SUBJECT:

BRAIDWOOD STATION - INTEGRATED INSPECTION REPORT 05000456/2022001 AND 05000457/2022001

Dear Mr. Rhoades:

On March 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Braidwood Station. On April 8, 2022, the NRC inspectors discussed the results of this inspection with Mr. G. Gugle, Acting Site Vice President and other members of your staff. The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Braidwood Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Braidwood Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Signed by Peterson, Hironori on 05/03/22 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: 05000456/2022001 and 05000457/2022001 Enterprise Identifier: I-2022-001-0057 Licensee: Constellation Energy Generation, LLC Facility: Braidwood Station Location: Braceville, IL Inspection Dates: January 01, 2022 to March 31, 2022 Inspectors: R. Bowen, Illinois Emergency Management Agency D. Kimble, Senior Resident Inspector J. Masse, General Engineer NRAN N. Shah, Senior 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

Inadequate Work Instructions for Disassembly/Reassembly of Safety Injection (SI) Cold Leg Throttle Valve Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.1] - 71152A Systems NCV 05000457/2022001-01 Resources Open/Closed A self-revealed finding of very low safety significance (i.e., Green) and an associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, were identified for the licensees failure to include adequate detail within their maintenance work instructions for the disassembly/reassembly of 2SI8822B, Safety Injection System Copes-Vulcan Throttle Valve to 2B Reactor Coolant System (RCS) Cold Leg.

Specifically, work instructions provided by the licensee under safety-related Work Order (WO)4840548-02, Flow Change During 2BwOSR 5.5.8.SI-11: MVR - 2SI8822B, Disassemble /

Inspect / Repair Valve: 2SI8822B, during Unit 2 Refuel Outage A2R20 in October of 2018 contained less than adequate instructions for reassembly of the valve internals, such that valve internals were installed upside down within the valve body during reassembly.

Operation of the valve in this condition ultimately placed abnormal stress on the valve internals, causing the internals to crack in several locations. This condition was subsequently revealed when the licensee opened the 2SI8822B valve again for inspection during the most recent A2R22 Refuel Outage in October 2021.

Additional Tracking Items

Type Issue Number Title Report Section Status URI 05000456,05000457/20 2SI8822B Cold Leg Injection 71152S Closed 21004-01 Throttle Valve Cage Failure

PLANT STATUS

Unit 1 and Unit 2 began the inspection period operating at full power. With the exception of short duration reductions in power to support scheduled testing activities and load changes requested by the transmission system dispatcher, both units remained operating at or near full power for the entire inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors 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.

71111.01 - Adverse Weather Protection

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

(1) The inspectors evaluated the adequacy of the overall preparations to protect risk significant systems from an impending snowstorm during the week ending February 5, 2022.

71111.04 - Equipment Alignment

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

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

(1) The 1B and 2A Station Air Compressors (SACs) while protected and in standby following a trip of the 1A SAC and the failure of the Unit 2 SAC to start and run on demand, during the week ending January 29, 2022.

(2) The Unit 2 Containment Spray (CS) Train while protected during planned 2B CS Train maintenance, during the week ending February 12, 2022.

(3) The 2A Emergency Diesel Generator (EDG) while protected during emergent 2B EDG corrective maintenance, during the week ending March 26, 2022.

(4) The 1B Safety Injection (SI) Train during 1A SI Train maintenance, during the week ending April 2, 2022.

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

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

(1) The Unit 1 Auxiliary Feedwater (AF) system, during the weeks ending March 12 through March 31, 2022

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) Fire Zone 12.1-0; Fuel Handling Building, 426' and 401' Elevations, during the week ending February 19, 2022

(2) Fire Zones 9.1-1 and 9.4-1; Turbine Building, 401' Elevation, 1B EDG, during the week ending March 12, 2022

(3) Fire Zone 11.1B-0; Auxiliary Building, 330' Elevation, 1B/2B Essential Service Water (SX) Pump Room, during the week ending March 26, 2022

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

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

(1) Observation of announced and unannounced fire drills with multiple crews on March 10, 2022

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:

Unit 1 power maneuvering in response to the system transmission dispatcher, during the week ending January 29, 2022.

