IR 05000456/2022003

Integrated Inspection Report 05000456/2022003 and 05000457/2022003 and Exercise of Enforcement Discretion

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

October 25, 2022

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. 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 Kozak, Laura on 10/25/22 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: NPF-72 and NPF-77 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 Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Braidwood Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

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

Additional Tracking Items

Type Issue Number Title Report Section Status EDG EA-22-088 Failure to Comply with 10 71124.08 Open CFR Part 37

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.

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,

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

(2) Shipment RWS22-005 UN2916 Type B; Resin Liner P0694669-5 in Cask RT-100

(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 Enforcement Action EA-22-088: Failure to Comply with 10 CFR 71124.08 Discretion Part 37

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) 71152A Following Reactor Refueling 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 Type Designation Description or Title Revision or

Procedure Date

71111.01 Procedures BwOP RH-M1 Operating Mechanical Lineup Unit 1 1A RH Train 14

71111.04 Procedures BwOP CS-E1 Electrical Lineup Unit 1 Containment Spray System 4

Electrical Lineup

BwOP CS-M1 Core Spray Operating Mechanical Lineup Unit 1 12

BwOP FP-E1 Electrical Lineup for the Unit 0 Fire Protection System Unit 2

Operating

BwOP FP-E1 Electrical Lineup for the Unit 0 Fire Protection System Unit 2

Operating

BwOP FP-E2 Electrical Lineup for the Unit 0 Fire Protection System Unit 2E1

Operating

BwOP FP-E3 Unit 0 Electrical Lineup Unit 0 Operating 2

BwOP FP-M1 Operating Mechanical Lineup Unit 0 LSH and Outside Ring 15

HDR Operating

BwOP FP-M6 Operating Mechanical Lineup Unit 0 Auxiliary Building Ring 6

Header Operating

BwOP RH-E1 Residual Heat Removal Electrical Lineup Unit 1 10

71111.05 Fire Plans Pre-Fire Plan No. Fire Zone 11.2-0; Auxiliary Building 346' Elevation Unit 1 2

100 Auxiliary Building General Area (NE)

Pre-Fire Plan No. Fire Zone 11.2-0; Auxiliary Building 346' Elevation Unit 2 4

101 Auxiliary Building General Area (South)

Pre-Fire Plan No. Fire Zone 11.3-0 Center; Unit 2 Auxiliary Building General 2

111 Area (Center)

Pre-Fire Plan No. Fire Zone 11.3-0 South; Unit 1 Auxiliary Building General 2

2 Area (North)

Pre-Fire Plan No. Fire Zone 1.3-0 South; Unit 2 Auxiliary Building General Area 2

113 (South)

Pre-Fire Plan No. Fire Zone 11.4-0; Auxiliary Building 383' Elevation Auxiliary 2

2 Building General Area Center

Pre-Fire Plan No. Fire Zone 11.4-0 North; Auxiliary Building 383' Unit 1, 2

133 Auxiliary Building General Are North

Pre-Fire Plan No. Fire Zone 11.4-0 South; Auxiliary Building 383' Elevation Unit 3

134 2 Auxiliary Building General Area South

Inspection Type Designation Description or Title Revision or

Procedure Date

Pre-Fire Plan No. Fire Zone 11.5-0 Center; AB 401' Unit 2 Auxiliary Building 1

146 General Area Center

Pre-Fire Plan No. Fire Zone 11.6-0; Auxiliary Building 426' Elevation Auxiliary 3

156 Building General Area Center

Pre-Fire Plan No. Fire Zone 11.6-0; Auxiliary Building 426' Elevation Unit 1 3

156 Auxiliary Building General Area North

Pre-Fire Plan No. Fire Zone 11.6-0; Auxiliary Building 426' Elevation Unit 2 2

156 Auxiliary Building General Area South

Pre-Fire Plan No. Fire Zone 11.6C-0; Auxiliary Building 426' Elevation Auxiliary 1

165 Building Laundry Room

Pre-Fire Plan No. Fire Zone 18.12-0; Lake Screen House 602' Elevation 5

24

Pre-Fire Plan No. Fire Zone 5.4-2; Auxiliary Building 451' Elevation, Unit 2 1

Division 22 Miscellaneous Electric Equipment Room and

Battery Room

Pre-Fire Plan No. Fire Zone 5.6-2; Auxiliary Building 451' Elevation, Unit 2 1

Division 21 Miscellaneous Electric Equipment Room and

Battery Room

Procedures ER-BR-600-1069 Site List of High Risk Fire Areas Braidwood Unit 1 and 0

