IR 05000456/2019004

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Integrated Inspection Report 05000456/2019004 and 05000457/2019004
ML20027B437
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 01/24/2020
From: Hironori Peterson
NRC/RGN-III
To: Bryan Hanson
Exelon Generation Co
References
EA-16-126 IR 2019004
Download: ML20027B437 (31)
v • d • e


Text

ary 24, 2020

SUBJECT:

BRAIDWOOD STATION, UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000456/2019004 AND 05000457/2019004

Dear Mr. Hanson:

On December 31, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Braidwood Station, Units 1 and 2. On January 9, 2020, the NRC inspectors discussed the results of this inspection with Ms. M Marchionda, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

No NRC-identified or self-revealing findings were identified during this inspection.

A licensee-identified violation which was determined to be of very low safety significance is documented in this report. We are treating this violation as a non-cited violation (NCV)

consistent with Section 2.3.2 of the Enforcement Policy.

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,

/RA/

Hironori Peterson, Chief Branch 3 Division of Reactor Projects Docket Nos. 05000456 and 05000457 License Nos. NPF-72 and NPF-77

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000456 and 05000457 License Numbers: NPF-72 and NPF-77 Report Numbers: 05000456/2019004 and 05000457/2019004 Enterprise Identifier: I-2019-004-0058 Licensee: Exelon Generation Company, LLC Facility: Braidwood Station, Units 1 and 2 Location: Braceville, IL Inspection Dates: October 01, 2019 to December 31, 2019 Inspectors: R. Bowen, Illinois Emergency Management Agency J. Bozga, Senior Reactor Inspector J. Corujo-Sandin, Senior Resident Inspector G. Edwards, Health Physicist T. Go, Health Physicist D. Kimble, Senior Resident Inspector C. Phillips, Project Engineer M. Porfirio, Illinois Emergency Management Agency P. Smagacz, Resident Inspector L. Torres, Illinois Emergency Management Agency Approved By: Hironori Peterson, Chief Branch 3 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Braidwood Station, Units 1 and 2, 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. A licensee-identified non-cited violation is documented in report section: 71111.05Q.

List of Findings and Violations No findings or violations of more than minor significance were identified.

Additional Tracking Items Type Issue Number Title Report Section Status URI 05000456,05000457/20 Installed Plant Equipment 71111.15 Closed 18011-01 Protection Against Tornado EDG EA-16-126 Closure of EA-16-126 and 71111.15 Closed Associated Enforcement Discretion Regarding Tornado Missiles Protection

PLANT STATUS

Unit 1 began the inspection period operating at approximately 90 percent power with end-of-cycle power coast down operations in progress. On October 7, 2019, the unit was shut down for its planned 21st refueling outage (A1R21). Following completion of refueling and other maintenance activities, the reactor was restarted and taken critical on October 22, 2019, and the main electrical generator was synchronized to the power grid later that same day. The unit reached full power operation on October 27, 2019, and 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 remainder of the inspection period.

Unit 2 began the inspection period operating at full power. With the exception of minor reductions in power to support scheduled testing activities and load changes requested by the transmission system dispatcher, the unit remained operating at or near full power for the entire inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. 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

71111.01 - Adverse Weather Protection Seasonal Extreme Weather Sample (IP Section 03.02)

Main article: IP 71111.01
(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures during the weeks ending November 9, through December 21, 2019

External Flooding Sample (IP Section 03.04) (1 Sample)

(1) The inspectors evaluated the licensee's readiness to cope with external flooding during the week ending December 7, 2019

71111.04Q - Equipment Alignment Partial Walkdown Sample (IP Section 03.01)

Main article: IP 71111.04Q

The inspectors evaluated system configurations and conducted selected alignment verifications on the following systems/equipment trains that were important to safety:

(1) The 1A Safety Injection (SI) Train while it was being credited as a mitigation system during reduced Reactor Coolant System (RCS) inventory operations during the week ending October 12, 2019
(2) The pre-staged FLEX equipment to support Unit 1 shutdown safety during reactor refueling cavity draindown and RCS reduced inventory operations during the weeks ending October 19 through October 26, 2019
(3) The 1B Auxiliary Feedwater (AF) Train while the 1A AF Train was undergoing maintenance during the week ending November 2, 2019
(4) The Unit 1 and Unit 2 Essential Service Water (SX) systems while the 2B SX Pump was undergoing scheduled maintenance during the week ending November 23, 2019

71111.05Q - Fire Protection Quarterly Inspection (IP Section 03.01)

Main article: IP 71111.05Q

The inspectors assessed fire protection program implementation for the issues noted and/or in the following selected plant areas:

(1) The Unit 1 Missile Shield Area, Containment 377' - 0" Elevation, Fire Zone 1.1-1 during the week ending October 12, 2019
(2) The Unit 1 Missile Shield Area, Containment 401' - 0" Elevation, Fire Zone 1.1-1 during the week ending October 19, 2019
(3) The Unit 1 Containment Annular Area, Containment 401' - 0", Fire Zone 1.1-1 during the week ending October 19, 2019
(4) The Unit 1 Diesel AF Pump Room, Auxiliary Building 383' Elevation, Fire Zone 11.4A-1 during the week ending November 2, 2019
(5) A missed compensatory fire watch for an out of service automatic CO2 fire suppression system in the Unit 2 Lower Cable Spreading Room on November 15, 2019

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

Main article: IP 71111.08
(1) The inspectors verified that the reactor coolant system boundary, steam generator tubes, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from October 7, 2019 to October 17 2019:

03.01.a - Nondestructive Examination and Welding Activities.

  • Ultrasonic (UT) examination of main steam system pipe to elbow weld 1-MS-02-24
  • UT examination of main steam system elbow to pipe weld 1-MS-02-25
  • UT examination of main steam system pipe to elbow weld 1-MS-02-26
  • UT examination of main steam system elbow to pipe weld 1-MS-02-27
  • UT examination of main steam system pipe to elbow weld 1-MS-02-28
  • UT examination of main steam system elbow to pipe weld 1-MS-02-29
  • UT examination of main steam system elbow to pipe weld 1-MS-02-32
  • General Visual Examination (GV) of IWE Containment Liner Surfaces:

Elevation 426'-0" OMB

  • Visual Examination (VT-3) of snubber support 1RC02006BS
  • Visual examination for leakage (VT-2) of 1RC14AA
  • Visual examination for leakage (VT-2) of 1RC14AB
  • Visual examination for leakage (VT-2) of 1RC14AC
  • Visual examination for leakage (VT-2) of 1RC14AD 03.01.b - Pressurized-Water Reactor Vessel Upper Head Penetration Examination Activities.
  • Bare Metal Visual (BMV) examination of the reactor vessel upper head penetrations;
  • Boric Acid Leakage Evaluation on Component ID 1SI121B
  • Boric Acid Leakage Evaluation on Component ID 1CS020A

