IR 05000456/2023002

Integrated Inspection Report 05000456/2023002 and 05000457/2023002

ML23214A383
Person / Time
Site:	Braidwood
Issue date:	08/03/2023
From:	Hironori Peterson NRC/RGN-III/DORS/RPB3
To:	Rhoades D Constellation Energy Generation, Constellation Nuclear
References
IR 2023002
Download: ML23214A383 (1)

Text

SUBJECT:

BRAIDWOOD STATION - INTEGRATED INSPECTION REPORT 05000456/2023002 AND 05000457/2023002

Dear David Rhoades:

On June 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Braidwood Station. On July 11, 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.August 3, 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: NPF-72 and NPF-77

Report Numbers: 05000456/2023002 and 05000457/2023002

Licensee: Constellation Energy Generation, LLC

Facility: Braidwood Station

Location: Braceville, IL

Inspection Dates: April 01, 2023 to June 30, 2023

Inspectors: R. Bowen, Illinois Emergency Management Agency G. Edwards, Senior Enforcement Specialist E. Fernandez, Senior Reactor Inspector G. Hansen, Senior Emergency Preparedness Inspector D. Kimble, Senior Resident Inspector J. Kutlesa, Emergency Preparedness Inspector A. Shaikh, Senior Reactor 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

Failure to Follow Steam Generator Eddy Current Testing Analysis Procedure Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.12] - Avoid 71111.08P NCV 05000457/2023002-01 Complacency Open/Closed The inspectors identified a finding of very low safety significance (Green) and an associated Non-Cited Violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50,

Appendix B, Criteria V, "Instructions, Procedures, and Drawings", for the licensee's failure to follow the site-specific steam generator (SG) Eddy current testing (ECT) analysis procedure. Specifically, the licensee failed to follow procedure ER-MW-335-1003, Steam Generator Eddy Current Data Analysis Guidelines for Braidwood and Byron Stations Unit 2, when analyzing an indication that was identified in SG 2A tube during ECT performed in October 2021.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000456/2022-001-00 LER 2022-001-00 for 71153 Closed Braidwood Station, Unit 1,

Liquid Penetrant Indications in Control Rod Drive Mechanism Nozzle Seal Weld Repair due to Subsurface Weld Defects Opening Up from Thermal and Pressure Stresses during Operation

PLANT STATUS

Unit 1 began the inspection period operating at full power. With the exception of minor planned 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 approximately 97.4 percent power and in power coast down for the planned end of the fuel cycle. On April 24, 2023, the unit was shut down for its 23rd refueling outage (A2R23). Following completion of refueling and other maintenance activities, the reactor was restarted and taken critical on May 12, 2023, and the main electrical generator was synchronized to the power grid on May 13, 2023. The unit reached full power operation on May 16, 2023, and continued operating at or near full power for the remainder 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.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (2 Samples)

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

(1) The spent fuel pool cooling system during the Unit 2 full core offload conducted as part of the A2R23 Refuel Outage during the week ending May 6, 2023.

(2) The 2B Residual Heat Removal (RH) Train while protected for shutdown operations during the week ending May 13, 2023.

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 2A Safety Injection (SI) Train during Refuel Outage A2R23. The inspectors' activities were conducted during the weeks ending April 22 through May 20, 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 Zones 5.4-1 and 5.6-1; Switchgear Area 451' Elevation, Unit 1 Divisions 11 and 12 Miscellaneous Electric Equipment Rooms and Battery Rooms during the week ending April 29, 2023.

(2) Fire Zone 1.3-2; 426' Elevation, Unit 2 Containment Upper Area during the weeks ending April 29 through May 13, 2023.

(3) Fire Zone 1.1-2; 377' and 401' Elevations, Unit 2 Containment Inside Missile Shield during the weeks ending May 6 through May 13, 2023.

(4) Fire Zone 1.2-2; 377' and 401' Elevations, Unit 2 Containment Annular Region during the weeks ending May 6 through May 13, 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 May 27, 2023.

===71111.08P - Inservice Inspection Activities (PWR)

The inspectors verified that the reactor coolant system boundary, 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:

PWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding Activities (IP Section 03.01)===

The inspectors verified that the following nondestructive examination and welding activities were performed appropriately:

(1) Ultrasonic Examination Welds 2AF-05-06, 07, 08, and 10, Aux FW Pipe to Elbow Welds Welds 2-SI-34-12, 15,18, and 26, SI Suction Line from Refueling Water Storage Tank (RWST)

Dye Penetrant Examination Weld 2CS-03, Containment Spray Pump Room 2A Welded Pipe Saddle

Visual Examination Metrology (Dimensional Measurements) on Control Rod Drive Mechanism (CRDM) Thermal Sleeves Volumetric or surface examination records and associated evaluations for relevant indications from the previous outage that the licensee analytically evaluated and accepted for continued service Ultrasonic Exam Indication on 2RH-03-2B, RHR Mixing Tee-Pipe Weld

Welding Activities GTAW/SMAW Repair Weld on Weld 2 SI-34-26, SI Suction Line from RWST Valve Replacement Welding on 2RC804 C and D RC Loop Equalization Line Manual Isolation Valve

PWR Inservice Inspection Activities Sample - Vessel Upper Head Penetration Inspection

Activities (IP Section 03.02) (1 Sample)

The inspectors verified that the license conducted the following vessel upper head penetration inspections and addressed any identified defects appropriately:

(1) Ultrasonic Examination (UT) of all 78 Reactor Vessel Upper Head Penetrations Bare Metal Visual (BMV) Examination of Reactor Vessel Upper Head Surface and Penetrations

PWR Inservice Inspection Activities Sample - Boric Acid Corrosion Control Inspection Activities (IP Section 03.03) (1 Sample)

The inspectors verified the licensee is managing the boric acid corrosion control program through a review of the following evaluations:

(1) AR 04522637, 2FC01 Outboard Pump Seal Leak AR 04552114, Boron Found on Valve 2CV8119 During Survey AR 04521341, Dry-wet Boric Acid at 2PT-RC012 non-EPN AR 04506201, Packing Leakage on 2RC016B AR 04520651, Worsening 2CV01PB Outboard Seal Leak

PWR Inservice Inspection Activities Sample - Steam Generator Tube Inspection Activities (Section 03.04) (1 Sample)

The inspectors verified that the licensee is monitoring the steam generator tube integrity appropriately through a review of the following examinations:

(1) Eddy Current Testing (ECT) of all operational steam generator (SG) tubes for Unit 2 SG A, B, C, and D Secondary side visual examinations for Unit 2 SG A, B, C, and D

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:

Observation of selected portions of 1A Emergency Diesel Generator (EDG)testing and 4160 Vac electrical bus manipulations during the week ending April 22, 2023.

Observation of selected portions of Unit 2 main steam safety valve (MSSV)testing during the week ending April 22, 2023.

Observation of selected portions of the shutdown of Unit 2 for Refuel Outage A2R23 during the week ending April 29, 2023.

Observation of selected portions of the cooldown of Unit 2 for Refuel Outage A2R23 during the week ending April 29, 2023.

Observation of selected portions of the reactor coolant system (RCS) drain to reduced inventory in support of Refuel Outage A2R23 reactor vessel head lift during the week ending April 29, 2023.

Observation of selected portions of RCS heatup and Unit 2 startup from Refuel Outage A2R23 during the week ending May 13, 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 facility's simulator on June 13, 2023.

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (5 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 receipt and insertion of rod cluster control assemblies into new fuel assemblies, as documented in Work Order (WO) 5198459-04 during the week ending April 22, 2023.

