IR 05000456/2022011
| ML22201A227 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 07/20/2022 |
| From: | Hironori Peterson Region 3 Branch 3 |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2022011 | |
| Download: ML22201A227 (15) | |
Text
SUBJECT:
BRAIDWOOD STATION - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000456/2022011 AND 05000457/2022011
Dear Mr. Rhoades:
On June 29, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Braidwood Station and discussed the results of this inspection with Mr. James Petty, Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations problem identification and resolution program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for problem identification and resolution programs.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information, and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
July 20, 2022 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, Hironori Peterson, Chief Branch 3 Division of Reactor Projects Docket Nos. 05000456 and 05000457 License Nos. NPF-72 and NPF-77
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000456 and 05000457
License Numbers:
Report Numbers:
05000456/2022011 and 05000457/2022011
Enterprise Identifier:
I-2022-011-0038
Licensee:
Constellation Energy Generation, LLC
Facility:
Braidwood Station
Location:
Braceville, IL
Inspection Dates:
June 06, 2022 to June 29, 2022
Inspectors:
A. Demeter, Resident Inspector
D. Kimble, Senior Resident Inspector
A. Muneeruddin, Resident Inspector
N. Shah, Project Engineer
Approved By:
Hironori Peterson, Chief
Branch 3
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution 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
None.
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 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.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)
- (1) The inspectors performed a biennial assessment of the effectiveness of the licensees Problem Identification and Resolution program, use of operating experience, self-assessments and audits, and safety-conscious work environment.
Problem Identification and Resolution Effectiveness: The inspectors assessed the effectiveness of the licensees Problem Identification and Resolution program in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the Unit 1 and 2 heating, ventilation, and air conditioning (HVAC) Chillers.
Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience.
Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through audits and self-assessments.
Safety-Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B Assessment of the Corrective Action Program Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
No violations or findings were identified.
Effectiveness of Problem Identification Overall, the station was effective at identifying issues at a low threshold and was properly entering them into the corrective action program (CAP) as required by station procedures.
During interviews, workers were familiar with how to enter issues into the CAP and stated that they were encouraged to use it to document issues. During plant walkdowns, the team observed numerous action tags, indicating that workers were identifying issues in the field. A selective review of several of these action tags verified that these issues were being properly documented in the CAP. The team determined that the station was generally effective at identifying negative trends that could potentially impact nuclear safety. For the areas reviewed, the team did not identify any issues in problem identification.
Effectiveness of Prioritization and Evaluation of Issues In-depth reviews of a risk-informed sampling of issue reports (IRs), work orders (WOs), and root and apparent cause and condition evaluations were completed. The team determined that the licensee had established a low threshold for entering deficiencies into the CAP, that the issues were generally being appropriately prioritized and evaluated for resolution, and that corrective actions (CAs) were implemented to mitigate the future risk of issues occurring that could affect overall system operability and/or reliability.
The inspectors noted that issues were properly screened with most either classified as Conditions Adverse to Quality (CAQ) or Non-Corrective Action Program (NCAP) items.
Through a selective review of CAP and NCAP items, the inspectors found no issues either with the assigned level of evaluation or the proposed corrective actions. Issues having potential operability concerns were properly addressed through the screening process and during control room observations and accompaniment of non-licensed operators during daily rounds, the inspectors did not identify any significant operator workarounds or similar deficiencies.
The inspectors also did a selective review of issues identified by the NRC either documented as observations or for which findings or other enforcement was issued. These issues were properly documented and screened in the CAP.
Issue evaluations were generally sound and of good quality. Most issues were screened as low significance and were assigned a work group evaluation (the lowest level of review);more significant issues were assigned a Corrective Action Program Evaluation or if highly significant, a root cause evaluation. The inspectors verified that the assigned evaluations were consistent with the significance of the issue as defined in the licensees process.
Effectiveness of Corrective Actions The team concluded that the licensee was generally effective in developing CAs that were appropriately focused to correct the identified problem and to address the root and contributing causes for significant conditions adverse to quality to preclude repetition. The licensee generally completed CAs in a timely manner and in accordance with procedural requirements commensurate with the safety significance of the issue. For NRC-identified issues, the team determined that the licensee generally assigned CAs that were effective and timely. The inspectors also did a selective review of CAs that were still open at least two years after the issue was identified to verify that it was appropriate for these items to remain open and that the licensee was managing them correctly; no issues were identified.
