IR 05000456/2022004

Integrated Inspection Report 05000456/2022004 and 05000457/2022004

ML23025A107
Person / Time
Site:	Braidwood
Issue date:	01/26/2023
From:	Hironori Peterson NRC/RGN-III/DORS/RPB3
To:	Rhoades D Constellation Energy Generation, Constellation Nuclear
References
IR 2022004
Download: ML23025A107 (1)

Text

January 26, 2023

SUBJECT:

BRAIDWOOD STATION - INTEGRATED INSPECTION REPORT 05000456/2022004 AND 05000457/2022004

Dear David Rhoades:

On December 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Braidwood Station. On January 18, 2023, the NRC inspectors discussed the results of this inspection with J. Petty, Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.

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

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Signed by Peterson, Hironori on 01/26/23 Hironori Peterson, Chief Reactor Projects 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: 05000456/2022004 and 05000457/2022004 Enterprise Identifier: I-2022-004-0044 Licensee: Constellation Energy Generation, LLC Facility: Braidwood Station Location: Braceville, IL Inspection Dates: October 01, 2022 to December 31, 2022 Inspectors: R. Bowen, Illinois Emergency Management Agency A. Demeter, Project Engineer G. Edwards, Health Physicist E. Fernandez, Senior Reactor Inspector D. Kimble, Senior Resident Inspector P. Smagacz, Resident Inspector Approved By: Hironori Peterson, Chief Reactor Projects 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 URI 05000456/2022004-01 Startup from Braidwood 71111.20 Open Unit 1 Refueling Outage A1R23 with 1A Main Steam Isolation Valve (MSIV)

Closed

PLANT STATUS

Unit 1 began the inspection period at approximately 80 percent power, with the unit at the end of the nuclear fuel cycle and in power coast down operations in preparation for a planned refuel outage. On October 3, 2022, the reactor was shut down for planned Refuel Outage A1R23.

Following refueling and other maintenance activities, the reactor was restarted and made critical on October 19, 2022. On October 20, 2022, the reactor was subsequently shut down again to facilitate maintenance activities on the 1A Main Steam Isolation Valve. (See Unresolved Item

===2022004-01 in the Inspection Results section of this report for additional details.) The reactor was restarted later that same day and the main electrical generator was synchronized to the power grid on October 21, 2022. The unit achieved full power operation on October 25, 2022, and remained operating at or near full power for the remainder 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.

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP section 03.01) ===

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures during the weeks ending November 19 through November 26, 2022.

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 severe winter storm during the week ending

===December 17, 2022.

External Flooding Sample (IP section 03.03) (1 Sample)===

(1) The inspectors reviewed and evaluated selected flood protection barriers, mitigation plans, procedures, and equipment to verify that they were consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding during the week ending December 24, 2022.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP section 03.01) (3 Samples)

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

(1) The 1A and 1B Residual Heat Removal (RH) Trains during unit 1 Refuel Outage A1R23 during the week ending October 8, 2022.

(2) The 1A Emergency Diesel Generator (EDG) while protected as a risk-significant component to support the unit 1 shutdown cooling function during the Refuel Outage A1R23 during the week ending October 8, 2022.

(3) The unit 1 spent fuel pool cooling system during Refuel Outage A1R23 during the week ending October 15, 2022.

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

(1) The inspectors reviewed and evaluated system configurations during a complete physical alignment verification of the unit 1 Containment Spray (CS) system during Refuel Outage A1R23. This was the completion of the partial sample for the unit 1 CS system previously documented during the 3rd Quarter of 2022. The inspectors' activities were concluded during the week ending October 8, 2022.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP section 03.01) (6 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting physical inspections and performing reviews to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Fire Zone 18.3-1: unit 1 Main Steam and Auxiliary Feed Pipe Tunnel, during preparations for valve removal and replacement during the week ending October 8, 2022.

(2) Fire Zones 1.1-1 and 1.2-1: unit 1 Containment, 377' Elevation - Inside and Outside Missile Barrier, during the week ending October 8, 2022.

(3) Fire Zone 1.3-1: unit 1 Containment, 426' Elevation - Containment Upper Area, during the week ending October 8, 2022.

(4) Fire Zone 1.2-1: unit 1 Containment, 401' Elevation - unit 1 Annular Area, during the week ending October 22, 2022.

(5) Fire Zone 9.2-2: 2A EDG Room, 401' Elevation, during the week ending November 5, 2022.

(6) Fire Zone 11.4-0: unit 1 Auxiliary Building, 383' Elevation, during welding on the Auxiliary Feedwater (AF) crosstie flush hardline, as documented in Work Order (WO)

===5230135 during the week ending November 28, 2022.

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP section 03.01) ===

The inspectors reviewed and evaluated internal flooding mitigation protections for the following areas of the station:

(1) The unit 1 Turbine Building basement during the week ending November 5, 2022.

(2) The Lake Screen House during the week ending November 26, 2022.

71111.08P - Inservice Inspection Activities (PWR) PWR Inservice Inspection Activities Sample (IP section 03.01)

(1) The inspectors verified that the reactor coolant system boundary, steam generator tubes, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from 10/03/2022 to 10/14/2022:

03.01.a - Nondestructive Examination and Welding Activities.

Ultrasonic Examination (UT) of Elbow-to-Pipe Component ID 1-MS-06-30 Ultrasonic Examination (UT) of Elbow-to-Pipe Component ID 1-MS-06-31 Ultrasonic Examination (UT) of Elbow-to-Pipe Component ID 1-MS-06-32 Welding of Replacement Valve 1FW079B (W/O# 05179024-18)

Phased Array Ultrasonic Testing (PAUT) Pipe-to-Pipe weld Component ID 1FW079D 03.01.b - Pressurized-Water Reactor Vessel Upper Head Penetration Examination Activities.

Visual Examinations (VE) of 79 penetrations on the Reactor Vessel Closure Head (RVCH)

Ultrasonic Testing (UT) of 78 penetrations on the RVCH Liquid Penetrant (PT) examination of RVCH Penetration No. 69 03.01.c - Pressurized-Water Reactor Boric Acid Corrosion Control Activities.

Evaluation 04517560-02/04492850-05 Boric Acid Leak on 1A Regen Hx CHG Outlet Isolation Valve, 1CV8321A 03.01.d - Pressurized-Water Reactor Steam Generator Tube Examination Activities.