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

Main article: IP 71111.11Q
(1) The inspectors observed and evaluated licensed operator performance in the Main Control Room during various activities, including Unit 1 shutdown for Refueling Outage A1R21 and subsequent restart during the weeks ending October 5 through October 26, 2019

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness Inspection (IP Section 02.01)

Main article: IP 71111.12

The inspectors evaluated the effectiveness of maintenance activities associated with the following equipment and/or safety significant functions:

(1) The 0B Control Room Heating, Ventilation and Air Conditioning Chiller/Train maintenance during the weeks ending November 23 through December 7, 2019
(2) The 1B EDG maintenance during the weeks ending December 21 through December 28, 2019

71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01)

Main article: IP 71111.13

The inspectors reviewed and evaluated the licensee's assessment of plant risk for the following work activities:

(1) Emergent work associated with the 1C Steam Generator (SG) Power Operated Relief Valve (PORV) (1MS018C) as documented in Issue Report (IR) 4293122 during the weeks ending November 2 through November 23, 2019
(2) Emergent work associated with the 1A SG PORV (1MS018A) as documented in IR 4297820 during the weeks ending November 23, through November 30, 2019

71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 02.02)

Main article: IP 71111.15

The inspectors evaluated the following licensee operability determinations:

(1) Closure of EA-16-126 and the associated Enforcement Discretion regarding protection against tornado missiles during the weeks ending October 12 through November 2, 2019
(2) Evaluation of 1A AF Pump operability following issues identified during testing as documented in IR 4285855 during the weeks ending October 12 through October 19, 2019
(3) Evaluation of 2B EDG operability following observation of jacket water system pressure surges during testing as documented in IR 4298842 during the weeks ending November 23 through November 30, 2019

71111.18 - Plant Modifications Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

Main article: IP 71111.18

The inspectors evaluated the following permanent modifications and/or changes to the facility:

(1) Changes to the operation of the AF system to support a loss of normal feedwater during a unit startup as documented in Engineering Change (EC) 627959 during the weeks ending October 5 through December 7, 2019
(2) Enhancements to the existing Unit 1 digital control system (Westinghouse Ovation) as documented in EC 625405 during the weeks ending October 19 through December 7, 2019

71111.19 - Post-Maintenance Testing Post-Maintenance Test Sample (IP Section 03.01)

Main article: IP 71111.19

The inspectors reviewed and evaluated the following post maintenance testing activities:

(1) The Unit 1 core alignment verification following reactor refueling as documented in Work Order (WO) 4775529 during the week ending October 19, 2019
(2) Operability testing of the 1B EDG following maintenance as documented in WO 4751478 during the week ending October 19, 2019
(3) Testing of the 1A Charging (CV) Pump following maintenance as documented in WO 4751462 during the weeks ending October 19 through October 26, 2019
(4) Unit 1 digital rod position indication (DRPI) operability checks following reactor refueling as documented in WO 4781082 during the week ending October 26, 2019
(5) Unit 1 control rod drop time testing following reactor refueling as documented in WO 4820752 during the week ending October 26, 2019
(6) Functional testing of the of 0B VC Ventilation Train/Chiller following guide vane replacement as documented in WO 1929795 during the week ending November 30, 2019
(7) Operability testing of the 1B EDG following maintenance as documented in WO 4798246 during the week ending December 28, 2019

71111.20 - Refueling and Other Outage Activities Refueling/Other Outage Sample (IP Section 03.01)

Main article: IP 71111.20
(1) The inspectors reviewed and evaluated Unit 1 Refueling Outage A1R21 activities from October 12 through October 26, 2019

==71111.22 - Surveillance Testing The inspectors evaluated the following surveillance testing activities:

Surveillance Tests (other) (IP Section 03.01)==

Main article: IP 71111.22
(1) 1BwOSR 3.3.2.9-2: Unit 1 - Train B SI manual initiation and Phase "A" Containment Isolation manual initiation surveillance during the week ending October 12, 2019
(2) 2BwOSR 3.8.1.13-1: 2A EDG bypass of automatic trips surveillance during the week ending November 9, 2019

Inservice Testing (IP Section 03.01) (2 Samples)

(1) BwMP 3305-003: Main Steam Safety Valve testing using a setpoint verification device during the weeks ending October 5 through October 12, 2019
(2) 1BwOSR 5.5.8.AF-4A: Unit 1 comprehensive inservice testing requirements for AF pumps during the weeks ending October 5 through October 12, 2019 Containment Isolation Valve Testing (IP Section 03.01) (2 Samples)
(1) 1BwOSR 3.6.1.1-17: Primary Containment Type C local leakage rate tests for the make-up demineralizer system during the weeks ending October 19 through October 26, 2019
(2) The overall fuel cycle test results and summation of Unit 1 Primary Containment Type B and Type C local leak rates as documented in WO 4821955 during the week ending November 2, 2019

71114.06 - Drill Evaluation Drill/Training Evolution Observation (IP Section 03.02)

Main article: IP 71114.06

The inspectors evaluated the site's emergency response organization during observation of the following drill activity:

(1) A graded emergency scenario for a crew of licensed operators in the station's control room simulator on November 15,

RADIATION SAFETY

71124.01 - Radiological Hazard Assessment and Exposure Controls Radiological Hazard Assessment (IP Section 02.01)

Main article: IP 71124.01

The inspectors evaluated radiological hazards assessments and controls.

(1) The inspectors reviewed the following:

Radiological Surveys

  • Containment 377' A1R21 Shutdown
  • Containment 401' Inside Missile Barrier
  • Containment 426' Lower Cavity Survey
  • Containment 410' Seal Table Area Risk Significant Radiological Work Activities
  • Seal Table Activities
  • Under-vessel Activities Incore Sump
  • Seal Table activities on Unit-1 401'
  • Upper Internal and Reactor Head Activities on Unit-1 426'
  • Lower Cavities on Unit-1 426'

Instructions to Workers (IP Section 02.02) (1 Sample)

The inspectors evaluated instructions to workers including radiation work permits used to access high radiation areas.

(1) The inspectors reviewed the following:

Radiation Work Packages

  • BW-01-19-00619; Undervessel Activities Incore Sump
  • BW-01-19-00614; Reactor Head and Upper Internals Move
  • BW-01-19-00649; Seal Table Room Outage Activities
  • BW-01-19-00613; Reactor Head Disassembly/Reassembly Electronic Alarming Dosimeter Alarms
  • There were no electronic dosimeter alarms available for review during this inspection.

Labeling of Containers

  • Three or More Plastic Bags Containing Dry Active Waste (DAW) in Radwaste 401' Facility
  • Multiple Bags Containing DAW at the Upper and Lower Containment Contamination and Radioactive Material Control (IP Section 02.03) (1 Sample)

The inspectors evaluated licensee processes for monitoring and controlling contamination and radioactive material.

(1) The inspectors verified the following sealed sources are accounted for and are intact:
  • J.L. Shepherd Model 89 Calibrator Containing 400 Ci of Cs-137 S.N.