The inspectors noted that while issue evaluations were generally sound, there were several examples where additional research was needed to verify that the appropriate corrective actions were taken, primarily due to a lack of clear documentation. This theme had previously been identified in earlier licensee self-assessments and CAP audits, and several recent CAP items had been written to address this issue. These CAPs were still open; however, the inspector determined the proposed corrective actions were adequate.
Assessment 71152B Five-Year Review of Units 1 and 2 Heating, Ventilation, and Air Conditioning System Chillers The inspectors performed an expanded 5-year review of the Units 1 and 2 heating, ventilation and air conditioning (HVAC) chillers; specifically, by performing system walkdowns, evaluating condition reports and work orders. The inspectors also interviewed personnel responsible for working on the system. Overall, the inspectors determined that the licensee was effectively managing issues associated with this system.
Since 2017, the licensee has observed challenges in the operation of Unit 1 and 2 HVAC chillers. Frequently observed issues by the licensee dealt with the guide vanes, divider plate gaskets, out of band oil level, and various trips throughout this time period. These issues were documented in the CAP and the NRC resident inspectors have been reviewing them through the baseline inspection program. The inspectors identified no operability or other immediate safety concerns with these issues and concluded that the licensee had taken proactive actions to find and correct the cause of these issues.
No violations or findings were identified.
Assessment 71152B Assessment of Operating Experience and Self-Assessment and Audits Based on the samples reviewed, the team determined that licensee performance in the use of Operating Experience (OE) and Self-Assessments and Audits adequately supported nuclear safety.
No violations or findings were identified.
Use of Operating Experience The licensee routinely screened industry and NRC OE information for station applicability.
Based on these initial screenings, the licensee-initiated actions in the CAP to fully evaluate the impact, if any, to the station. When applicable, actions were developed and implemented in a timely manner to prevent similar issues from occurring. During interviews, licensee staff stated that operating experience lessons-learned were communicated during work briefings and department meetings and incorporated into plant operations.
Self-Assessments and Audits The inspectors reviewed several audits and self-assessments and deemed those sampled as thorough and intrusive with regards to following up with the issues that were identified through previous NRC inspections, and in the self-assessments and fleet oversight audits.
Reviewed corrective actions for the identified issues were deemed reasonable and completed commensurate with their safety significance. The inspectors regarded licensee performance as adequately self-critical of their own performance and that performance-related issues were being identified through their self-assessment process.
Assessment 71152B Assessment of Safety-Conscious Work Environment The team reviewed the stations programs to establish and maintain a safety-conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews, workers at the station expressed freedom to raise and enter safety concerns through any one of the various avenues available to them, and the team encountered no indications of chilling or retaliation.
During interviews, some staff expressed concerns about workload and staffing primarily due to effects from the ongoing COVID epidemic. This same issue was also identified by the licensee during recent safety culture assessments, and actions were being taken to increase staffing and manage the workload. The interviewees acknowledged these efforts and generally stated that management was taking steps to address the issue. Additionally, none of the interviewees expressed any safety culture concerns from this issue. Employees consistently communicated the belief that sufficient competency, engagement, resources, and commitment exist at the station to maintain high performance standards at the site.
Workers expressed favorable opinions of the Employee Concerns Program (ECP) during interviews, but not all workers were familiar with how to raise issues through the ECP, specifically, who to contact on-site. The site ECP representative had recently resigned and in the interim, the function was being fulfilled by the corporate ECP manager, who was only on-site periodically. Although there were several signs posted with the name and contact info of the corporate ECP representative, this information was apparently not well known by the interviewees. The inspectors noted that issues were still being identified by the ECP and that most workers felt no need to approach the ECP. The inspectors reviewed those issues documented in the ECP over the previous two years and identified no adverse trends.
Overall, inspectors found no evidence of challenges to the licensee's safety-conscious work environment, as licensee employees were willing to raise nuclear safety concerns through at least one of several means available.