Eddy Current (ET) testing of 6601 steam generator tubes in steam generator A ET testing of 6593 steam generator tubes in steam generator B ET testing of 6617 steam generator tubes in steam generator C ET testing of 6632 steam generator tubes in steam generator D

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

Requalification Examination Results (IP section 03.03) (1 Sample)

(1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam administered between August 19 and September 16, 2022. Eleven crews and fifty-nine individual operators were examined. Two operators who presently have an inactive license due to temporary medical conditions will be examined when they are medically fit and prior to reactivating their licenses.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP section 03.01)

(1 Sample)

The inspectors observed and evaluated the following licensed operator activities in the control room:

(1) Various activities involving on-watch operations crews. These activities included, but were not limited to:

Selected portions of the shutdown of unit 1 for Refuel Outage A1R23, during the week ending October 8, 2022.

Selected portions of the cooldown of unit 1 for Refuel Outage A1R23, during the week ending October 8, 2022.

Selected portions of the reactor coolant system (RCS) drain to reduced inventory in support of Refuel Outage A1R23 reactor vessel head lift, during the week ending October 8, 2022.

Selected portions of the RCS and unit 1 containment refuel cavity flood up for Refuel Outage A1R23, during the week ending October 8, 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 evaluated scenario involving a crew of licensed operators was observed in facility's simulator on November 15, 2022.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP section 03.01) (2 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure that selected structures, systems, and components (SSCs) remain capable of performing their intended functions. The following SSCs and/or maintenance activities were reviewed:

(1) A maintenance effectiveness review associated with the licensee's ongoing monitoring program for control rod drive mechanism (CRDM) thermal sleeves on unit 1 was conducted during the weeks ending October 15 through October 30, 2022.

(2) A maintenance effectiveness review associated with the licensee's bolting practices for the 1(2)CV8321A&B, Regenerative Heat Exchanger Outlet Isolations Valves, as documented in Issue Report (IR) 4527583, was conducted during the weeks ending November 5 through December 24, 2022.

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP section 03.01) (2 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 plant risk associated with the changing of operating modes utilizing the provisions of Technical Specification (TS) 3.0.4.b while conducting unit 1 plant heatup for Refuel Outage A1R23, as documented in BW-MODE-033 during the week ending October 22, 2022.

(2) Evaluation of the planned work associated with leak repairs to the 1RC8040C Hot Leg Loop Drain, as documented in WO 5141755 during the week ending October 22, 2022.

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP section 03.01) (4 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 unit 1 source range nuclear instruments following anomalous indications, as documented in IR 4527206 during the weeks ending October 8 through November 5, 2022.

(2) Evaluation of the operability of various unit 1 emergency core cooling system valve relays following outage testing issues, as documented in IRs 4526618 and 4526631 during the weeks ending October 8 through November 12, 2022.

(3) Evaluation of the operability of the 1B EDG following its trip on overspeed during Refuel Outage A1R23 governor testing, as documented in IR 4528007 during the weeks ending October 15 through November 5, 2022.

(4) Evaluation of the operability of the 1B EDG following identification of potential fuel rack binding issues during Refuel Outage A1R23 testing, as documented in IR 4528116 during the weeks ending October 15 through November 5, 2022.

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP section 03.01 and/or 03.02)

(1 Sample)

The inspectors reviewed and evaluated the following permanent change to the facility:

(1) Engineering Change (EC) 624258: Upgrade Existing Automatic Voltage Regulator (AVR) with Digital ABB Unitrol Model, during the weeks ending October 15 through October 29, 2022.

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP section 03.01) (12 Samples)

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

(1) Functional and operational testing of the 1B EDG following electrical governor replacement during Refuel Outage A1R23, as documented in WOs 4986514 and

===5293773 during the weeks ending October 15 through 22, 2022.

(2) Functional and operational testing of the unit 1 main electrical generator AVR following replacement during Refuel Outage A1R23, as documented in WO 4589156 and SP 22-001 during the week ending October 22, 2022.

(3) Low power startup physics testing following reloading of the unit 1 reactor core for Operating Cycle No. 24, as documented in WOs 5148475 and 5149407 during the week ending October 22, 2022.

(4) Functional and operational testing of the digital rod position indication (DRPI) system following reactor reassembly from Refuel Outage A1R23, as documented in WO 5146416 during the week ending October 22, 2022.

(5) unit 1 core alignment verification activities following reactor refueling, as documented in WOs 5162111 and 5144600 during the week ending October 22, 2022.

(6) Functional and operational testing of the 1D Main Steam Isolation Valve (MSIV),1MS001D, following troubleshooting during Refuel Outage A1R23, as documented in IR 4530461 during the week ending October 22, 2022.

(7) Functional and operational testing of the 1B AF Pump following outage maintenance, as documented in WOs 4986652 and 5180994 during the weeks ending October 22 through October 29, 2022.

(8) Automatic rod drop time testing following unit 1 Refuel Outage A1R23 reactor reassembly, as documented in WO 5160060 during the week ending October 29, 2022.

(9) Functional and operational testing for the 1A MSIV, 1MS001A, following repairs to the hydraulic system during Refuel Outage A1R23, as documented in WO 53002865 during the weeks ending October 22 through November 5, 2022.

(10) Functional and operational testing of various electrical relays for the 2A EDG following performance of an extended 6-year EDG maintenance work window, as documented in WOs 4794002, 1599520, and 4794003 during the week ending November 5, 2022.

(11) Functional and operational testing of the station's temporary fire pump, following its installation to support an extended maintenance and repair outage for the site's installed diesel-driven fire pump, as documented in Procedure FP-50 during the week ending November 12, 2022.

(12) System leakage testing at normal operating primary pressure and temperature (NOP/NOT) following return of the unit 1 RCS to operation after reactor refueling, as documented in WOs 5162130 and 5162134 during the weeks ending November 12 through November 19, 2022.

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP section 03.01) ===

(1) The inspectors reviewed licensee activities and evaluated licensee performance associated with unit 1 Refuel Outage A1R23, during the weeks ending October 8 through October 22, 2022. An unresolved item (URI) associated with the station's performance during unit 1 restart at the end of the outage is documented in the Results section of this report.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:

Surveillance Tests (other) (IP section 03.01) (3 Samples)

(1) Semiannual 1A EDG fast start surveillance test, as documented in WOs 5261230 and

===5299750 during the week ending October 29, 2022.

(2) Regularly scheduled monthly 1A EDG surveillance test performed after experiencing issues with the 1A EDG lube oil system in November 2022, as documented in WO 5316998 during the week ending December 31, 2022.

(3) Observation and review of selected elements of the unit 1 and unit 2 Modes 1, 2, and 3 Shiftly and Daily Operating Surveillance by licensed operators in the main control room during the week ending December 31, 2022.