Response to station and instrument air system transients, including trips on multiple SACs, during the week ending January 29, 2022.

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 February 24, 2022

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Maintenance effectiveness review of the Unit 1 and 2 EDG starting air systems, during the weeks ending March 12 through March 31, 2022

(2) Maintenance effectiveness review of Unit 1 and 2 Copes Vulcan manual throttle valves within the station's emergency core cooling systems, during the weeks ending March 12 through March 31, 2022

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) Review and evaluation of the risk associated with emergent work activities for the Unit 2 Control Rod Drive 2BD Power Supply Cabinet, as documented in Issue Reports (IRs) 4467108 and 4468189, during the week ending January 29, 2022

(2) Evaluation of the emergent work associated with the 2C Circulating Water Pump that required the pump to be secured with the unit operating power, as documented in WOs 5206556 and 4639101, during the week ending March 5, 2022

(3) Evaluation of the emergent work associated with the Unit 1 Westinghouse Ovation' digital control system, as documented in WO 5236261, during the weeks ending March 5 through March 12, 2022

(4) Evaluation of the emergent work associated with the 2S-47 Fire Protection Zone Alarm and CO2 Actuation/Suppression system, as documented in WO 4944490, during the week ending March 12, 2022

(5) Evaluation of the emergent jacket water cooling system repairs on the 2B EDG, as documented in WO 5240543, during the weeks ending March 19 through March 26, 2022.

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (7 Samples)

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

(1) Evaluation of the operability of the 1A EDG following receipt of a 1A EDG Trouble Alarm, as documented in IR 4468690, during the week ending January 15, 2022

(2) Evaluation of the operability of the 1B SX system following identification of a degraded cubicle cooler valve, as documented in IR 4472535, during the week ending January 22, 2022

(3) Evaluation of the operability of the 1RE9159A Containment Isolation Valve following identification of anomalous closing time, as documented in IR 4473614, during the week ending January 29, 2022

(4) Evaluation of the operability of the 2B EDG following identification of a jacket water leak, as documented in IR 4472544, during the weeks ending February 12 through March 19, 2022

(5) Evaluation of the operability of the Unit 2 N43 Power Range Nuclear Instrument following identification of an anomalous voltage reading during routine surveillance testing, as documented in IR 4480091, during the week ending February 26, 2022

(6) Evaluation of the operability of the RCS pressure boundary following identification of boric acid near 1CV050D in containment, as documented in IR 4482584, during the weeks ending March 12 through March 31, 2022

(7) Evaluation of the operability of the core exit thermocouples, as documented in IR 4484367, during the weeks ending March 19 through March 31, 2022

71111.19 - Post-Maintenance Testing

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

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

(1) Functional and operational testing of the Unit 2 SAC following overhaul and repairs after mechanical failure, as documented in WO 4858793, during the weeks ending February 19 through February 26, 2022

(2) Functional and operational testing of the 1B Component Cooling Water Pump following replacement of the pump's 4 KV circuit breaker, as documented in WO 4870082, during the week ending March 19, 2022

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance testing activities:

Surveillance Tests (other) (IP Section 03.01)

(1) 1BwOSR 3.8.1.2-2: EDG Operability Surveillance, as documented in WO 5214083, during the week ending January 15, 2022

(2) 1BwOSR 3.7.5.4-2: Unit 1 Diesel Driven Auxiliary Feedwater Pump Surveillance, as documented in WO 5225008, during the weeks ending February 12 through

February 19, 2022 Inservice Testing (IP Section 03.01) (1 Sample)

(1) 1BwOSR 5.5.8.RH-5A: Group A Inservice Testing (IST) Requirements for Residual Heat Removal Pump 1RH01PA, as documented in WO 5230274, during the week ending March 31, 2022

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

(1) Review of Unit 1 RCS leakage surveillance data, as documented in IRs 4461023,

===4468523, 4475005, and 4475753, during the week ending February 5, 2022

71114.06 - Drill Evaluation

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

=

The inspectors evaluated site's emergency plan by observing the following emergency response organization (ERO) activities:

