IR 05000456/2023001
| ML23124A225 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 05/08/2023 |
| From: | Hironori Peterson NRC/RGN-III/DORS/RPB3 |
| To: | Rhoades D Constellation Energy Generation |
| References | |
| IR 2023001 | |
| Download: ML23124A225 (1) | |
Text
SUBJECT:
BRAIDWOOD STATION - INTEGRATED INSPECTION REPORT 05000456/2023001 AND 05000457/2023001
Dear David Rhoades:
On March 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Braidwood Station. On April 14, 2023, the NRC inspectors discussed the results of this inspection with G. Gugle, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Braidwood Station.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Braidwood Station.
May 8, 2023 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 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:
Report Numbers:
05000456/2023001 and 05000457/2023001
Enterprise Identifier:
I-2023-001-0052
Licensee:
Constellation Energy Generation, LLC
Facility:
Braidwood Station
Location:
Braceville, IL
Inspection Dates:
January 01, 2023 to March 31, 2023
Inspectors:
R. Bowen, Illinois Emergency Management Agency
A. Demeter, Resident Inspector, Byron Station
D. Kimble, Senior Resident Inspector
P. Smagacz, Resident Inspector
Approved By:
Hironori Peterson, Chief
Reactor Projects Branch 3
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Braidwood Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Follow 1A Emergency Diesel Generator Maintenance Work Instructions Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000456/2023001-01 Open/Closed
[H.5] - Work Management 71111.12 A self-revealed finding of very low safety significance (i.e., Green) and an associated non-cited violation (NCV) of 10 Code of Federal Regulations Part 50, Appendix B, Criterion V,
Instructions, Procedures, and Drawings, was identified for the licensees failure to follow the prescribed and established maintenance work instructions and procedures for a scheduled 2-year maintenance and inspection of the 1A Emergency Diesel Generator (EDG). Specifically, work instructions provided by the licensee under safety-related Work Order (WO) 4967061,
Perform 2-Year Inspection of the 1A Emergency Diesel Generator, during the period from November 29, 2021, through December 6, 2021, specified that the main lubricating oil strainers be opened, inspected, and cleaned as part of the EDGs 2-year maintenance activities. However, without providing any technical justification or utilizing the stations approved process for making a change to the procedure steps, licensee technical personnel overseeing the work marked these instruction steps as not applicable and completed the procedure without performing the requisite inspection and cleaning of the strainers. This condition was subsequently revealed in late November of 2022 when unusually low 1A EDG lubricating oil pressures were noted with the engine running.
Additional Tracking Items
None.
PLANT STATUS
Unit 1 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.
Unit 2 began the inspection period operating at full power. On March 24, 2023, the unit reached the end of the fuel cycle and power coast down operations commenced in preparation for its planned A2R23 Refuel Outage. The unit continued to reduce power in accordance with the licensees approved reactivity management plan, and was operating at approximately 97.4 percent power at the end of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors reviewed and evaluated selected system configurations during partial physical alignment verifications of the following systems/trains:
- (1) The 1A Auxiliary Feedwater (AF) Train, associated with a degraded condition identified by the NRC on the Service Water (SX) supply to the 1A AF Pump, as documented in Issue Report (IR) 4546554 during the weeks ending January 7 through January 21, 2023
- (3) The 2A Emergency Diesel Generator (EDG) during 2B EDG maintenance during the week ending March 18, 2023
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 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 11.2-0; Auxiliary Building 346' Elevation, Unit 2 General Area (South)during the week ending January 21, 2023.
- (2) Fire Zone 8.3-2; Turbine Building 401' Elevation, Unit 2 grade level (Southeast)during the week ending February 4, 2023.
- (3) Fire Zone 11.3-0 South; Auxiliary Building 364' Elevation, General Area (South)during the week ending March 4, 2023.
- (4) Fire Zone 9.1-2; Diesel Generator 401' Elevation, Unit 2B EDG Room during the week ending March 18, 2023.
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
The inspectors evaluated the performance and training of the on-site fire brigade during observation of the following drill activities:
- (1) Observation of announced and unannounced fire drills with multiple crews on February 21, 2023.
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 Unit 2 Component Cooling (CC) Heat Exchanger, as documented in Work Order (WO) 4943128 during the weeks ending March 4 through March 18, 2023.