Inservice Testing (IP section 03.01) ===

(1) Inservice Testing for unit 1 Safety Injection Pumps and Safety Injection System Check Valves, as documented in WOs 5154224 and 5154249 during the week ending October 8, 2022.

Containment Isolation Valve Testing (IP section 03.01) (1 Sample)

(1) Reactor Coolant Drain Tank containment isolation valve stroke surveillance for 1RE9157, as documented in WO 4986536 during the week ending October 15, 2022.

71114.04 - Emergency Action Level and Emergency Plan Changes

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

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

Evaluation No. 21-72, Emergency Action Levels for Braidwood Station, January 20, 2022 This evaluation does not constitute NRC approval.

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (IP section 03.01) (1 Sample)

(1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.

Instructions to Workers (IP section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.

Contamination and Radioactive Material Control (IP section 03.03) (2 Samples)

The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:

(1) Licensee surveys of potentially contaminated material leaving the Radiological Controlled Area.

(2) Workers exiting the unit 1 containment access facility during the refueling outage.

Radiological Hazards Control and Work Coverage (IP section 03.04) (4 Samples)

The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:

(1) Reactor head removal and reinstallation of the upper internals and the flange inspection activities.

(2) In-Core sump inspection activities.

(3) Reactor cavity decontamination activities.

(4) Reactor vessel head penetration 69 repair actives.

High Radiation Area and Very High Radiation Area Controls (IP section 03.05) (3 Samples)

The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:

(1) Steam generator platforms during eddy current testing.

(2) Sandbox covers in the reactor cavity.

(3) Reactor vessel head penetrations area.

Radiation Worker Performance and Radiation Protection Technician Proficiency (IP section 03.06) (1 Sample)

(1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP section 02.10) ===

(1) Unit 1 (September 1, 2021 through September 30, 2022)

(2) Unit 2 (September 1, 2021 through September 30, 2022)

BI02: RCS Leak Rate Sample (IP section 02.11) (2 Samples)

(1) Unit 1 (October 1, 2021 through September 30, 2022)

(2) Unit 2 (October 1, 2021 through September 30, 2022)

OR01: Occupational Exposure Control Effectiveness Sample (IP section 02.15) (1 Sample)

(1) September 1, 2021 through September 31, 2022 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP section 02.16) (1 Sample)

(1) September 1, 2021 through September 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 a steam leak from the unit 1, train A, Regenerative Heat Exchanger Outlet Isolation Valve (1CV8321A), as documented in IR 4492850 during the week ending November 28, 2022. Specific elements of the inspectors' review are documented in an observation in the Results section of this report.

71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (section 03.02)

(1) The inspectors conducted a semiannual review of the licensees CAP for potential adverse trends that might be indicative of a more significant safety concern during the weeks ending December 3 through December 24, 2022. A specific trend related to certain issues involving the timely completion of surveillance testing requirements is documented in the Results section of this report.

71153 - Follow-Up of Events and Notices of Enforcement Discretion Reporting (IP section 03.05)

The inspectors reviewed and evaluated the following licensee event notification (EN) made by the station to the NRC Headquarters Operations Center:

(1) Review and assessment of the licensee's non-emergency report made under 10 CFR 50.72(b)(3)(ii)(A) for unacceptable indications identified on unit 1 Control Rod Drive Mechanism Penetration No. 69, as documented in NRC EN 56153 during the week ending October

INSPECTION RESULTS

Unresolved Item Startup from Braidwood Unit 1 Refueling Outage A1R23 71111.20 (Open) with 1A Main Steam Isolation Valve (MSIV) Closed URI 05000456/2022004-01

Description:

On October 19, 2022, during unit 1 plant startup from Braidwood Refueling Outage A1R23, the licensee was experiencing technical difficulties with the 1A Steam Generator (SG) Main Steam Isolation Valve (MSIV) hydraulic operating system. The unit 1 reactor was restarted and made critical at 1:10 p.m. (all times noted are Central Daylight Time - CDT), and low power reactor physics testing was commenced with reactor power stable in the intermediate range - below the point where reactor power would add heat to the reactor coolant system. As the dayshift outage activities wrapped up, the inspectors departed the station for the day with the understanding that the licensee fully intended to complete repairs on the 1A MSIV, perform the requisite testing on the valve, and then place it in its normally open at-power position before raising unit 1 power into the power range.

As difficulties with the 1A MSIV continued, the licensees schedule for completing the A1R23 Refuel Outage on unit 1 began to slip. Shortly after evening shift turnover on October 19, 2022, licensee personnel made a decision to raise unit 1 power with the 1A MSIV closed and the 1A MSIV Bypass Valve open. A target power of approximately 10 percent was selected in order to support scheduled testing for a newly installed main turbine electrical generator automatic voltage regulator. Unit 1 entered MODE 1 operation at 8:34 p.m.

During the evening of October 19, 2022, as control room operators attempted to raise unit 1 power to towards the target value of 10 percent, control of 1A SG level and pressure became more and more problematic. While unit 1 suffered no significant adverse effects, the 1A SG power-operated relief valve (PORV) did reach its actuation setpoint and lift several times. Recognizing that control of the plant was untenable in this configuration, licensee management made the decision to reduce power and stabilize unit 1. At 12:31 a.m. on October 10, 2022, unit 1 returned to operation in MODE 2, and the inspectors were informed of the event by licensee management later that morning following arrival at the site.

Ultimately, the licensee completed repairs to the 1A MSIV hydraulic systems on October 20, 2022. At 2:44 p.m. on that day, the licensee returned unit 1 to MODE 3 in order to open and test the 1A MSIV in accordance with established plant procedures.

On November 10, 2022, station management approved the charter for a formal corrective action program (CAP) causal evaluation to look into the event, with a specific focus on the decision-making process that was employed during the evening of October 19, 2022. The licensees decision to move forward with unit 1 operation at power with the 1A MSIV closed raises a number of questions. These include, but are not limited to:

How did the licensee justify accepting deviations from step F.4, MSIV Position for Startup, of station procedure 1BwGP 100-2, Plant Startup, as well as the prerequisites called out in section C of procedure BwOP MS-9, Opening the Main Steam Isolation Valves? What were the bases for these deviations?

The 1A MSIV provides steam flow through a 30.25-inch line and the 1A MSIV Bypass Valve only supports steam flow through a 4-inch line; how did licensee personnel justify placing the plant in this configuration with no formal or documented review by the stations Engineering Department?