(1) A site-wide emergency preparedness drill performed on January 25,

OTHER ACTIVITIES - BASELINE

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

IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) ===

(1) Unit 1 (January 1, 2021 through December 31, 2021)

(2) Unit 2 (January 1, 2021 through December 31, 2021)

IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02)

(2 Samples)

(1) Unit 1 (January 1, 2021 through December 31, 2021)

(2) Unit 2 (January 1, 2021 through December 31, 2021)

IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (2 Samples)

(1) Unit 1 (January 1, 2021 through December 31, 2021)

(2) Unit 2 (January 1, 2021 through December 31, 2021)

71152A - Annual Follow-Up Problem Identification and Resolution Annual Follow-Up of Selected Issues (Section 03.03)

The inspectors conducted in-depth reviews of the licensees implementation of the CAP related to the following issues:

(1) Review and assessment of the station's corrective actions from a missed TS surveillance on Unit 2, as documented in IR 4469855, during the weeks ending January 29 through March 31, 2022

(2) Review and assessment of the station's corrective actions following identification of the mis-assembly of 2SI8822B (Safety Injection Manual Throttle Valve for the 2B RCS Cold Leg), as documented in IRs 4455415 and 4477366, during the weeks ending March 12 through March 31,

INSPECTION RESULTS

Inadequate Work Instructions for Disassembly/Reassembly of Safety Injection (SI) Cold Leg Throttle Valve Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.1] - 71152A Systems NCV 05000457/2022001-01 Resources Open/Closed A self-revealed finding of very low safety significance (i.e., Green) and an associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, were identified for the licensees failure to include adequate detail within their maintenance work instructions for the disassembly/reassembly of 2SI8822B, Safety Injection System Copes-Vulcan Throttle Valve to 2B Reactor Coolant System (RCS) Cold Leg.

Specifically, work instructions provided by the licensee under safety-related Work Order (WO)4840548-02, Flow Change During 2BwOSR 5.5.8.SI-11: MVR - 2SI8822B, Disassemble /

Inspect / Repair Valve: 2SI8822B, during Unit 2 Refuel Outage A2R20 in October of 2018 contained less than adequate instructions for reassembly of the valve internals, such that valve internals were installed upside down within the valve body during reassembly.

Operation of the valve in this condition ultimately placed abnormal stress on the valve internals, causing the internals to crack in several locations. This condition was subsequently revealed when the licensee opened the 2SI8822B valve again for inspection during the most recent A2R22 Refuel Outage in October 2021.

Description:

Unit 2 entered Refuel Outage A2R22 on October 18, 2021. Part of the scheduled outage work activities included full flow surveillance testing of the Unit 2 SI system under surveillance procedure 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 condition.

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. A comprehensive causal evaluation was commissioned by the licensee to investigate the circumstances surrounding the issue; this evaluation was not completed, however, prior to the end of the 4th Quarter 2021 inspection period and an unresolved item (URI 05000457/2021004-01) was documented by the inspectors in the stations 4th Quarter 2021 integrated inspection report (IR 05000456/2021004;05000457/2021004 - ADAMS Accession Number: ML22028A195).

During the licensees formal causal evaluation into the 2SI8822B throttle valve cage cracking and failure, it was revealed that the valves cage assembly had been installed upside down in the valve body on reassembly during the Unit 2 A2R20 Refuel Outage in October of 2018.

Because of the fairly symmetric nature of the cage assembly, the licensee was able to successfully complete SI system flow balancing and post-maintenance testing by simply readjusting the 2SI8822Bs typical valve position. In retrospect, while such an adjustment was atypical, it was permitted by the flow balancing procedure and allowed the SI system safety function to be maintained. Despite the valves cage assembly fitting into the valve body upside down, this error caused the stack up of the internal components to be too high such that torquing the valve bonnet down onto the body crushed the outer cylinder of the cage assembly. The licensee concluded that it was likely that the valves internal seat ring failed under the same torque loading that was applied during reassembly in A2R20, but that it was also possible that the cage assembly failed sometime later due to abnormal stress loading.