BWS-106i

  • J.L. Shepherd Model 89 Calibrator Containing 2nd Source of 130 mCi of Cs-137 S.N. BWS-105i
  • AmBe Sealed Source in Shape of a Sphere Containing 5Ci Am-241/Beryllium S.N. BWS-102
  • Neutron Calibrator Containing 65 mCi of Cf-252 S.N. BWS-104i Radiological Hazards Control and Work Coverage (IP Section 02.04) (1 Sample)

The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities.

(1) The inspectors also reviewed the following radiological work package for areas with airborne radioactivity:
  • BW-01-19-00619; Under-vessel Activities Incore Sump
  • BW-01-19-00614; Reactor Head and Upper Internals Move
  • BW-01-19-00649; Seal Table Room Outage Activities
(1) The inspectors evaluated risk-significant high radiation area and very high radiation area controls.

Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 02.06) (1 Sample)

(1) The inspectors evaluated radiation worker performance and radiation protection technician proficiency.

71124.02 - Occupational ALARA Planning and Controls Radiological Work Planning (IP Section 02.01)

Main article: IP 71124.02

The inspectors evaluated the licensees radiological work planning.

(1) The inspectors reviewed the following activities:
  • BW-01-19-00649; Seal Table Room Outage Activities
  • BW-01-19-00619; Under-vessel Activities
  • BW-01-19-00613; Reactor Head Disassembly/Reassembly
  • BW-01-19-00614; Reactor Head and Upper Internal Move

71124.06 - Radioactive Gaseous and Liquid Effluent Treatment Instrumentation and Equipment (IP Section 02.04)

Main article: IP 71124.06

The inspectors reviewed the following radioactive effluent discharge system surveillance test results:

(1) Auxiliary Building Ventilation Test of Nuclear-Grade Activated Carbon

71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation Radioactive Material Storage (IP Section 02.01)

Main article: IP 71124.08

The inspectors evaluated radioactive material storage.

(1) The inspectors toured the following areas:
  • Sea Vans Located and Stored Within the Protected Area
  • Radioactive Waste Storage/Processing Area (Various Locations)
  • Auxiliary Building (Various Locations)

The inspectors performed a container check (e.g., swelling, leakage and deformation)on the following containers:

  • Filter Drum 0AB02FA
  • Filter Drum 0AB02FB
  • Filter Drum 1FC02F
  • Filter Drum 0AB02FA
  • Filter Drum 0AB02FB Radioactive Waste System Walkdown (IP Section 02.02) (1 Sample)

The inspectors evaluated the following radioactive waste processing systems and processes during plant walkdowns:

(1) Liquid or Solid Radioactive Waste Processing Systems
  • Advanced Liquid Processing System (ALPS) Located in the Radioactive Waste Area
  • Reverse Osmosis Water Processing Equipment Located in the Radioactive Waste Area Radioactive Waste Resin and/or Sludge Discharges Processes
  • Vendor Conducted Resin Sluicing Into an Onsite Liner Waste Characterization and Classification (IP Section 02.03) (1 Sample)

The inspectors evaluated the radioactive waste characterization and classification for the following waste streams:

(1)

  • 2018 Dry Activated Waste (DAW) Stream 10 CFR 61 Database Analysis
  • 2018 Radwaste Resin Stream 10 CFR 61 Database Analysis

Shipment Preparation (IP Section 02.04) (1 Sample)

The inspectors evaluated the following radioactive material shipment preparation processes:

(1) RWS19-003; UN2916, Radioactive Material, Type B(U) Package, 7; 0W05T Resin Liner PO676656-19 in Cask RT-100 #3

-This sample supplements inspection activities that were documented in integrated report 2019001. This constitutes one complete sample.

Shipping Records (IP Section 02.05) (1 Sample)

The inspectors evaluated the following non-excepted package shipment records:

(1)

  • RWS19-018; UN3321, Radioactive Material, Low Specific Activity (LSA-II), 7; 20' Shielded DAW Sealand
  • RWS19-003; UN2916, Radioactive Material, Type B(U) Package, 7; 0W05T Resin Liner PO676656-19 in Cask RT-100 #3
  • RWS19-004; UN2916, Radioactive Material, Type B(U) Package, 7, 0W05T Resin Liner PO676656-13 in Cask RT-100 #3
  • RWS19-012; UN2910, Radioactive Material, Excepted Package - Limited Quantity of Material,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicator information through the selected review of the submittal information listed below:

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

Main article: IP 71151
(1) Unit 1 RCS Specific Activity Samples (March 2018 through June 2019)
(2) Unit 2 RCS Specific Activity Samples (March 2018 through June 2019)

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

(1) Unit 1 (October 1, 2018 through September 30, 2019)
(2) Unit 2 (October 1, 2018 through September 30, 2019)

PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)

(1) Radiological Effluent Occurrences Samples (July 2018 through July 2019)

71152 - Problem Identification and Resolution Semiannual Trend Review (IP Section 02.02)

Main article: IP 71152
(1) The inspectors reviewed the licensees corrective action program and other work documentation for potential adverse trends associated with alternating current (AC)circuit breaker trip testing during the A1R21 refueling outage during the weeks ending December 21 through December 31, 2019 Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)

The inspectors performed an in-depth review of the licensees corrective actions for the following issue:

(1) The need for the 1C SG Feedwater Regulating Valve (1FW530) to be operated in the fully open position following power ascension after the A1R21 refueling outage, as documented in IR 4291137 during the weeks ending December 21 through December 31, 2019

71153 - Followup of Events and Notices of Enforcement Discretion Event Followup (IP Section 03.01)

Main article: IP 71153
(1) The inspectors reviewed and evaluated the licensee's response to the inadvertent actuation of emergency plan sirens as documented in NRC Event Notification (EN) 54360 during the week ending November 2,

INSPECTION RESULTS

Licensee-Identified Non-Cited Violation 71111.05Q This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: Technical Specification (TS) Section 5.4.1.c requires that written procedures be established, implemented, and maintained for activities associated with the implementation of the sites Fire Protection Program. One of several procedures established by the licensee to meet this requirement was BwAP 1110-1A4, GOCAR [General Operation Condition Action Requirement] Required Compensatory Measures Action Response Carbon Dioxide Fire Suppression Systems. Revision 10 of this procedure, which was the revision active and in effect on November 15, 2019, required that a continuous fire watch be established and maintained for Fire Zone 2S-43 within the Unit 2 Lower Cable Spreading Room when the carbon dioxide suppression system associated with that fire zone was not operable.

Contrary to this requirement, on November 15, 2019, the licensee failed to implement the compensatory continuous fire watch as required by TS Section 5.4.1.c and BwAP 1110-1A4, Revision 10. Specifically, a communications error between the on-shift Operations crew and craft personnel resulted in the inadvertent securing of the continuous fire watch for Fire Zone 2S-43 for approximately 53 minutes while the carbon dioxide suppression system associated with that fire zone was not operable.

