IR 05000456/2022003
| ML22291A068 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 10/25/2022 |
| From: | Laura Kozak NRC/RGN-III/DORS/RPB3 |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| EA-22-088 IR 2022003 | |
| Download: ML22291A068 (1) | |
Text
SUBJECT:
BRAIDWOOD STATION - INTEGRATED INSPECTION REPORT 05000456/2022003 AND 05000457/2022003 AND EXERCISE OF ENFORCEMENT DISCRETION
Dear Mr. Rhoades:
On September 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Braidwood Station. On October 6, 2022, the NRC inspectors discussed the results of this inspection with Mr. G. Gugle, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
No findings or violations of more than minor significance were identified during this inspection.
October 25, 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, Laura L. Kozak, Acting Chief Branch 3 Division of Operating Reactor Safety 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:
05000456/2022003 and 05000457/2022003
Enterprise Identifier:
I-2022-003-0044
Licensee:
Constellation Energy Generation, LLC
Facility:
Braidwood Station
Location:
Braceville, IL
Inspection Dates:
July 01, 2022 to September 30, 2022
Inspectors:
R. Bowen, Illinois Emergency Management Agency
A. Demeter, Acting Resident Inspector
G. Edwards, Health Physicist
D. Kimble, Senior Resident Inspector
P. Smagacz, Resident Inspector
Approved By:
Laura L. Kozak, Acting Chief
Branch 3
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Braidwood Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
Type Issue Number Title Report Section Status EDG EA-22-088 Failure to Comply with 10 CFR Part 37 71124.08 Open
PLANT STATUS
Unit 1 began the inspection period operating at full power. On September 3, 2022, the unit reached the end of the fuel cycle and power coast down operations commenced in preparation for a planned refuel outage. The unit continued to reduce power in accordance with the licensees approved reactivity management plan, and was operating at approximately 80 percent power at the end of the inspection period.
Unit 2 began the inspection period operating at full power. With the exception of minor reductions in power to support scheduled testing activities and load changes requested by the transmission system dispatcher, the unit remained operating at or near full power for the entire inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, 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
71111.04 - 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 2A Containment Spray (CS) Train following planned 2B CS Train maintenance during the weeks ending August 13 through August 20, 2022
- (2) The Unit 1 Residual Heat Removal (RH) System during a planned 1B CS Train maintenance window, as documented in Work Order (WO) 5213824 during the week ending August 20, 2022
- (3) The 2B Component Cooling (CC) Train during planned 2A CC Train maintenance, as documented in WOs 512398, 5155287, and 5142044 during the week ending September 3, 2022
- (4) The 0A Motor-Driven Fire Pump during extended maintenance on the 0B Diesel-Driven Fire Pump, as documented in WO 5179895 during the weeks ending September 3 through September 24, 2022 Complete Walkdown Sample (IP Section 03.02) (1 Partial)
The inspectors evaluated system configurations during complete physical alignment verifications of the following systems/trains:
(1)
(Partial)
The Unit 1 CS System complete physical alignment verification performed, in part, during the week ending August 13, 2022.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (7 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 11.5-0 Center; Auxiliary Building, 401' Elevation, Unit 2 General Area during the week ending July 23, 2022
- (2) Fire Zone 11.3-0 North, South, and Center; Auxiliary Building 364; Elevation, Units 1 and 2 Auxiliary Building General Areas during the week ending July 23, 2022
- (3) Fire Zone 11.4-0 North, South, and Center; Auxiliary Building 383' Elevation, Units 1 and 2 Auxiliary Building General Areas during the week ending July 23, 2022
- (4) Fire Zones 5.4-2, 5.5-1, 5.5-2, 5.6-1, and 5.6-2; Auxiliary Building 451' Elevation, Units 1 and 2 Miscellaneous Electric Equipment and Battery Rooms during the week ending July 30, 2022
- (5) Fire Zone 11.2-0; Auxiliary Building 346' Elevation, Units 1 and 2 Auxiliary Building during the week ending July 30, 2022
- (6) Fire Zone 11.6-0 North, South, and Center; Auxiliary Building 426' Elevation, Units 1 and 2 Auxiliary Building General Areas during the week ending August 13, 2022
- (7) Fire Zone 18.12-0; Lake Screen House during the weeks ending August 13 through September 3, 2022
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)
The inspectors conducted physical inspections in the plant and selected document reviews to evaluate internal flooding mitigation protections in the following area(s):
- (1) The Unit 1 and Unit 2 Auxiliary Building 330' and 346' Elevations during a Unit 0 CC Heat Exchanger repair work window with flood barriers removed and/or impaired during the week ending September 17, 2022
71111.07A - Heat Exchanger/Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors conducted a review that evaluated readiness and performance of the following safety-related heat exchanger:
- (1) The 1B CS Cubical Cooler Heat Exchanger, as documented in WO 4764712 during the weeks ending August 20 through September 3, 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 activities performed by licensed operators in the facility's main control room:
- (1) Various activities involving on-watch operations crews. These activities included, but were not limited to:
Unit 1 Essential Service Water (SX) Pump swaps during the week ending August 6, 2022