Review of the WO 4840548-02 work package and instructions from the 2SI8822B reassembly in A2R20 revealed two key issues. The WO did not reference the correct maintenance procedure. BwMP 3305-099, Disassembly/Reassembly of Copes Vulcan Throttle Valve, is the correct procedure, and written specifically for maintenance on the set of emergency core cooling system (ECCS) throttle valves that includes 2SI8822B. Instead, the WO instructions incorrectly referenced BwMP 3305-013, Disassembly-Reassembly of Copes Vulcan Manually Operated Throttling Globe Valves, which is a generic procedure not intended for use with the specific set of throttle valves that includes 2SI8822B. Perhaps more importantly, the WO instructions did not include a field fit-up measurement. This measurement is made by inserting the valve internal components and then comparing a measurement between the top flange of the body and the top surface of the internal components against acceptance criteria to ensure that the internal component effective stack up height is correct before assembling the valve bonnet. Although not referenced or required by the BwMP 3305-099 maintenance procedure, this field fit-up measurement is recommended by the vendor. As part of their formal causal evaluation, the licensee concluded that had such a field fit-up measurement been performed, as recommended by the vendor, that it is likely that the incorrect orientation of the cage assembly would have been identified and corrected during reassembly and that damage to the valve internals would have been prevented.

Corrective Actions: The inspectors did not identify any issues with the licensees CAP actions taken for this aspect of the condition.

Corrective Action References:

- 4455415; Foreign Material Recovered from 2SI8822B/C/D Throttle Valves; 10/25/2021

- 4475336; 2SI8822B (A2R22) Autopsy Results; 02/01/2022

- 4477366; 2SI8822B Extent of Condition Investigation Findings; 02/10/2022

Performance Assessment:

Performance Deficiency: Safety-related Copes-Vulcan throttle valve 2SI8822B was disassembled and reassembled by the licensee during their Unit 2 A2R20 Refuel Outage in October of 2018. The work instructions provided by the licensee to technicians for reassembly of this valve were contained in WO 4840548-02, Flow Change During 2BwOSR 5.5.8.SI-11: MVR - 2SI8822B, Disassemble / Inspect / Repair Valve: 2SI8822B. The inspectors concluded that the licensees failure to have referenced the proper maintenance procedure, BwMP 3305-099, or to have included the vendor recommended field fit-up measurement within these instructions contributed to the incorrect installation of the 2SI8822B valve internals and the ultimate failure of the valve cage assembly. Further, the inspectors concluded that this failure 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 Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the inspectors determined that the licensees failure to have included adequate detail within their maintenance work instructions for the reassembly of 2SI8822B contributed to the failure of the valve internals, and as such, had an adverse impact on the components reliability. The inspectors also compared the finding with the examples listed in Inspection Manual Chapter (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 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Because the finding involved a deficiency affecting the design or qualification of a mitigating system, structure, or component (2SI2288B) that did not impact component operability or PRA [Probabilistic Risk Analysis] functionality, the inspectors determined the finding to be of very low safety significance (i.e., Green). Specifically, even though the performance deficiency contributed to the ultimate cracking of the 2SI8822B valve internals, the component was always able to demonstrate its ability to perform its specified safety function through surveillance testing.

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

Specifically, this finding involved a missed opportunity for licensee technicians to have been provided with work instructions that were more appropriate for the circumstances involved.

Enforcement:

Violation: Appendix B to 10 CFR Part 50, Criterion V, Instructions, Procedures, and Drawings, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

Contrary to this requirement, during the licensees Unit 2 A2R20 Refuel Outage in October of 2018, manual throttle valve 2SI8822B, a safety-related component subject to the requirements of Appendix B to 10 CFR Part 50, was reassembled using written instructions in WO 4840548-02, Flow Change During 2BwOSR 5.5.8.SI-11: MVR - 2SI8822B, Disassemble

/ Inspect / Repair Valve: 2SI8822B, that were not appropriate to the circumstances.

