IR 05000461/2019003

Integrated Inspection Report 05000461/2019003

ML19309F220
Person / Time
Site:	Clinton
Issue date:	11/05/2019
From:	Kenneth Riemer NRC/RGN-III
To:	Bryan Hanson Exelon Generation Co
References
IR 2019003
Download: ML19309F220 (26)

Text

ber 5, 2019

SUBJECT:

CLINTON POWER STATION - INTEGRATED INSPECTION REPORT 05000461/2019003

Dear Mr. Hanson:

On September 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Clinton Power Station. On October 11, 2019, the NRC inspectors discussed the results of this inspection with Mr. T. Stoner, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspectors did not identify any finding or violation of more than minor significance.

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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Kenneth R. Riemer, Chief Branch 1 Division of Reactor Projects Docket No. 05000461 License No. NPF-62

Enclosure:

As stated

Inspection Report

Docket Number: 05000461 License Number: NPF-62 Report Number: 05000461/2019003 Enterprise Identifier: I-2019-003-0067 Licensee: Exelon Generation Company, LLC Facility: Clinton Power Station Location: Clinton, IL Inspection Dates: July 01, 2019 to September 30, 2019 Inspectors: J. Beavers, Senior Resident Inspector S. Bell, Health Physicist M. Domke, Reactor Inspector G. Edwards, Health Physicist M. Garza, Emergency Preparedness Inspector T. Go, Health Physicist M. Holmberg, Senior Reactor Inspector C. Mathews, Illinois Emergency Management Agency E. Sanchez Santiago, Senior Reactor Inspector D. Sargis, Resident Inspector C. St. Peters, Reactor Engineer L. Torres, Illinois Emergency Management Agency Approved By: Kenneth R. Riemer, Chief Branch 1 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Clinton Power Station in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

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

Additional Tracking Items Type Issue Number Title Report Section Status URI 05000461/2019003-01 Unresolved Item Regarding 71124.06 Open the Primary Calibration of the Heating, Ventilation, and Air Conditioning Effluent Monitor Noble Gas Channel

PLANT STATUS

The unit operated at full achievable power (approximately 99 percent power) and approximately 1120 MWe for the majority of the inspection period. On August 3, 2019, the plant was automatically shut down on low reactor water level. The unit returned to full power on August 8, 2019. The unit was shut down on September 16, 2019, for Refueling Outage C1R19.

The unit remained in a shutdown condition through the end of the inspection period.

INSPECTION SCOPES

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

71111.01 - Adverse Weather Protection External Flooding Sample (IP Section 03.04)

(1) The inspectors evaluated readiness to cope with external flooding for the following areas:

• dam inspection on July 15, 2019

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

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) residual heat removal 'C' during lowered inventory conditions on September 17, 2019

(2) Division 2 shutdown service water on September 19, 2019

(3) Division 2 emergency diesel generator on September 19, 2019

71111.04S - Equipment Alignment Complete Walkdown Sample (IP Section 03.02)

(1) The inspectors evaluated system configurations during a complete walkdown of the feedwater system on August 21, 2019.

71111.05A - Fire Protection (Annual) Annual Inspection (IP Section 03.02)

(1) The inspectors evaluated fire brigade performance during the fire in the turbine building, elevation 762' on September 25, 2019.

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

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Fire Zone T-1a, turbine building basement, elevation 712-0 on July 5, 2019

(2) Fire Zone D-6a/b, Division 2 diesel generator and day tank room, elevation 737-0 on July 12, 2019

(3) Fire Zone CB-3E, Division 2 nuclear system protection system inverter room, elevation 781-0 on July 19, 2019

(4) Fire Zones A-2n and A-4, Division 1 switchgear room and Division 1 battery room, elevation 781-0 on July 24, 2019

71111.06 - Flood Protection Measures Inspection Activities - Internal Flooding (IP Section 02.02a.)

The inspectors evaluated internal flooding mitigation protections in:

(1) auxiliary electrical equipment room on September 3, 2019

71111.07A - Heat Sink Performance Annual Review (IP Section 02.01)

The inspectors evaluated readiness and performance of:

(1) leakage past 1CC075A and 1CC076A impact to ultimate heat sink on August 14, 2019

===71111.08G - Inservice Inspection Activities (BWR)

BWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding Activities (IP Section 03.01) (1 Partial)

(1) (Partial)

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 from September 23, 2019 to September 30, 2019:

03.01.a - Nondestructive Examination and Welding Activities.