Why were on-watch licensed operators in the unit 1 main control room not afforded the opportunity for additional training in the stations simulator prior to moving forward with operating the plant in such an unusual configuration?

Why did a focused test case that was run in the plant simulator by previously licensed personnel assigned to the stations Training Department fail to identify issues with the ability to control 1A SG steam pressure as power was increased, or the fact that the 1A SG PORV would reach its actuation setpoint and lift?

Planned Closure Actions: The issues surrounding the licensees decision to startup from Braidwood unit 1 Refueling Outage A1R23 with the 1A MSIV closed are considered unresolved pending the inspectors receipt and review of the licensees formal causal evaluation. At the end of the inspection period, the licensee planned to complete this evaluation early in the 1st Quarter of 2023.

Licensee Actions: As noted above, a licensee formal causal evaluation into the circumstances surrounding this event was in progress at the end of the inspection period. No additional licensee actions are necessary at this time.

Corrective Action References:

IR 4531005: 1A Steam Generator PORV Lift IR 4530477: OSP-A: 1A MSIV Failed to Open Observation: Development of Steam Leak on 1CV8321A, 1A Regenerative Heat 71152A Exchanger Outlet Isolation Valve, During the Operating Cycle The inspectors performed a detailed review of Issue Report (IR) 4492850, 1CV8321A Steam Leak. On April 13, 2022, during Operating Cycle 23 on unit 1, a steam leak was identified on the 1A Regenerative Heat Exchanger Outlet Isolation Valve, 1CV8321A. The exact origin of the steam plume could not be identified due to a buildup of boric acid deposits on the valve, but based on various visual clues, was believed by station personnel to be originating from the body-to-bonnet bolted mechanical joint on the valve. The steam leak resulted in increased unidentified leakage and derived air concentration readings within the unit 1 containment.

IR 4414126, 01-OSP-A A1R22 Mode 3 BACC W/D - 1CV8321A Body-Bonnet Leak, was previously written on April 5, 2021, identifying a minor, inactive boric acid leak on the body-to-bonnet connection of the same valve. In response to this IR, Work Order (WO)05142152, 01-OSP-A A1R22 Mode 3 BACC W/D - 1CV8321A Body-Bonnet Leak, was generated to clean and retorque the valves body-to-bonnet fasteners. When the valve was retorqued and no movement was observed, a gasket replacement was recommended. The replacement of the gasket was deferred, based on licensee engineering judgment, until A1R23.

As discussed in the stations Technical Specification (TS) Bases, the regenerative heat exchanger is a component within the reactor coolant system (RCS) and is therefore subject to RCS operational leakage limits in order to prevent compromises in safety, up to and including loss of coolant accidents. The inspectors chose this issue for an in-depth review of the licensees actions within their corrective action program (CAP) because of the inherent safety significance associated with the potential of increased leakage from 1CV8321A exceeding the RCS leakage limits specified in TS 3.4.13.

The inspectors examined the licensees corrective actions related to the identification of the boric acid leak on 1CV8321A in an effort to determine whether or not the deferment of the gasket replacement was consequential to the development of an active steam leak in the valve. Specific licensee actions targeting this event included the creation of a Technical Skills Alert for Mechanical Maintenance personnel and a request for additional training. While the inspectors did not identify any performance deficiencies with the licensees CAP actions that were taken, several specific observations related to this issue were worthy of note:

In IR 4414126, under the initial screening questions section, it is stated that the leak cannot be defined as minor leakage per ER-AP-331, Boric Acid Corrosion Control (BACC) Program. However, it is later noted within the same IR that the leak is considered a special case of minor BACC leakage.

In IR 4414126, the component materials are characterized as all being made from corrosion resistant stainless steel, so no further evaluation is required. A year later in IR 4492850 when the steam leak was discovered, it is again ascertained that the entire valve, including all components, are made of stainless steel. However, several weeks later in June, additional information is provided within the comments of IR 4492850 documenting the discovery that the yoke of the valve is made of carbon steel in contradiction to what was written in the body of the IR. Ultimately, the licensees technical staff concluded that this was acceptable since the yoke was painted to protect it from the effects of the boric acid.

The gasket and other materials that were removed and replaced during the disassembly of 1CV8321A during Refuel Outage A1R23 were not retained. This precluded additional examination as part of the licensees CAP that could have been performed in an effort to deduce the damage done to components, the cause of any damage, or provide insight into the cause of the loosened fasteners that were identified during the maintenance as documented in IR 4527583, OSP-A I.R. to document as found condition of 1CV8321A.

Finally, it is reasonable to assume that a conservative decision by the licensee to have disassembled the valve and preemptively replaced the gasket prior to the commencement of unit 1 Operating Cycle 23 could have prevented the increase in unidentified leakage that occurred during the cycle. This was, therefore, a missed opportunity by the licensees staff that may warrant additional study and/or review.

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

Observation: Trend in the Timely Completion of Surveillance Tests/Procedures 71152S The inspectors performed a review of plant issues, particularly those entered into the licensees corrective action program (CAP) over the past several months. During their review, the inspectors noted an adverse trend involving the timely completion of surveillance tests/procedures. Specific CAP entries reviewed by the inspectors included, but were not limited to:

- IR 4469855; Surveillance Closed Out in PassPort with Work Not Performed

- IR 4504261; 1/2SX005 Exercise Frequency Correction

- IR 4522197; IST Non-Compliance 2RF027 Fail Safe Test

- IR 4522164; NOS ID: Fire Rated Assembly Visual Inspections were Missed While each of these individual issues had its own unique and distinct cause, in all cases the Stations Operations Department was forced to take emergent actions to rectify the errors involved. The inspectors did note that a common theme involving insufficient attention to detail and planning rigor was common to all of the occurrences. Braidwood Stations Technical Specification (TS), Surveillance Requirement (SR) 3.0.3, lists the conditions and provisions applicable for addressing missed/tardy surveillance requirements, which includes an allowable delay period for the requirement to declare that the TS Limiting Condition for Operation (LCO) hasnt been met. The Bases for TS SR 3.0.3 states, in part:

The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the surveillance, the safety significance of the delay in completing the required surveillance, and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the requirements.

The TS SR 3.0.3 Bases further goes on to state:

Failure to comply with specified frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used repeatedly to extend surveillance intervals.

In the cases reviewed, since the licensee was able to rapidly perform the surveillances and testing required with the provisions of TS SR 3.0.3, the inspectors did not identify any findings or violations of NRC requirements of more than minor safety significance in the course of this review. However, increased efforts might be necessary to ensure that the licensees use of the provisions of TS SR 3.0.3 remains an infrequent occurrence, as noted in the TS SR 3.0.3 Bases. The licensee generated IR 4527990; Trend in Completion of Surveillances in Correct Timeframe, within the stations CAP to drive additional station reviews into this issue.