Specifically, these work instructions did not reference the correct maintenance procedure, BwMP 3305-099, Disassembly/Reassembly of Copes Vulcan Throttle Valve, nor did they specify a field fit-up measurement that was recommended by the component vendor.

URI 05000457/2021004-01, 2SI8822B Cold Leg Injection Throttle Valve Cage Failure, is closed.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

The disposition of this finding and associated violation closes URI:

05000456,05000457/2021004-01.

Observation: Missed Technical Specification Surveillance 71152A The inspectors performed a detailed review of IR 4469855, Surveillance Closed Out in Passport with Work Not Performed. The issue involved Technical Specification (TS)surveillance procedure 2BwOSR 3.5.2.2-2, Unit Two ECCS [Emergency Core Cooling System] and CS [Containment Spray] Venting and Valve Alignment / UT Verification Surveillance, which went past due on December 27, 2021. On December 10, 2021, station personnel in the Operations Services group mistakenly closed the work order controlling this instance of the surveillance (WO 5209621) to work performed during the fall 2021 Unit 2 A2R22 Refuel Outage. The error was not identified until January 4, 2022, when the paperwork for WO 5209621 could not be located. Upon discovery, the station immediately invoked TS Surveillance Requirement (SR) 3.0.3 and performed the applicable surveillance procedure, 2BwOSR 3.5.2.2-2, which passed.

In accordance with the stations TS Bases, Surveillances are performed to verify the operability of systems and components, and that variables are within specified limits. The inspectors chose this issue for an in-depth review of the licensees actions within their corrective action program (CAP) because of the risk associated with not performing TS surveillances and/or not performing those surveillances within their specified frequencies, which potentially could mask the presence of an inoperable safety-significant system or component. 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 addressing the administrative controls and tracking that could impact properly registering surveillance credit.

The inspectors determined that the missed performance of the 2BwOSR 3.5.2.2-2 surveillance within its specified frequency had constituted a violation of the requirements of TS 5.4.1(a), which requires that written procedures be established, implemented, and maintained for the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. In this case, Section 1.f of Regulatory Guide 1.33, Revision 2, Appendix A, February 1978, contains the requirement for administrative procedures associated with surveillance test schedules, and licensee procedure WC-AA-111, Surveillance Program Requirements, Revision 7, is an applicable procedure. Section 4.5 of this procedure states that TS required surveillances should be performed by their due date and shall be performed within the specified surveillance interval, with the maximum allowable extension not to exceed 25% of the surveillance interval. However, because the missed 2BwOSR 3.5.2.2-2 surveillance was successfully completed within the 24-hour period stipulated in TS SR 3.0.3, the error did not result in any adverse consequences and the inspectors concluded that the violation had not adversely impacted the Reactor Safety Mitigating Systems Cornerstone objective. As a result, the issue was determined to be a violation of minor significance that was not subject to formal actions per Section 2.3.1 of the NRC Enforcement Policy.

The inspectors did not identify any issues with the licensees CAP actions taken. Actions targeting the more generic issue of the administrative controls and tracking that could impact the proper registering of surveillance credit were focused on various enhancements to communications and training for applicable station personnel, as well as evaluation of possible procedure changes to create a formal mechanism to put into place a means to identify work orders erroneously taken to finished within the licensees work order tracking database. Actions targeting this specific event included conducting a review of work orders with issues preventing proper closure for credit; no other similar issues were identified.

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 April 8, 2022, the inspectors presented the integrated inspection results to Mr. G. Gugle, Acting Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