1. Volumetric, ultrasonic, manual examination of reactor pressure vessel nozzle, N10, inner radius welds for ASME category B-D located within the bio-shield of the containment drywell 2. Volumetric, ultrasonic, manual examination of reactor recirculation weld, 1-RR-AC-1, for ASME category R-A located in the drywell 750 elevation 3. Volumetric, ultrasonic, manual examination of reactor pressure vessel head meridional weld, CH-ME, at 255° for ASME category B-A located on the refueling floor 4. Volumetric, ultrasonic, manual examination of reactor pressure vessel head meridional weld, CH-MF, at 315° for ASME category B-A located on the refueling floor 5. Surface, magnetic particle examination of one third of reactor pressure vessel head-to-flange weld, CH-C-2 (1/3), for ASME category B-A located on the refueling floor 6. *IN-PROGRESS* pressure boundary weld(s) review

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) The inspectors observed and evaluated licensed operator performance in the control room during unit restart following SCRAM on August 5, 2019.

(2) The inspectors observed and evaluated licensed operator performance in the control room during planned reactor shutdown for Refueling Outage C1R19 on September 15, 2019.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) ===

(1) The inspectors observed and evaluated Just-in-Time training to prepare for the upcoming outage on September 3, 2019.

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

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

(1) electrohydraulic control system on September 3, 2019

(2) emergency core cooling ventilation system on August 29, 2019

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

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) liquid discharge, elevated risk due to first liquid discharge in 27 years, Work Order

===4955690-13

(2) heavy lift over main turbine for outage mobilization on September 5, 2019

(3) planned Yellow risk for reactor core isolation cooling valve operability checks on September 6, 2019

(4) shutdown risk Yellow due to lowered inventory on September 17, 2019

(5) shutdown risk Yellow due to shutdown cooling on September 18, 2019

(6) shutdown risk Yellow due to electrical power work on September 19, 2019

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

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Action Request 4258762, #4 BPV [bypass valve] Stuck Full Open During 9072.10 on July 11, 2019

(2) Action Request 4279700, SRM [source range monitor] B Failed Linear Response on September 18, 2019

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

The inspectors evaluated the following temporary or permanent modifications:

(1) Engineering Change 624142, Slip-on Flange on 1RH19BB-4

(2) Engineering Change 625821, Modify Unit Sub B for Reliable VC [control room heating, ventilation, and air conditioning] Load Shedding

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

The inspectors evaluated the following post maintenance tests:

(1) shutdown service water hydromotor 1SX019B rebuild post maintenance test on June 7, 2019

(2) reactor core isolation cooling water leg pump post maintenance testing on July 25, 2019

(3) source range monitor channel B post maintenance test on September 19, 2019

(4) Division 3 shutdown cooling water pump post maintenance test on July 22, 2019

==71111.20 - Refueling and Other Outage Activities Refueling/Other Outage Sample (IP Section 03.01) (1 Partial)

(1) (Partial)

The inspectors evaluated Refueling Outage C1R19 planning activities and outage activities from September 9 through October 31, 2019.

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests:

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

(1) Clinton Power Station (CPS) 9061.10, Fuel Pool Cooling Valve Operability, on July 26, 2019

(2) diesel generator operability - independent verification on September 15, 2019

(3) heatup/cooldown, inservice leak and hydrostatic 30 minute temperature log on September 16, 2019

(4) CPS 9069.01, Shutdown Service Water Operability Test, on July 8, 2019 Containment Isolation Valve Testing (IP Section 03.01) ===

(1) upper air lock barrel leak rate test on September 15, 2019

(2) high pressure core spray injection valve local leak rate test on September 17, 2019

71114.04 - Emergency Action Level and Emergency Plan Changes Inspection Review (IP Section 02.01-02.03)

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

• Evaluation 18-45, Exelon Nuclear Standardized Radiological Emergency Plan, Revision 30 This evaluation does not constitute NRC approval.