Various pump and valve manipulations on the 1A Safety Injection Train for testing during the week ending August 27, 2022
End-of-cycle reactivity maneuvers leading into Unit 1 coast down operations for the A1R23 Refuel Outage during the week ending September 10, 2022
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
The inspectors observed and evaluated the following licensed operator training activity, which included the administration of the annual requalification operating test required by 10 CFR 55.59(a)(2) in the facility's control room simulator:
- (1) A complex casualty graded scenario involving a crew of licensed operators was observed in facility's simulator during the conduct of the annual requalification operating test on September 6, 2022.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
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 associated with issues and repair activities for the 0B Diesel-Driven Fire Pump during the weeks ending September 3 through September 30, 2022
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance, quality control activities, and component performance histories to ensure the following SSCs remain capable of performing their intended function:
- (1) Maintenance effectiveness review of the 1B CS System during replacement of the 1B CS Pump Cubicle Cooler Essential Service Water Return Valve (1SX091B) during the weeks ending August 20 through September 3, 2022
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Evaluation of the planned work associated with a 1B CS work window, as documented in WO 5213824 during the week ending August 20, 2022
- (2) Evaluation of the planned work associated with filling the spent fuel pool (SFP) from the 0A Radwaste Monitor Tank, as documented in WO 5287466 during the week ending September 10, 2022
- (3) Evaluation of the planned work associated with new fuel receipt and inspection in preparation for the Unit 1 A1R23 Refueling Outage, as documented in WO 517946 during the weeks ending August 13 through September 17, 2022
- (4) Evaluation of the planned work associated with repairs to the Unit 0 CC Heat Exchanger, as documented in Issue Report (IR) 4510008 during the week ending September 17, 2022
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 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 Charging (CV) Pump following identification of a degraded pump outboard seal package, as documented in IR 4510008 during the week ending July 16, 2022
- (2) Evaluation of the operability of the 1B CS Train following identification of degraded cooling water flow to the pump cubicle cooler, as documented in IR 4510738 during the weeks ending July 16 through 23, 2022
- (3) Evaluation of the operability of the 1A SX Pump following identification of reduced margin in differential pressure during ASME surveillances, as documented in IRs
===4511236 and 4503733 during the weeks ending July 30 through August 6, 2022
- (4) Evaluation of the operability of the Unit 2 Reactor Coolant System (RCS) following identification of a step increase in RCS unidentified leakage rate, as documented in IR 4522009 during the weeks ending September 17 through September 24, 2022
- (5) Evaluation of the operability of the station's fire protection and detection system and safety-related SSCs following identification of missed fire rated assembly visual inspections, as documented in IR 4522164 during the week ending September 24, 2022
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)
=
The inspectors evaluated the following temporary configuration change to the facility:
- (1) Review of the temporary plant modification per Engineering Changes (ECs) 634192 (Unit 1) and 635519 (Unit 2): Temporarily Exchange A Train and B Train Core Exit Thermocouples, during the weeks ending July 26 through August 27, 2022
Severe Accident Management Guidelines (SAMG) Update (IP Section 03.03) (1 Sample)
The inspectors verified the site Severe Accident Management Guidelines (SAMGs) were updated in accordance with the Pressurized Water Reactor Generic Severe Accident Technical Guidelines and validated in accordance with Nuclear Energy Institute (NEI) 14-01, Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents, Revision 1, as follows:
- (1) Changes to the Braidwood Unit 1 and Unit 2 SAMGs were reviewed during the weeks ending July 23, through September 17, 2022
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:
- (1) Functional and operational testing of the Unit 0 CC Pump and discharge check valves following a Unit 0 CC Train work window, as documented in WOs 5122696 and
===5125839 during the weeks ending July 30 through August 6, 2022
- (2) Functional and operational testing of the 2A RH Pump following a 2A RH Train work window, as documented in WOs 5145601, 5142646, and 5263410 during the weeks ending August 6 through 13, 2022
- (3) Functional and operational testing of the 1A SX Pump following issues with newly installed test flow measurement instrumentation, as documented in WO 5270865 during the weeks ending August 20 through August 27, 2022
- (4) Functional and operational testing of the 1B CS System following a planned work window, as documented in WOs 5213824 and 4763712 during the weeks ending September 3 through September 10, 2022
- (5) Functional and operational testing of the 0B Diesel-Driven Fire Pump following a planned work window, as documented in WO 5278379 during the weeks ending August 27 through September 17, 2022
- (6) Functional and operational testing of Main Steam Safety Valve (MSSV) 1MS017A following set pressure testing and adjustments, as documented in WO 5160505 during the week ending September 30, 2022
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance testing activities:
Surveillance Tests (other) (IP Section 03.01)