EXIT MEETINGS AND DEBRIEFS

The inspectors confirmed that proprietary information was controlled to protect from public disclosure.

On January 18, 2023, the inspectors presented the integrated inspection results to J. Petty, Plant Manager, and other members of the licensee staff.

On October 14, 2022, the inspectors presented the radiation protection inspection results to G. Gugle, Site Vice President, and other members of the licensee staff.

On October 14, 2022, the inspectors presented the inservice inspection results to G. Gugle, Site Vice President, and other members of the licensee staff.

On November 28, 2022, the inspectors presented the emergency action level and emergency plan changes inspection results to M. Spillie and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Corrective Action 4523772 U-2 CAF Tank 'B' Winter Readiness 09/21/2022

Documents 4532744 0B PWST Level Transmitter Heat Trace 10/27/2022

4538315 1VV69AF Does Not Work 11/21/2022

Miscellaneous Letter from Greg Gugle, Site Vice President to Marri- 11/15/2022

Marchionda Palmer, Senior Vice President Midwest

Operations Exelon Nuclear, 2023 Winter Readiness

Certification

Letter from Mr. Glen Kaegi to NRC; Mitigating Strategies 06/30/2016

Flood Hazard Assessment (MSFHA) Submittal

Letter from NRC to Mr. Bryan

C. Hansen; Braidwood Station, 11/28/2016

Units 1 and 2 - Flood Hazard Mitigation Strategies

Assessment (CAC Nos. MF7898 and MF7899)

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

0BwOS SFT-A2a Unit Common Station Heat Area Heaters Freezing 9

Temperature Equipment Protection Surveillance

0BwOS XFT-A1 Unit Common Freezing Temperature Equipment Protection 21

Surveillance

0BwOS XFT-A2b unit Common Station Heat Area Heaters Freezing 7

Temperature Equipment Protection Surveillance

0BwOS XFT-A3 Unit Common Cold Weather Surveillance 14

0BwOS XFT-A4 Unit Common Freezing Temperature Equipment Protection 13

Inside Surveillance

0BwOS XFT-A5 unit Common Freezing Temperature Equipment Protection 30

Out Building Surveillance

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

OP-AA-108-107- Station Response to Grid Capacity Conditions 9

1001

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

1001

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

WC-AA-107 Seasonal Readiness 25

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

Inspection Type Designation Description or Title Revision or

Procedure Date

Electrical Lineup

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

BwOP DG-E1 Electrical Lineup - Unit 1 1A Diesel Generator 7

BwOP DG-M1 Operating Mechanical Lineup Unit 1 1A D/G 17

BwOP FC-E1 Electrical Lineup - Unit 1 Lineup Operating 1

BwOP FC-M1 Operating Mechanical Lineup Unit 1 10

BwOP RH-E1 Electrical Lineup - Unit 1 Operating 10

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

BwOP RH-M2 Operating Mechanical Lineup Unit 1 1B RH Train 10

71111.05 Fire Plans Pre-Fire Plan No. Containment 377'-0" Elevation Unit 1 Annular Area 1

1; Fire Zone 1.1-1

Pre-Fire Plan No. Auxiliary Building 383' Elevation Unit 1, Auxiliary Building 2

133; Fire Zone General Area - North

11.4-0 North

Pre-Fire Plan No. Unit 1, Main Steam and Auxiliary Feed Pipe Tunnel 1

203; Fire Zone

18.3-1

Pre-Fire Plan No. Containment 377'-0" Elevation Unit 1 Annular Area 1

5; Fire Zone 1.2-1

Pre-Fire Plan No. Containment 401'-0" Elevation Unit 1 Annular Area 1

6; Fire Zone 1.2-1

Pre-Fire Plan No. Containment 426'-0" Elevation Unit 1 Containment Upper 2

9; Fire Zone 1.3-1 Area

Pre-Fire Plan No. DG 401' Elevation Diesel Generator Room 2A and Day Tank 2

91; Fire Zone 9.2- Room

2, 9.3-2

Procedures OP-AA-201-008 Pre-Fire Plan Manual 6

71111.06 Drawings A-121 Turbine Building Basement Floor Plan Area 6 Unit-1 AF

Plumbing Turbine Building Basement Diagram Elevation O

369-0 Areas 5 Thru 8

M-19 General Arrangement Lake Screen House Units 1 and 2 G

M-906 Essential Service Water Lake Screen House AC

Procedures BwAP 1110-3 Plant Barrier Impairment Program 40

CCAA-201 Plant Barrier Control Program 14

Inspection Type Designation Description or Title Revision or

Procedure Date

ER-AA-300-150 Cable Condition Monitoring Program 7

ER-AA-450 Structures Monitoring 11

71111.08P Corrective Action AR 04415489 05-OSP-X Scratch Rx Head O-Ring Surface near 04/09/2021

Documents Stud #46-47

Corrective Action AR 04527320 1A SG Tubesheet Anomaly in Tube R2C141 (A1R23) 10/06/2022

Documents AR 04527538 Rejectable Indications on CRDM Pen 69 Weld Buildup 10/07/2022

Resulting from AR 04528044 NDE Linear Indication Identified during LR Exam on Line 10/09/2022

Inspection 1SI4A4-8

Engineering 54-PQ-603-003 Procedure Qualification for Automated Ultrasonic 03/03/2020

Evaluations Examination of RPV Closure Head Penetrations

EC 637362 A1R23 Degradation Assessment 0

NDE Reports 385473 Remote Bare Metal Visual Examination of 79 RV Closure 10/09/2022