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

The inspectors evaluated:

(1) Technical Support Center drill on August 13,

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

The inspectors evaluated radiological hazards assessments and controls.

(1) The inspectors reviewed the following:

Radiological Surveys

• C1R19 Drywell 768 9/19/2019 through 9/26/2019

• C1R19 Refuel Floor 828 09/16/2019 through 09/22/2019

• C1R19 Drywell 755 09/19/2019 through 09/20/2019 Risk Significant Radiological Work Activities

• C1R19 Drywell Emergent Activities

• C1R19 Refuel Floor Activities (No Cavity Access)

• C1R19 Refuel Floor IVVI Activities

• C1R19 Drywell Bioshield ISI Activities Air Sample Survey Records

• Sample 19-231; C1R19 Refuel Floor 09/16/2019 10:10

• Sample 19-240; C1R19 Refuel Floor Cavity 09/17/2019 00:40

• Sample 19-253; C1R19 Refuel Floor 09/18/2019 23:15

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

• CL-1-19-00543; C1R19 Drywell Emergent Work; Revision 3

• CL-1-19-00902; C1R19 Refuel Floor Activities (No Cavity Access); Revision 0

• CL-1-19-00903; C1R19 Refuel Floor Cavity Platform IVVI; Revision 0 Electronic Alarming Dosimeter Alarms

• Dosimeter Dose Rate Alarm 05/06/2018 01:23

• Dosimeter Dose Rate Alarm 05/07/2018 14:28

• Dosimeter Dose Rate Alarm 05/24/2018 04:39

• Dosimeter Dose Rate Alarm 06/21/2019 11:06

• Dosimeter Dose Rate Alarm 09/22/2019 02:52 Labeling of Containers

• Five refueling equipment containers on north side of containment refueling floor 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:

• Cs-137 Source Number 10187

• Cs-137 Source Number 9042 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) There were no radiological work package for areas with airborne radioactivity available for review during the inspection.

High Radiation Area and Very High Radiation Area Controls (IP Section 02.05) (1 Sample)

(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 Implementation of ALARA and Radiological Work Controls (IP Section 02.03)

The inspectors reviewed as low as reasonably achievable practices and radiological work controls.

(1) The inspectors reviewed the following activities:

• CL-1-19-00543; C1R19 Drywell Emergent Work; Revision 3

• CL-1-19-00902; C1R19 Refuel Floor Activities (No Cavity Access); Revision 0

• CL-1-19-00903; C1R19 Refuel Floor Cavity Platform IVVI; Revision 0

Radiation Worker Performance (IP Section 02.04) (1 Sample)

The inspectors evaluated radiation worker and radiation protection technician performance during the following activities:

(1)

• CL-1-19-00543; C1R19 Drywell Emergent Work; Revision 3

• CL-1-19-00902; C1R19 Refuel Floor Activities (No Cavity Access); Revision 0

• CL-1-19-00903; C1R19 Refuel Floor Cavity Platform IVVI; Revision 0

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation Engineering Controls (IP Section 02.01)

The inspectors evaluated airborne controls and radioactive monitoring.

(1) The inspectors reviewed the following:

Installed Ventilation Systems

• Standby Gas Treatment System 0VG01SB at 719 Control Building

• Drywell Purge Trains 0VQ07FC at 702 Control Building Temporary Ventilation System Setups

• There were none available for review during this inspection.

Portable or Installed Monitoring Systems

• Three Portable Ventilation Units Containing HEPA/Charcoal at Various Elevations inside the Drywell Use of Respiratory Protection Devices (IP Section 02.02) (1 Sample)

The inspectors evaluated the licensees use of respiratory protection devices by:

(1) Observing in-field applications; verifying the licensee validated the level of protection provided by the devices; inspecting the material condition of devices, reviewing records and certification of devices issued for use; reviewing the qualifications of workers that use the devices; and observing workers donning, doffing and testing devices.

Self-Contained Breathing Apparatus for Emergency Use (IP Section 02.03) (1 Sample)

The inspectors evaluated self-contained breathing apparatus program implementation.