No violations or findings were identified.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On June 29, 2022, the inspectors presented the biennial problem identification and resolution inspection results to Mr. James Petty, Plant Manager, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
1451512
Unit 2 Core Exit Thermocouple, Nozzle 77 Connections
Swapped Affecting Indications
2/12/2012
2448240-03
Westinghouse NSAL 15-1 FQ(z) Tech Spec Surveillance
2/05/2015
4033543
Fuel Pool Temperature Exceeding Rounds Setpoint
07/20/2017
4194578
Unit 0 Instrument Air Dryer Trouble, 0BWOA SEC-4 Entry
11/13/2018
4195675
Instrument Air Dryer Vulnerability
11/16/2018
217180
Part 21 Deviation of Switches (SOR)-EN 53856
2/04/2019
27719
04-OSP-A 2C Hot Leg Flow Out-of-Tolerance Low During
2BwOSR 5.5.8.SI-11
04/22/2020
235265
Potential Deficiency in Emergency Preparedness Scenario
03/05/2019
280416
Entry into 0/1/2BwOA SEC-04
09/18/2019
4307603
NRC Special Inspection-Cooper Essential Service Water
Inoperable due to Silt Buildup
01/02/2020
4307925
Follow-up Inspection of Power Take Off Coupling-Auxiliary
Feedwater Diesel 1AF01PM
01/03/2020
4309449
SIF-Foreign Material Exclusion Practices
01/10/2020
4309728
1FW035B Stroke Time Exceeded Operability Limits
01/13/2020
4314287
Level 3 OPEX Review Request for Clinton ABB 27N Relays
01/31/2020
4315003
2A VP Chiller Evap Missing 1 ft of Divider Plate Gasket
01/28/2020
4315005
2A VP Chiller Condenser Missing 10 in of Divider Plate Gasket
01/28/2020
4316542
Roll up of NOS Maintenance Audit Deficiencies
2/10/2020
4316631
INPO Significant Event Unintentional Draining Reactor Cavity
2/10/2020
4319985
Self-Assessment-2020 Nuclear Oversight Audit of the
Employee Concerns Program
3/12/2020
23077
2A Station Air Compressor Implementation Delays
03/02/2020
25067
Corrective Action Program Evaluation Following Inaccurate
Identification of Release Path During the March 3, 2020,
Braidwood NRC Graded Exercise
04/06/2020
26961
Leakage (Dry LCS-60) at Packing on 2CC9489A
03/16/2020
Corrective Action
Documents
28788
CFR Part 21 Notice on the Rosemont 1150 and 3150
Transmitters
03/23/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
4335846
2MS016A - Pre-A2R21 Testing As-Found Outside of
Acceptance Range
04/15/2020
4338581
2A VP Chiller Drain Back Solenoid Stuck Open
04/17/2020
4348893
OIO Benchmark-Effluent Calculations
06/08/2020
4353381-02
Midcycle GTE: MA. 1-17/LE.1-e/TE.5-d
06/26/2020
4355375
Spent Fuel Pool Temperature Above Rounds Limit - Trend
Only
07/08//2020
4355832
Unexpected Alarm 1-1-A2, Cnmt Drain Leak Detect Flow High
07/09/2020
4361295
Unit 0 Station Air Compressor Outboard Motor Bearing Oil Is
Discolored
08/05/2020
4362232
Unexpected Annunciator 1-15-D4 SG 1D Flow Mismatch
08/10/2020
4366140
Unexpected Alarm 1-1-A2 Cnmt Drain Leak Detect Flow High
08/29/2020
4368131
Industry Scram: Catawba Human Error Over Power Delta T
09/08/2020
4369686
NRC IN 2020-02 - Flex Diesel Operational Challenges
09/15/2020
4370636
Unexpected Alarm 2-22-C8: 2B Diesel Generator Control
Power Failure
09/19/2020
4374128
P2301 Indication Suspect
01/22/2021
4375974
2MP01E TMS Warning Light is Lit
10/12/2020
4376375
Trend in TMS Alarms