Significance/Severity: Green. The inspectors assessed the significance of the finding using Inspection Manual Chapter (IMC) 0609, Appendix F, Attachment 1, Fire Protection Significance Determination Process Worksheet, dated May 2, 2018. In accordance with Step 1.5 of this document, a Senior Reactor Analyst (SRA) reviewed the licensee's risk evaluation and verified the core damage frequency results were significantly less than the 1E-6/year threshold (Green).

Corrective Action References: Issue Report (IR) 42977714, Plant Barrier Impairment, BwAP 1110-1A4 Fire Watch Communication Issue Unresolved Item Installed Plant Equipment Protection Against Tornado 71111.15 (Closed) URI 05000456,05000457/2018011-01

Description:

This Unresolved Item (URI) was identified while performing Temporary Instruction (TI)2515/191, Mitigating Strategies, Spent Fuel Pool Instrumentation and Emergency Preparedness (ML18033A711). The inspectors questioned whether the installed plant equipment which was nonconforming to the current licensing basis for protection against tornado-generated missiles, and is relied upon to implement the mitigating strategies, met the requirements of Order EA-12-049 for reasonable protection from external events.

Specifically, the inspectors were concerned about non-conforming structures, systems or components which the licensee had identified in their corrective action program (AR 2673854).

At the time of the inspection the licensee had invoked EGM 15-002, Enforcement Discretion for Tornado-Generated Missile Protection Non-compliance, which allowed the NRC to exercise enforcement discretion when an operating power plant does not comply with its current licensing basis for tornado-generated missile protection. Inspectors had previously documented the exercise of enforcement discretion in inspection reports 2016-002 (ML16209A139) and 2017-001 (ML17121A339). Enforcement Action (EA) number, EA-16-126, was tracking the use of the enforcement discretion until final corrective actions were implemented.

As discussed in the Enforcement Discretion section of this report, final corrective actions regarding EA-16-126 have been completed. The affected structures, systems and components were restored to compliance with their tornado-generated missile licensing bases. As a result, URI 05000456,05000457/2018011-01 is considered closed.

Corrective Action Reference(s): AR 04109224 - "NRC URI - Tornado Missile Protection for Installed Equipment" AR 02673854 - "Non-Conforming Conditions Identified - Tornado Missiles" Enforcement Enforcement Action EA-16-126: Closure of EA-16-126 and 71111.15 Discretion Associated Enforcement Discretion Regarding Tornado Missiles Protection

Description:

On June 10, 2015, the NRC issued Regulatory Issue Summary (RIS) 2015-06, Tornado Missile Protection, (ML15020A419) and Enforcement Guidance Memorandum (EGM) 15-002, "Enforcement Discretion for Tornado-Generated Missile Protection Noncompliance" (ML15111A269). The RIS focused on the requirements regarding tornado-generated missile protection and required compliance with the facility-specific licensing basis. The EGM provided guidance to allow the NRC staff to exercise enforcement discretion when an operating power plant licensee did not comply with the current license basis for tornado-generated missile protection.

On May 25, 2016, the licensee documented several identified non-conformances related to tornado missile protection in their corrective action program (AR 02673854). In addition, the licensee discussed their intent to request to use the enforcement discretion, afforded by EGM 15-002, and discussed the actions required to comply with the provisions in the EGM.

Inspectors documented the exercise of enforcement discretion in the baseline quarterly reports 2016-002 (ML16209A139) and 2017-001 (ML17121A339). Enforcement Action (EA)number, EA-16-126, was assigned to administratively track the use of enforcement discretion until final corrective actions were implemented.

Corrective Actions: By letter dated February 1, 2018, (ML18036A227), as supplemented by letters dated July 9, 2018, (ML18036A227) and August 3, 2018, (ML18215A421) the licensee submitted a license amendment request to revise their licensing bases regarding protection from tornado-generated missiles. As part of the amendment process the licensee committed to protecting the reactor water storage tanks (RWSTs) hatches from tornado-generated missiles. The licensee installed the committed physical protection via Engineering Change 618920, Tornado Missile Protection for Refueling Water Storage Tank Roof Hatches.

On November 8, 2018, the NRC issued license amendment No. 199 to NPF-72, amendment No. 199 to NPF-77 and its associated safety evaluation report (ML18291A980). Based on its evaluation the NRC approved Braidwood Station, Units 1 and 2, to revise the Updated Final Safety Analysis Report (UFSAR) to incorporate the TORMIS computer Code as the methodology used for assessing tornado-generated missile protection of specific unprotected plant structures, systems and components and to describe the results of the site-specific tornado hazard analysis as described in the licensees application and safety evaluation.

Corrective Action References: AR 02673854 - "Non-Conforming Conditions Identified -

Tornado Missiles" AR 04014784 - "1Q17 LIV - Lack of Adequate Tornado Missile Protection" AR 04217133 - "DBAI - Global Effects of Missile Impact on RWST Hatch Cover"

Enforcement:

Based on the licensees corrective actions described above no additional violations were identified, the enforcement discretion afforded by EGM 15-002 is no longer required and EA-16-126 is considered closed.

The disposition of this issue closes URI: 05000456,05000457/2018011-01.

Observation: Steam Generator 1C Main Feedwater Regulating Valve, 1FW530, 71152 Required to be Operated in the Fully Open Position The inspectors performed a detailed review of IR 4291137, 1FW530 Full Open Following Power Ascension. The issue involved the need for the licensee to operate the 1C Steam Generator (SG) Main Feedwater Regulating Valve (FRV), 1FW530, in the fully open position to provide adequate feedwater flow to the 1C SG at full power following return of Unit 1 to operation after the licensees October 2019 A1R21 refueling outage. This condition stemmed from the fact that the associated main feedwater check valve in that line, 1FW079C, did not open to the expected position for the full power operating condition and additional open travel on 1FW530 was required to compensate for the additional flow resistance in the line.

The failure of the 1FW079C check valve to move to the expected open position for full power operation appears to be a design issue associated with the FW079 series check valves in the stations main feedwater lines. Similar issues have been observed from time to time by the licensee with various FW079 series check valves going back a number of years. In 2018 when an analogous condition occurred on the 1B SG main feedwater line, the inspectors reviewed the licensees operability and functionality evaluation for the 1FW079B check valve being more closed than expected for the full power operating condition and did not identify any findings or violations of NRC requirements. (Reference: Braidwood Station, Units 1 and 2 - NRC Integrated Inspection Report 05000456/2018003 and 05000457/2018003; ADAMS Accession Number: ML18304A205). Consequently, for this detailed Problem Identification and Resolution inspection sample, the inspectors focused on assessment of the licensees corrective actions taken to date and those planned going forward.