Unit 2

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

71111.06 Miscellaneous CC-AA-201-F-01 Plant Barrier Impairment Permit for 1SXFSO1-3 Access 09/12/2022

Plate during Common Heat Exchanger Work Window

Operability BwAP 1110-3 Plant Barrier Impairment Program 40

Evaluations BwMP 3100-094 Removal and Installation of Flood Seal Opening Barriers 23

Procedures 0BwOA PRI-8 Auxiliary Building Flooding Unit 0 10

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

Matrix

Work Orders 5252064 SX Piping Leakage at the Outlet of U-0 CC HX 09/07/2022

71111.07A Corrective Action 4510738 1B CS Pump Cubicle Cooler Flow 07/12/2022

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

71111.11Q Miscellaneous BR1C23-09.0 Braidwood 1 Cycle 23 Coastdown Reactivity Plan 08/08/2022

Procedures 1BwOSR Group A Inservice Testing Requirements for 1A Safety 12

Inspection Type Designation Description or Title Revision or

Procedure Date

5.5.8.SI-10A Injection Pump (1SI01PA)

BwOP SI-1 Safety Injection System Startup 23

BwOP SI-2 Safety Injection System Shutdown 18

OP-AA-101-111- Operations Standards and Expectations 31

1001

OP-AA-101-113 Operator Fundamentals 16

OP-AA-101-113- 4.0 Crew Critique Guidelines 12

1006

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

OP-AA-300 Reactivity Management 14

OP-BR-108-101- Operations Department Standards and Expectations 54

1002

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

TQ-AA-150 Operator Training Programs 22

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

TQ-AA-201 Examination Security and Administration 18

TQ-AA-306 Simulator Management 11

TQ-BR-201-0113 Braidwood Training Department Simulator Examination 26

Security Actions

71111.12 Corrective Action 4260334 OI Benchmark 2019 NEIL Property Workshop 06/28/2019

Documents 4309174 OTI-FP8023 Temp Indicator Erratic 01/09/2020

20048 Request Additional Vibe Readings Taken During March 02/21/2020

DDFP Run

22158 0FP03PB Diesel Driven Fire Pump JW Heater Leak at Fitting 02/28/2020

4357805 0FP03PB Diesel Driven Fire Pump JW Heater Leak Getting 07/20/2020

Worse

4367479 0B FP Jockey Pump Seal Leakage 09/04/2020

4391511 Abnormal Oil Results for 0FP03PB-CC 12/21/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

4391873 Follow Up Oil Sample 0FP03PB 12/23/2020

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 08/26/2022

Criteria

4519018 0B Fire Pump Exhaust Filling Room 08/26/2022

4519144 Time Clock Will Be Exceeded for BwAP 1110-1A2 08/27/2022

Engineering 636697 Evaluate Freeze Seal on 1SX54AB-3" to Support Work on 05/11/2022

Changes 1SX091B Valve

Miscellaneous Quality Receipt Inspection Package Receipt #251181 for 3" 10/10/2018

Globe Valve

Quality Receipt Inspection Package Receipt #133026 for 04/03/2007

Valve Stem

Quality Receipt Inspection Package Receipt #129199 for 11/21/2006

Valve Disc

Quality Receipt Inspection Package Receipt #114201 for 07/01/2005

Disc Union

Quality Receipt Inspection Package #116114 for Valve Yoke 09/20/2006

and Bushing

Quality Receipt Inspection Package Receipt #251182 for 3" 10/10/2018

Globe Valve Bonnet, and Body

OP-AA-201-004 Attachment 2 Hot Work Permit for Replacement of 08/16/2022

1SX091B Valve

Procedures 1BwOSR 3.7.8.1 Unit One Essential Service Water System Surveillance 22

Work Orders 4865223 Create WR to Install Upgraded Valve for 1SX2183D 08/16/2022

4865224 Create WR to Install Upgraded Valve for 1SX2183B 08/16/2022

Inspection Type Designation Description or Title Revision or

Procedure Date

213824 1S091B Stem is Bound 08/16/2022

71111.13 Corrective Action 4520647 BwOP FC-11 Procedure Change Request Action (PCRA) to 09/04/2022

Documents Add Step to Fill Spent Fuel Pool from 0A Radwaste Monitor

Tank

22241 6 Pipe Diviots Below Backing Ring 09/14/2022

Engineering 636697 1B Containment Spray Pump Cubicle Cooler Return Isolation 05/20/2022