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 observations involving the operation of Unit 1 without a functional plant process computer (PPC), during the week ending January 21, 2023.
Observation of 1A EDG testing and 4160 Vac electrical bus manipulations, during the week ending February 25, 2023.
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 the facility's simulator on February 16, 2023.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (3 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 for EDG lube oil systems, with specific emphasis on the adequacy of lube oil filter and lube oil strainer maintenance activities during the weeks ending January 7 through March 31, 2023. A finding of very low safety significance (Green) and an associated non-cited violation associated with the inspectors' review are documented in the Inspection Results section of this report.
- (2) A maintenance effectiveness review for SX supply to the AF pumps, with specific emphasis on the adequacy of maintenance activities associated with low flow/stagnant water lines during the weeks ending January 7 through March 31, 2023.
- (3) A maintenance effectiveness review associated with pressurizer power-operated relief valve (PORV) planned/preventative maintenance and leakage during the weeks ending February 11 through March 31, 2023.
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) Review and evaluation of the risk associated with power restoration to the Unit 1 PPC following a small electrical fire that destroyed the normal power supply, as documented in WO 5329160 during the week ending January 21, 2023.
- (2) Review and evaluation of the risk associated with removal of the 2D Main Condenser Waterbox from service with the unit operating at full power to support troubleshooting and repair of a main condenser tube leak, as documented in WO 5337065 during the week ending February 25, 2023.
- (3) Review and evaluation of the risk and activities associated with the 2B EDG planned overhaul and maintenance window, as documented in WO 5105822 during the week ending March 18, 2023.
- (4) Review and evaluation of the risk and activities associated with the 1A SX Cubicle Cooler freeze seal and maintenance window, as documented in WO 5225725 during the week ending March 25, 2023.
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Evaluation of the operability of the 1A EDG with respect to its mission time following identification of lube oil supply pressure issues, as documented in IR 4539225 during the weeks ending January 14 through January 28, 2023.
- (2) Evaluation of the operability of the 2B Diesel-Driven AF Pump following the identification of clear control power fuses and a failed alarm relay in the pump's control power circuit, as documented in IR 4551248 during the week ending February 4, 2023.
- (3) Evaluation of the operability of the 2B EDG following discovery of low peak firing pressure in the 3L cylinder, as documented in IR 4549907 during the weeks ending January 28 through February 11, 2023.
- (4) Evaluation of the operability of SX supply to the 1A AF Pump following NRC identification of a pinhole leak in line 1SX25AA-6, as documented in IR 4546554 during the weeks ending January 7 through February 18, 2023.
- (5) Evaluation of the operability of the SX return line from the 1A EDG following identification of a pinhole leak in line 1SX27DA-10, as documented in IR 4550393 during the weeks ending February 4 through February 18, 2023.
- (6) Evaluation of the operability of the 0C Auxiliary Building Non-Accessible Ventilation Train following questions regarding charcoal filter penetration test results, as documented in IR 4565467 during the week ending March 31, 2023.
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 temporary change to the configuration of the facility:
- (1) Review of temporary plant modification per Engineering Change (EC) 638311:
Evaluation for Temporarily Bypassing Computer Inverter 1CS08J to Facilitate Repairs during the weeks ending January 29 through March 31, 2023.
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors reviewed and evaluated the following post-maintenance and surveillance testing activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (3 Samples)
- (1) Functional and operational testing of the 1B Residual Heat Removal Pump following a normally scheduled periodic replacement of the pump's supply breaker, as documented in WO 5303140 during the week ending January 21, 2023.
- (2) Functional and operational testing of the 2B EDG lockout relays following a periodic 2-year maintenance window, as documented in WO 5180938 during the week ending March 18, 2023.
- (3) Functional and operational testing of the 2B EDG following a periodic 2-year maintenance window, as documented in WO 5105822 during the week ending March 25, 2023.
Surveillance Testing (IP Section 03.01) (2 Samples)
(1)2BwOSR 3.8.1.2-1: Unit Two 2A Diesel Generator Operability Surveillance, as documented in WO 5330596 during the week ending February 4, 2023.