(2) Review and evaluation of the risk associated with implementation of an unplanned risk informed completion time (RICT) for Technical Specification (TS) 3.8.7 associated with the failure of Unit 1 Instrument Bus Inverter 114, as documented in Issue Reports (IRs) 4672131 and 4673173 during the weeks ending April 29 through May 20, 2023.

(3) Review and evaluation of the risk associated with an emergent maintenance activity on the 2B EDG, as documented in IR 4676013 and WO 5362733 during the week ending May 13, 2023.

(4) Review and evaluation of the risk associated with plant startup activities under the provisions of TS 3.0.4.b with selected plant components out-of-service, as documented in Braidwood Risk Management Evaluation BW-MODE-035 during the week ending May 13, 2023.

(5) Review and evaluation of the risk associated with emergent work to repair a hydraulic leak on the 2A Steam Generator Main Feedwater Stop Valve (2FW009A), as documented in IR 4678226 and WO 5365171 during the week ending May 20, 2023.

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (2 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 1B Component Cooling Water (CC) Train following identification that the 1B RH Heat Exchanger (HX) thermal relief valve (1CC94228)had lifted and was stuck open, as documented in IR 4667428 during the weeks ending April 8 through April 22, 2023.

(2) Evaluation of the operability of the DC Bus 212 Battery Charger following identification of anomalous voltage readings on the battery charger output, as documented in IR 4686690 during the week ending June 30, 2023.

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)

The inspectors evaluated the following permanent changes to the facility:

(1) Review of permanent plant modification per Engineering Change (EC) 628212: Install MSIV Roof Slab Restrains on Braidwood Unit 2, during the weeks ending May 6 through May 20, 2023.

(2) Review of permanent plant modification per EC 630851: Unit 2 Ovation TM Auto Runback Upon Loss of Multiple Feedwater Pumps, during the weeks ending May 13 through May 20, 2023.

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1) The inspectors reviewed licensee activities and evaluated licensee performance associated with Unit 2 Refuel Outage A2R23 during the weeks ending April 29 through May 13, 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) (12 Samples)

(1) Functional and operational testing of the 2B EDG following various maintenance activities during Unit 2 Refuel Outage A2R23, as documented in WO 5348311-02 during the week ending April 22, 2023.

(2) Functional and operational testing of Unit 1 Instrument Bus Inverter 114 following unplanned repairs, as documented in WO 5357898-08 during the weeks ending April 29 through May 6, 2023.

(3) Functional and operational testing of the 2B Auxiliary Feedwater Train following planned maintenance activities during Unit 2 Refuel Outage A2R23, as documented in WO 5205404 during the week ending May 13, 2023.

(4) Functional set pressure testing of MSSV 2MS015D following adjustment of the relief setpoint setting, as documented in WO 5240076-12 during the weeks ending April 22 through May 20, 2023.

(5) Functional set pressure testing of MSSV 2MS013A following adjustment of the relief setpoint setting, as documented in WO 5240076-01 during weeks ending April 22 through May 20, 2023.

(6) Core verification after refueling in A2R23, as documented in WO 5200757 during the weeks ending May 13 through May 20, 2023.

(7) Functional testing of Unit 2 Instrument Bus Inverter 212 following planned and scheduled maintenance during Unit 2 Refuel Outage A2R23, as documented in WO 5292902 during the weeks ending May 6 through May 27, 2023.

(8) Functional testing of Unit 2 Instrument Bus Inverter 214 following planned and scheduled maintenance during Unit 2 Refuel Outage A2R23, as documented in WO 5292901 during the weeks ending May 6 through May 27, 2023.

(9) Unit 2 automatic rod drop timing testing following planned and scheduled reactor refueling during Unit 2 Refuel Outage A2R23, as documented in WO 5203298 during the weeks ending May 13 through June 3, 2023.

(10) Low power and startup nuclear core physics testing following planned and scheduled reactor refueling during Unit 2 Refuel Outage A2R23, as documented in WOs 5203365 and 5206547 during the weeks ending May 13 through June 3, 2023.

(11) VT-2 leakage testing specified by Section XI of the ASME [American Society of Mechanical Engineers] Boiler & Pressure Vessel Code on Class 1, 2, and 3 systems and components following planned and scheduled reactor refueling during Unit 2 Refuel Outage A2R23, as documented in WOs 5212230 and 5213752 during the weeks ending May 13 through June 3, 2023.

(12) Post-modification testing of the Unit 2 Main Electrical Generator Auto Voltage Regulator following installation under EC 624259 during Unit 2 Refuel Outage A2R23, as documented in WO 4877286 during the weeks ending May 13 through June 10, 2023.

Surveillance Testing (IP Section 03.01) (3 Samples)

(1) Unit 2 RH system comprehensive pump and check valve stroke testing, as documented in WO 5214105 during the weeks ending May 6 through May 20, 2023.

(2) Semiannual Technical Specification fast start testing of the 2B EDG, as documented in WOs 5361575 and 5352260 during the week ending May 20, 2023.

(3) Technical Specification required testing of the 1A EDG to ensure that applicable automatic engine trips are appropriately bypassed during the emergency start sequence, as documented in WO 5185824 during the week ending May 27, 2023.

Inservice Testing (IST) (IP Section 03.01) (2 Samples)

(1) Periodic set pressure testing of MSSVs 2MS015A and 2MS013D, as documented in WOs 5240076-09 and 5240076-04 during the weeks ending April 22 through May 20, 2023.

(2) Pre-outage full flow testing of the 2A Auxiliary Feedwater Train (2BwOSR 5.5.8.AF-4A: Unit Two Comprehensive Inservice Testing (IST)

Requirements for 2A Auxiliary Feedwater Pump), as documented in WO 5204031-01 during the weeks ending April 22 through June 3, 2023.

Containment Isolation Valve (CIV) Testing (IP Section 03.01) (1 Sample)

(1) Local leak rate testing of Primary Containment Isolation Valve 2RE9159, as documented in WO 5224678 during the weeks ending April 29 through May 13, 2023.

Diverse and Flexible Coping Strategies (FLEX) Testing (IP Section 03.02) (1 Sample)

(1) 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 off-site vendor, as documented in WO 5011129 during the weeks ending January 14 through June 17, 2023.

71114.02 - Alert and Notification System Testing

Inspection Review (IP Section 02.01-02.04) (1 Sample)

(1) The inspectors evaluated the following maintenance and testing of the alert and notification system:

Monthly alert notification system (siren) tests for the period from March 2021 to March 2023 Annual siren inspection and maintenance records for the period from March 2021 to March 2023

71114.03 - Emergency Response Organization Staffing and Augmentation System

Inspection Review (IP Section 02.01-02.02) (1 Sample)

(1) The inspectors evaluated the readiness of the Emergency Preparedness Organization.

71114.05 - Maintenance of Emergency Preparedness

Inspection Review (IP Section 02.01 - 02.11) (1 Sample)

(1) The inspectors evaluated the maintenance of the emergency preparedness program.

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) workers utilizing the tool and equipment monitors and the whole body contamination monitors while exiting the radiologically controlled area during the Unit 2 refueling outage.

(2) radiation protection technicians performing work coverage for CRDM inspections.

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) various valve maintenance, repair and replacement activities in Unit 2 containment.

(2) Unit 2 containment snubber work and inspections.

(3) reactor coolant pump motor replacement and maintenance activities.

(4) reactor head disassembly.

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) Unit 2 refueling water storage tank SI line repairs.

(2) Unit 2 steam generator platforms.

(3) Unit 2 chemical and volume control system 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.