Changes Valve Freeze Seal Assessment

Procedures BwMP 3300-054- Freeze Checklist and Communication Tool 0

F-01

BwOP WX-131 Radwaste Monitor Tank Recirculation 13

CC-AA-403 Maintenance Specification: Selection and Control of Freeze 0

Seal Location

CY-AP-120-330 Spent Fuel Pool/Transfer Canal/Refuel Pool 9

ER-AA-330-009 ASME Section XI Repair/Replacement Program 18

ER-AA-600 Risk Management 7

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

MA-AA-736-610 Application of Freeze Seal to All Piping 13

MA-AA-736-620 Application of Freeze Seal Using Rigid Superfreeze SF-2500 4

OP-AA-107 Integrated Risk Management 4

OP-AA-108-117 Protected Equipment Program 7

OU-AP-200 Administrative Controls During Fuel Handling Activities for 24

Byron and Braidwood

OU-AP-201 New Fuel Receipt and Inspection for Byron, Braidwood, and 18

Ginna

OU-AP-203 Operation of the New Fuel Elevator for Byron and Braidwood 8

OU-AP-204 Fuel Movement in the Spent Fuel Pool for Byron and 16

Braidwood

OU-AP-216 Operation of the Spent Fuel Pool Bridge Crane for Byron and 17

Braidwood

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

Work Orders 5179476 Reactor Services New Fuel Receipt 07/26/2022

287466 Fill the Spent Fuel Pool Utilizing Water from the 0A 08/28/2022

Radwaste Monitor Tank

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.15 Corrective Action 4503733 Reduce Margin for 1A Essential Service Water Pump 06/03/2022

Documents 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 07/15/2022

Inconsistent with Previous Test

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 09/13/2022

Missed

22897 NOS Finding: Fire Rated Assemblies Not Visually Inspected 08/16/2022

Miscellaneous SONARtrac System Performance Report for Commissioning 07/31/2022

of CIDRA Flow Meter

SONARtrac System Performance Report of CEDRA Flow 07/27/2022

Meter Data Following Reduced Margin in 1A Essential

Service Water Pump Differential Pressure

Procedures 1BwOSR Group A IST Requirements for 1A Essential Service Water 19

5.5.8.SX-3A Pump (1SX01PA)

1BwOSR Comprehensive Inservice Test (IST) Requirements for 1A 17

5.5.8.SX-6A Essential Service Water Pump (1SX01PA)

BwAP 1110-1 Fire Protection Program System Requirements 46

BwAP 1110-1 Fire Protection Program System Requirements 46

BwAP 1110-1A1 OGCAR Required Compensatory Measure Action Response 9

Fire Detection Instrumentation

BwAP 1110-1A7 Fire Rated Assemblies Required Compensatory Measures 6

Action Response Cover Sheet

BwMS FP.7.1.E-1 Fire Rated Assemblies Visual Inspection 10

BwMS FP.7.1.E- Fire Rated Assemblies Visual Inspection Accessible Areas 7

Inspection Type Designation Description or Title Revision or

Procedure Date

1A0 (CM-1) Data Sheets

NO-AA-210 Nuclear Oversite Regulator Audit Procedure 10

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

1006

OP-AA-108-111 Adverse Condition Monitoring and Contingency Planning 17

Work Orders 1451512 U2 CETC, Nozzle 77 Connections Swapped Affecting 12/12/2012

Indications

4419609 U1 CETC, Nozzle 74 Connections Swapped Affecting 04/28/2021

Indications

24250 U1 CETC, Nozzle 74 Connections Swapped Affecting 05/18/2021

Indications

4458973 U2 CETC, Nozzle 74 Connections Swapped Affective 11/05/2021

Indications

266841 1FE-SX146 1A Essential Service Water Pump Flow Meter 08/03/2022

71111.18 Engineering 634192 Temporarily Exchange A Train and B Train Core Exit 05/26/2021

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

Unit 1

635519 Temporarily Exchange A Train and B Train Core Exit 11/17/2021

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

Unit 2

Miscellaneous SAMG Diagnostic Process Guideline 02/18/2019

Procedures CC-AA-112 Temporary Configuration Changes 30

SAMG TSG-3 Site Capabilities 0

71111.19 Corrective Action 4511236 1A Essential Service Water Pump Flowmeter Data 07/15/2022

Documents Inconsistent with Previous Tests

Procedures 0BwOS Diesel Driven Fire Pump Surveillance 18

FP.2.2.M-2

0BwOSR A IST Requirements for Component Cooling Pump 0CC01P 9

5.5.8.CC-1 and Discharge Check Valves

1BwOSR Group A IST Requirements for Residual Heat Removal 23

5.5.8.RH-5A Pump 1RH01PA

1BwOSR Group A IST Requirements for 1A Essential Service Water 19

5.5.8.SX-3A Pump (1SX01PA)

BwMP 3305-003 Main Steam Safety Valve Testing Using Setpoint Verification 12

Inspection Type Designation Description or Title Revision or

Procedure Date

Device

BwMSR 3.7.1.1 Main Steam Safety Valve Operability Test (Setpoint 15

Verification Using the Furmainte Trevitest System)