(2)1BwOSR 3.3.2.3: Unit One Undervoltage Simulated Start of 1A Auxiliary Feedwater Pump Surveillance, as documented in WO 5315860 during the weeks ending March 4 through March 11, 2023.
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
(1)0BwOSR 5.5.8.CC-1; A IST Requirements for Component Cooling Pump 0CC01P and Discharge Check Valves, as documented in WO 53212190 during the week ending January 28, 2023.
Reactor Coolant System Leakage Detection Testing (IP Section 03.01) (1 Sample)
- (1) Review and evaluation of Unit 2 reactor coolant system unidentified leakage following a small increase in the normal periodic calculated leakage, as documented in IR 4556108 during the week ending February 25, 2023.
Diverse and Flexible Coping Strategies (FLEX) Testing (IP Section 03.02) (1 Partial)
(1)
(Partial)
On-site full flow performance testing of the 0FX02PB (0B High Head FLEX Pump) by station personnel following rebuild of the positive displacement pump by an offsite vendor, as documented in IR 4548150 during the weeks ending January 14 through March 31, 2023.
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)
The inspectors evaluated site's emergency plan by observing the following emergency response organization (ERO) activities:
- (1) A site-wide emergency preparedness drill that resulted in a simulated Site-Area Emergency event classification on March 15, 2023.
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated site's emergency plan by observing the following ERO activities:
- (1) A site-wide emergency preparedness drill that resulted in a simulated Site-Area Emergency event classification on March 29,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors reviewed and verified selected portions of the licensee's performance indicator submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01)===
- (1) Unit 1 (January 1, 2022 through December 31, 2022)
- (2) Unit 2 (January 1, 2022 through December 31, 2022)
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (2 Samples)
- (1) Unit 1 (January 1, 2022 through December 31, 2022)
- (2) Unit 2 (January 1, 2022 through December 31, 2022)
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (2 Samples)
- (1) Unit 1 (January 1, 2022 through December 31, 2022)
- (2) Unit 2 (January 1, 2022 through December 31, 2022)
===71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03) (1 Partial)
The inspectors conducted an in-depth review of the licensees implementation of the corrective action program (CAP) related to the following issue:
(1)
(Partial)
Review and assessment of the station's corrective actions stemming from the startup of Braidwood Unit 1 from Refueling Outage A1R23 with the 1A Main Steam Isolation Valve (MSIV) closed, as documented in IR 4531005 during the weeks ending January 7, 2023 through March 31, 2023.
71153 - Follow-up of Events and Notices of Enforcement Discretion Personnel Performance (IP Section 03.03)===
The inspectors reviewed and evaluated the performance of licensee personnel associated with the following unplanned event:
- (1) Review of operator and overall station response to a small electrical fire on January 18, 2023, in cabinet 1CX08J, which supplies power to the Unit 1 PPC, as documented in IR 4548945 during the week ending January 21,
INSPECTION RESULTS
Failure to Follow 1A Emergency Diesel Generator Maintenance Work Instructions Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000456/2023001-01 Open/Closed
[H.5] - Work Management 71111.12 A self-revealed finding of very low safety significance (i.e., Green) and an associated non-cited violation (NCV) of 10 Code of Federal Regulations Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified for the licensees failure to follow the prescribed and established maintenance work instructions and procedures for a scheduled 2-year maintenance and inspection of the 1A Emergency Diesel Generator (EDG). Specifically, work instructions provided by the licensee under safety-related Work Order (WO) 4967061, Perform 2-Year Inspection of the 1A Emergency Diesel Generator, during the period from November 29, 2021, through December 6, 2021, specified that the main lubricating oil strainers be opened, inspected, and cleaned as part of the EDGs 2-year maintenance activities. However, without providing any technical justification or utilizing the stations approved process for making a change to the procedure steps, licensee technical personnel overseeing the work marked these instruction steps as not applicable and completed the procedure without performing the requisite inspection and cleaning of the strainers. This condition was subsequently revealed in late November of 2022 when unusually low 1A EDG lubricating oil pressures were noted with the engine running.