(1)2BwOSR 3.8.1.2-2; 2B Emergency Diesel Generator (EDG) Operability Surveillance, as documented in WO 5271794 during the weeks ending July 23 through 30, 2022
- (2) Steam Generator 2A Channel II and Channel IV narrow range level instrument calibrations, as documented in WOs 5115059 and 5115063 during the week ending July 30, 2022
- (3) The Unit 1 and Unit 2 Diesel-Driven Auxiliary Feedwater (AF) Pump surveillances, as documented in WOs 5277318 and 5279829 during the weeks ending August 13 through 20, 2022
- (4) Diagnostic testing for Limitorque Motor-Operated Valve 2SI8920, 2B Safety Injection Pump Minimum Flow Isolation Valve, as documented in WO 4903613 during the weeks ending September 17 through 30, 2022 Inservice Testing (IP Section 03.01)===
- (1) Main Steam Safety Valve Set Pressure Testing, as documented in WO 5160505 during the week ending September 30, 2022
- (2) AF Train full flow testing, as documented in WO 5165923 during the week ending September 30,
RADIATION SAFETY
71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &
Transportation
Radioactive Material Storage (IP Section 03.01)
The inspectors evaluated the licensees performance in controlling, labeling and securing the following radioactive materials:
- (1) Radioactive materials in the radioactive waste on-site storage facility
- (2) Radioactive materials stored in the instrumentation room
Radioactive Waste System Walkdown (IP Section 03.02) (2 Samples)
The inspectors walked down the following accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality:
- (1) Resin processing equipment
- (2) Liquid processing equipment
Waste Characterization and Classification (IP Section 03.03) (2 Samples)
The inspectors evaluated the following characterization and classification of radioactive waste:
- (1) Resin waste streams at the facility
- (2) Dry activated waste (DAW) stream at the facility
Shipping Records (IP Section 03.05) (3 Samples)
The inspectors evaluated the following non-excepted radioactive material shipments through a record review:
- (1) Shipment RWS22-003 UN3321 LSA-II; Resin Liner P0698226-30 in Cask 14-215
- (3) Shipment RWS21-001 UN3321 LSA-II; Resin Liner P0695283-14 in Cask 14-215
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS08: Heat Removal Systems (IP Section 02.07)===
- (1) Unit 1 (July 1, 2021 through June 30, 2022)
- (2) Unit 2 (July 1, 2021 through June 30, 2022)
MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)
- (1) Unit 1 (July 1, 2021 through June 30, 2022)
- (2) Unit 2 (July 1, 2021 through June 30, 2022)
MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)
- (1) Unit 1 (July 1, 2021 through June 30, 2022)
- (2) Unit 2 (July 1, 2021 through June 30, 2022)
71152A - Annual Follow-Up Problem Identification and Resolution Annual Follow-Up of Selected Issues (Section 03.03)
The inspectors conducted an in-depth review of the licensees implementation of the corrective action program (CAP) related to the following issue:
- (1) Review and assessment of the station's corrective actions following identification of the mis-assembly of Unit 1 and Unit 2 Core Exit Thermocouples during Unit 1 Refuel Outage A1R22 and Unit 2 Refuel Outage A2R22, as documented in IRs 4419609 and 4458973 during the weeks ending August 27 through September 17,
INSPECTION RESULTS
Enforcement Discretion Enforcement Action EA-22-088: Failure to Comply with 10 CFR Part 37 71124.08
Description:
On January 15, 2016, the licensee was issued NRC Inspection Report No.
05000456/2015407;05000457/2015407, which documented a licensee identified violation of 10 CFR Part 37, Physical Protection of Category 1 and Category 2, Quantities of Radioactive Material at Facilities with a 10 CFR Part 73, Physical Protection Program. The violation met the criteria for Enforcement Discretion as described in Enforcement Guidance Memorandum (EGM) 14-001, "Interim Guidance for Dispositioning 10 CFR Part 37 Violations with Respect to Large Components or Robust Structures Containing Category 1 or Category 2 Quantities of Material at Power Reactor Facilities Licensed Under 10 CFR Parts 50 and 52."
Subsequently, the inspectors re-evaluated this activity and found that while a violation of regulatory requirements continues to exist, the conditions remain within the criteria for enforcement discretion established within EGM 14-001 Corrective Actions: As specified in EGM 14-001, the application of discretion is authorized until the underlying technical issue is dispositioned through rulemaking or other regulatory action. Additional corrective actions are not required.
Corrective Action References: Not applicable.
Enforcement:
Violation: On January 15, 2016, a violation of 10 CFR Part 37 was documented in Braidwood Inspection Report No. 05000456/2015407;05000457/2015407. The inspectors determined that the previously identified violation remains.
Basis for Discretion: This violation met the criteria for Enforcement Discretion as described in Enforcement Guidance Memorandum (EGM) 14-001, "Interim Guidance for Dispositioning 10 CFR Part 37 Violations with Respect to Large Components or Robust Structures Containing Category 1 or Category 2 Quantities of Material at Power Reactor Facilities Licensed Under 10 CFR Parts 50 and 52."
Observation: Error in Reconnection of Core Exit Thermocouples (CETCs)
Following Reactor Refueling 71152A The inspectors performed a detailed review of IR 4419609, U1 CETC, Nozzle 74 Connections Swapped Affecting Indicators. The issue involved Instrument Maintenance Department (IMD)
CETC reconnection procedure BwIP 2000-023, Unit One Reactor Head Instrument Cable Reconnect With 40-Pin Reactor Vessel Level Indication System (RVLIS) Connectors Installed, which was performed under Work Order (WO) 4980915, 1RC01R Head Disconnect CETC & RVLIS Outage, during the Unit 1 A1R22 Refuel Outage.