BwOP RH-2 Securing the RH System for Recirculation 17

BwOP RH-5 RH System Startup for Recirculation 29

Work Orders 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 07/27/2022

Internals

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 09/28/2022

Test

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 06/21/2022

SERVC W

287229 0B Fire Pump Overheated During PMT Test 09/02/2022

71111.22 Corrective Action 4525800 Standing Water in AF Tunnel Lowest Elevation 09/30/2022

Documents 4525871 OSP-R Water Buildup Around AF Tunnel Dehumidifier 09/30/2022

25890 00-OSP-R: 1A AF Pump Inboard Seal Weeping 09/30/2022

25898 OSP-X 1LL1-33 Emergency Light Green 'Ready' Light Bulb 09/30/2022

Non On

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

Surveillance

1BwOSR Unit One Comprehensive Inservice Testing (IST) 17

5.5.8.AF-4A Requirements for 1A Auxiliary Feedwater Pump

1BwOSR Unit One Comprehensive Inservice Testing (IST) 22

5.5.8.AF-4B Requirements for 1B Auxiliary Feedwater Pump

2BwOSR 3.7.5.4- Unit Two Diesel Driven Auxiliary Feedwater Pump 26

Surveillance

Inspection Type Designation Description or Title Revision or

Procedure Date

2BwOSR 3.8.1.2- Unit Two 2B Diesel Generator Operability Surveillance 51

ER-AA-302 Motor-Operated Valve Program Engineering Procedure 9

MA-AA-723-300 Diagnostic Testing of Motor Operated Valves 14

MA-AA-723-300- Review and Evaluation of Motor Operated Valve Test Data 3

1005

Work Orders 4903613 2SI8920 Motor Operated Valve Diagnostic Testing 09/15/2022

Surveillances

5115059 Electrical Calibration of Steam Generator 2A Narrow Range 07/26/2022

Level Loop 2L-0517

5115063 Electrical Calibration of Steam Generator 2A Narrow Range 07/26/2022

Level Loop 2L-0519

5165923 IST - Unit 1 AF Pumps Comprehensive Full Flow Test and 09/30/2022

Equipment Response

271794 LR-IST-2B D/G Operability Monthly 07/21/2022

277318 LR-OP U-1 Diesel Driven Auxiliary Feedwater Pump Monthly 08/12/2022

Run

279829 OP U-2 Diesel Driven Auxiliary Feedwater Pump Monthly 08/12/2022

Run

71124.08 Corrective Action AR 04315942 Flow Path Could Not Be Established to 0A RW DEMIN 02/06/2020

Documents AR 04369760 Radwaste High Level Drum Area Radiation Monitor in Alarm 09/16/2020

AR 04513257 U1 CAF Tank Needs to be Emptied in Radwaste 07/22/2022

Miscellaneous 10 CFR 61 Dry Activated Waste Analysis 05/26/2022

CFR 61 Spent Resin Filter Analysis 10/29/2021

Procedures NISP-RP-007 Control of Radioactive Material 1

RP-AA-500-1003 10 CFR 37 Material Accountability Program 5

RW-AA-100 Process Control Program for Radioactive Wastes 12

Shipping Records RWS21-001 Shipment RWS21-001 UN3321 LSA-II; Resin Liner 01/13/2022

P0695283-14 in Cask 14-215.

RWS22-003 Shipment RWS22-003 UN3321 LSA-II; Resin Liner 04/27/2022

P0698226-30 in Cask 14-215.

RWS22-005 Shipment RWS22-005 UN2916 Type B; Resin Liner 03/17/2022

P0694669-5 in Cask RT-100.

71151 Miscellaneous NRC Performance Indicator Data; Mitigating Systems 07/02/2021 -

Inspection Type Designation Description or Title Revision or

Procedure Date

Mitigating System Performance Index for Heat Removal 06/30/2022

Systems

NRC Performance Indicator Data; Mitigating Systems 07/01/2021 -

Mitigating System Performance Index for Residual Heat 06/30/2022

Removal Systems

NRC Performance Indicator Data; Mitigating Systems 07/01/2021 -

Mitigating System Performance Index for Cooling Water 06/30/2022

Systems

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

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

Reporting

71152A Corrective Action 4418835 1BwOS TRM 3.3.H.1 Failed Symmetric CETC Temperature 04/25/2021

Documents Limits

Procedures BwIP 200-023 Unit One Reactor Head Instrument Cable Reconnect with 0E1

40-Pin RVLIS Connectors Installed

BwIP 2000-014 Unit Two Reactor Head Instrument Cable Reconnect 1

BwIP 2000-024 Reactor Head Instrument Cable Removal with 40-Pin RVLIS 1

Connectors Installed

23