Description:
On November 27, 2022, during a normally scheduled 1A EDG monthly surveillance, plant operators noted that indicated engine lubricating oil pressure and indicated turbocharger lubricating oil pressure were lower than the expected values. The normally expected range for engine lubricating oil pressure is 45 to 60 psig, while the normally expected range for the turbocharger lubricating oil pressure is 33 to 40 psig. Instead of obtaining indicated oil pressures within these ranges, operators noted that the indicated engine lubricating oil pressure was reading approximately 39 psig, and had declined after the first hour that the 1A EDG was running in a loaded condition. Similarly, the indicated turbocharger lubricating oil pressure was noted to be 31 psig, and had been declining from the beginning of the 1A EDG loaded run. While outside of their respective expected bands, the licensee concluded that neither indicated lubricating oil pressure represented an unacceptable condition that would impact the EDGs availability or operability, and that the 1A EDG lubricating (lube) oil system was satisfactorily performing its specified function. A maintenance action was created to adjust the systems oil pressure regulators to restore indicated oil pressures to their nominal bands.
The licensee ran the 1A EDG again on November 29, 2022, to support the adjustment of the oil systems pressure regulating valves. Both the 1DG5041A, 1A EDG Turbocharger Lube Oil Pressure Regulating Valve, and 1DG5032A, 1A EDG Lube Oil Header Relief Valve, were adjusted. With the 1A EDG running and the 1DG5041A valve adjusted to its maximum setting, the licensee noted only minor increases in lube oil and turbocharger lube oil pressures.
In a continuation of their troubleshooting efforts, the licensee removed the 1A EDG from service on December 1, 2022, to facilitate more detailed inspection of components within the lube oil system. An inspection of Lube Oil Strainers 1DG02MA and 1DG03MA revealed significant blockage, with Lube Oil Strainer 1DG03MA almost completely plugged. No metal was present in either strainer. Oil sludge and fiber material were recovered from each strainer. A subsequent inspection of Main Lube Oil Filter 1DG01MA showed indication that the filter elements had started to plug and some had begun to degrade and shed fiber filter medium. The licensee replaced the filter elements in Main Lube Oil Filter 1DG01MA and cleaned and restored Lube Oil Strainers 1DG02MA and 1DG03MA to their original condition. During the subsequent post-maintenance testing run of the 1A EDG, the licensee was able to adjust both the engine lube oil pressure and the turbocharger lube oil pressure into their respective normal operating bands.
The licensee performed a corrective action program (CAP) evaluation regarding the circumstances surrounding this issue. As part of that evaluation, it was discovered that the procedure section requiring the cleaning of Lube Oil Strainers 1DG02MA and 1DG03MA had not been performed as required during the last 2-year 1A EDG maintenance window in November/December 2021. Instead, that portion of the procedure (Section 4.10.12 of safety-related maintenance procedure BwMP 3100-022, Diesel Generator 2-Year Inspection)was marked as not applicable by the licensees technical staff supporting the 1A EDG maintenance work. No justification for this deviation from the required steps of the procedure was provided. A similar procedure section for inspecting/replacing the filter elements in Main Lube Oil Filter 1DG01MA was allowed to be marked as not applicable based on the filter elements being within the manufacturers 6-year replacement periodicity and measured differential oil pressure across the filter being within established specifications.
Corrective Actions: In addition to the licensee replacing the filter elements in Main Lube Oil Filter 1DG01MA and cleaning and restoring Lube Oil Strainers 1DG02MA and 1DG03MA to their original condition on the 1A EDG, reviews of the history of lube oil strainer cleaning and main lube oil filter element replacements were performed for the remaining 3 EDGs at Braidwood Station. Both the 1B and 2A EDGs had their lube oil strainers and lube oil filter elements replaced during their respective maintenance windows in 2022. Based on this maintenance history review, the licensee inspected and cleaned the lube oil strainers on the 2B EDG on December 12, 2022. Those lube oil strainers were found to be as expected - dirty, but not abnormally fouled. Based on the 2B EDG oil pressures and trends being normal, the 2B EDG lube oil filter elements were replaced during the subsequent regularly scheduled 2B EDG maintenance window in March 2023.