(1) The inspectors reviewed the following:

Status and Surveillance Records for Self-Contained Breathing Apparatus

• Ultra Elite MSA Firehawk PD-065

• Ultra Elite MSA Premier P-17

• Ultra Elite MSA Premier P-12 Self-Contained Breathing Apparatus Fit for On-Shift Operators

• MSA Firehawk PD-063; Operator 1

• MSA Firehawk PD-106; Operator 2 Self-Contained Breathing Apparatus Maintenance Check

• Ultra Elite MSA Firehawk P-123

• Ultra Elite MSA Firehawk P-7

71124.04 - Occupational Dose Assessment Source Term Categorization (IP Section 02.01)

(1) The inspectors evaluated the licensees characterization of the source term and use of scaling factors for the use of hard-to-detect radionuclide activity.

External Dosimetry (IP Section 02.02) (1 Sample)

(1) The inspectors evaluated the external dosimetry program implementation.

Internal Dosimetry (IP Section 02.03) (1 Sample)

The inspectors evaluated the internal dosimetry program implementation.

(1) The inspectors reviewed the following:

Whole Body Counts

• Whole Body Count Intake Investigation 02/08/2019

• Whole Body Count Intake Investigation 10/19/2018 In-Vitro Internal Monitoring

• There were no In-Vitro Internal Monitoring Investigations during this inspection period.

Dose Assessments Performed Using Air Sampling and Derived Air Concentration-Hour Monitoring

• TEDE ALARA Evaluation Screening Worksheet for Reactor Disassembly-Reassembly; Reactor Cavity Entry-Reactor Head

Special Dosimetric Situations (IP Section 02.04) (1 Sample)

The inspectors evaluated the following special dosimetric situation:

(1) Licensees implementation of requirements to manage radiation protection of declared pregnant workers for three workers, application of NRC-approved external dosimetry methods (i.e. EDEX), shallow dose equivalent and neutron dose assessments.

71124.06 - Radioactive Gaseous and Liquid Effluent Treatment Walk Downs and Observations (IP Section 02.01)

The inspectors walked down the following gaseous and liquid radioactive effluent monitoring and filtered ventilation systems to assess the material condition and verify proper alignment according to plant design:

(1)

• Plant service water effluent

• HVAC effluent

• Liquid radioactive waste effluent Calibration and Testing Program (Process & Effluent Monitors) (IP Section 02.02) (1 Sample)

The inspectors reviewed the following gaseous and liquid effluent monitor instrument calibrations and tests:

(1)

• Plant service water effluent monitor 1RIX-PR036 calibration; 02/21/2019

• Liquid radiation monitor sensitivities to I-131 and setpoint determination; 11/30/1999

• HVAC System Effluent Exhaust monitor PR001 calibration; 01/08/2019

Sampling and Analysis (IP Section 02.03) (1 Sample)

The inspectors reviewed the following:

(1) Radioactive Effluent Sampling and Analysis Activities

• Offgas pretreatment effluent; 08/20/2019

• HVAC effluent tritium and noble gas; 08/22/2019 Effluent Discharges

• There were none available for review during the inspection.

Instrumentation and Equipment (IP Section 02.04) (1 Sample)

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

(1) Standby Gas Treatment System Train A tests 03/20/2018

Dose Calculations (IP Section 02.05) (1 Sample)

The inspectors reviewed the following to asses public dose:

(1) Liquid and Gaseous Discharge Permits

• Gaseous continuous effluent permit 07/26/2019

• Gaseous continuous effluent permit 07/15/2019 Annual Radiological Effluent Release Reports

• 2018 Annual Radioactive Effluent Release Report

• 2017 Annual Radioactive Effluent Release Report Abnormal Gaseous or Liquid Tank Discharges

• There were none available for review during this inspection.

71124.07 - Radiological Environmental Monitoring Program Site Inspection (IP Section 02.01)

The inspectors evaluated the radiological environmental monitoring program implementation.

(1) The inspectors reviewed the following:

Walkdowns, Calibrations, and Maintenance Record Review

• Air Sampling Station CL-2

• Air Sampling Station CL-3

• Air Sampling Station CL-94

• Optically Stimulated Luminescent Dosimeter (OSLD) Monitoring Station CL-2

• OSLD Monitoring Station CL-3

• OSLD Monitoring Station CL-94 Environmental Sample Collections and Preparation Observation

• Sampling not available due to pre-determined sample scheduling that was contrary to onsite inspection time frame.