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

Temporary Ventilation Systems (IP Section 03.02) (1 Sample)

The inspectors evaluated the configuration of the following temporary ventilation systems:

(1) Unit 2 steam generator platforms during eddy current testing.

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors reviewed and verified selected portions of the licensee's performance indicator submittals listed below:

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===

(1) Unit 1 (April 1, 2022 - March 31, 2023)

(2) Unit 2 (April 1, 2022 - March 31, 2023)

MS06: Emergency AC Power Systems (IP Section 02.05) (2 Samples)

(1) Unit 1 (April 1, 2022 - March 31, 2023)

(2) Unit 2 (April 1, 2022 - March 31, 2023)

MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)

(1) Unit 1 (April 1, 2022 - March 31, 2023)

(2) Unit 2 (April 1, 2022 - March 31, 2023)

EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)

(1) January 1, 2022 through December 31, 2022

EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)

(1) January 1, 2022 through December 31, 2022

EP03: Alert And Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)

(1) 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 Sample 1 Partial)

The inspectors conducted in-depth reviews of the licensees implementation of the corrective action program (CAP) related to the following issues:

(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 April 22 through June 17, 2023.

(2) Review and assessment of the station's corrective actions stemming from long-term issues with the 0B High Head FLEX Pump (0FX02PB), as documented in IRs 4507623, 4508035, 4513349, 4548150, 4548287, and 4552101 during the weeks ending June 24 through June 30, 2023. 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 June 24 through June 30, 2023. A specific trend related to performance issues and the obsolescence of the station's 125 Vdc safety-related battery chargers is documented in the Results Section of this report.

71153 - Follow-up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

The inspectors reviewed, evaluated, and closed the following licensee event report (LER):

(1) Unit 1 LER 05000456/2022-001-00, Liquid Penetrant Indications in Control Rod Drive Mechanism Nozzle Seal Weld Repair due to Subsurface Weld Defects Opening Up from Thermal and Pressure Stresses during Operation (ADAMS Accession No.

ML22334A008). The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER, therefore no performance deficiency was identified. The inspectors reviewed the LER during the week ending May 6, 2023, and determined there were no associated findings or violations. Details of the inspectors review are documented in the Results Section of this report.

INSPECTION RESULTS

Failure to Follow Steam Generator Eddy Current Testing Analysis Procedure Cornerstone Significance Cross-Cutting Report Aspect Section The inspectors identified a finding of very low safety significance (Green) and an associated Non-Cited Violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criteria V, "Instructions, Procedures, and Drawings", for the licensee's failure to follow the site-specific steam generator (SG) Eddy current testing (ECT) analysis procedure. Specifically, the licensee failed to follow procedure ER-MW-335-1003, Steam Generator Eddy Current Data Analysis Guidelines for Braidwood and Byron Stations Unit 2 when analyzing an indication that was identified in SG 2A tube during ECT performed in October 2021.

Description:

Eddy current testing is currently the primary nondestructive evaluation (NDE)method used for inservice inspection (ISI) of SG tubes during plant outages. Eddy current testing provides information about SG tube discontinuities. In general, depending on the technique being employed, the measured probe response can provide information about an indications location, origin (i.e., initiated from inner or outer surface of the tube), spatial extent, and relative orientation (axial, circumferential, or volumetric).

During the review of the ECT data obtained for Unit 2 SGs during the 2023 outage, the inspector also examined the ECT data from the previous outage. Specifically, the inspector requested the licensees SG resolution experts to retrieve the 2023 outage ECT data for flagged indications and areas of special interest, such as Anti Vibration Bar (AVB) wear signals and Tube Support Plate signals. Of particular interest was an axial indication detected in SG 2A, located in row 41 column 82, which was found to be 66% thru-wall in the free-span region of a tube. The inspector requested the licensee's analysts to superimpose the ECT signal from the last ECT performed in 2021 on the same SG tube at that specific location.

The comparison revealed a similar signal amplitude in 2021; however, there was insufficient data to interpret the indication's thru-wall dimension. Consequently, the inspector raised concerns regarding the previous "non flaw condition" classification of this indication signal in 2021.

Procedure ER-MW-335-1003, Section 4.19, titled Data Evaluation (Bobbin Coil), stated, this section defines special augmented data screening and analysis requirements for various classes of indications. Section 4.19.6 - 1 stated, REPORT new and previous free span differential indications in accordance with the applicable ETSS and flowchart. Procedure CDE-061-021, "Eddy Current Examination Technical Specification Sheet", contained the flowcharts for disposition of new and previous signals specific to Braidwood Unit 2 SG ECT. The flowchart in CDE-061-021, pertaining to Bobbin Coil free-span data, instructed the analyst to disposition the 2021 signal as a "Differential Free-Span Indication" (DFI) and employ different ECT probe techniques for further characterization. However, the signal was instead dispositioned as a "non-flaw condition," and no further ECT probe technique was used to determine the indication's thru-wall size. The licensee reviewed the previous data from 2021 and the procedures in place at that time and determined a potential missed call on the indication.

Since the 2023 indication was accurately identified and sized, and its size falls below the criteria for conducting an In Situ pressure test on the tube based on the EPRI Steam Generator In situ Pressure Test Guidelines, Revision 5, the licensee concluded that an In Situ pressure test is not necessary for this indication.

Corrective Actions: The licensee entered the inspectors question and concern into their corrective action program as a potential missed indication from 2021 and initiated actions to understand where the breakdown during analysis and independent review occurred resulting in this condition.

Corrective Action References: ARs 04675314 and 04674115

Performance Assessment:

Performance Deficiency: The licensee's failure to follow procedure ER-MW-335-1003, titled Steam Generator Eddy Current Data Analysis Guidelines for Braidwood and Byron Stations Unit 2, when analyzing an indication that was identified in one the SG tubes during ECT performed in the October 2021 Unit 2 refueling outage was determined to be a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the licensee's failure to follow the ECT analysis procedure when identifying the 2021 ECT signal as a potential indication allowed a degraded and uncharacterized SG tube to be put back to service for continued operation. This condition does not limit the likelihood of unacceptable RCS pressure boundary leakage or a SG tube rupture event.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors answered "No" to questions, "Does the finding involve a degraded steam generator tube condition where one tube cannot sustain three times the differential pressure across a tube during normal full power, steady state operation?" and "Do one or more SGs violate accident leakage performance criterion (i.e., involve degradation that would exceed the accident leakage performance criterion under design basis accident conditions)?"

Therefore, the finding was screened as having very low safety significance (Green).

Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Based on interviews conducted with licensee and vendor staff, the inspector determined that there was a failure to implement adequate error reduction tools during the multiple stages of analysis and resolution after the acquisition of ECT data. This led to a human error that went unnoticed throughout the various review levels.