Corrective Action References:
-
4539225; Low Lube Oil and Turbo Oil Pressure During 1A EDG Run; 11/27/2022
-
4539982; 1A EDG Low Lube Oil and Turbo Oil Pressure After Adjustment; 11/30/2022
-
4540521; 1DG01MA, 1DG02MA, and 1DG03MA As Found Conditions; 12/02/2022
Performance Assessment:
Performance Deficiency: Safety-related WO 4967061, Perform 2-Year Inspection of the 1A Emergency Diesel Generator, was implemented by the licensee during the period from November 29, 2021, through December 6, 2021, to accomplish a periodic and planned maintenance window on the 1A EDG. This WO directed the performance of safety-related maintenance procedure, BwMP 3100-022, Diesel Generator 2-Year Inspection, and Section 4.10.12 of the procedure specified that Lube Oil Strainers 1DG02MA and 1DG03MA be inspected and cleaned per the steps provided. The inspectors concluded that the licensees failure to have performed Section 4.10.12 of BwMP 3100-022 as written, and to have restored Lube Oil Strainers 1DG02MA and 1DG03MA to their original condition, allowed for the continued buildup of material within the strainers and the eventual issue with low 1A EDG lube oil pressures that was identified in November 2022. Further, the inspectors concluded that this failure constituted a performance deficiency that was within the licensees ability to have foreseen and that should have been prevented.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the inspectors determined that the licensees failure to have cleaned Lube Oil Strainers 1DG02MA and 1DG03MA and restored them to their original condition as required by Section 4.10.12 of BwMP 3100-022 contributed to the subsequent plugging of those strainers, and as such, had an adverse impact on 1A EDG reliability. The inspectors also compared the finding with the examples listed in Inspection Manual Chapter (IMC) 0612, Power Reactor Inspection Reports, Appendix E, Example of Minor Issues. Example 4.k was found to be similar in that the performance deficiency adversely affected Mitigating Systems Cornerstone of Reactor Safety objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.
Because the finding involved a deficiency that did not impact 1A EDG operability or PRA
[Probabilistic Risk Analysis] functionality, the inspectors determined the finding to be of very low safety significance (i.e., Green). Specifically, the low indicated oil pressures experienced by the 1A EDG due to the plugging of Lube Oil Strainers 1DG02MA and 1DG03MA, were not significant enough to have had an adverse impact on 1A EDG PRA mission time or operation. As part of their inspection sample, the inspectors pulled several months of historical 1A EDG oil pressure data from the plant computer in an effort to identify any discernible rate of change that would call into question the 1A EDGs capability to have met its mission time. No such trend was found.
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Specifically, this finding involved a significant error in work execution where a section of a safety-related maintenance procedure was intentionally not performed with no technical justification for the deviation.
Enforcement:
Violation: Appendix B to 10 CFR Part 50, Criterion V, Instructions, Procedures, and Drawings, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Contrary to this requirement, during the licensees most recent 1A EDG maintenance work window from November 29, 2021, through December 6, 2021, Section 4.10.12 of BwMP 3100-022, Diesel Generator 2-Year Inspection, requiring the inspection and cleaning of safety-related 1A EDG Lube Oil Strainers 1DG02MA and 1DG03MA was improperly marked as not applicable by the licensee and not performed.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On April 14, 2023, the inspectors presented the integrated inspection results to G. Gugle, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
4546554
SX Leak in Pipe Upstream of 1AF017A
01/04/2023
BwOP AF-E1
Electrical Lineup - Unit 1 Operating
BwOP AF-E2
Electrical Lineup - Unit 2 Operating
BwOP AF-M1
Operating Mechanical Lineup Unit 1
BwOP AF-M2
Operating Mechanical Lineup, Auxiliary Feedwater, Unit 2
Procedures
BwOP DG-M3
Operating Mechanical Lineup Unit 2 2A D/G
Corrective Action
Documents
4561001
Fire Marshall Identified 1st Fire Drill Observations
03/10/2023
Pre-Fire Plan No.
101
Fire Zone 11.2-0; Auxiliary Building 346' Elevation, Auxiliary
Building General Area - South
Pre-Fire Plan No.
113
Fire Zone 11.3-0 South; AB 364' Unit 1 Auxiliary Building
General Are (South)
Pre-Fire Plan No.
Fire Zone 8.3-2; Turbine Building 401' Elevation, Unit 2
Turbine Grade Level (SE)
Fire Plans
Pre-Fire Plan No.