Licensee Actions in Response to Missed Sample, Inoperable Sampler, Lost TLD or Anomalous Measurement

• CL-115; Food Product; Insufficient Vegetation Collected; 07/25/2018

• CL-118; Food Product; Insufficient Vegetation Collected; 07/25/2018

• CL-114; Food Product; Insufficient Vegetation Collected; 08/29/2018 Sampling Program for the Potential of Licensed Material Entering Groundwater

• Monitoring Well MW-CL-13I

• Monitoring Well MW-CL-13S

• Monitoring Well MW-CL-14S Groundwater Protection Initiative (GPI) Implementation (IP Section 02.02) (1 Sample)

(1) The inspectors reviewed licensee actions as a result of a 2006 onsite release of the Cycled Condensate System Tank.

OTHER ACTIVITIES - BASELINE

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

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

(1) Unit 1 (07/01/2018 - 06/30/2019)

MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)

(1) Unit 1 (07/01/2018 - 06/30/2019)

MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)

(1) Unit 1 (07/01/2018 - 06/30/2019)

BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (1 Sample)

(1) Unit 1 (09/5/2018 - 09/9/2019)

BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)

(1) Unit 1 09/01/2018 - 06/01/2019 OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) 04/01/2018 - 06/30/2019 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) 09/01/2018 - 06/01/2019

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues (IP Section 02.03)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Action Request 4221847, 1A Diesel Generator Fuel Priming Pump Motor Sparking

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

(1) The inspectors evaluated an automatic reactor scram on low reactor water level and the licensees response on August 3, 2019.

Personnel Performance (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated an arc flash event and worker injury on September 11,

INSPECTION RESULTS

Unresolved Item Unresolved Item Regarding the Primary Calibration of the 71124.06 (Open) Heating, Ventilation, and Air Conditioning Effluent Monitor Noble Gas Channel URI 05000461/2019003-01

Description:

The licensee was unable at the time of the inspection to provide records of its primary calibration of the station heating, ventilation, and air conditioning exhaust effluent monitor 0RIX-PR001/2 for the high range noble gas channel.

Planned Closure Actions: Upon receipt of the licensees documentation, the agency will perform its review to determine if a performance deficiency occurred.

Licensee Actions: The licensee was performing a review of the effluent monitors primary calibration to locate the applicable records and information. Once complete, this will be forwarded to the Agency for its review.

Corrective Action References: Action Request 4282015 Observation: Review of Action Request 4221847, 1A Diesel Generator Fuel 71152 Priming Pump Motor Sparking During the inspection quarter, the inspectors reviewed the licensees corrective actions associated with Action Request 4221847, 1A Diesel Generator Fuel Priming Pump Motor Sparking. The inspectors assessed the following performance attributes in their review:

• complete and accurate identification of the problem in a timely manner commensurate with its safety significance and ease of discovery;

• consideration of the extent of condition, generic implications, common cause, and previous occurrences;

• evaluation and disposition of operability/functionality/reportability issues;

• classification and prioritization of the resolution of the problem commensurate with safety significance;

• identification of corrective actions, which were appropriately focused to correct the problem; and

• completion of corrective actions in a timely manner commensurate with the safety significance of the issue.

The inspectors selected this sample due to the potential impact to the operability of the associated diesel generator; a safety significant system. After further testing performed on the fuel priming pump, it was determined it would have been able to fulfill its safety function; therefore, the diesel generator remained operable. The inspectors review focused on whether the licensee had sufficient information prior to the fuel priming pump motor sparking to determine there was a degraded condition. There were indications of oil leaks in the area that had the potential to leak onto the pump but the corrective action documents that described these leaks did not specify whether an impact to the fuel priming pump was identified. Based on the information reviewed the inspectors concluded there was not a performance deficiency associated with this issue.

EXIT MEETINGS AND DEBRIEFS

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

• On October 11, 2019, the inspectors presented the integrated inspection results to Mr. T. Stoner, Site Vice President, and other members of the licensee staff.

• On August 22, 2019, the inspectors presented the Radiation Protection inspection results to Mr. G. Olsen - Maintenance Director and other members of the licensee staff.