On April 20, 2021, as part of the Unit 1 reactor reassembly sequence, IMD technicians were identifying the appropriate mating connectors for each CETC. Per procedure BwIP 2000-024, Reactor Head Instrument Cable Removal with 40-Pin RVLIS Connectors Installed, Step 4.2.1, each half of the cable was to have been previously properly labeled to allow for correct reconnection as the reactor was being restored following refueling. The procedure steps identified the correct cable numbers associated with the CETCs, and technicians performing the work in the field determined that colored electrical tape had been properly used to mark the connections previously during disassembly. All comments in the WO package indicated that the reconnections were completed satisfactorily. However, on April 25, 2021, during the Unit 1 power ascension following reactor restart, a part of scheduled surveillance 1BwOS TRM 3.3.h.1, Unit One Power Distribution Monitoring System (PDMS) Operability Weekly Surveillance, having to do with symmetric CETC temperature limits yielded unsatisfactory results. Reactor Engineering personnel subsequently determined that the Unit 1 CETC connections associated with Reactor Vessel Closure Head Nozzle 74 had been improperly reconnected during the A1R22 restoration activities, affecting the indications of 12 CETCs in quadrant 2 of the Unit 1 reactor.
As discussed in the stations Technical Specification (TS) Bases, CETCs are used as a primary means to determine reactor coolant system subcooling margin and are also utilized extensively within the stations emergency operating procedures for such things as termination or re-initiation of Safety Injection during accident scenarios, as well as for the verification and extended monitoring of the effectiveness of post-accident core cooling. The inspectors chose this issue for an in-depth review of the licensees actions within their CAP because of the inherent safety significance associated with the potential reduction in the effectiveness of the CETCs.
Following the A1R22 CETC reconnection error, IMD performed an evaluation as part of the licensees CAP process. In part, IMD was tasked to address why corrective actions taken after a similar occurrence in 2012 were not effective (IR 1451512, Unit 2 CETC, Nozzle 77 Connections Swapped Affecting Indication). The occurrence from 2012 mirrored the A1R22 issue, with the exception that it took place on Unit 2 at Nozzle 77. For the 2012 issue on Unit 2, IMD had also performed the CAP evaluation, and both evaluations, from 2012 and May 2021 as well, had concluded that the omission of a first line supervisor (FLS) hold point and inconsistencies with the labeling and/or marking of cables were the likely contributors to the errors.
In November 2021 during power ascension following the Unit 2 A2R22 Refuel Outage, planned testing by the licensee identified that 12 CETCs in quadrant 2 of the Unit 2 reactor had again been swapped during reconnection activities at the end of that outage. The licensee entered IR 4458973, Unit 2 CETC, Nozzle 74 Connections Swapped Affecting Indications, into their CAP on November 5, 2021, to document the error. Although it was originally recommended that the CAP evaluation for this issue be assigned to IMD, the stations Electrical Maintenance Department (EMD) was eventually assigned the CAP evaluation. As a result, IMD actions and possible contributors to the issue were not evaluated.
With the Unit 1 A1R23 Refuel Outage scheduled to begin on October 3, 2022, the inspectors examined the licensees corrective actions from the previous three events (Unit 2 in 2012, Unit 1 in 2021, and Unit 2 in 2021) in an effort to determine whether or not vulnerabilities associated with the process to reconnect CETCs following reactor refueling accurately might still exist. Several observations by the inspectors were discussed station management, which included but were not limited to:
Procedures for the disconnection and reconnection of the CETCs were not updated to reflect certain CAP evaluation learnings in a timely fashion. Despite changes being submitted, the procedures had not been updated during the time of the inspectors reviews. In one case, a due date for had been rescheduled 11 times out to March 15, 2023, months after the scheduled occurrence of the Unit 1 A1R23 Refuel Outage in October 2022. Following discussions with the inspectors, this due date was readjusted and the procedure change process was reinitiated.
The procedures to be updated did not encompass the totality of the procedures used for CETC disconnection and reconnection work activities. Procedure BwIP 2000-023 only pertains to Unit 1. A separate procedure, BwIP 2000-014, Unit Two Reactor Head Instrument Cable Reconnect, is used for the reconnection of cables for Unit 2, and no similar procedure revision at the time of the inspectors reviews existed for updating the BwIP 2000-014. Additionally, upon further review by the licensee, it was determined that some of the procedures referenced were intended to be superseded by a newer procedure, and this had not yet been accomplished.
The CAP evaluation duties between EMD and IMD in the aftermath of these issues were not entirely consistent or coordinated. As a result, each respective department generated corrective actions independently, and the failure of the departments to effectively communicate and coordinate their actions contributed to a mixed approach towards issue resolution. For example, EMD took a CAP action involving the addition of FLS hold points in their applicable procedures, while IMD took no similar action even though their CAP evaluation noted such an enhancement would be beneficial.