At Braidwood Stations sister facility, Byron Station, the licensee replaced the FW079 series main feedwater check valves several years ago with check valves of a different design in order to alleviate the condition at that facility. In reviewing the licensees corrective actions for this most recent condition at Braidwood Station, the inspectors noted that one of the actions within the licensees corrective action program (CAP) tasked licensees engineering organization with evaluating the modification performed at Byron Station for potential use at Braidwood. In addition, the licensee established corrective actions to evaluate possibly increasing the speed of the running turbine-driven main feedwater pumps to force the 1C SG FRV to close somewhat. This, however, would also impact the other three Unit 1 FRVs, which are presently operating as desired. Lastly, the licensee has developed an adverse condition monitoring plan in accordance with station procedures and processes to monitor the condition, with trigger points for additional analysis and/or actions should the condition degrade.

The FRVs are intended to be able to modulate to adjust SG level as necessary during plant operation. The overall safety significance of the issue comes down to an increased risk of SG level instability if a second Unit 1 FRV were to reach the fully open position with 1FW530 already needing to be fully open to ensure proper main feedwater flow to the 1C SG.

Following their review, the inspectors concluded that the licensees actions taken in accordance with their CAP were reasonable given the overall safety significance of the issue.

The inspectors did not identify any findings or violations of NRC requirements in the course of their review.

Observation: Potential Trend in Molded Case Circuit Breaker Trip Testing Issues 71152 The inspectors performed a review of plant issues, particularly those entered into the licensees corrective action program (CAP), associated with problems encountered during MCCB trip testing that was accomplished as part of the licensees Unit 1 A1R21 refueling outage. During their review, the inspectors noted that there had been several MCCB testing issues encountered by the licensee. In each of the six cases noted, the subject MCCB was subsequently evaluated as being capable of adequately tripping if required. Four of the cases involved MCCBs not tripping within their specified tolerances. These MCCBs were evaluated by licensee engineering and determined to be capable of adequately tripping if required and capable of maintaining proper breaker coordination. One issue involved an MCCB that could not be reset following successful trip testing, and one involved an MCCB that had to have its testing sequence aborted when technicians identified some minor signs of smoke coming from the breaker. The MCCB that tripped but could not be reset was subsequently replaced by the licensee prior to Unit 1 restart. The MCCB that had its testing aborted was removed from service and sent to an offsite testing facility where its testing was completed within tolerances; the breaker was replaced, however, due to the minor signs of smoke noted by licensee technicians during its initial testing sequence.

Following their review, the inspectors queried the licensee regarding the number and nature of the testing issues observed, specifically asking about whether or not the scope and nature of the issues was comparable to prior refueling outage testing campaigns. The licensee entered the potential trend with A1R21 MCCB issues into their CAP as Issue Report (IR) 4305858. The licensees initial evaluation of their MCCB testing data from previous refuel outages did not indicate that this most recent MCCB testing campaign issues represented anything unusual.

The inspectors did not identify any findings or violations of NRC requirements in the course of their review.

EXIT MEETINGS AND DEBRIEFS

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

  • On January 9, 2020, the inspectors presented the integrated inspection results to Ms. M Marchionda, Site Vice President and other members of the licensee staff.
  • On October 11, 2019, the inspectors presented the radiation protection baseline inspection results to Ms. M. Marchionda, Site Vice President and other members of the licensee staff.
  • On October 17, 2019, the inspectors presented the Inservice Inspection inspection results to Ms. M. Marchionda, Site Vice President and other members of the licensee staff.
  • On November 20, 2019, the inspectors presented the URI 2018011-01 (FLEX) and EA 16-126 (Tornado Missile Discretion) Closures inspection results to Mr. R. Schliessmann, NRC Coordinator, and other members of the licensee staff.
  • On December 5, 2019, the inspectors presented the Radiation Protection Inspection Results inspection results to Mr. J. Keenan, Plant Manager and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Corrective Action 4301787 NRC ID: Unit 1 Auxiliary Building Roof Drains Plugged 12/05/2019

Documents

Resulting from

Inspection

Miscellaneous Letter 2020 Winter Readiness Certification 12/13/2019

Procedures 0BwOA ENV-1 Adverse Weather Conditions Unit 0 123

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

Surveillance

0BwOS XFT-A2b Unit Common Station Heat Area Heaters Freezing 6

Temperature Equipment Protection Surveillance

0BwOS XFT-A3 Unit Common Cold Weather Surveillance 11

0BwOS XFT-A4 Unit Common Freezing Temperature Equipment Protection 12

Inside Surveillance

0BwOS XFT-A5 Unit Common Freezing Temperature Equipment Protection 29

of Out Building Surveillance

OP-AA-102-102 General Area Checks and Operator Field Rounds 17

OP-AA-108-111- Severe Weather and Natural Disaster Guidelines 20

1001

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

1001

WC-AA-107 Seasonal Readiness 22

71111.04Q Drawings ECCS-1 Training Document - Emergency Core Cooling System 7

Drawing

Procedures 1BwFSG-14 Shutdown Reactor Coolant System (RCS) Makeup 1

BwOP AF-E1 Electrical Lineup - Unit 1 Operating 15

BwOP AF-M1 Operating Mechanical Lineup Unit 1 20

BwOP SX-E1 Electrical Lineup - Unit 1 Essential Service Water System 11

Operating

BwOP SX-E2 Electrical Lineup - Unit 2 Essential Service Water System 13

BwOP SX-M1 Operating Mechanical Lineup Unit 1 35

BwOP SX-M2 Operating Mechanical Lineup Unit 2 39

OP-BR-FX-1004 Medium Head FLEX Pump Operating Guideline 0

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.05Q Corrective Action 4297714 Plant Barrier Impairment, BwAP 1110-1A4 Fire Watch 11/15/2019

Documents Communication Issue

Fire Plans No. 1; Fire Zone Containment 377'-0" Elevation; Unit 1 Containment Missile 0

1.1-1 Shield Area

No. 2; Fire Zone Containment 401'-0" Elevation; Unit 1 Containment Missile 0

1.1-1 Shield Area

No. 5; Fire Zone Containment 377'-0" Elevation; Unit 1 Annular Area 0

1.2-1

No. 6; Fire Zone Containment 401'-0" Elevation; Unit 1 Annular Area 0

1.2-1

No. 9; Fire Zone Containment 426'-0" Elevation; Unit 1 Containment Upper 1

1.3-1 Area

Miscellaneous Transient Reactor Head Stand Area 10/07/2019

Combustible

Permit 618

Transient ROV Control Point for Head Lift 10/07/2019

Combustible

Permit 619

Transient RCP Motor Replacement 01/07/2019

Combustible

Permit 629

Transient Pipefitters Working RCP Motor 10/07/2019

Combustible

Permit 630

Procedures BwAP 1110-1 Fire Protection Program System Requirements 43

BwAP 1110-1A4 GOCAR [General Operation Condition Action Requirement] 10

Required Compensatory Measures Action Response Carbon

Dioxide Fire Suppression Systems

BwAP 1110-3 Plant Barrier Impairment Program 38

BwOP PBI-1 Plant Barrier Impairment Program Pre-Evaluated Barrier 3

Matrix

CC-AA-201 Plant Barrier Control Program 12

71111.05Q Procedures 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 0

Unit 2

OP-AA-201-004 Fire Prevention for Hot Work 17

OP-AA-201-007 Fire Protection System Impairment Control 0

OP-AA-201-008 Pre-Fire Plan Manual 4

OP-AA-201-009 Control of Transient Combustible Material 24

71111.08P Corrective Action 4202190 Unable to Complete Final Review for ASME XI Repair 12/11/2018