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

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

OP-AA-108-111- Severe Weather and Natural Disaster Guidelines 24

1001

OP-BR-102-1001 Augmented Operator Field Rounds 4

71111.04 Corrective Action 4482577 1B SI Pump ASME Surveillance Data Not Recorded Properly 03/04/2022

Documents 4485313 Missing EPN Tag 03/16/2022

4485319 Minor Leak 1B AF Pump 03/16/2022

Drawings M-37 Diagram of Auxiliary Feedwater Unit 1 BK

Procedures BwOP AF-E1 Electrical Lineup - Unit 1 Operating 15

BwOP AF-M! Operating Mechanical Lineup Unit 1 20

BwOP CS-E2 Electrical Lineup Unit 2 Containment Spray Electrical 2

Lineup

BwOP CS-M2 Operating Mechanical Lineup Unit 2 11

BwOP DG-M3 Operating Mechanical Lineup Unit 2 2A D/G 15

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

BwOP SA-M2 Operating Mechanical Lineup Unit 2 16

BwOP SI-E2 Electrical Lineup - Unit 1 Operating 12

BwOP SI-M2 Operating Mechanical Lineup Unit 1 27

71111.05 Fire Plans Pre-Fire Plan No. Fire Zone 12.1-0; FH 401' Elevation, Fuel Handling Building 1

178

Pre-Fire Plan No. Fire Zone 12.1-0; FH 426' Elevation, Fuel Handling Building 1

179

Pre-Fire Plan No. Fire Zone 8.3-1; Turbine Building 401' Elevation, Unit 1 4

Turbine Building Grade Level Southeast

Pre-Fire Plan No. Fire Zone 8.3-1; Turbine Building 401' Elevation, Unit 1 4

turbine Building Grade Level Southwest

Pre-Fire Plan No. Fire Zone 8.3-1; Turbine Building 401' Elevation, Unit 1 6

Turbine Building Grade Level Northeast

Pre-Fire Plan No. Fire Zone 9.1-1, 9.4-1; DG 401' Elevation, Diesel Generator 2

Room 1B & Day Tank Room

Inspection Type Designation Description or Title Revision or

Procedure Date

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

Auxiliary Building Basement (1B/2B SX)

Procedures BwAP 1100-16 Fire/Hazardous Materials Spill and/or Injury Response 38

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

Procedure

BwAP 1100-4 Fire Brigade Implementing Procedure 5

BwAP 1110-1 Fire Protection Program System Requirements 46

BwAP 1110-3 Plant Barrier Impairment Program 40

BwAR 0-37-A4 Unit One Area Fire 18

BwOP FP-100 Fire Response Guidelines 25

Fire Response

Guidelines

BwOP PBI-1 Plant Barrier Impairment Program Pre-Evaluated Barrier 5

Matrix

CC-AA-201 Plant Barrier Control Program 14

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 2 0

OP-AA-201-003 Fire Drill Performance 20

OP-AA-201-004 Fire Prevention for Hot Work 18

OP-AA-201-005 Fire Brigade Qualification 11

OP-AA-201-008 Pre-Fire Plan Manual 5

OP-AA-201-009 Control of Transient Combustible Material 27

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

1001

OP-BR-201-012- Braidwood On-Line Fire Risk Management 4

1001

71111.11Q Operability OP-AA-300 Reactivity Management 14

Evaluations TQ-AA-155 Conduct of Simulator Training and Evaluation 12

Procedures OP-AA-101-111- Operations Standards and Expectations 30

1001

OP-AA-101-113 Operator Fundamentals 15

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

1006

Inspection Type Designation Description or Title Revision or

Procedure Date

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

OP-AA-103-102- Strategies for successful Transient Mitigation 3

1001

OP-AA-103-103 Operation of Plant Equipment 2

OP-AA-104-101 Communications 5

OP-AA-111-101 Operating Narrative Logs and Records 19

TQ-AA-10 Systematic Approach to Training Process Description 7

TQ-AA-150 Operator Training Programs 22

TQ-AA-201 Examination Security and Administration 18

TQ-AA-306 Simulator Management 11

TQ-BR-201-0113 Braidwood Training Department Simulator Examination 25

Security Actions

71111.12 Corrective Action 4467715 2A DG Starting Air Compressor #1 Cycling Every 15-20 12/20/2021

Documents Minutes

4482997 2DG01SA-C Degraded 03/07/2022

4483273 2FSV-SA361A Porting Continuously 03/07/2022

4483877 1DG01SB-D DB 1B Starting Air Dryer Drain Valve/s Leak By 03/10/2022

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

Classification

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

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

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

ER-AA0320 Maintenance Rule Implementation per NEI 18-10 0

ER-AA0320-1001 Maintenance Rule 18-10 Scoping 0

Work Orders 5197918-26 MVR (OP1) 2SI8822D: Disassemble / Inspect / Repair 10/24/2021