Enforcement:

Violation: Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criteria V, states 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 the above, in October 2021, the licensee failed to accomplish an activity affecting quality in accordance with a documented procedure. Specifically, Section 4.19.6 - 1 of procedure ER-MW-335-1003, Revision 10, stated, REPORT new and previous free span differential indications in accordance with the applicable ETSS and flowchart. Procedure CDE-061-021, "Eddy Current Examination Technical Specification Sheet (ETSS)", Revision 0, contained the flowcharts for disposition of new and previous signals specific to Unit 2 SG ECT. The applicable flowchart instructed the analyst to disposition an ECT signal obtained for Unit 2 SGs during the 2021 outage as a "Differential Free-Span Indication" (DFI) and employ different ECT probe techniques for further characterization. However, the signal was instead dispositioned as a "non-flaw condition," and no further ECT probe technique was used to determine the indication's thru-wall size.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Observation: 0B High Head FLEX Pump (0FX02PB) Performance Issues 71152A The inspectors performed a detailed review of several issue reports (IRs) related to the subject performance problem. These included, but were not limited to:

- IR 4507623, B High Head FLEX Pump Did Not Meet Test Parameters;

- IR 4508035, 0B High Head FLEX Pump High Oil Temperature Trip;

- IR 4513349, 0FX02PB Could Not Achieve 0BwOS FX-12 Parameters as Needed;

- IR 4517970, 0FX02PC Failed 0BwOS FX-12 Requirements;

- IR 4522293, High Head FLEX Pump Compensatory Actions Adequacy;

- IR 4548150, 0FX02PB: Acceptance Criteria Not Met During Testing;

- IR 4548287, Post-Maintenance Testing (PMT) Failure: 0B High Head FLEX Pump;

- IR 4552101, 0FX02PB 0B High Head FLEX Pump Failure;

- IR 4680217, High Head Pump Deficiency; and

- IR 4682187, Issues During Testing of 0B High Head FLEX Pump.

On March 12, 2012, the NRC issued Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events. The order was effective immediately and directed the licensee to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in response to a beyond-design-basis external event. Later, the NRC incorporated these requirements into the Code of Federal Regulations under 10 CFR 50.155, Mitigation of Beyond-Design-Basis Events.

On December 7, 2016, the licensee informed the NRC that they had completed development and implementation of their mitigation strategies (Exelon Generation Company, LLC Letter No. RS-16-223 - ADAMS Accession Number ML16348A053). Like many utilities, the licensee chose to base the development and implementation of their mitigation strategies on Nuclear Energy Institute (NEI) 12-06, Revision 0, Diverse and Flexible Coping Strategies (FLEX)

Implementation Guide (ADAMS Accession Number ML12242A378). The licensees strategies require the use of three different pumps, low head, medium head, and high head. The guidance in NEI 12-06 specifies that sites must maintain enough components to implement their strategies on all units (N) at the site, and have one additional (N + 1) component. To implement their strategies at Braidwood Station, the licensee requires one high head FLEX pump per unit, which means that a total of three high head FLEX pumps must be maintained at the site in order to satisfy the N + 1 requirements.

Additionally, the licensees mitigation plan based on the guidance stipulated in NEI 12-06 allows for the N + 1 high head FLEX pump to be out-of-service (to facilitate extended maintenance or repairs) for a period of up to 90 days.

During the summer of 2022, the licensee conducted full flow testing on all three high head FLEX pumps. The 0A High Head FLEX Pump (0FX02PA) passed this testing. The 0C High Head FLEX Pump (0FX02PC) did not meet the acceptance criteria as stated in the test procedure, but the licensee was able to evaluate the test results obtained and declare that the pump had sufficient capability to meet their FLEX strategy. On June 26, 2022, the 0B High Head FLEX Pump (0FX02PB) was tested and could not produce acceptable results. The licensee conducted troubleshooting on site with this component, including attempting different testing configurations, all without success. Ultimately, after several weeks the 0B High Head FLEX Pump was sent off-site to a vendor facility in the local area for testing and repair.

On January 12, 2023, the licensee attempted to test the 0B High Head FLEX Pump following its return from the vendors local facility. Once again, the acceptance criteria within the licensees full flow test procedure, 0BwOS FX-12, FLEX Pump Full Flow Test Surveillance, could not be met. With the pump vendor on-site providing assistance, troubleshooting was again performed by the licensee without success. Ultimately, the 0B High Head FLEX Pump was shipped off-site to the pump manufacturing facility in New Jersey for troubleshooting and repairs.

At the pump manufacturing facility in New Jersey, the 0B High Head FLEX Pump was overhauled and modified with the addition of a second hydraulic oil cooler. Following its return to the site, on June 2, 2023, the 0B High Head FLEX Pump was returned to an available status after successful completion of full flow performance testing. The 0B High Head FLEX Pump had been out-of-service for a total of 342 days, or 252 days beyond the 90 days permitted by the licensees NEI 12-06 based mitigation plan.

In reviewing this issue, the inspectors determined that the licensees inability to return the 0B High Head FLEX Pump to service within the 90 days allowed by their mitigation plan/strategy constituted a performance deficiency that was within their ability to foresee and which should have been prevented. Recognizing, however, that the licensee still maintained the ability to implement their mitigation plan/strategy even with the N + 1 high head FLEX pump out-of-service for the extended period of time, the inspectors determined that issue was of minor significance and not subject to formal actions per Section 2.3.1 of the NRC Enforcement Policy.

With the return of the 0B High Head FLEX Pump to service, the inspectors examined the licensees corrective actions from the previous twelve months in an effort to determine whether or not all outstanding issues and questions had been addressed. Several observations by the inspectors were discussed station management, which included but were not limited to:

Periodic full flow testing for the stations high head FLEX pumps was originally contracted out to a 3rd party vendor, and then subsequently transferred to the stations Operations Department. The inspectors noted that a number of the issues with high head FLEX pump full flow testing seemed to align with the transfer of the testing regimen to the stations own personnel using station procedures, and that the possibility of this change having played a part in various subsequent high head FLEX pump performance issues had yet to be fully explored.

The need for the 0B High Head FLEX Pump to be equipped with a second hydraulic oil cooler in order for it to be returned to service raises some questions regarding the original design of the high head FLEX pumps and their suitability, as originally built, for their intended function. The inspectors noted during the course of their review that the licensee was intending to equip the remaining 0A and 0C High Head FLEX Pumps with additional hydraulic oil coolers as well as an enhancement.

If the high head FLEX pumps, as built and procured by the licensee, were appropriately suited for their function, then the possibility exists that the performance issues observed to date may have been the result of one or more degraded components on the pump(s). The inspectors noted that the licensees investigation efforts had yet to be completed in this area.

In the course of the inspectors review, no findings or violations of NRC requirements of more than minor safety significance were identified.

Observation: Safety-Related 125 Vdc Battery Chargers 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 that the licensee continues to experience performance issues involving the stations safety-related 125 Vdc battery chargers, all of which are original plant equipment. Specific CAP entries reviewed by the inspectors included, but were not limited to:

- IR 4686690; Unexpected Alarm 2-22-E10, 125V DC Distribution Panel 212/214 Voltage Low.

- IR 4527879; Unexpected Alarm 2-22-E10, 125V DC Distribution Panel 212/214 Voltage Low.

- IR 4527763; Unexpected Alarm 2-22-E8, 125V DC Battery Charger 212 Trouble.

- IR 4436885; Battery 112 Charger Unexpected System Response.

The 125 Vdc electrical power system for each unit consists of two independent and redundant safety-related DC electrical power subsystems (Division 11

(21) and Division 12 (22)). Within the stations probabilistic risk analysis (PRA), they are near the top of the list of highly risk-significant key plant equipment. Each subsystem consists of one 125 Vdc battery, the associated battery charger for each battery, and all the associated control equipment and interconnecting cabling. During normal operation, 125 Vdc loads are powered from the battery chargers, with the batteries floating on the bus. If/when a loss of normal power to the battery charger occurs, electrical loads on the bus are picked up and powered uninterrupted from the respective station battery. While there is no connection between redundant 125 Vdc subsystems, such as batteries, battery chargers or distribution panels on a given unit, it is possible to interconnect the Unit 1 and Unit 2 125 Vdc subsystems of the same division. This permits a given 125 Vdc battery charger to be taken out of service for the purposes of maintenance and/or testing.