Fire Zone 9.1-2; DG 401' Diesel Generator Room 2B & Day
Tank Room
Fire Drill Scenario
20.18.09.24
Unit 1 Flammable Liquids Cabinet Fire
09/24/2018
Miscellaneous
Fire Drill Scenario
20.22.03.18
2EH01PB Motor Fire
03/18/2022
BwAP 1100-16
Fire/Hazardous Materials Spill and/or Injury Response
BwAP 1100-3
Fire Chief (Designated Field Supervisor) Implementing
Procedure
BwAP 1100-4
Fire Brigade Implementing Procedure
BwAP 1110-1
Fire Protection Program System Requirements
BWAP 1110-3
Plant Barrier Impairment Program
BwAR 0-37-A4
Unit One Area Fire
BwOP FP-100
Fire Response Guidelines
BwOP PBI-1
Plant Barrier Impairment Program Pre-Evaluated Barrier
Matrix
Procedures
Plant Barrier Control Program
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
High Risk Fire Area Identification
ER-BR-600-1069
Site List of High Risk Fire Areas - Braidwood Unit 1 and
Unit 2
Fire Drill Performance
Fire Prevention for Hot Work
Fire Brigade Qualification
Pre-Fire Plan Manual
Control of Transient Combustible Material
OP-AA-201-012-
1001
Operations On-Line Fire Risk Management
OP-BR-201-012-
1001
Braidwood On-Line Fire Risk Management
Work Orders
4943128
LR-2CC01A Eddy Current Testing and Inspection
03/01/2023
Miscellaneous
BR2C23-06.0
Braidwood 2 Cycle Coastdown Reactivity Plan
03/20/2023
OP-AA-101-111-
1001
Operations Standards and Expectations
Operator Fundamentals
OP-AA-101-113-
1006
4.0 Crew Critique Guidelines
Watch-Standing Practices
OP-AA-103-102-
1001
Strategies for Successful Transient Mitigation
Operation of Plant Equipment
Communications
Operating Narrative Logs and Records
Reactivity Management
Systemic Approach to Training Process Description
Operator Training Programs
Conduct of Simulator Training and Evaluation
Examination Security and Administration
Simulator Management
Procedures
TQ-BR-201-0113
Braidwood Training Department Simulator Examination
Security Actions
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
4539225
Low Lube Oil and Turbo Oil Pressure During 1A EDG Run
11/27/2022
4539982
1A EDG Low Lube Oil and Turbo Oil Pressure After
Adjustment
11/30/2022
4540521
1DG01MA, 1DG02MA, and 1DGo3MA as Found Conditions
2/02/2022
Corrective Action
Documents
4550413
Trend in SX System Leaks
01/25/2023
BwMP 3100-022
Diesel Generator 2-Year Inspection
BwMP 3100-082
Diesel Generator 6-Year Inspection
Maintenance Rule Functions - Safety Significant
Classification
Maintenance Rule Implementation per NEI 18-10
Maintenance Rule 18-10 - Scoping
Maintenance Rule 18-10 - Failure Definitions
Procedures
Maintenance Rule 18-10 - Performance Monitoring and
Dispositioning Between (a)(1) and (a)(2)
Work Orders
4967061
Perform 2-Year Inspection of the 1A Emergency Diesel
Generator
11/29/2021
4549385
Plant Process Computer Links Still Not Connected
01/19/2023
4549386
Unit 1 Plant Process Computer Network Switch
Unresponsive after Power Restoration
01/19/2023
4549391
Unit 1 Plant Process Computer Network Switch
Unresponsive after Power Restoration
01/19/2023
Corrective Action
Documents
4549730
4.0 Critique - 1CX08J Fire Response
01/22/2023
Miscellaneous
Adverse Condition Monitoring and Contingency Plan;
2CS08J Monitoring
ASME Section XI Repair/Replacement Program
ER-AA-335-015-
2013
VT-2 Visual Examination in Accordance with ASME 2013
Risk Management
On-Line Risk Management
Conduct of Troubleshooting