Valve

5197918-60 MVR (OP1) 2SI8822C: Disassemble / Inspect / Repair 10/24/2021

Valve

71111.13 Corrective Action 4467108 Unexpected Annunciator 2-10-D6: Rod Control Non-Urgent 12/16/2021

Documents Failure

4468189 Reflash of Unit 2 Rod Control Non-Urgent Failure Alarm 12/24/2021

2-10-D6

4482191 Hot Relay in 2CW02JC 03/03/2022

Inspection Type Designation Description or Title Revision or

Procedure Date

4482314 Ovation' System Trouble/Drop 5 Failure 03/03/2022

4485341 2B DG Jacket Water Leak Worse 03/16/2022

Drawings KSV-47-21 Jacket Water Schematic 7

Engineering 635793 Install Temporary Power Supply in 2RD03J 01/13/2022

Changes

Miscellaneous BRW-2-2021- Final ODM: Unit 2 RD Non-Urgent Failure 01/19/2022

0304

Procedures BwHP 4006-021 Repair/Replacement Relay/Coil Assemblies 9

CC-AA-112 Temporary Configuration Changes 29

ER-AA-600 On-Line Risk Management 13

ER-AA0600 Risk Management 7

IP-ENG-001 Standard Design Process (SDP) 2

MA-AA-716-004 Conduct of Troubleshooting 19

MA-BR-772-215 Administration and Configuration Management of the 6

Ovation System

MA-BR-772-216 Ovation System Gross Function Test 4

OP-AA-107 Integrated Risk Management 4

OP-AA-108-117 Protected Equipment Program 7

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

Work Orders 4639101 2CW01PC: Replace Relay 3W3CX 03/03/2022

4944490 Lower Cable Tunnel Area 2DD Low Pressure CO2 System 03/08/2022

Actuation 18-Month

206556 Unit 2 Thermography of Circulating Water Pump Exciter 03/03/2022

Panels

214697 Unexpected Annunciator 2-10-D6: Rod Control Non-Urgent 01/03/2022

Failure

236261 Ovation System Trouble/Drop 5 Failure 03/03/2022

240543 2B Diesel Generator Jacket Water Leak Worse 03/18/2022

71111.15 Corrective Action 4458973 U2 CETC, Nozzle 74 Connections Swapped Affecting 11/05/2021

Documents Indications

4472457 1B SX Upper Cubicle Cooler Isolation Issue 01/18/2022

4472535 1SX2157B Valve Handle Broken 01/18/2022

4472544 2DG01KB has Jacket Water Leak 01/18/2022

Inspection Type Designation Description or Title Revision or

Procedure Date

4473614 1RE9159A Outside of Operability Limit for Close Time 01/24/2022

4480091 Voltage Fluctuations on 2N-NR8043 NM306 Output 02/23/2022

4482584 Dry Boric Acid on 1FIS-0612 1D RCP Bypass Flow 03/03/2022

Transmitter Hose

4484367 2BwOSR 3.3.3.1 Non-Symmetric CETC Deviation Exceeds 03/12/2022

60F

4485341 2B DG Jacket Water Leak Worse 03/16/2022

Engineering 405348 DG Closed System Leak Guidance (Lube Oil, Jacket Water, 0

Changes Fuel Oil)