10/13/2020
4382448
Unexpected Alarms - 0-28-C4 and D4, RSH Air System
Alarms
11/05/2020
4387762
0A VC Chiller Trip
2/02/2020
4389024
U1 RCS Leak Rate Trend
01/08/2021
4389421
3Q20 NRC LIV - 0B VC Chiller Issues (Ref. IR 4321449)
2/10/2020
4391803
NRC Information Notice 2020-04 Fire Protection Maintenance
Yard Buried Cast Iron Pipe Failures
2/23/2020
4399254
4Q20 NRC Level IV NCV on MPC Blowdown Event
(Ref IR 4364058)
01/31/2021
4399255
4Q20 NRC NCV on Main Steam Safety Valve Lift Setpoint
Issue (Ref IR 4335846)
01/31/2021
4402949
Self-Assessment: Operator Fundamentals
2/17/2021
4416082
1Sl8842 Failed Relief Valve Testing
04/13/2021
4417141
2-OSP-A 1RD02E Coupling Damaged & Will Need to be
04/16/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Replaced
4417966
18-OSP-R CETC #19 (C-12) Reading High
04/21/2021
4418449
U1 CETC Information Update Following Outage Repairs
04/22/2021
4418688
Level 3 Configuration Control: Source Range Nuclear
Instruments (SRNIs) Required Trip Function Bypassed
04/24/2021
4418835
1BWOS TRM 3.3.H.1 Failed Symmetric CETC Temperature
Limits
04/25/2021
4419609
U1 CETC, Nozzle 74 Connections Swapped Affecting
Indications
04/28/2021
21660
2-10-C6 Rod Control Urgent Failure, SER#2165
05/05/2021
23455
Support Activities for EC 634192 CETC Train Swap at Pen 74
05/13/2021
24250
U1 CETC, Nozzle 74 Connections Swapped Affecting
Indications
05/18/2021
27164
2W MPT WO Needed to Support SCFR Action
06/02/2021
4430441
U1 Automatic Reactor Trip due to Generator Load Reject
06/21/2021
4430441
Root Cause Investigation Report for Braidwood Unit 1 Reactor
Trip on Generator Load Rejection
08/02/2021
4432865
Braidwood Site Ground Testing Following Unit 1 Trip due to
Lightning Strike in Switchyard
07/01/2021
4433415
Corrective Action Program Evaluation for Foreign Material
Recovered from Unit Two SI8822B/C/D Throttle Valves
2/11/2022
4435859
NOSA-BRW-21-05 Corrective Action Program Audit Report
08/27/2021
4437157
2Q21 NRC Obs. Trend U1 MSIV Bypass Valve Ops
Ref IR 4428897
07/27/2021
4440617
Unexpected BwAR 1-10-C3 Power Range Flux Rate Trip Alert
for N41
01/14/2022
4440852
NRC Information Notice 2020-04 Fire Protection Maintenance
Yard Buried Cast Iron Piping Failures
2/23/2020
4440852
NRC Information Notice 2021-03 Operating Experience on
Duane Arnold Derecho
08/16/2021
4440914
NERC: PRC-019 R2 Coordination Verification
05/14/2021
4443522
2A Diesel Generator Bolt on 4L Cylinder Sheared During
Scheduled Run
08/30/2021
4445827
1MS101C Failed to Open During Position Indication Test (PIT)
09/11/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
4455045
Need Work Request for 2A Emergency Diesel Generator
10/23/2021
4455415
FM Recovered from 2SI8822B/C/D Throttle Valves
10/25/2021
4456561
Foreign Material Exclusion: Foreign Material Found in 2B
Steam Generator Secondary Side-A2R22
10/28/2021
4458973
U2 CETC, Nozzle 74 Connections Swapped Affecting
Indication
11/05/2021
4459657
Support Activities for EC 635519 CETC Train Swap at Pen 74
11/09/2021
4465956
22 Pre-PI&R Inspection Self-Assessment
06/24/2022
4473438
Unexpected Annunciator 0-38-A2 SAC 1A Trip
01/23/2022
4473444
U2 SAC Trip After Start. Continuation of IR# 4473438.