Documents Replacement

286524 04-OSP-X A1R21 Snubber 1CV41036S Degraded Req's 10/09/2019

Replacement

287141 06-OSP-A A1R21 Snubber Operation Test Failure 10/11/2019

1RC02006AS

287143 06-OSP-A A1R21 Snubber Operation Test Failure 10/11/2019

1RC02006BS

287727 10-OSP-A (ISI) Constant Spring Can 1FW05024C FOUND 10/13/2019

OOT

287731 10-OSP-A (ISI) Variable Spring Can 1CV16034V FOUND 10/13/2019

OOT

287815 10-OSP-X Defer ASME Section XI Support Exam 10/14/2019

1CC13045X (ISI)

287816 10-OSP-X Defer ASME Section XI Support Exam on 10/14/2019

1SX16019V (ISI)

Miscellaneous 02410146-02 Eductor 1A Spray Add Suct Check VLV 06/22/2018

2731397-02 Bonnet Thermal Relief Valve for 1SI8811B 06/22/2018

NDE Reports A1R21-PT-001 Reactor Head Surface Penetration 69 10/12/2019

A1R21-UT-007 RCP Main Flange Bolt (01-24) 10/13/2019

A1R21-UT-034 Main Steam Pipe to Elbow Weld 1-MS-02-24 10/17/2019

A1R21-UT-035 Main Steam Elbow to Pipe Weld 1-MS-02-25 10/17/2019

A1R21-UT-036 Main Steam Pipe to Elbow Weld 1-MS-02-26 10/17/2019

A1R21-UT-040 Main Steam Elbow to Pipe Weld 1-MS-02-32 10/17/2019

A1R21-UT-041 Main Steam Elbow to Pipe Weld 1-MS-02-29 10/17/2019

A1R21-UT-042 Main Steam Elbow to Pipe Weld 1-MS-02-27 10/17/2019

A1R21-UT-043 Main Steam Pipe to Elbow Weld 1-MS-02-28 10/17/2019

SN-19-0034 Pipe Support 1RC02006BS 10/10/2019

SN-19-0041 Pipe Support 1RC02006AS 10/10/2019

Procedures ER-AA-335-002 Liquid Penetrant (PT) Examination 11

ER-AA-335-015- VT-2 Visual Examination in Accordance with ASME 2013 0

2013

ER-AA-335-018 Visual Examination of ASME IWE Class MC and Metallic 13

Liners of IWL Class CC Components

ER-AA-335-031 Ultrasonic Examination of Austenitic Piping Welds 8

ER-AA-335-037 Ultrasonic Examination of Studs and Bolts 3

ER-AA-335-1008 Code Acceptance & Recording Criteria for Nondestructive 5

(NDE) Surface Examination

ER-AP-335-001 Bare Metal Visual Examination for Nickel Alloy Materials 6

EXE-PDI-UT-2 Ultrasonic Examination of Austenitic Pipe Welds in 8

Accordance with PDI-UT-2

EXE-PDI-UT-5 Straight Beam Ultrasonic Examination of Bolts and Studs in 2

Accordance with PDI-UT-5

Work Orders 04775229-01 1CV8396B Is Spraying from Diaphragm Between Body and 04/20/2018

Bonnet

71111.11Q Procedures 1BwGP 100-4 Power Decension 47

OP-AA-101-111- Operations Standards and Expectations 23

1001

OP-AA-101-113 Operator Fundamentals 14

OP-AA-101-113- 4.0 Crew Critique Guidelines 10

1006

OP-AA-103-102 Watch-Standing Practices 18

OP-AA-103-102- Strategies for Successful Transient Mitigation 2

1001

OP-AA-103-103 Operation of Plant Equipment 1

OP-AA-104-101 Communications 4

OP-AA-108-107- Interface Procedure Between BGE/COMED/PECO and 12

1002 Exelon Generation (Nuclear/Power) for Transmission

Operations

OP-AA-111-101 Operating Narrative Logs and Records 15

OP-AA-300 Reactivity Management 13

71111.12 Corrective Action 4149917 Oil Slinger Ring Not Installed on 0A and 0B VC Chillers 06/24/2018

Documents 4297028 Degradation on 0B VC Chiller Condenser Head Flange 11/13/2019

Faces

297481 Rejectable NDE Indication 0WO01CB Outlet Flange 11/15/2019

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

Classification

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

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

ER-AA-320-1003 Maintenance Rule 18-10 - Failure Definitions 0

ER-AA-320-1004 Maintenance Rule 18-10 - Performance Monitoring and 1

Dispositioning Between (a)(1) and (a)(2)

Work Orders 1917679 Replace 0TS-WO207 - Chiller 0WO1CB Hot Gas Bypass 11/24/2019

Temperature Switch

29795 0WO01CB: Replace Guide Vanes 11/13/2019

4609716 0WO01CB Condenser PM and Eddy Current Testing 11/12/2019

4802125 Oil Slinger Ring Not Installed on 0A and 0B VC Chillers - 11/14/2019

Disassemble / Take Measurements / Reassemble Chiller

71111.13 Corrective Action 4287867 09-OSP-A: 1C Steam Generator PORV Hydraulic Reservoir 10/15/2019

Documents Level Low

288936 13-OSP-A: Annunciator 1-15-C10, Steam Generator 1C 10/18/2019

PORV Trouble

293122 1-/15-C10, Steam Generator 1C PORV Trouble - 1MS018C 10/31/2019

Hydraulic Fluid Low

297820 1-15-A10: Steam Generator 1A PORV Trouble - Accumulator 11/16/2016

Pressure Low

Corrective Action 4295505 1MS018C Lost Paperwork for Hydraulic Fill Evolution 11/07/2019

Documents

Resulting from

Inspection

Procedures 1BwOSR Main Steam System Containment Isolation Valve Stroke 13

3.6.3.5.MS-1 Surveillance

ER-AA-600 Risk Management 7

ER_AA-600-1042 On-Line Risk Management 11

MA-AA-716-004 Conduct of Troubleshooting 16

OP-AA-108-117 Protected Equipment Program 5

WC-AA-101-1006 On-Line Risk Management and Assessment 2

Work Orders 4970682 1MS018C Add Oil to PORV (Unscheduled Maintenance) 11/08/2019

71111.15 Corrective Action 2673854 Non-Conforming Conditions Identified - Tornado Missiles 05/25/2016

Documents 4014784 1Q17 LIV - Lack of Adequate Tornado Missile Protection 05/25/2017

4109224 NRC URI - Tornado Missile Protection for Installed 02/28/2018

Equipment

285855 02-OSP: 1A Auxiliary Feedwater Pump Breaker did not 10/08/2019

Close During ATWS (Anticipated Transient Without Scram)