In reviewing each issue, the inspectors determined that the licensees failures to properly reconnect CETCs following reactor refueling operations constituted a performance deficiency that was within their ability to foresee and which should have been prevented. However, in each case the licensee was able to compensate for the CETC reconnection errors by applying a temporary configuration change to the system. Essentially, CETC lines were intentionally swapped again further downstream away from the reactor head so that ultimately the correct signal was being processed at its terminus. As such, there was no loss of function and the inspectors determined that issues were of minor significance and not subject to formal actions per Section 2.3.1 of the NRC Enforcement Policy. Consequently, no findings or violations of NRC requirements of more than minor safety significance were identified by the inspectors in the course of this review.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On October 6, 2022, the inspectors presented the integrated inspection results to Mr. G. Gugle, Site Vice President, and other members of the licensee staff.
On August 19, 2022, the inspectors presented the radiation protection inspection results to Mr. G. Gugle, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
BwOP RH-M1
Operating Mechanical Lineup Unit 1 1A RH Train
BwOP CS-E1
Electrical Lineup Unit 1 Containment Spray System
Electrical Lineup
BwOP CS-M1
Core Spray Operating Mechanical Lineup Unit 1
BwOP FP-E1
Electrical Lineup for the Unit 0 Fire Protection System Unit
Operating
BwOP FP-E1
Electrical Lineup for the Unit 0 Fire Protection System Unit
Operating
BwOP FP-E2
Electrical Lineup for the Unit 0 Fire Protection System Unit
Operating
2E1
BwOP FP-E3
Unit 0 Electrical Lineup Unit 0 Operating
BwOP FP-M1
Operating Mechanical Lineup Unit 0 LSH and Outside Ring
HDR Operating
BwOP FP-M6
Operating Mechanical Lineup Unit 0 Auxiliary Building Ring
Header Operating
Procedures
BwOP RH-E1
Residual Heat Removal Electrical Lineup Unit 1
Pre-Fire Plan No.
100
Fire Zone 11.2-0; Auxiliary Building 346' Elevation Unit 1
Auxiliary Building General Area (NE)
Pre-Fire Plan No.
101
Fire Zone 11.2-0; Auxiliary Building 346' Elevation Unit 2
Auxiliary Building General Area (South)
Pre-Fire Plan No.
111
Fire Zone 11.3-0 Center; Unit 2 Auxiliary Building General
Area (Center)
Pre-Fire Plan No.
2
Fire Zone 11.3-0 South; Unit 1 Auxiliary Building General
Area (North)
Pre-Fire Plan No.
113
Fire Zone 1.3-0 South; Unit 2 Auxiliary Building General Area
(South)
Pre-Fire Plan No.
2
Fire Zone 11.4-0; Auxiliary Building 383' Elevation Auxiliary
Building General Area Center
Pre-Fire Plan No.
133
Fire Zone 11.4-0 North; Auxiliary Building 383' Unit 1,
Auxiliary Building General Are North
Fire Plans
Pre-Fire Plan No.
134
Fire Zone 11.4-0 South; Auxiliary Building 383' Elevation Unit
Auxiliary Building General Area South
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Pre-Fire Plan No.
146
Fire Zone 11.5-0 Center; AB 401' Unit 2 Auxiliary Building
General Area Center
Pre-Fire Plan No.
156
Fire Zone 11.6-0; Auxiliary Building 426' Elevation Auxiliary
Building General Area Center
Pre-Fire Plan No.
156
Fire Zone 11.6-0; Auxiliary Building 426' Elevation Unit 1
Auxiliary Building General Area North
Pre-Fire Plan No.
156
Fire Zone 11.6-0; Auxiliary Building 426' Elevation Unit 2
Auxiliary Building General Area South
Pre-Fire Plan No.
165
Fire Zone 11.6C-0; Auxiliary Building 426' Elevation Auxiliary
Building Laundry Room
Pre-Fire Plan No.
24
Fire Zone 18.12-0; Lake Screen House 602' Elevation
Pre-Fire Plan No.
Fire Zone 5.4-2; Auxiliary Building 451' Elevation, Unit 2
Division 22 Miscellaneous Electric Equipment Room and
Battery Room
Pre-Fire Plan No.