The stations four 125 Vdc safety-related battery chargers are considered to be obsolete. The original equipment manufacturer, Power Conversions Products in Crystal Lake, Illinois, was bought out by a foreign company in the early 2000s and no longer exists. While replacement parts for the stations 125 Vdc safety-related battery chargers still can be found, the status of the battery chargers as obsolete within the industry represents a challenge to the continued availability of spare parts. Recognizing this vulnerability, in May - June of 2021 the licensee developed a plan to replace the battery chargers with a newer/upgraded design.

The inspectors did not identify any findings or violations of NRC requirements in the course of this review. The inspectors did note, however, that the licensees present schedule for the upgrade of these key pieces of highly risk-significant plant equipment currently has the replacement activities for the stations 125 Vdc safety-related battery chargers out in the 2027 2028 timeframe.

Observation: LER 05000446/2022-001-00: Liquid Penetrant Indications in 71153 Control Rod Drive Mechanism Nozzle Seal Weld Repair due to Subsurface Weld Defects Opening Up from Thermal and Pressure Stresses during Operation The inspectors performed a detailed review of the licensees causal evaluation associated with IR 4527538, OSP-A: Rejectable Indications on CRDM Pen 69 Weld Buildup.

On October 7, 2022, during a Liquid Penetrant examination on the embedded flaw seal weld repair of Control Rod Drive Mechanism (CRDM) Penetration (Pen) 69, five 1/4-inch rounded indications were discovered that were determined to be unacceptable per the acceptance criteria in Section Ill of the ASME Boiler & Pressure Vessel Code (ASME Section III). Each unacceptable indication was identified during a scheduled ASME Section XI examination. An approved ASME Section XI Code repair method was applied consisting of blending the indications to remove or reduce the size to meet the applicable acceptance criteria in ASME Section Ill. Liquid penetrant examinations were then performed by the licensee to confirm that the ASME Section III acceptance criteria were met. The unacceptable indications did not penetrate through the embedded flaw seal weld or result in any through-wall reactor coolant pressure boundary leakage.

The licensees CAP evaluation subsequently attributed the cause of these indications to existing mechanical discontinuities and/or minor subsurface voids growing or opening to the weld surface due to thermal and/or pressure stresses during plant operation. The inspectors did not identify any issues with the licensees actions taken in response to this event. No findings or violations of NRC requirements were identified by the inspectors in the course of this review.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On July 11, 2023, the inspectors presented the integrated inspection results to G. Gugle, Site Vice President, and other members of the licensee staff.

On April 20, 2023, the inspectors presented the emergency preparedness inspection results to A. Trespalacios, Director, Organizational and Regulatory Performance, and other members of the licensee staff.

On May 4, 2023, the inspectors presented the radiation protection inspection results to G. Gugle, Site Vice President, and other members of the licensee staff.

On May 15, 2023, the inspectors presented the inservice inspection results to J. Petty, Plant Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.04 Drawings M-136, Sheet 1 Diagram of Safety Injection Unit 2 BR

M-136, Sheet 2 Diagram of Safety Injection AF

M-136, Sheet 3 Diagram of Safety Injection AY

M-136, Sheet 4 Diagram of Safety Injection BH

M-136, Sheet 5 Diagram of Safety Injection X

M-136, Sheet 6 Diagram of Safety Injection AP

Procedures 2BwOSR Residual Heat Removal System Comprehensive Pump Test 14

5.5.8.RH-6 and Check Valve Stroke Test

2BwOSR Comprehensive Inservice Testing (IST) Requirements for Unit 16

5.5.8.SI-11 2 Safety Injection Pumps and Safety Injection System Check

Valve Stroke Test

BwOP FC-E1 Electrical Lineup - Unit 1 Operating 1

BwOP FC-E2 Electrical Lineup - Unit 2 Operating 1

BwOP FC-M1 Operating Mechanical Lineup Unit 1 10

BwOP FC-M2 Operating Mechanical LIneup Unit 2 8

BwOP RH-E2 Electrical Lineup - Unit 2 Operating 9

BwOP RH-M4 Operating Mechanical Lineup Unit 2 2B Train 8

BwOP SI-E2 Electrical Lineup - Unit 2 Operating 10

BwOP SI-M2 Operating Mechanical Lineup Unit 2 24

Work Orders 5200408 IST-2SI8005/A-D/2SI8949B/D/2SI8922A/B - S Hot Leg Check 04/26/2023

Valves

204032 IST-2SI8819/A/B/C/D/2SI8926 - SI Cold Let Check Valve 04/26/2023

205408 IST-CO-2SI8818/A/B/C/D & CP-2SI8948/A/B/C/D - U2 RH 0/27/2023

Cold Leg

205408 IST-CO-2SI8818A/B/C/D & CP-2SI8948A/B/C/D - U2 RH Cold 04/27/2023

Leg

255220 IST-CO-2SI8841A/B & CO-2SI8949A/C - U2 RH Hot Leg 04/26/2023

71111.05 Corrective Action 4685793 Fire Marshal Identified: 2nd Fire Drill Observations 06/20/2023

Documents

Fire Plans Pre-Fire Plan No. Fire Zone 1.3-2; Containment 426' -0" Elevation, Unit 2 3

Containment Upper Area

Inspection Type Designation Description or Title Revision or

Procedure Date

Pre-Fire Plan No. Fire Zone 1.1-2; Containment 377' -0" Elevation, Unit 2 1

Containment Missile Shield

Pre-Fire Plan No. Fire Zone 1.1-2; Containment 401' -0" Elevation, Unit 2 1

Containment Missile Shield

Pre-Fire Plan No. Fire Zone 5.4.1; Switchgear Are 451' Elevation, Unit 1 Division 1