• On September 27, 2019, the inspectors presented the Radiation Protection inspection results to Mr. T. Stoner, Site Vice President, and other members of the licensee staff.

• On October 3, 2019, the inspectors presented the Emergency Preparedness inspection results to Mr. L. Baker, EP Fleet Programs Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.04S Corrective Action AR 4267205 EOID - Through Wall Leak Immediately Upstream of 07/26/2019

Documents 1CB050A

Drawings Drawing M05- P&ID Reactor Feedwater (FW) AH

1004

Drawing M05- P&ID Condensate (CD) AH

1005

Drawing M05- P&ID Condensate Booster (CB) P

1006

Procedures CPS Feedwater Electrical Lineup 13a

3103.01E001

CPS Feedwater Valve Lineup 11

3103.01V001

71111.05A Corrective Action AR 4282239 Electrical Cable Fire at 762 Turbine Hallway 09/25/2019

Documents AR 4282262 Documentation of No-Call EAL for TB Fire per EP-AA-120 09/25/2019

AR 4282649 Critique for Response to Fire at 762 TB on 09/25/2019 09/25/2019

Procedures CPS 762 Turbine: Turbine Auxiliaries Prefire Plan 6c

1893.04M720

71111.05Q Corrective Action AR 4255569 9071.13 FP CO2 Sys Auto Actuation (Div 2 DG) 06/09/2019

Documents

Procedures CPS 737 Diesel Generator: Div 2 Diesel Generator & Day Tank 7b

1893.04M512 Room Prefire Plan

CPS 712 Turbine: Basement Prefire Plan 6b

1893.04M700

OP-AA-201-004 Fire Prevention for Hot Work 16

Work Orders WO 4762970 Hot Tap Line Per EC to Improve Water Delivery During 08/30/2019

Outage

71111.06 Procedures CPS 781 Control: Aux. Elect. Equip., Inverter & Battery Rooms 7d

1893.04M351 Prefire Plan

CPS 4304.01 Flooding 6c

71111.07A Corrective Action AR 4053236 Unexpected CCW Tank Level Increase During 1RIX-PR004 09/18/2017

Documents CAL

AR 4130127 1CC075A and 1CC076A Leaking By 04/24/2018

Inspection Type Designation Description or Title Revision or

Procedure Date

AR 4130828 NRC Question on Last Performance of 9861.09D006 04/25/2018

AR 4139396 9861.09 & Data Sheets - SX Boundary Leak Test Proc. 05/20/2018

Changes

AR 4258659 CCP Procedures 9861.09D006/7 Cannot Be Performed as 06/21/2019

Written

AR 4264675 9861.09D0006 Exceeds Admin Limit 07/17/2019

AR 4268801 Leakage Table Parameters Wrong in 9861.09 08/01/2019

Corrective Action AR 4268907 NRC IDd Error in SX Boundary Leakage Procedure 08/01/2019

Documents Pressures

Resulting from

Inspection

Engineering EC 624294 Maximum Flow from 3/4 SX Hose Test Connection 0

Changes EC 624532 9861.09 & Data Sheets - SX Boundary Leak Test Proc. 0

Changes Supporting Information

EC 628812 Evaluate Leakage from UHS for Valves 1CC075A and 0

1CC076A

Miscellaneous Design Analysis Determination of Allowable Leak Rates and Loss of UHS 02/13/2012

IP-M-0563 Volume from Shutdown Service Water (SX) Boundary

Valves

Procedures CPS 9861.09 Shutdown Service Water Boundary Valve Leak Testing 2

CPS Leakage Test on Valve 1CC075A and 1CC076A 2a

9861.09D006

71111.08G Corrective Action 4134785 Low Thickness Readings Discovered on B RHR Min Flow 05/05/2018

Documents Piping

4135345 Erosion on 1E12F018B Valve Internals 05/07/2018

4136024 Need RHR B Alternate Valves 05/09/2018

Corrective Action 4282058 Revision of GEH-UT-300 is Required 09/25/2019

Documents 4282747 NRC ISI: Wear Rate Methodology in EC 624182 09/27/2019

Resulting from 4283049 NRC ID Questions on Work Order 1230601-01/39 09/28/2019

Inspection 4283637 Follow-Up to IR 4283049, Questions on Work Order 09/30/2019

230601

NDE Reports C1R19-008 Examination Summary Sheet 09/23/2019

C1R19-009 Examination Summary Sheet 09/23/2019

C1R19-011 Examination Summary Sheet 09/25/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