Fire Zone 5.6-2; Auxiliary Building 451' Elevation, Unit 2
Division 21 Miscellaneous Electric Equipment Room and
Battery Room
ER-BR-600-1069
Site List of High Risk Fire Areas Braidwood Unit 1 and
Unit 2
Procedures
Pre-Fire Plan Manual
Miscellaneous
CC-AA-201-F-01
Plant Barrier Impairment Permit for 1SXFSO1-3 Access
Plate during Common Heat Exchanger Work Window
09/12/2022
BwAP 1110-3
Plant Barrier Impairment Program
Operability
Evaluations
BwMP 3100-094
Removal and Installation of Flood Seal Opening Barriers
0BwOA PRI-8
Auxiliary Building Flooding Unit 0
Procedures
BwOP PBI-1
Plant Barrier Impairment Program Pre-Evaluated Barrier
Matrix
Work Orders
252064
SX Piping Leakage at the Outlet of U-0 CC HX
09/07/2022
4510738
1B CS Pump Cubicle Cooler Flow
07/12/2022
Corrective Action
Documents
4516287
Update on 1B CS Cubicle Cooler Flow
08/11/2022
Work Orders
4764712
LR-1VA03SB PM Clean 1B CS Pump Cubicle Cooler
08/18/2022
Miscellaneous
BR1C23-09.0
Braidwood 1 Cycle 23 Coastdown Reactivity Plan
08/08/2022
Procedures
1BwOSR
Group A Inservice Testing Requirements for 1A Safety
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
5.5.8.SI-10A
Injection Pump (1SI01PA)
BwOP SI-1
Safety Injection System Startup
BwOP SI-2
Safety Injection System Shutdown
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
OP-BR-108-101-
1002
Operations Department Standards and Expectations
Systematic Approach to Training Process Description
Operator Training Programs
Conduct of Simulator Training and Evaluation
Examination Security and Administration
Simulator Management
TQ-BR-201-0113
Braidwood Training Department Simulator Examination
Security Actions
260334
OI Benchmark 2019 NEIL Property Workshop
06/28/2019
4309174
OTI-FP8023 Temp Indicator Erratic
01/09/2020
20048
Request Additional Vibe Readings Taken During March
DDFP Run
2/21/2020
22158
0FP03PB Diesel Driven Fire Pump JW Heater Leak at Fitting
2/28/2020
4357805
0FP03PB Diesel Driven Fire Pump JW Heater Leak Getting
Worse
07/20/2020
4367479
0B FP Jockey Pump Seal Leakage
09/04/2020
Corrective Action
Documents
4391511
Abnormal Oil Results for 0FP03PB-CC
2/21/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
4391873
Follow Up Oil Sample 0FP03PB
2/23/2020
4411466
Abnormal Oil Results 0FP03PB
03/25/2021
24281
0B FP Excessive Seal Leakage
05/18/2021
24281
0B FP Excessive Seal Leakage
05/18/2021
24549
DDFP Auto Start Requirements for Monthly Runs per NEIL
05/19/2021
24838
Excessive Packing Leak on 0B FP Jockey Pump
05/20/2021
4459495
1SX091B Stem is Bound
11/08/2021
4517219
1SX091B Needs to be replaced, can not be repaired
08/16/2022
4518611
0B Fire Pump Overheated During PMT Test
08/24/2022
4518908
0FP03PB Coolant Expansion Tank Sight Glass
08/26/2022
4518909
0B Fire Pump, 0BwOS FP.2.1.E-1B Failed Acceptance
Criteria
08/26/2022
4519018
0B Fire Pump Exhaust Filling Room
08/26/2022
4519144
Time Clock Will Be Exceeded for BwAP 1110-1A2
08/27/2022
Engineering
Changes
636697
Evaluate Freeze Seal on 1SX54AB-3" to Support Work on
1SX091B Valve
05/11/2022
Quality Receipt Inspection Package Receipt #251181 for 3"
10/10/2018
Quality Receipt Inspection Package Receipt #133026 for
Valve Stem
04/03/2007
Quality Receipt Inspection Package Receipt #129199 for
Valve Disc
11/21/2006
Quality Receipt Inspection Package Receipt #114201 for
Disc Union
07/01/2005
Quality Receipt Inspection Package #116114 for Valve Yoke
and Bushing
09/20/2006
Quality Receipt Inspection Package Receipt #251182 for 3"
Globe Valve Bonnet, and Body
10/10/2018
Miscellaneous
Hot Work Permit for Replacement of
1SX091B Valve
08/16/2022
Procedures
1BwOSR 3.7.8.1
Unit One Essential Service Water System Surveillance
4865223
Create WR to Install Upgraded Valve for 1SX2183D
08/16/2022
Work Orders
4865224
Create WR to Install Upgraded Valve for 1SX2183B
08/16/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
213824
1S091B Stem is Bound
08/16/2022
20647
BwOP FC-11 Procedure Change Request Action (PCRA) to
Add Step to Fill Spent Fuel Pool from 0A Radwaste Monitor
Tank
09/04/2022
Corrective Action
Documents
22241
Pipe Diviots Below Backing Ring
09/14/2022
Engineering
Changes
636697
1B Containment Spray Pump Cubicle Cooler Return Isolation
Valve Freeze Seal Assessment
05/20/2022
BwMP 3300-054-
F-01
Freeze Checklist and Communication Tool
BwOP WX-131
Radwaste Monitor Tank Recirculation
Maintenance Specification: Selection and Control of Freeze