Testing

298842 2B DG EMG Stop Due to Abnormal JW Surging 11/20/2019

Drawings M-152, Sheet 14 Manufacturers Supplemental Diagram of Diesel Generator V

Jacket Water Schematic Units 1 & 2

Procedures 1BwOS ATWS- Unit 1 Anticipated Transient Without Scram Mitigation 0

R1 System Refueling Outage End to End Surveillance

2BwOSR 3.8.1.2- Unit 2B Diesel Generator Operability Surveillance 46

BwOP AF-5 Motor-Driven Auxiliary Feedwater Pump 'A' Startup on 33

Recirculation

BwOP DG-11 Diesel Generator Startup and Operation 51

BwOP DG-11T2 Diesel Generator Operating Log 31

ER-AA-600-1012 Risk Management Documentation 14

OP-AA-106-101- Operational Decision Making Process 21

1006

OP-AA-108-111 Adverse Condition Monitoring and Contingency Planning 13

OP-AA-108-115 Operability Determinations (CM-1) 22

Work Orders 1956941 Unit 1 ATWS (Anticipated Transient Without Scram) 04/09/2018

Refueling Outage Testing

1956941 Unit 1 ATWS [Anticipated Transient Without Scram] 04/09/2018

Refueling Outage Testing

71111.18 Corrective Action 4272924 EC 627959 Follow-Up Actions for Auxiliary Feedwater 08/19/2019

Documents Procedure Changes

280595 CDO - Inadequate 50.59 Review for EC 625405 09/12/2019

Engineering 625405 Unit 1 Ovation Post N-Outage Backfit 1

Changes 627959 Auxiliary Feedwater System Operation to Support a Loss of 0

Normal Feedwater During a Unit Startup

Procedures EC 625405-1 Braidwood Station N+1 Outage Mod Acceptance Test (MAT) 1

71111.19 Corrective Action 4299555 0WO01CB Chiller Tripped 11/24/2019

Documents

Operability BwVP 500-14 Core Alignment Verification 3

Evaluations

Procedures 1BwOS RD-3 Shutdown Rod Insertion Limit During Approach to Criticality 1

Surveillance

1BwOS TRM Unit 1 Digital Rod Position Indication (DRPI) Operability 6

3.1.k.1 Verification Prior to and During Rod Drop Testing

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

1BwOSR 1B Diesel Generator ECCS Sequencer Surveillance 23

3.8.1.19-2

1BwOSR 3.8.11- 1B Diesel Generator Loss of ESF Bus Voltage with No SI 20

Signal

1BwOSR Group A IST Requirements for 1A Centrifugal Charging 8

5.5.8.CV-4A Pump (1CV01PA) and Check Valve 1CV8480A Stroke Test

BwISR 3.1.4.3.a Rod Drop Time (Automatic) 10

NF-AA-330-1001 Core Verification Guideline 12

OU-AP-230 Newton Core Gap Alignment Data Acquisition for Byron and 4

Braidwood

Work Orders 1966510 1B Diesel Generator 24 Hour Load Test and ECCS 10/26/2019

Surveillance

4709143 Functional Run of 0WO01CB Following Control Panel Relay 11/24/2019

Replacements

4751413 1CV01PA Disassemble, Inspect & Clean Gearbox Oil Filter 10/16/2019

4751462 Check Shaft Driven Oil Pump Drive Mechanism 10/16/2019

475147B 1B Diesel Generator Loss of ESF Buss Voltage with No SI 10/16/2019

Signal

4775529 Core Alignment Verification - Unit 1 10/16/2019

4781082 Unit 1 Digital Rod Position Indication (DRPI) Operability 10/21/2019

Checkout

4790778 Change Oil in Motor Bearings and Take Sample 10/16/2019

4798246 Perform 2 Year Inspection of Diesel Generator 12/15/2019

20752 Unit 1 Automatic Rod Drop Time Surveillance 10/21/2019

4875703 1SC-DG250B Replace DG Governor Actuator 12/15/2019

4897408 Digital Rod Position Indication (DRPI) Surveillance During 10/21/2019

Rod Drop Testing

71111.20 Corrective Action 4286018 212 DC Ground 10/08/2019

Documents 4286592 Unexpected Toggling of Alarm SR S/D Flux High 10/10/2019

289506 Mode 3 Entry with LCO 3.0.4B Requirements 10/20/2019

289892 Active Water Leak in Unit 1 Seal Table Room 10/21/2019

(Clean/Tighten)

Corrective Action 4285795 NRC ID: BWOP RC-4 Improvement Opportunity 10/07/2019

Documents

Resulting from

Inspection

Procedures 1BwGP 100-1 Plant Heatup 38

1BwGP 100-3 Power Ascension 5% to 100% 80

1BwGP 100-5 Plant Shutdown and Cooldown 60

1BwOS TRM Unit 1 - Containment Loose Debris Inspection 18

2.5.b.1

BwAP 1450-1 Access to Containment 44

BwGP 100-2 Plant Startup 46

BwOP DG-1 Diesel Generator Alignment to Standby Condition 30

BwOP RC-4 Reactor Coolant System Drain 41

BwVS 500-6 Low Power Physics Test Program 45

BwVS TRM Core Reload Sequence and Verification 22

3.1.h.1

HU-AA-1211 Pre-Job Briefings 14

LS-AA-119 Fatigue Management and Work Hour Rules 13

MA-AA-716-1008 Reactor Services: Refuel Floor FME Plan 16

OP-AA-108-108 Unit Restart Review 20

OP-AA-108-110 Evaluation of Special Tests or Evolutions 3

71111.22 Corrective Action 1BwOSR Unit One Comprehensive Inservice Testing (IST) 13

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

284962 1MS015A Did Not Pass As Found Testing 10/04/2019

286889 06-OSP-X: Safety Injection Full Flow Testing Post 10/10/2019

Calibration Unsatisfactor

Procedures 1BwOSR 3.3.2.9- Unit One - Train B Safety Injection Manual Initiation and 28