Head Penetrations

A1R23-PT-001 Liquid Penetrant Report for Penetration 69 10/07/2022

A1R23-PT-004 Liquid Penetrant Report for Penetration 69 10/11/2022

A1R23-UT-003 Ultrasonic Examination of Elbow-to-Pipe Weld Component 10/07/2022

ID 1MS-06-32

A1R23-UT-004 Ultrasonic Examination of Elbow-to-Pipe Weld Component 10/07/2022

ID 1MS-06-31

A1R23-UT-005 Ultrasonic Examination of Elbow-to-Pipe Weld Component 10/07/2022

ID 1MS-06-30

Procedures 54-ISI-494-004 Multi-Frequency Eddy Current Array ID Probe Examination 03/22/2022

of Vent Line and RVLIS Nozze Bores

54-ISI-603-011 Automated Ultrasonic Examination of RPV Closure Head 02/24/2020

Penetrations Containing Thermal Sleeves

54-ISI-604-017 Automated Ultrasonic Examination of Open Tube RPV 09/22/2021

Closure Head Penetrations

ER-AA-335-002 Liquid Penetrant (Pt) Examination 12

ER-AA-335-030 Ultrasonic Examination of Ferritic Piping Welds 5

ER-AP-335-001 Bare Metal Visual Examination for Nickel Alloy Materials 8

LMT-14-PAUT- Non-Encoded Phased Array Ultrasonic Examination of 1

017 Ferritic and Austenitic Welds

LMT-14-PAUT- Encoded Phased Array Ultrasonic Examination of Ferritic 4

24 and Austenitic Welds

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.11A Procedures TQ-AA-150-F25 Braidwood Generating Station LORT Annual Exam Status 10/01/2022

Report

71111.11Q Procedures OP-AA-101-111- Operator Standards and Expectations 32

1001

OP-AA-101-113 Operator Fundamentals 16

OP-AA-103-102 Watch-Standing Practices 21

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 9

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 55

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 19

TQ-AA-306 Simulator Management 11

TQ-BR-201-0113 Braidwood Training Department Simulator Examination 27

Security Actions

TQ-BR-201-0113 Braidwood Training Department Simulator Examination 27

Security Actions

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

Surveys 1006

71111.12 Corrective Action 4482320 Boron Accumulation at 1CV8321A 03/03/2022

Documents 4517560 Walkdown of 1CV8321A Leakage 08/18/2022

27710 1CV8321A Gasket Issues 10/07/2022

27895 A1R23 CRDM Thermal Sleeve Metrology Results 10/08/2022

Miscellaneous 142-9355156-000 Framatome Inc. Metrology Services Information Record: 10/07/2022

Braidwood 1 CRDM Thermal Sleeve As-Found Dimensional

Report 2022 [PROPRIETARY]

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

Inspection Type Designation Description or Title Revision or

Procedure Date

Classification

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

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

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)

71111.13 Drawings 637760 Alternate Detail for Installation of Valve Seal Cap on 1

1RC8040C

M-35, Sheet 2 Diagram of Main Steam AL

Miscellaneous BW-MODE-033 TS 3.0.4.b Evaluation - Mode Change with Technical 0-3

Specification Equipment Out of Service

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

ER-AA-335-015- VT-2 Visual Examination in Accordance with ASME 2013 1

2013

ER-AA-600 Risk Management 7

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

OP-AA-107 Integrated Risk Management 6

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

Self-Assessments OP-AA-108-117 Protected Equipment Program 7

Work Orders 5141755-07 1RC8040C - Leak Check During MODE 3 Ascending 10/18/2022

5141755-09 1RC8040C - Leak Test at NOP/NOT 10/18/2022

5141755-25 1RC8040C - Remove Valve Cap and Retorque Bonnet 10/17/2022

71111.15 Corrective Action 4526618 OSP-A K603B and K630B Relays Failed During 1BwOSR 10/03/2022

Documents 3.3.2.9-2

26631 OSP-A Request Engineering Evaluation 10/03/2022

26943 Need Further Testing on Unit 1 N32 Noise 10/05/2022

27206 1-10-A6, SR S/D FLUX HIGH, Continuously Toggling 10/05/2022

27224 U1 Source Range Channel Deviation > 4% 10/06/2022

27232 OSP-ROL Discoveries During N31 Preamp Troubleshooting 10/06/2022

27637 U1 Source Range Channel Deviation > 6% 10/07/2022

28007 OSP-A 1B DG Trip on Overspeed 10/09/2022

28116 1B DG RPM Indication/Behavior 10/11/2022

28479 1B DG RPM Indication/Behavior 10/11/2022

Inspection Type Designation Description or Title Revision or

Procedure Date

28821 A1R23 LL - 1B DG Governor Replacement 10/12/2022

4532523 A1R23 4.0 Critique DG Sequence Testing 10/27/2022

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 24

1006

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

OP-AA-108-115 Operability Determinations (CM-1) 25

71111.18 Corrective Action 4531726 AVR U-1 EC is Incomplete and Different from U-2 EC 10/24/2022

Documents 4532595 1BwPR 1-19-B6 Needs to be Changed or Removed 10/27/2022

Engineering 624258 Upgrade Existing AVR with Digital ABB Unitrol Model 1

Changes

Procedures SPP-22-001 Modification Testing, Commissioning and Power Ascension 1

Procedure for ABB Unitrol 6000 Automatic Voltage Regulator

(AVR) Replacement

Work Orders 4589156 Install EC 624258 Replacement MG Voltage Regulators U1 10/14/2022

71111.19 Corrective Action 4530461 OSP-A 1MS001D Failed to Close on B Train Manual 10/19/2022

Documents Actuation Test

4531909 U-2 Switchyard Voltage Taken Outside of BwOP MP-27 10/25/2022

Limits

4534778 Oil Residue in 2A EDG Room Exhaust Duct 11/04/2022

4534778 Oil Residue in 2A EDG Room Exhaust Duct 11/04/2022

4534881 Intentionally Abbreviated Maintenance on 2JR-DG729 11/04/2022

4534916 Unexpected Annunciator 2-21-D6: 125 Vdc Bus 211 Ground 11/04/2022

Operability 1BwOSR 1B Diesel Generator Emergency Core Cooling System 27

Evaluations 3.8.1.19-2 Sequencer Surveillance

Procedures 1BwOSR 0.1- Unit One Modes 1, 2, and 3 Shiftly and Daily Operating 100

1,2,3 Surveillance

1BwOSR 3.1.7.1 Digital Rod Position Indication (DRPI) Operability Checkout 9

1BwOSR 3.3.2.8- Unit One Emergency Safety Features Actuation System 12

611B Instrumentation Slave Relay Surveillance (B Train Automatic

Safety Injection - K611)