Seal Location
Spent Fuel Pool/Transfer Canal/Refuel Pool
ASME Section XI Repair/Replacement Program
Risk Management
On-Line Risk Management
Application of Freeze Seal to All Piping
Application of Freeze Seal Using Rigid Superfreeze SF-2500
Integrated Risk Management
Protected Equipment Program
Administrative Controls During Fuel Handling Activities for
Byron and Braidwood
New Fuel Receipt and Inspection for Byron, Braidwood, and
Ginna
Operation of the New Fuel Elevator for Byron and Braidwood
Fuel Movement in the Spent Fuel Pool for Byron and
Braidwood
Operation of the Spent Fuel Pool Bridge Crane for Byron and
Braidwood
Procedures
On-Line Risk Management and Assessment
5179476
Reactor Services New Fuel Receipt
07/26/2022
Work Orders
287466
Fill the Spent Fuel Pool Utilizing Water from the 0A
Radwaste Monitor Tank
08/28/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
4503733
Reduce Margin for 1A Essential Service Water Pump
06/03/2022
4510008
Larger Than Usual Leakage on 1A CV Outboard Seal
07/08/2022
4510392
1BwOSR 3.4.13.1 Results Action Level 2 and 3
07/11/2022
4511236
1A Essential Service Water Pump Flowmeter Data
Inconsistent with Previous Test
07/15/2022
4517150
NOSA-BRW-22-05 Braidwood Fire Protection Audit
08/16/2022
4519683
Unexpected Alarm 2-7-A2 2B Seal Injection Filter DP HIGH
08/30/2022
4519727
Unexpected Annunciator 2-7-B2
08/30/2022
20009
Unit 2 RCS Leakrate Deviation Action Level III Exceeded
08/31/2022
20133
Unit 2 RCS Leakrate Deviation Action Level II Exceeded
09/01/2022
21202
2CV01FB - 2B Seal Injection Filter Housing
09/07/2022
21439
2CV8385B is Broken in the Open Position
09/08/2022
22009
Unit 2 RCS Leakrate Exceeds STD Action Level I
09/13/2022
22164
NOS ID: Fire Rated Assembly Visual Inspections Were
Missed
09/13/2022
Corrective Action
Documents
22897
NOS Finding: Fire Rated Assemblies Not Visually Inspected
08/16/2022
SONARtrac System Performance Report for Commissioning
of CIDRA Flow Meter
07/31/2022
Miscellaneous
SONARtrac System Performance Report of CEDRA Flow
Meter Data Following Reduced Margin in 1A Essential
Service Water Pump Differential Pressure
07/27/2022
1BwOSR
5.5.8.SX-3A
Group A IST Requirements for 1A Essential Service Water
Pump (1SX01PA)
1BwOSR
5.5.8.SX-6A
Comprehensive Inservice Test (IST) Requirements for 1A
Essential Service Water Pump (1SX01PA)
BwAP 1110-1
Fire Protection Program System Requirements
BwAP 1110-1
Fire Protection Program System Requirements
BwAP 1110-1A1
OGCAR Required Compensatory Measure Action Response
Fire Detection Instrumentation
BwAP 1110-1A7
Fire Rated Assemblies Required Compensatory Measures
Action Response Cover Sheet
BwMS FP.7.1.E-1
Fire Rated Assemblies Visual Inspection
Procedures
BwMS FP.7.1.E-
Fire Rated Assemblies Visual Inspection Accessible Areas
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
1A0
(CM-1) Data Sheets
Nuclear Oversite Regulator Audit Procedure
OP-AA-106-101-
1006
Operational Decision Making Process
Adverse Condition Monitoring and Contingency Planning
1451512
U2 CETC, Nozzle 77 Connections Swapped Affecting
Indications
2/12/2012
4419609
U1 CETC, Nozzle 74 Connections Swapped Affecting
Indications
04/28/2021
24250
U1 CETC, Nozzle 74 Connections Swapped Affecting
Indications
05/18/2021
4458973
U2 CETC, Nozzle 74 Connections Swapped Affective
Indications
11/05/2021
Work Orders
266841
1FE-SX146 1A Essential Service Water Pump Flow Meter
08/03/2022
634192
Temporarily Exchange A Train and B Train Core Exit
Thermocouples at Reactor Head Penetration 74 (E-15) for
Unit 1
05/26/2021
Engineering
Changes
635519
Temporarily Exchange A Train and B Train Core Exit
Thermocouples at Reactor Head Penetration 74 (E-15) for
Unit 2
11/17/2021
Miscellaneous
SAMG Diagnostic Process Guideline
2/18/2019
Temporary Configuration Changes
Procedures
Site Capabilities
Corrective Action
Documents
4511236
1A Essential Service Water Pump Flowmeter Data
Inconsistent with Previous Tests
07/15/2022
0BwOS
FP.2.2.M-2
Diesel Driven Fire Pump Surveillance
0BwOSR
5.5.8.CC-1
A IST Requirements for Component Cooling Pump 0CC01P
and Discharge Check Valves
1BwOSR
5.5.8.RH-5A
Group A IST Requirements for Residual Heat Removal
Pump 1RH01PA
1BwOSR
5.5.8.SX-3A
Group A IST Requirements for 1A Essential Service Water
Pump (1SX01PA)
Procedures
BwMP 3305-003
Main Steam Safety Valve Testing Using Setpoint Verification