12 Miscellaneous Electric Equipment Room and Batter Room

Pre-Fire Plan No. Fire Zone 5.6-1; Switchgear Area 451' Elevation, Unit 1 1

Division 11 Miscellaneous Electric Equipment Room and

Batter Room

Pre-Fire Plan No. Fire Zone 1.2-2; Containment 377' -0" Elevation, Unit 2 2

Annular Area

Pre-Fire Plan No. Fire Zone 8.5-1; Turbine Building 426' Elevation, Unit 1 1

Turbine Building Mezzanine Floor - Northwest

Pre-Fire Plan No. Fire Zone 8.5-1; Turbine Building 426' Elevation, Unit 1 2

Turbine Building Mezzanine Area - Northeast

Pre-Fire Plan No. Fire Zone 1.2-2; Containment 401' -0" Elevation, Unit 2 2

Annular Area

Miscellaneous Fire Drill Scenario Hot Work Fire 02/21/2022

20.23.05.23

Procedures BwAP 1100-16 Fire/Hazardous Materials Spill and/or Injury Response 39

BwAP 1100-3 Fire Chief (Designated Field Supervisor) Implementing 4

Procedure

BwAP 1100-4 Fire Brigade Implementing Procedure 5

BwAP 1110-1 Fire Protection Program System Requirements 48

BwAP 1110-3 Plant Barrier Impairment Program 40

BwAR 0-37-A4 Unit One Area Fire 18

BwOP FP-100 Fire Response Guidelines 25

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

Matrix

CC-AA-201 Plant Barrier Control Program 14

ER-AA-600-1069 High Risk Fire Area Identification 4

ER-BR-600-1069 Site List of High Risk Fire Areas - Braidwood Unit 1 and Unit 20

OP-AA-201-003 Fire Drill Performance 21

OP-AA-201-004 Fire Prevention for Hot Work 19

Inspection Type Designation Description or Title Revision or

Procedure Date

OP-AA-201-005 Fire Brigade Qualification 11

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

OP-AA-201-009 Control of Transient Combustible Material 28

OP-AA-201-012-Operations On-Line Fire Risk Management 5

1001

OP-BR-201-012-Braidwood On-Line Fire Risk Management 4

1001

71111.08P Corrective Action AR 04506201 Packing Leakage on 2RC016B 07/29/2022

Documents AR 04520651 Worsening 2CV01PB Outboard Seal Leak 11/01/2022

AR 04521341 Dry-Wet Boric Acid at 2PT-RC012 non-EPN Drain Valves 10/20/2022

AR 04522637 2FC01P Outboard Pump Seal Leak 10/26/2022

AR 04552114 Boron Found on Valve 2CV8119 During Survey 02/07/2023

AR 04673843 A2R23 CRDM Thermal Sleeves Metrology Results 04/27/2023

AR 04673991 Indication Discovered in Weld 2SI-34-26 During ISI 04/29/2023

AR 04674115 A2R23 Eddy Current Examination Indication in SG 2A 04/30/2023

AR 04674445 A2R23 ISI Relevant Condition Identified on 2CV06009C Pipe 05/01/2023

Support

Corrective Action AR 04675314 Investigate Prior Eddy Current Indications from A2R22 (2021)05/03/2023

Documents

Resulting from

Inspection

NDE Reports 180-9363870-000 Braidwood Unit A2R23 RVCH Penetrations Examination 05/02/2023

Report

23-RT--001 Radiographic Examination Report for Radiography on Weld 05/02/2023

2SI-34-26

A2R17-UT-031 Ultrasonic Examination on Elbow-Pipe Weld 2SI-34-26 05/12/2014

A2R22-UT-Ultrasonic Examination on 2RH-03-2B RHR Mixing Tee-Pipe 10/24/2021

074/075 Weld

A2R23-PT-001 Liquid Penetrant Examination on Containment Spray Pump 04/28/2023

Room 2A 180 Degree Welded Pipe Saddle 2-CS-03-SW01

A2R23-UT--029 Ultrasonic Examination on Safety Injection Line Weld 04/29/2023

2SI-34-26

A2R23-UT-Ultrasonic Examination on Safety Injection Line Welds 04/30/2023

043/044/045 2SI-34-12/15/18

Inspection Type Designation Description or Title Revision or

Procedure Date

A2R23-UT-Ultrasonic Examination on Aux Feedwater Welds 04/28/2023

046/07/08/09 2AF-05/06/07/08/10

A2R23-UT-053 Ultrasonic Examination on Safety Injection Line Weld 05/03/2023

2SI-34-26

A2R23-VEN-002 Bare Metal Visual (BMV) Examination of Reactor Closure 04/30/2023

Head Top Head and Penetrations

Procedures 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

CDE-001-021 Examination Technique Specification Sheet 0

ER-AA-335-002 Liquid Penetrant Examination 12

ER-AA-335-031 Ultrasonic Examination of Austenitic Pipe Welds 10

ER-AP-335-040 Evaluation of Eddy Current Data for Steam Generator Tubing 9

ER-MW-335-1003 Steam Generator Eddy Current Data Analysis Guidelines for 10

Braidwood and Byron Unit 2

MRS-2.4.2 GEN-Eddy Current Inspection of Pre-Service and In-Service Heat 20

Exchanger Tubing

WPS 8.8 - GTSM Welding Procedure Specification Record for GTAW and 7

SMAW

Work Orders 05105558 Replace Valve 2RC804C/D RC Loop Equalization Line 10/22/2021

Manual Isolation Valve

71111.11Q Miscellaneous BR2C23-06.0 Braidwood 2 Cycle 23 Coastdown Reactivity Plan 03/20/2023

Procedures 1BwGP 100-8 Generic Reactor Control Guidance 39

2BwGP 100-8 Generic Reactor Control Guidance 36

OP-AA-101-1006 4.0 Crew Critique Guidelines 12

OP-AA-101-111-Operations 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 5

Inspection Type Designation Description or Title Revision or

Procedure Date

OP-AA-111-101 Operating Narrative Logs and Records 19

OP-AA-300 Reactivity Management 14

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

TQ-AA-150 Operator Training Programs 23

TQ-AA-155 Conduct of Simulator Training and Evaluation 13

TQ-AA-210 Examination Security and Administration 19

TQ-AA-306 Simulator Management 11

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

Security Actions

71111.13 Corrective Action 4672131 Alarm 1-4-D5, Bus 114 Inverter (1IP08E) Trouble SER No. 04/22/2023

Documents 2264

4673147 +130 Vdc Ground DC Bus 112 During Inverter 114 Testing 04/26/2023

4673173 Instrument Inverter 114 Failure After Maintenance 04/26/2023

4673457 1SI-IP092 Inverter 114 Output Frequency Meter Suspect 04/272/2023

4673812 Fire PRA Overconservative Modeling 04/28/2023

4676013 OSP - Cylinder 1L Temperature Abnormal 05/06/2023

4678226 2FW009A 6 Drops per Minute Hydraulic Leak 05/15/2023

Drawings 20E-1-4030IP04, Schematic Diagram - 10 KVA Inverter for Instrument Bus 114 B

Sheet 1 (1IP08E), Part 1

20E-1-4030IP04, Schematic Diagram - 10 KVA Inverter for Instrument Bus 114 A

Sheet 2 (1IP08E), Part 2

Miscellaneous Final RICT Record for Failure of Instrument Bus Inverter 114 04/30/2023

(1IP08E)

BW-MODE-035 TS 3.0.4.b Evaluation - Mode Change with Technical 0-2

Specification Equipment Out of Service

Procedures BwMP 3100-082 Diesel Generator 6-Year Inspection 37

ER-AA-600 Risk Management 7

ER-AA-600-1023 PARAGON Model Capability 11

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

ER-AA-600-1052 Risk Management Support of RICT 1

ER-AA-600-1053 Calculation of RMAT and RICT for Risk Informed Completion 0

Time Program

ER-BW-600-2001 Braidwood RICT System Guidelines 0

Inspection Type Designation Description or Title Revision or

Procedure Date

MA-AA-716-004 Conduct of Troubleshooting 20

NF-AA-411 Receipt Inspection of Nuclear Fuel and Associated Fuel 11

Related Components

NF-AP-309 PWR Special Nuclear Material and Core Component Move 3

Sheet Development

OP-AA-107 Integrated Risk Management 6

OP-AA-108-117 Protected Equipment Program 7

OP-AA-108-118 Risk Informed Completion Time 3

OU-AA-101-1011 Outage Risk Management 3-4

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

Byron and Braidwood

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

Ginna

OU-AP-203 Operation of the New Fuel Elevator for Byron and Braidwood8

OU-AP-204 Fuel Movement in the Spent Fuel Pol for Byron and Braidwood18

OU-OU-AP-4001 PWR Fuel and Core Component Handling Practices 18

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

Work Orders 5198459-04 Unit 2 New Fuel Download into The Spent Fuel Pool 02/07/2023

5357898-01 Replace the X5 Synch Card and the X201 Card on 1IP08E 04/23/2023

5362733-01 FNM - 2DG01KB - Replace 1L Fuel Injector Pump 05/09/2023

5365171-01 FNI - 2PS-FW162 - Replace Pressure Switch 05/16/2023

71111.15 Corrective Action 4667428 1CC9422B Relief Valve Lifting 04/04/2023

Documents 4686690 Unexpected Alarm 2-22-E10, 125V DC Distribution Panel 06/25/2023