01/23/2022
4474052
Level 3 Config Control: Incorrect Connection of Test
Equipment
01/26/2022
4477450
4Q21 NRC Observation - CRDM Thermal Sleeves
(Ref IR 4455790)
2/11/2022
4479173
Nuclear Oversight Finding: The Measurement and Test
Equipment Program was not Adequately Implemented
2/18/2022
4481238
A Level 3 Operating Experience Review is Warranted for
IRIS 514499
2/28/2022
4483946
0B VC Chiller Lowering Oil Trend and Refrig Recommendation
03/10/2022
4484304
VA/VC Filters Information Obtained
03/11/2022
4504131
2MP02E Warning Light Lit
06/07/2022
4504501
Steam Leak Under U2 Dawghouse
06/08/2022
4504849
22 PI&R: MA Excellence Standards Improvement
Opportunity
06/10/2022
4506106
22 PI&R: Preliminary OPEX Review Improvement
Opportunity
06/17/2022
Corrective Action
Documents
Resulting from
Inspection
4506856
22 PI&R: SA Completed Without Creation of Actions
06/22/2022
Engineering
Changes
636627
Configuration Control Processing of Design Analysis 051853,
Rev. 005M, for Evaluation of the Structural Integrity of Line
0SX03A-30" per Code Case N-513-4, Considering the Through
Wall Leakage Identified
000
Engineering
Evaluations
631400
Unit 2 Main Steam Safety Valves As-Found Lift Setpoint
Evaluation for Pre-A2R21 Testing
Revision 0
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
631485
Lost Parts Evaluation for Foreign Materials in Safety Injection
Hot Leg 2SI8816C - A2R21
Revision 0
631492
Evaluation of Running Unit 2 One Cycle with the 2MS014B and
2MS016C Valves Not Rebuilt
Revision 0
CPA - Compressed Air Engage Health Report
06/08/2022
Braidwood Nuclear Safety Culture Committee Meeting Minutes
05/20/2022
Braidwood Nuclear Safety Culture Committee Meeting Minutes
01/31/2022
Emergent Braidwood Nuclear Safety Culture Committee
Meeting Minutes
08/25/2021
BRWD SA-11 (A)(1) Determination
11/20/2019
051853
Design Analysis and Piping Stress Report for the Essential
Service Water System (Subsystem 1SX02)
005M
FLEX Diesel Generator Operational Challenges
09/15/2020
Operating Experience Related to the Duane Arnold Energy
Center Derecho Event on August 10, 2020
08/11/2021
IRIS Experience
Report 460761
Unplanned Decrease in Reactor Cavity Level During
Decontamination Activities
05/17/2019
IRIS Experience
Report 485806
Overpower Delta Temperature Human Performance-Related
09/08/2020
LER 2020-001-00
Licensee Event Report 2020-001-00: The Unit 1 Train A
Auxiliary Feedwater Pump was Inoperable Due to a Failed
Suction Pressure Lead/Lag Card
11/25/2020
LER 2021-001-00
Train A and B Source Range Neutron Flux Trip Functions
Bypassed During Plant Startup
06/21/2021
Miscellaneous
LER 2021-002-00
Licensee Event Report 2021-002-00 - Unit Trip on Generator
Load Rejection Due to Lightning Strick Within the Unit
Switchyard Exceeding the Capabilities of the Switchyard
Grounding System
08/18/2021
NDE Reports
BRW-41029
Exelon PowerLabs On-Site Material Identification of Debris
from SI System
04/28/2020
BwOP RC-4
Reactor Coolant System Drain
Adverse Condition Monitoring and Contingency Plan for SX
Procedures
Operating Experience Program
Revision 5
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Level 3 OpEx Evaluation for NRC IN 2021-03: Duane Arnold
Derecho Event
11/05/2021
Operating Experience Related to Unplanned Decrease in
Reactor Level During Decontamination Activities
09/23/2021
Level 3 OpEx Evaluation for Catawba Scram
10/09/2020
Operating Experience Related to FLEX Diesel Generator
Operational Challenges
03/03/2020
Issue Identification and Screening Process
Revision 11
04327092-02
Braidwood Operations Training Objective 1 and Simulator
Compliance Self-Assessment
08/03/2020
4333108-03
21 FME Program Health
01/25/2021
4363689-03
Freon Management, Ozone Depleting Substances, Refrigerant
Program
09/29/2021
4375038-03
Station Leak Reduction
01/28/2021
4402105
21 ISM Self-Assessment Discrepancies
2/12/2021
Self-Assessments
4402949-04
Braidwood Operator Fundamentals
05/31/2021
256109-01
Day Periodic Non-Destructive Testing of 0SX03A to Monitor
the Growth of the Through Wall Flax Identified on 0SX03A per
05/19/2022
Work Orders
264068-01
Day Periodic Non-Destructive Testing of 0SX03A to Monitor
the Growth of the Through Wall Flax Identified on 0SX03A per
06/17/2022