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Device
BwMSR 3.7.1.1
Main Steam Safety Valve Operability Test (Setpoint
Verification Using the Furmainte Trevitest System)
BwOP RH-2
Securing the RH System for Recirculation
BwOP RH-5
RH System Startup for Recirculation
4865223
Create WR to Install Upgraded Valve for 1SX2183D
08/17/2022
4865224
Create WR to Install Upgraded Valve for 1SX2183B
08/17/2022
22696
Perform Oil Change-Out for Shaft Bearing
07/27/2022
25306
LR-0B Fire Protection Pump Flow and Pressure Test
08/26/2022
25839
Change Grease in CPLG and Perform Inspection of CPLG
Internals
07/27/2022
5142646
UMP Oil Change & Sample, Visually Inspect for Degradation
08/04/2022
5145601
LMB Oil Change & Sample, Visually Inspect for Degradation
08/04/2022
5160505
IST-RT-1MS013S/014S/015S/016S/017S-MSSV Operability
Test
09/28/2022
213824
1SX091B Stem is Bound
08/17/2022
263410
IST-2RH01PA ASME Group A Test & CC-2SI8958A
08/04/2022
270865
LR-ISTFor 1SX002A SRV ReQMTS for 1A Essential
SERVC W
06/21/2022
Work Orders
287229
0B Fire Pump Overheated During PMT Test
09/02/2022
25800
Standing Water in AF Tunnel Lowest Elevation
09/30/2022
25871
OSP-R Water Buildup Around AF Tunnel Dehumidifier
09/30/2022
25890
00-OSP-R: 1A AF Pump Inboard Seal Weeping
09/30/2022
Corrective Action
Documents
25898
OSP-X 1LL1-33 Emergency Light Green 'Ready' Light Bulb
Non On
09/30/2022
1BwOSR 3.7.5.4-
Unit One Diesel Driven Auxiliary Feedwater Pump
Surveillance
1BwOSR
5.5.8.AF-4A
Unit One Comprehensive Inservice Testing (IST)
Requirements for 1A Auxiliary Feedwater Pump
1BwOSR
5.5.8.AF-4B
Unit One Comprehensive Inservice Testing (IST)
Requirements for 1B Auxiliary Feedwater Pump
Procedures
2BwOSR 3.7.5.4-
Unit Two Diesel Driven Auxiliary Feedwater Pump
Surveillance
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2BwOSR 3.8.1.2-
Unit Two 2B Diesel Generator Operability Surveillance
Motor-Operated Valve Program Engineering Procedure
Diagnostic Testing of Motor Operated Valves
MA-AA-723-300-
1005
Review and Evaluation of Motor Operated Valve Test Data
4903613
2SI8920 Motor Operated Valve Diagnostic Testing
Surveillances
09/15/2022
5115059
Electrical Calibration of Steam Generator 2A Narrow Range
Level Loop 2L-0517
07/26/2022
5115063
Electrical Calibration of Steam Generator 2A Narrow Range
Level Loop 2L-0519
07/26/2022
5165923
IST - Unit 1 AF Pumps Comprehensive Full Flow Test and
Equipment Response
09/30/2022
271794
LR-IST-2B D/G Operability Monthly
07/21/2022
277318
LR-OP U-1 Diesel Driven Auxiliary Feedwater Pump Monthly
Run
08/12/2022
Work Orders
279829
OP U-2 Diesel Driven Auxiliary Feedwater Pump Monthly
Run
08/12/2022
Flow Path Could Not Be Established to 0A RW DEMIN
2/06/2020
Radwaste High Level Drum Area Radiation Monitor in Alarm
09/16/2020
Corrective Action
Documents
U1 CAF Tank Needs to be Emptied in Radwaste
07/22/2022
CFR 61 Dry Activated Waste Analysis
05/26/2022
Miscellaneous
CFR 61 Spent Resin Filter Analysis
10/29/2021
NISP-RP-007
Control of Radioactive Material
CFR 37 Material Accountability Program
Procedures
Process Control Program for Radioactive Wastes
RWS21-001
Shipment RWS21-001 UN3321 LSA-II; Resin Liner
P0695283-14 in Cask 14-215.
01/13/2022
RWS22-003
Shipment RWS22-003 UN3321 LSA-II; Resin Liner
P0698226-30 in Cask 14-215.
04/27/2022
Shipping Records
RWS22-005
Shipment RWS22-005 UN2916 Type B; Resin Liner
P0694669-5 in Cask RT-100.
03/17/2022
71151
Miscellaneous
NRC Performance Indicator Data; Mitigating Systems
07/02/2021 -
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Mitigating System Performance Index for Heat Removal
Systems
06/30/2022
NRC Performance Indicator Data; Mitigating Systems
Mitigating System Performance Index for Residual Heat
Removal Systems
07/01/2021 -
06/30/2022
NRC Performance Indicator Data; Mitigating Systems
Mitigating System Performance Index for Cooling Water
Systems
07/01/2021 -
06/30/2022
Collecting and Reporting of NRC Performance Indicator Data
Procedures
Mitigating System Performance Index Data Acquisition and
Reporting
Corrective Action
Documents
4418835
1BwOS TRM 3.3.H.1 Failed Symmetric CETC Temperature
Limits
04/25/2021
BwIP 200-023
Unit One Reactor Head Instrument Cable Reconnect with
40-Pin RVLIS Connectors Installed
0E1
BwIP 2000-014
Unit Two Reactor Head Instrument Cable Reconnect
Procedures
BwIP 2000-024
Reactor Head Instrument Cable Removal with 40-Pin RVLIS
Connectors Installed
1