2/214 Voltage Low

Procedures ER-AA-600-1012 Risk Management Documentation 14

71111.18 Engineering 628216 Install Unit 2 MSIV Roof Slab Restraints 0-1

Changes 630851 Unit 2 Ovation' Auto Runback Upon Loss of Multiple 0

Feedwater Pumps

Work Orders 4983252-03 Install EC 628216: 2A MSIV Roof Slab Restraints 05/08/2023

4983252-04 Install EC 628216: 2D MSIV Roof Slab Restraints 05/08/2023

4983252-05 Install EC 628216: 2B MSIV Roof Slab Restraints 05/08/2023

4983252-06 Install EC 628216: 2C MSIV Roof Slab Restraints 05/08/2023

5012832-04 Install EC 630851: Unit 2 Ovation' Auto Runback Upon Loss 04/12/2023

Inspection Type Designation Description or Title Revision or

Procedure Date

of Multiple Feedwater Pumps

5012832-05 Install EC 630851: Unit 2 Ovation' Auto Runback Upon Loss 05/05/2023

of Multiple Feedwater Pumps - Modification Acceptance Test

71111.20 Corrective Action 4675931 Fuel Assembly Unable to Properly Seat 05/05/2023

Documents

Miscellaneous A2R23 Shutdown Safety Plan 0 - 2

Procedures 2BwGP 100-1 Plant Heatup 44

2BwGP 100-2 Plant Startup 41

2BwGP 100-3 Power Ascension 5% to 100% 89

2BwGP 100-4 Power Descension 54

2BwGP 100-5 Plant Shutdown and Cooldown 60

2BwGP 100-6 Refueling Outage 35

2BwOS TRM Unit Two Containment Loose Debris Inspection 25

2.5.b.1

BwAP 1450-1 Access to Containment 45

ER-AA-600-1043 Shutdown Risk Management 8

HU-AA-1211 Pre-Job Briefings 14

LS-AA-119 Fatigue Management and Work Hour Rules 16

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

1008

OP-AA-108-108 Unit Restart Review 23

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

1001

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

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

Refueling

OU-AA-103 Shutdown Safety Management Program 23

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

71111.24 Corrective Action 4563135 Fuel Oil Leak 2B DG 03/18/2023

Documents 4671070 Low Fuel Oil Pressure on Start of 2B D/G 04/18/2023

4676928 OSP - 2B Emergency Diesel Generator 1L Fuel Injection 05/10/2023

Pump Leaking While Diesel Generator Running

Procedures 0BwOS FX-12 FLEX Pump Full Flow Test Surveillance 0-2

Inspection Type Designation Description or Title Revision or

Procedure Date

1BwOSR 1A Diesel Generator Bypass of Automatic Trips Surveillance 21

3.8.1.13-1

2BwOSR 3.6.1.1-Primary Containment Type C Local Leakage Rate Testing of 17

Reactor Building Drains and Vents System

2BwOSR 3.7.5.7-Unit Two Train B Auxiliary Feedwater Flow Path Operability 7

Non-Routine Surveillance (Following Cold Shutdown)

2BwOSR 2B Diesel Generator Loss of ESF Bus Voltage with No SI 23

3.8.1.11-2 Signal

2BwOSR 3.8.1.2-Unit Two 2B Diesel Generator Operability Surveillance 53

2BwOSR Unit 2 Comprehensive Inservice Testing (IST) Requirements 20

5.5.8.AF-4A for 2A Auxiliary Feedwater Pump

2BwOSR Residual Heat Removal System Comprehensive Pump and 14

5.5.8.RH-6 Check Valve Stroke Test

BwAR 1-4-D5 Buss 114 Inverter Trouble 53

BwISR 3.1.4.3.1 Rod Drop Time (Automatic) 12

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

Device

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

BwOP IP-1 Instrument Bus Inverter Startup 45

BwOP IP-2 Transferring an Instrument Bus from the Inverter to the 43

Constant Voltage Transformer

BwVS 500-6 Low Power Physics Test Program 48

BwVS TRM Core Reload Sequence and Verification 24

3.1.h.1

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

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

2013 Edition

MA-AA-723-325 Molded Case Circuit Breaker Testing 20

MA-AA-793-044 Inspection/Certification of Portable Pressure Test Equipment5

OP-BR-FX-1003 High Head FLEX Pump Operating Guideline 1-2

SPP-19-002 Modification Testing, Commissioning, and Power Ascension 1

Inspection Type Designation Description or Title Revision or

Procedure Date

Procedure for ABB Unitrol 6000 Automatic Voltage Regulator

(AVR) Replacement

Work Orders 4877286-75 Modification Test for EC 624259: Replacement Main 06/08/2023

Generator Voltage Regulators - Unit 2

5011129 0FX02PB Performance Test 06/10/2023

5011129 0FX02PB Performance Test 06/10/2023

5185824 1A Emergency Diesel Generator Bypass of Automatic Trips 05/24/2023

Surveillance

200757 Physical Reactor Inventory Prior to Installing Reactor Head 05/04/2023

Upon

203365 Low Power Physics Test Program with Dynamic Rod Worth 05/12/2023

Measurement

204031-01 IST - Unit 2 Full Flow Test and Equipment Response Time of 04/21/2023

Auxiliary Feedwater

206547 Reload Startup Physics Testing Following Refueling 05/25/2023

212230 VT-2 Exam - Unit 2 Class 2 & 3 Components - Outage MODE 05/18/2023

Ascending

213752 VT-2 Exam - Unit 2 Class 1 Components - Outage MODE 3 05/18/2023

Ascending

214105 IST Comprehensive & Response Time Test of 2A RH Pump 05/04/2023

24678 IST-LT-U2 LLRT RE 9159A/B P65 RCDT to Gas Analyzer 04/27/2023

240076-01 2MS013A: Testing of Main Steam Safety Valve 04/19/2023

240076-04 2MS013D: Testing of Main Steam Safety Valve 04/19/2023

240076-09 2MS015A: Testing of Main Steam Safety Valve 04/19/2023

240076-12 2MS015D: Testing of Main Steam Safety Valve 04/19/2023

292901-01 2IP08E Replace Components and Test Inverter 05/01/2023

292901-05 2IP08E Perform Loaded Capacity Test 05/04/2023

292902-01 2IP06E Replace Components and Test Inverter 05/02/2023

292902-05 2IP06E Perform Loaded Capacity Test 05/03/2023

5348311 Fuel Oil Leak 2B DG 04/18/2023

5350647 LR-IST-2B D/G Operability Monthly 04/18/2023

5352260 OP 2DG01KB Operability Semiannual Surveillance 05/17/2023

5357898-08 EM: 1IP08E Instrument Inverter 114 Performance Monitoring 04/30/2023

Inspection Type Designation Description or Title Revision or

Procedure Date

5361575 LR-OP IST - 2B Emergency Diesel Generator Monthly 05/18/2023

5361975 FNE 2B DG Field Flash Relay 90FF T/S 05/09/2023

71114.02 Corrective Action AR 04433568 EP-Siren - Failure (BW06,BD18) 07/06/2021

Documents AR 04438720 Grundy County 911 Siren Controller Error 08/03/2021

AR 04445149 Siren BD04 Indicated an issue during morning poll 09/08/2021

AR 04458668 EP-Siren Failure BW14 11/04/2021

AR 04512746 Siren BW29 Indicated an issue during polling 07/05/2022

Miscellaneous Off-Site Emergency Plan Alert and Notification System 08/01/2009

Addendum (ANS) for the

Braidwood Nuclear Power Station

Alert Notification System Maintenance Records 03/01/2023 -

03/31/2023

Alert Notification Testing Records 03/01/2021 -

03/31/2023

KLD TR - 985 Braidwood Generating Station Alert and Notification System 09/19/2018