C1R19-MT-006 Magnetic Particle Examination 09/23/2019

C1R19-UT-031 UT Calibration/Examination 09/26/2019

Procedures ER-AA-335-003 Magnetic Particle Examination 9

ER-AA-430-1004 Erosion in Piping and Components (EPC) Guide 2

GEH-PDI-UT-1 PDI Generic Procedure for the Ultrasonic Examination of 12

Ferritic Welds

GEH-UT-300 Procedure for Manual Examination of Reactor Vessel 12

Assembly Welds in Accordance with PDI

WPS 1-1-GTSM- ASME Welding Procedure Specification Record 4

PWHT

71111.12 Corrective Action AR 4139393 Found Fuses Blown for Fast Open Acting Solenoids 05/20/2018

Documents AR 4193090 (A)(1) Determination for MR Function LAS-2-FUEL-02 11/08/2018

AR 4214931 GE MK II EHC Circuit Cards Are Now Obsolete 01/29/2019

AR 4257126 BPV #1 Fast Acting Solenoid Did Not Energize During 06/15/2019

9072.01

AR 4258812 BPV #3 Fast Acting Solenoid Did Not Energize During 06/22/2019

9072.01

Miscellaneous ER-AA-310-1005 (a)(1) Action Plan Development and Action Plan (Monitoring) 7

Goal Setting Template

Work Orders WO 1525186 Replace Fast Opening Solenoid Valve - 1C85F013 10/09/2013

WO 1525189 Replace Fast Opening Solenoid Valve - 1C85F022 10/10/2013

71111.13 Procedures CPS 9054.02 Reactor Core Isolation Cooling Valve Operability Checks 43c

HU-AA-1211-F-01 Briefing Topic Supplemental Form 7

MA-AA-716-021 Rigging and Lifting Program 30

WC-AA-104-F-01 Risk Screening/Mitigation Plan 0

Work Orders WO 4840584 Pre-Outage Mobilization & Demobilization Turbine Deck 08/28/2019

WO 4946966 9054.02A20 OP RCIC Valve Operability (D001) 08/01/2019

WO 4955690 Ops Perform a Liquid Radioactive Discharge 09/10/2019

71111.15 Corrective Action AR 289539 Provisions for Liquid Tight Jacket Repair 01/11/2005

Documents AR 4257126 BPV #1 Fast Acting Solenoid did not Energize During 06/15/2019

9072.01

AR 4258298 Fast Acting Fuse Blew While Testing BPV 1 06/20/2019

AR 4258762 #4 BPV Stuck Full Open During 9072.01 06/22/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

AR 4258812 BPV #3 Fast Acting Solenoid did not Energize During 06/22/2019

9072.01

AR 4261761 SBV #1 FAS Plunger Stuck 07/03/2019

AR 4262116 Bypass Valve 1C85F0012: Leaking Steam by Seat 07/05/2019

AR 4262629 9072.01 Steam Bypass Valve Tests Surveillance Has Gone 07/07/2019

Late

AR 4279700 SRM B Failed Linear Response 09/13/2019

Procedures CPS 9072.01 Steam Bypass Valve Tests 34d

71111.18 Corrective Action AR 4134785 Low Thickness Readings Discovered on B RHR Min Flow 05/05/2018

Documents Piping

AR 4135297 APS As Found: 1E12D001B Replacement Not Like for Like 05/07/2018

AR 4264806 NOS ID: Issues with UFSAR Changes Related to Design 07/17/2019

Changes

Drawings Drawing M05- P&ID Residual Heat Removal (RH) AO

1075

Engineering EC 624142 Slip-On Flange on 1RH19BB-4 0

Changes

Work Orders WO 1230601-01 When Required, Replace Eroded RHR B Pump Min Flow 05/13/2018