25908 SX Cubicle Coolers with One Set of Coils/Fans Out of 0

Service for Preventive Maintenance

26166 MR90 Allow Disconnect SX Piping from 2A SX Cubicle 0

Cooler

27864 1B SX Pump Cubicle Cooler Operable with One Half of 0

Cooler Inservice

635519 Temporarily Exchange A Train and B Train Core Exit 0

Thermocouples at Reactor Head Penetration 74 (E-15) for

Unit 2

636286 Update Passport Classification for RCP Seal Bypass 0

Instrument Lines

Procedures CC-AA-309-101 Engineering Technical Evaluations 16

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 16

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

71111.19 Procedures 1BwOSR Group A IST Requirements for Component Cooling Water 12

5.5.8.CC-6B Pump (1CC01PB) and Discharge Check Valves

2BwOS SA-1 Unit 2 Station Air Compressor Surge Point Testing 5

BwOP CC-1 Component Cooling Water System Startup 23

Work Orders 4858793-10 OPS: 2SA01C Perform Post-Maintenance Testing 02/19/2022

4870082 Replace 4 KV Breaker for 1CC01PB 03/15/2022

218742 ASME Surveillance Requirements for Component Cooling 03/15/2022

Water Pump 1CC01PB

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.22 Calculations BYR97-272 Seismic Evaluation for Temporary Installation of Extension 0

Piece on Kiene Valves on the Diesel Generators for Engine

Analysis

Corrective Action 4461023 Unit 1 Containment H-3 DAC Trend 11/15/2021

Documents 4468523 Unit 1 Containment H-3 DAC Trending Higher 12/28/2021

4475005 Unit 1 Containment Sump Inputs 1RF008 01/31/2022

4475753 Unit 1 Containment H-3 DAC Trend 02/03/2022

4477279 1SX168 100 DPM Packing Leak When 1B AF Pump Runs 02/10/2022

Procedures 1BwOSR 3.7.5.4- Unit One Diesel Driven Auxiliary Feedwater Pump 21

Surveillance

1BwOSR 3.8.1.2- 1B Diesel Generator Operability Surveillance 49

1BwOSR Group A IST Requirements for Residual Heat Removal 23

5.5.8.RH-5A Pump 1RH01PA

BwOP DG-1 Diesel Generator Alignment to Standby Condition 31

BwOP DG-11 Diesel Generator Startup and Operation 53

BwOP DG-12 Diesel Generator Shutdown 30

BwVS 900-8 Diesel Generator Engine Analysis 11

CC-AA-112 Temporary Configuration Changes 20

Work Orders 5214083 LR-IST-1B Diesel Generator Operability Monthly 01/12/2022

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

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

71151 Miscellaneous NRC Performance Indicator Data; Initiating Events 01/01/2021

Unit/Reactor Shutdown Occurrences

2/31/2021

NRC Performance Indicator Data; Initiating Events 01/01/2021

Unplanned Power Changes per 7000 Critical Hours

2/31/2021

Procedures LS-AA-2001 Collecting and Reporting of NRC Performance Indicator Data 17

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

Shutdown Occurrences

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

per 7000 Critical Hours

71152A Corrective Action 4455415 Foreign Material Recovered from 2SI8822B/C/D Throttle 10/25/2021

Inspection Type Designation Description or Title Revision or

Procedure Date

Documents Valves

4469855 Surveillance Closed Out in Passport with Work Not 01/04/2022

Performed

4475336 2SI8822B (A2R22) Autopsy Results 02/01/2022

4477366 2SI8822B Extent of Condition Investigation Findings 02/10/2022

Procedures 2BwOSR 3.4.2.2- Unit Two ECCS [Emergency Core Cooling System] and CS 30

[Containment Spray] Venting and Valve Alignment / UT

Verification Surveillance

2BwOSR Comprehensive Inservice Testing (IST) Requirements for 15

5.5.8.SI-11 Unit 2 Safety Injection Pumps and Safety Injection System

Check Valve Stroke Test

BwMP 3305-013 Disassembly-Reassemble of Copes Vulcan Manually 7

Operated Throttling Globe Valves

BwMP 3305-099 Disassemble/Reassembly of Copes Vulcan Throttle Valve 2

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

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

WC-AA-111 Surveillance Program Requirements 7

Work Orders 4840548-02 Flow Change During 2BwOSR 5.5.8.SI-11: MVR - 2SI8822B, 10/13/2018

Disassemble / Inspect / Repair Valve

5197918-03 MVR - (OP1) 2SI8822B: Disassemble / Inspect / Repair 10/24/2021

Valve

19