1BwOSR 3.7.2.1 Main Steam Isolation Valve Full Stroke Surveillance 22

Inspection Type Designation Description or Title Revision or

Procedure Date

1BwOSR 3.7.2.1 Main Steam Isolation Valve Full Stroke Surveillance 22

1BwOSR 1B Diesel Generator Full Load Rejection and Simulated 21

3.8.1.10-2 Safety Injection in Conjunction with Undervoltage During

Load Testing

1BwOSR 3.8.1.2- 1B Diesel Generator Operability Surveillance 52

1BwOSR Group A IST Requirements for Unit One Diesel Driven 24

5.5.8.AF-3B Auxiliary Feedwater Pump

1BwOSR Group A IST Requirements for Unit One Diesel Driven 24

5.5.8.AF-3B Auxiliary Feedwater Pump

BwHS 900-35 Diesel Generator Governor Set-Up Following Governor 4

Replacement

BwISR 3.1.4.3.a Rod Drop Time (Automatic) 12

BwOP FP-50 Temp Installed Diesel Driven Fire Pump 0

BwOP MP-27 Monitoring of Generator Output Voltage for NERC 7

Compliance

BwVP 500-14 Core Alignment Verification 3

BwVS 500-6 Low Power Physics Test Program 48

BwVS TRM Low Power Physics Data Interpretation 23

3.1.h.1

BwVS TRM Core Reload Sequence and Verification 23

3.1.h.1

MA-BR-723-507 Diesel Generator Post Relay Replacement Circuit 0

Verification

NF-AA-330-1001 Core Verification Guideline 14

OU-AP-230 Newton Core Gap Data Acquisition for Byron and Braidwood 5

SPP-22-001 Modification Testing, Commissioning and Power Ascension 1

Procedure for ABB Unitrol 6000 Automatic Voltage Regulator

(AVR) Replacement

Radiation ER-AA-330-001 Section XI Pressure Testing 20

Surveys

Shipping Records 1599520-03 2A EDG: Functional Check 2CD1 and 2CD2 Relays Via 11/05/2022

Simulated Cooldown

Work Orders 4589156 Install EC 624258 Replacement MG Voltage Regulators U1 10/11/2022

Inspection Type Designation Description or Title Revision or

Procedure Date

4794002-02 2A EDG: PMT - Normally Energized Agastat GP Series 11/05/2022

Relays - 2PL07J

4794003-03 2A EDG: Functional Check 2CD1 and 2CD2 Relays Via 11/05/2022

Simulated Cooldown

4986514-07 PMT - 1PL08J - Governor Devices 25GOV, 65DRU, 65MPU, 10/15/2022

65PWR

4986514-08 PMT - 1PL08J - 1B Emergency Diesel Generator Full Load

Reject Test 10/11/2022

4986514-09 PMT - 1PL08J - 1B Emergency Diesel Generator Sequence 10/15/2022

Testing

4986652 Change Grease in CPLG and Perform Inspection of CPLG 10/19/2022

Internals

4986652-02 CHG Grease in CPLG and Perform Insp of CPLG Internals 10/18/2022

4995189-01 1B Emergency Diesel Generator Sequencer Surveillance 10/15/2022

5144600-01 Core Alignment Verification, Unit 1 10/13/2022

5146416-01 Unit 1 Digital Rod Position Indication (DRPI) Operability 01/17/2022

Checkout

5148475 Low Power Physics Test Program with Dynamic Rod Worth 10/21/2022

Measurement

5149407 Reload Startup Physics Tests Following Refueling 11/07/2022

5160060 Automatic Rod Drop Time 10/04/2022

5162111-11 Newton Gap Measurements in A1R23 10/13/2022

5162130 VT-2 Exam unit 1 Class 2 & 3 Components - Outage MODE 10/18/2022

Ascending

5162134 VT-2 Exam unit 1 Class 1 Components - Outage MODE 3 10/18/2022

Ascending

5180994 LR-Perform 18 Mo Inspection in Support of 1BwBS 10/19/2022

7.1.2.3.C-1

5180994-02 LR-Perform 18 Month Inspection in Support of 1BwVS 10/18/2022

7.1.2.3.C-1

293773-01 IST - 1B Emergency Diesel Generator Operability Monthly 10/11/2022

5302865-02 PMT Main Steam Isolation Valves Partial Stroke 10/20/2022

71111.20 Corrective Action 4528080 SECID - Fatigue Assessment / Work Hour Waiver 01/09/2022

Documents 4530477 OSP-A 1A MSIV Failed to Open 10/19/2022

Inspection Type Designation Description or Title Revision or

Procedure Date

4531005 1A Steam Generator PORV Lift 10/20/2022

Miscellaneous Station Outage Control Center Logs 10/19/2022 -

10/20/2022

Unit 1 Main Control Room Logs 10/19/2022 -

10/20/2022

A1R23 Shutdown A1R23 Shutdown Safety Plan 1

Safety Plan

Procedures 1BwGP 100-1 Plant Heatup 38

1BwGP 100-1T26 Flowchart Exception Sheet 1

1BwGP 100-2 Plant Startup 48

1BwGP 100-2T1 1BwGP 100-2 Flowchart 15

1BwGP 100-2T2 MODE 3 to 2 Checklist 29

1BwGP 100-3 Power Ascension 5% to 100% 89

1BwGP 100-4 Power Descension 54

1BwGP 100-5 Plant Shutdown and Cooldown 64

1BwGP 100-6 Refueling Outage 35

1BwOS TRM unit One - Containment Loose Debris Inspection 23

2.5.b.1

BwAP 1300-6 Special Procedures, Test, or Experiments 16

BwAP 1450-1 Access to Containment 45

BwAP 340-1 Use of Procedures for Operating Department 33

BwOP MS-9 Opening the Main Steam Isolation Valves 10

ER-AA-600-1043 Shutdown Risk Management 7

HU-AA-104-101 Procedure Use and Adherence 7

HU-AA-1211 Pre-Job Briefings 14

LS-AA-119 Fatigue Management and Work Hour Rules 15

MA-AA-716-008- Reactor Services: Refuel Floor FME Plan 19

1008

OP-AA-108-108 Unit Restart Review 22

OP-AA-108-108- Drywell/Containment Closeout 1

1001

OP-AA-108-110 Evaluation of Special Tests or Evolution Evolutions 4

OP-AA-108-110 Evaluation of Special Tests or Evolutions 4

Inspection Type Designation Description or Title Revision or

Procedure Date

OP-AA-300-1520 Reactivity Management - Fuel Handling, Storage, and 7

Refueling

OU-AA-101-1011 Outage Risk Management 3

OU-AA-103 Shutdown Safety Management Program 23

OU-AA-103-1001 Shutdown Safety Plan Independent Review 5

Work Orders 4986536 Replace Valve Diaphragm 10/11/2022

71111.22 Corrective Action 4528542 LLRT Failed, Results Out of Spec 10/11/2022

Documents 4539225 Low Lube Oil and Turbo Oil Pressure during 1A Diesel 11/27/2022