Phase "A" Containment Isolation Manual Initiation

Surveillance

1BwOSR 3.6.1.1- Primary Containment Type C Local Leakage Rate Test of 9

Make-Up Demineralizer System

1BwVSR 3.6.1.25 Summation of Type "B" & "C" Tests for Acceptance Criteria 10

2BwOSR 2A Diesel Generator Bypass of Automatic Trips Surveillance 18

3.8.1.13-1

2BwOSR 3.8.1.2- 2A Diesel Generator Operability Surveillance 47

BwMP 3305-003 Main Steam Safety Valve Testing Using Setpoint Verification 2

Device

BwOP DG-11 Diesel Generator Startup and Operation 51

BwOP GD-12 Diesel Generator Shutdown 30

Work Orders 1961853 IST - Unit 1 Local Leak Rate Test WM 190/191 for 10/18/2019

Containment Penetration No. 30

1966521 Unit 1 Train B SI Signam Manual Initiation and Phase A 10/07/2019

Containment Isolation Manual Initiation

4787030 2DG01KA Bypass of Automatic Trips Not with Slave Start 11/06/2019

4795683 IST-Unit 1 AF Pumps Comprehensive Full Flow Test and 10/05/2019

Equipment Response Time

21955 Unit 1 Local Leak Rate Test Summation for Type "B" & "C" 10/20/2019

Tests

4851024 IST - Main Steam Safety Valve Test for 10/03/2019

1MS013S/014S/015S/016S/017S

4971355 2A Emergency Diesel Generator Monthly 11/06/2019

71114.06 Procedures EP-AA-1000 Standardized Radiological Emergency Plan 30

EP-AA-1001 Radiological Emergency Plan Annex for Braidwood Station 34

LS-AA-2100 Monthly Data Elements for NRC Reactor Coolant System 5

(RCS) Leakage

71124.01 Calculations BW-01-19-00513 Airborne Radioactivity Calculation Worksheet; U-1 426' 10/09/2019

Inside Cavity

BW-01-19-00619 Airborne Radioactivity Calculation Worksheet U-1 377' In- 10/07/2019

Core Sump

BW-01-19-00641 Airborne Radioactivity Calculation Worksheet U-1 10/11/2019

Containment 426' Reactor Head

BW-01-19-00649 Airborne Radioactivity Calculation Worksheet U-1 401' Seal 10/08/2019

Table

Procedures RP-AA-460 Controls for High and Locked High Radiation Areas 37

Radiation 054691 Containment 426' Lower Cavity 10/07/2019

Surveys 054692 Containment 401' Inside Missile Barrier 10/07/2019

054699 Containment 426' Upper Cavity 10/07/2019

054705 Containment 377 Outside Missile Barrier 10/07/2019

958270 Containment 390' A&D Steam Generator Platform 10/07/2019

958270 Containment 390' Steam Generator B&C Platform 10/07/2019

Radiation Work BW-01-19-00615 Reactor Cavity Work 0

Permits (RWPs)

71124.02 ALARA Plans BW-01-19-00613 Reactor Head Disassembly/Reassembly 0

BW-01-19-00614 Reactor Head and Upper Internal Move 0

BW-01-19-00619 Under-vessel Activities 0

BW-01-19-00649 Seal Table Room Outage Activity 0

71124.06 Miscellaneous Sample ID Radioiodine Test Report 07/06/2018

0VA05FA

Sample ID Radioiodine Test Report 07/06/2018

0VA05FB

Sample ID Radioiodine Test Report 07/06/2018

0VA05FC

Sample ID Radioiodine Test Report 06/15/2018

0VA05FD

Sample ID Radioiodine Test Report 06/15/2018

0VA05FE

Sample ID Radioiodine Test Report 06/15/2018

0VA05FF

Work Orders 01937904 01 Auxiliary Building Vent Stack Wide Range Gas Monitor Full 05/11/2018

Calibration

71124.08 Corrective Action AR 04148257 Spent Resin Pump 0WX79MA Does Not Rotate 06/18/2018

Documents AR 04193272 Brine Tank Booster Pump Degraded 11/09/2018

AR 04229135 0WX05DB Radwaste Demin is Leaking 03/13/2019

AR 04277770 Resin Not Available For The 1CV01DA De-Boration Bed 09/09/2019

Sluice

Corrective Action AR 04065270 NRC Open Item From Inspection Regarding RW Resin Resin 10/20/2017

Documents Sampling

Resulting from

Inspection

Engineering 0000623825 TCCP To Restore 0WX889-XA Interlocks to Allow Water 04/10/2018

Changes Processing Through 0W889 and 0WX890

Miscellaneous 10 CFR 61 Primary Filter Waste Stream Analysis 01/14/2019

CFR 61 Radwaste Resin Analysis 12/03/2018

CFR 61 Dry Activated Waste (DAW) Analysis 01/29/2019

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

Self-Assessments AR 04214019 NRC Inspection IP 71142.08 Radioactive Solid Waste 07/11/2019

Processing and Radioactive Material Handling, Storage and

Transportation

Shipping Records RWS19-003 0WX05T Resin Liner PO676656-19 in Cask RT-100 #3 03/05/2019

RWS19-004 0WX05T Resin in Liner PO676656-13 in Cask RT-100 #3 03/12/2019

RWS19-012 8 B-25s of Grossly Dewatered Resin 07/18/2019

RWS19-014 Resin Liner PO683742-17 in Cask 09/25/2019

71151 Miscellaneous LS-AA-2090 Monthly Data Element for NRC Reactor Coolant System 03/2018 -

Specific Activity 06/2019

LS-AA-2150 Monthly Data Elements for NRC RETS/ODCM Radiological 07/2018 -

Effluent Occurrences 07/2019

NRC Barrier Integrity - RCS Identified Leakage 10/01/2018 -

Performance 09/30/2019

Indicator Data

Procedures LS-AA-2001 Collecting and Reporting of NRC Performance Indicator Data 15

71152 Corrective Action 0699328 1FW079B Check Valve Further Closed Than Expected 11/14/2007

Documents 4141563 Ovation Alarm Associated with 1FW520 05/26/2018

4165777 1FW079B Check Valve Further Closed Than 1FW079A, C,

and D

08/20/2019

287309 08-OSP-A A1R21 ODEN 1AP27E-D1 Fail to Reset 10/12/2019

(1VX01C) Test

287313 A1R21 ODEN 1AP27E-C4F (1RY8000B) Tripped Out of 10/12/2019

Tolerance Low

287314 A1R21 ODEN 1AP23E-G4F (OSX165B) Tripped Out of 10/12/2019

Tolerance

287316 ODEN 1AP23E-G4R (0SX165B) Tripped Out of Tolerance 10/12/2019

287396 09-OSP-A A1R21 ODEN 1AP28E-D4 Did Not Trip 10/13/2019

287492 08-OSP-R A1R21 ODEN 1AP32E-D5 (1OG084) Tripped Out 10/13/2019

of Tolerance

291137 1FW1137 Full Open Following Power Ascension 10/25/2019

291137 1FW530 Full Open Following Power Ascension 10/25/2019

298999 Trend IR - Breaker Deficiencies in Breaker Refurbishments 11/21/2019

4305858 Trend IR for A1R21 ODEN Testing 12/23/2019

Procedures NO-AA-10 Quality Assurance Topical Report (QATR) 94

PI-AA-120 Issue Identification and Screening Process 9

PI-AA-125 Corrective Action Program (CAP) Procedure 7

PI-AA-125-1001 Root Cause Analysis Manual 5

PI-AA-125-1003 Corrective Action Program Evaluation Manual 5

71153 Corrective Action 4287444 11-OSP-A: Preliminary Data - Manufacturing Defect on 10/13/2019

Documents 1FW520 Digital Valve Controller Relay

292282 Inadvertent Siren Activation of Will County Sirens 10/29/2019

29

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