(ANS) Design Report Revision Submittal

71114.03 Corrective Action AR 04427264 2021 Braidwood EP HP Drill Learning 06/03/2021

Documents AR 04442499 2021 EP Focus Area Drills Critique and Learnings 08/25/2021

AR 04446913 Accountability / Evacuation Drill Critique 09/16/2021

AR 04466639 Annual EP Medical Drill Hospital Participation 12/14/2021

AR 04476316 EP Plume Phase and Environ Monitoring 02/06/2022

Miscellaneous Emergency Response Organization (ERO) Augmentation Drill 03/01/2021 -

Reports (Quarterly call-in drill results) 03/31/2023

Braidwood August 29, 2022 ERO Drive-In Drill 09/29/2022

Braidwood Station ERO Roster 03/17/2023

ERO Training and Qualification Records (Sample - 15 04/12/2023

personnel)

Procedures BwAP 320-1 Shift Staffing 27

EP-AA-1001, Braidwood On-Shift Staffing Technical Basis 2

Addendum 1

TQ-AA-113 ERO Training and Qualification 39

71114.05 Corrective Action AR 04424684 NOS ID: EP-Document observations in Training Suite 05/21/2021

Documents AR 04424896 EP - Mazon (Braidwood Alternative ERF) Quarterly Inventory 05/21/2021

Inspection Type Designation Description or Title Revision or

Procedure Date

AR 04436529 EP EMnet Phones Out of Service 07/22/2021

AR 04439313 URI Dose Assessment Program Conflicts with PWR E Plan 08/06/2021

AR 04552963 ERO Database files degraded impacting Fleet Everbridge 02/06/2023

System.

Miscellaneous Emergency Program Off-site Support Organization Letters of 03/01/2021 -

Agreement (LOAs) 03/31/2023

Braidwood Emergency Preparedness Program Drill and 03/01/2021 -

Exercise Reports 03/31/2023

21/2022 Braidwood Emergency Planning Public Information 08/25/2022

Bulletin

21 EVAL - 2021 Emergency Preparedness Off-site Agency Interface 03/08-

Emergency Annual Review 12/2021

Preparedness

23 EVAL - 2023 Off-Site Agency Interface Annual Review 02/01/2023 -

Emergency 03/20/2023

Preparedness

NOSA-BRW-22-Braidwood Station Emergency Preparedness Audit Report 04/13/2022

(AR 4478145)

NOSA-NCS-22-2022 Emergency Preparedness Off-site Agency Interface 03/21-

Annual Review 25/2022

Procedures EP-AA-1001, Evacuation Time Estimates for Braidwood Generating Station 1

Addendum 2 Plume Exposure Pathway Emergency Planning Zone

EP-AA-125-1006 54(T) Audit Performance Indicators Guide 0

NO-AA-21 Nuclear Oversight Audit Process Description 11

71124.01 Corrective Action AR 04673267 Dose Rates at U2 Cnmt PRT/RCDT were Elevated 04/26/2023

Documents AR 04673325 SG Worker Positive Whole Body Count 04/27/2023

AR 04674609 Accumulated Dose Alarm 05/01/2023

AR 04674650 Increasing Dose Rates "C" S/G Secondary 05/01/2023

Procedures NISP-RP-002 Radiation and Contamination Surveys 1

NISP-RP-005 Access Controls for High Radiation Areas 1

NISP-RP-009 Radiography 1

NISP-RP-010 Radiological Job Coverage 1

Radiation Surveys 2023-192700 401' Pressurizer Spray Line and Associated General Areas 04/25/2023

23-192939 Elevation 401' Inside Missile Barrier 04/28/2023

Inspection Type Designation Description or Title Revision or

Procedure Date

23-193088 Alpha/Delta Steam Generator Platform Elevation 390' 04/29/2023

Radiation Work BW-02-23-00505 CNMT Building Outage Scaffold 0

Permits (RWPs) BW-02-23-00510 CNMT Building Outage Valve Work with Added Controls 0

BW-02-23-00616 All RCP Motor Maintenance 0

BW-02-23-00645 2 "D" RCP Motor Replacement 0

BW-02-23-00701 S/G Bowl Drain 0

BW-02-23-00705 S/G Install/Remove Nozzle Covers 0

71124.03 Radiation Surveys 2023-192808 Bravo/Charlie Steam Generator Platform Elevation 390' 04/26/2023

Radiation Work BW-02-23-00705, S/G Eddy Current Testing and Tube Repair 0

Permits (RWPs) Task 2

71151 Miscellaneous Drill / Exercise Performance (DEP) Performance Indicator 01/01/2022 -

Data 12/31/2022

Emergency Response Organization (ERO) Participation 01/01/2022 -

Performance Indicator Data 12/31/2022

Alert Notification System (ANS) Reliability Performance 01/01/2022 -

Indicator Data 12/31/2022

Procedures NRC Performance Indicator Data; Mitigating Systems 04/01/2022 -

Safety System Functional Failures 03/31/2023

NRC Performance Indicator Data; Mitigating Systems 04/01/2022 -

Mitigating System Performance Index for Emergency AC 03/31/2023

Power

NRC Performance Indicator Data; Mitigating Systems 04/01/2022 -

Mitigating Systems Performance Index for High Pressure 03/31/2023

Injection

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

LS-AA-2080 Monthly Data Elements for NRC Safety System Functional 8

Failures

LS_AA-2200 Mitigating System Performance Index Data Acquisition and 7

Reporting

71152A Corrective Action 4507623 B High Head FLEX Pump Did Not Meet Test Parameters 06/26/2022

Documents 4508035 0B High Head FLEX Pump High Oil Temperature Trip 06/28/2022

4513349 0FX02PB Could Not Achieve 0BwOSFX-12 Parameters as 07/27/2022

Needed

4517970 0FX02PC Failed 0BwOS FX-12 Requirements 08/21/2022

Inspection Type Designation Description or Title Revision or

Procedure Date

22293 High Head FLEX Pump Compensatory Actions Adequacy 09/14/2022

4548150 0FX02PB: Acceptance Criteria Not Met During Testing 01/12/2023

4548287 Post-Maintenance Testing (PMT) Failure: 0B High Head FLEX 01/13/2023

Pump

4552101 0FX02PB 0B High Head FLEX Pump Failure 02/02/2023

4680217 High Head Pump Deficiency 05/25/2023

4682187 Issues During Testing of 0B High Head FLEX Pump 06/02/2023

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

PI-AA-120 Issue Identification and Screening Process 13

PI-AA-125 Corrective Action Program (CAP) Procedure 8

PI-AA-125-1001 Root Cause Analysis Manual 7

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

PI-AA-125-1004 Effectiveness Review Manual 2

71152S Corrective Action 4277356 Unexpected Alarm 1-21-E8, 125 Vdc Battery Charger 111 09/06/2019

Documents Trouble

4436885 Battery 112 Charger Unexpected System Response 07/25/2021

27763 Unexpected Alarm 2-22-E8, 125 Vdc Battery Charger 212 10/07/2022

Trouble

27879 Unexpected Alarm 2-22-E10, 125V DC Distribution Panel 10/08/2022

2/214 Voltage Low

Miscellaneous BRW-19-0132 Units 1/2 ESF 125 Vdc Battery Charger Replacement 06/01/2021

(PHC/PRC)

71153 Corrective Action 4527538 OSP-A Rejectable Indications on CRDM Pen 69 Weld Buildup 10/07/2022

Documents

31