Generator Run

4539226 Frothy-like Substance in 1A Diesel Generator Jacket Water 11/27/2022

Standpipe

4539982 1A Diesel Generator Low Lube Oil and Turbo Oil Pressure 11/30/2022

after Adjustment

4540521 1DG01MA, 1DG02MA and 1DG03MA as Found Conditions 12/20/2022

4540606 1ZT-DG714A Cable Detached 12/03/2022

4540613 1A Diesel Generator Failed to Trip 12/03/2022

4545327 1A Diesel Generator Lower Lube Oil Cooler Leaking Oil 12/29/2022

Procedures 1BwOSR Reactor Coolant Drain Tank Containment Isolation Valve 10

3.6.3.5.RE-1 Stroke Surveillance

1BwOSR 3.8.1.2- 1A Diesel Generator Operability Surveillance 53

1BwOSR Comprehensive Inservice Testing (IST) Requirements for 12

5.5.8.SI-11 unit 1 Safety Injection Pumps and Safety Injection System

Check Valve Stroke Test

1BwOST 0.1-1, 2, Unit 1 Modes 1, 2, and 3 Shiftly and Daily Operating 101

Surveillance

2BwOSR 0.1- unit 2 Modes 1, 2, and 3 Shiftly and Daily Operating 104

1,2,3 Surveillance

BwOP DG-1 Diesel Generator Alignment to Standby Condition 32

BwOP DG-11 Diesel Generator Startup and Operation 55

BwOP DG-12 Diesel Generator Shutdown 31

ER-AA-321 Administrative Requirements for Inservice Testing 14

Work Orders 5154224 IST - 1SI8905A-D8949B/D/8922A/B Safety Injection Hot Leg 10/05/2022

Check Valve

Inspection Type Designation Description or Title Revision or

Procedure Date

5154249 IST - 1SI8819A/B/C/D/1SI8926 - Safety Injection Cold Leg 10/05/2022

Check Valve

261230 1A Diesel Generator Operability Semi-Annual Surveillance 10/24/2022

299750 IST - 1A EDG Operability Monthly Surveillance 10/24/2022

5316998 IST - 1A EDG Operability Monthly Surveillance 12/28/2022

71114.04 Miscellaneous Q 21-72 Emergency Action Levels for Braidwood Station 01/20/2022

Procedures EP-AA-1001 Emergency Action Levels for Braidwood Station 6

ADDENDUM 3

EP-AA-1001 Emergency Action Levels for Braidwood Station 7

ADDENDUM 3

71124.01 Corrective Action AR 04457810 RP-AA-302 Conduct an Alpha Program Evaluation After 11/02/2021

Documents Outage

AR 04522597 Unit 1 Radiation Protection Refueling Outage Report 09/15/2022

Process

Corrective Action AR 04529179 NRC ID: Deficiency in Alpha Program Implementation 10/13/2022

Documents

Resulting from

Inspection

Miscellaneous RP-AA-302, Alpha Area Level Assessment 05/27/2021

Procedures NISP-RP-002 Radiation and Contamination Surveys 1

RP-AA-302 Determination of Alpha Levels and Monitoring 12

RP-AA-401-1003 Contamination Control Best Practice Application 5

Radiation 2021-095108 Reactor Head Stand 04/07/2021

Surveys 2021-095806 RF Sump 04/16/2021

21-095850 Unit 1 Cavity (Head, Chest and Knee Height) Survey 04/17/2021

Radiation Work BW-01-22-00614 Remove/Reinstall Reactor Head Upper Internals 0

Permits (RWPs) BW-01-22-00615 Reactor Cavity Work 0

BW-01-22-00618 Transfer Canal Blind Flange and LLRT 0

BW-01-22-00623 Reactor Cavity Decon Work 0

BW-01-22-00641 Setup/Demob, PT Pen 69 and All Associated Activities 0

71151 Miscellaneous Monthly Data Elements for NRC Radiological Effluent 09/01/2021 -

Technical Specifications/Offsite Dose Calculation Manual 09/30/2022

Radiological Effluent Occurrences (RETS/ODCM)

Inspection Type Designation Description or Title Revision or

Procedure Date

Radiological Effluent Occurrences Sample

(09/01/2021 - 09/30/2022)

Monthly Data Elements for NRC Reactor Coolant System 09/01/2021 -

(RCS) Specific Activity (09/01/2021 - 09/30/2022) 09/30/2022

Monthly Data Elements for NRC Occupational Exposure 09/01/2021 -

Control Effectiveness Sample (09/01/2021 - 09/30/2022) 09/30/2022

NRC Performance Indicator Data; Barrier Integrity - RCS 10/01/2021 -

Identified Leakage 09/30/2022

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

LS-AA-2100 Monthly Data Elements for NRC Reactor Coolant System 6

(RCS) Leakage

71152A Corrective Action 4414126 01-OSP-A A1R22 Mode 3 BACC W/D - 1CV8321A 04/05/2021

Documents Body-Bonnet Leak

4415586 O06-OSP-R Scope Expansion on 1CV8321A 04/10/2021

4492850 1CV8321 1A Steam Leak 04/13/2022

27583 OSP-A I.R. to Document as Found Condition of 1CV8321A 10/07/2022

Procedures BwMP 3305-007 Disassembly/Reassembly of Velan Motor Operated Globe 3

and Globe Stop Check Valves

ER-AP-331 Boric Acid Corrosion Control (BACC) Program 11

MA-AA-716-003 Tool Pouch/Minor Maintenance 13

MA-AA-733-1001 Guidance for Check Valve General Visual Inspection 11

PI-AA-125-1001 Root Cause Analysis Manual 6

Work Orders 5142152 01-OSP-A A1R22 Mode 3 BACC W/D - 1CV8321A Body- 04/10/2021

Bonnet Leak

71152S Corrective Action 4469855 Surveillance Closed Out in PassPort with Work Not 01/04/2022

Documents Performed

4504261 1/2SX005 Exercise Frequency Correction 06/07/2022

22164 NOS ID: Fire Rated Assembly Visual Inspections Were 09/13/2022

Missed

22197 IST Non-Compliance 2RF027 Fail Safe Test 09/13/2022

27990 Trend in Completion of Surveillances in Correct Timeframe 10/09/2022

Procedures NO-AA-10 Quality Assurance Topical Report (QATR) 98

PI-AA-120 Issue Identification and Screening Process 12

Inspection Type Designation Description or Title Revision or

Procedure Date

PI-AA-125-1003 Corrective Action Program Evaluation Manual 7

PI-AA-125-1004 Effectiveness Review Manual 2

29