Application of Freeze Seal to All Piping
Integrated Risk Management
Procedures
Protected Equipment Program
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
On-Line Risk Management and Assessment
5105822-01
2DG01KB - Perform 6-Year Inspection of Diesel Generator
03/13/2023
25725-02
1SX16AA-3" - Install and Remove Freeze Seal MR-90
03/21/2023
29160-04
1CX08J Install MR90 for Repairs - TCCP No. 638311
01/18/2023
Work Orders
5337065-07
2D Waterbox - Stage Ventilation and Open Upper Manways
2/23/2023
39622686
Engine Analysis 2A EDG Cylinder 6L Low Peak Firing
Pressure
01/11/2017
4541858
U1 PZR Porv Tailpiece Temperature Trend
2/09/2022
4549610
UT Readings Below Tminon 1SX25AA-6"
01/20/2023
4549908
Engine Analysis 2B EDG Cylinder 3L Low Peak Firing
Pressure
01/23/2023
4550393
Leak on Underside of Piping Just Downstream of 1SX057A
01/25/2023
4550631
UT Readings Below Tmin on 1SX25AA-6"
01/26/2023
4551248
2B AF Pump Control Power Fuse Cleared - 2PL05J-FU-6
01/30/2023
4551315
Scope Expansion Inspections on 1SX27DB-10"
01/30/2023
4551316
Scope Expansion Inspections on 2SX27DA-10"
01/30/2023
4551318
Scope Expansion Inspections on 1SX26AB-10"
01/30/2023
4551319
Scope Expansion Inspections on 1SX26AA-10"
01/30/2023
4553594
Unexpected Annunciator 1-12-C6 Pzr Porv Dsch Temp High
2/09/2023
4555819
Review of UT Data from 2SX27DA-10"
2/20/2023
4565454
Charcoal Sample Results 0VA05FH
03/28/2023
Corrective Action
Documents
4565467
0VA05FH Charcoal Penetration Exceeds Admin Limit
03/28/2023
Corrective Action
Documents
Resulting from
Inspection
4546554
SX Leak in Pipe Upstream of 1AF017A
01/04/2023
Drawings
20E-2-4030AF02
Schematic Diagram Auxiliary Building Feedwater Pump 2B
(Diesel Driven) 2AF01PB
W
638242
Operability Evaluation 23-001: Pinhole Leak on Pipe
1SX25AA-6"
and 1
638248
Piping Stress Report for Subsystems 1AF03, 1AFF20,
1AFF31, 1WFF44, and 1AFF03
Engineering
Changes
638358
Operability Evaluation 23-002: Pinhole Leak on Pipe
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
1SX27DA-10" Downstream of 1SX057A
638371
Piping Stress Analysis for Subsystem 1SX13
Adverse Condition Monitoring and Contingency Plan; SX
Piping Leaking Upstream 1SX017A (1SX25AA)
Miscellaneous
Adverse Condition Monitoring and Contingency Plan;
1SX27DA-10" Piping Through Wall Leak
BwISR 5.5.11.e-
1c
Auxiliary Building Non-Accessible Filter Plenum System
Total Bypass Leakage Test - Plenum 'C'
Engineering Technical Evaluations
Risk Management Documentation
OP-AA-106-101-
1006
Operational Decision-Making Process
Adverse Condition Monitoring and Contingency Planning
Procedures
Operability Determinations (CM-1)
24112
LR-Perform 2 Year Inspection of the Diesel Generator
2/21/2020
Work Orders
5148459
Diesel Generator Preoutage Engine Analysis (2MO Prior to
Out)
01/19/2023
Internal-External Wiring Diagram DEH Controller Cabinet
1PA22J
S
Drawings
External Wiring Diagram 20KVA Inverter, 1CX08J
K
Engineering
Changes
638311
MR90 - Evaluation for Temporarily Bypassing Computer
Inverter 1CX08J to Facilitate Repairs
4548150
0FX02PB, Acceptance Criteria Not Met During Testing
01/12/2023
4556108
2BwOSR 3.4.13.1 Deviation Action Level I Exceeded
2/21/2023
4558760
1PA13J Defective Light Socket
03/02/2023
Corrective Action
Documents
4561676
2BwOSR 3.4.13.1 Deviation Action Level I Exceeded
03/13/2023
0BwOS FX-12
FLEX Pump Full Flow Test Surveillance
1BwOSR 3.3.2.3
Undervoltage Simulated Start of 1A Auxiliary Feedwater
Pump
1BwOSR
5.5.8.CC-1
A IST Requirements for Component Cooling Pump 0CC01P
and Discharge Check Valves
Procedures
1BwOSR
5.5.8.RH-5B
Group A IST Requirements for Residual Heat Removal
Pump 1RH01PB
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2BwOS DG-2B
2B Diesel Generator Overspeed Trip Test
2BwOSR 3.4.13.1
Unit Two Reactor Coolant System Water Inventory Balance
Surveillance
2BwOSR
3.8.1.14-2
Unit 2 2B Diesel Generator 24 Hour Endurance Run
2BwOSR 3.8.1.2-
Unit Two 2A Diesel Generator Operability Surveillance
2BwOSR
3.8.11.2-2
Unit Two 2B Diesel Generator Operability Surveillance
BwOP DG-11T1
Diesel Generator Start/Stop Log
BwOP DG-11T2
Diesel Generator Operating Log
OP-BR-FX-1003
High Head FLEX Pump Operating Guideline
5105822-18
Ops PMT - 2B EDG Slave Relay Start
03/17/2023
5105822-19
Ops PMT - Verify 2B EDG 100% Load Capability
03/17/2023
5163389
2B Diesel Generator Overspeed Trip Test
03/17/2023
5180938
2FSV-DG5209B Replace DG Pneumatic Solenoid Valve
03/18/2023
5303140
IST-1RH01PB ASME Group A Test & CC-1SI8958B
01/19/2023
5309859
2B Diesel Generator Operability Semi-Annual Surveillance
03/17/2023
5312190
IST - For 1/2CC9463A/B & 0CC9464 - ASME Surveillance
Requirements for 0CC01P
01/24/2023
5330596
LR-IST-2A D/G Operability Monthly
2/01/2023
Work Orders
535340647
LR-IST-2B D/G Operability Monthly
03/17/2023
4668305
Braidwood 2023 PI Drill Series - MCR/SIM Learnings
04/07/2023
4668309
Braidwood 2023 PI Drill Series - TSC Learnings
04/07/2023
Corrective Action
Documents
4668310
Braidwood 2023 PI Drill Series - OSC Learnings
04/07/2023
Miscellaneous
EP Performance Indicator Drill Manual/Guide for 2023
23
Standardized Radiological Emergency Plan
Procedures
Radiological Emergency Plan Annex for Braidwood Station
NRC Performance Indicator Data; Initiating Events -
Unit/Reactor Shutdown Occurrences
01/01/2022 -
2/31/2022
Miscellaneous
NRC Performance Indicator Data; Initiating Events -
Unplanned Power Changes per 7000 Critical Hours
01/01/2022 -
2/31/2022
71151
Procedures
Collecting and Reporting of NRC Performance Indicator
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Data
Monthly Data Elements for NRC/WANO Unit/Reactor
Shutdown Occurrences
Monthly Data Elements for NRC Unplanned Power Changes
per Critical Hours
4530477
10/19/2022
Corrective Action
Documents
4531005
1A Steam Generator PORV Lift
10/20/2022
Station Outage Control Center Logs
10/19-
20/2022
Miscellaneous
Unit 1 Main Control Room Logs
10/19-
20/2022
1BwGP 100-1T26
Flowchart Exception Sheet
1BwGP 100-2
Plant Startup
- 49
1BwGP 100-2T1
1BwGP 100-2 Flowchart
- 16
1BwGP 100-2T2
MODE 3 to 2 Checklist
- 31
BwAP 1300-6
Special Procedures, Tests, or Experiments
BwAP 340-1
Use of Procedures for Operating Department
BwOP MS-9
Opening the Main Steam Isolation Valves
Procedure Use and Adherence
Quality Assurance Topical Report (QATR)
Evaluation of Special Tests or Evolution Evolutions
Issue Identification and Screening Process
Corrective Action Program (CAP) Procedure
Root Cause Analysis Manual
Corrective Action Program Evaluation Manual
Procedures
Effectiveness Review Manual
Corrective Action
Documents
4548945
Fire, 1CX08J, Unit 1 Miscellaneous Electrical Equipment
Room, 1VE01C Fan Trip
01/18/2023