Line

71111.19 Work Orders 929176 SRM B 0

WO 1784832-01 1SX019B Parts Issues with Linear Converter Rebuild 06/04/2019

WO 1784832-02 1SX019B Parts Issues with Linear Converter Rebuild 06/04/2019

WO 1784832-09 1SX019B Parts Issues with Linear Converter Rebuild 06/06/2019

WO 4582718-28 EM 1SX019B: Re-Install Hydramotor Following MMD Work 06/06/2019

WO 929176-70 Perform Detector Testing After Replacement 09/16/2019

71111.20 Procedures C1R19 Master Master Work Activity List 09/10/2019

(Fall 2019)

SSMP Final C1R19 Shutdown Safety Management Program 0

71111.22 Corrective Action AR 4245341 2017 PMMR Created Incorrectly 05/01/2019

Documents

Miscellaneous CL-SURV-012 Clinton PRA Application Notebook; Risk Assessment Missed 0

Surveillance - Upper Containment Air Lock Barrel; IR

243061

Procedures CPS 1305.01 Primary Containment Leakage Rate Testing Program 12c

Inspection Type Designation Description or Title Revision or

Procedure Date

CPS Type C Local Leak Rate Summary Sheet 7

1305.01F002

CPS Heatup/Cooldown, Inservice Leak and Hydrostatic 30 Minute 30b

9000.06D001 Temperature Log

CPS 9080.10 DG Operability - Independent Verification 30c

CPS 9843.01 IST Category A Valve Leak Rate Test 36c

CPS Leak Rate Testing of HPCS Injection 27d

9843.01V005

CPS Upper Air Lock Barrel Leak Rate Test 21d

9861.03D001

ER-AA-600-1045 Risk Assessments of Missed or Deficient Surveillances 7

Work Orders WO 1544886-02 MC003G01 LLRT: 1MC-03W CT Upper Air Lock Barrel 11/19/2013

WO 4571040-01 9059.01R20 LRT Vessel Pressure Test 05/13/2018

WO 4636109-02 MC003G01 LLRT: 1MC-03W CT Upper Air Lock Barrel 09/15/2019

WO 4781175 9843.01 10 LRT Cat A VLV LRT (1E22-F004) HPCS INJ 09/17/2019

71114.04 Miscellaneous Evaluation 18-45 Exelon Nuclear Standardized Radiological Emergency Plan 02/14/2019

71124.01 Corrective Action AR 4133783 RPID: Dose Rate Alarm 05/02/2018

Documents AR 4201060 RPID: High Beta Dose Rates on Source U-080 12/07/2018

AR 4259704 RPID: Elevated Dose Rates on Pipe in 737 AB 06/26/2019

AR 4264713 RPID: Rad surv HU Improvement Opportunity 07/17/2019

AR 4265692 RPID: Potential Weakness in Rad surv Security 07/20/2019

Miscellaneous ED Dose and Dose Rate Alarm Logs 01/01/2018 through

09/23/2019

Weekly Locked High Radiation Area Checklist 09/13/2019

Nation Source Tracking System Annual Reconciliation 01/06/2019

L80526 Dry Active Waste 10 CFR 61 Analysis 12/01/2018

Procedures RP-AA-460 Controls for High and Locked High Radiation Areas 36

Radiation Radioactive Source Leak Test 06/20/2019

Surveys 2019-053210 C1R19 BRAC Point Radiological Surveys 09/23/2019

Self-Assessments AR 4200413 Pre NRC Inspection 71124.01 Radiological Hazards 03/28/2019

Assessment and Exposure Controls

NOSA-CPS-17-06 Radiation Protection Audit Report 07/18/2017

71124.02 ALARA Plans CL-1-18-00901 Disassembly and Reassembly/Cavity Lift Installation Post 05/23/2018

Inspection Type Designation Description or Title Revision or

Procedure Date

Job Review

CL-1-18-00902 RFF Activities/Cavity Lift Installation Post Job Review 05/09/2018

CL-1-19-00543 C1R19 Drywell Emergent Work 3

CL-1-19-00902 C1R19 Refuel Floor Activities (No Cavity Access) 0

CL-1-19-00903 C1R19 Refuel Floor Cavity Platform IVVI 0

Corrective Action AR 4189624 RPID: Lack of Rigor in ALARA Planning 10/30/2018

Documents AR 4277962 RPID: Potential C1R19 Dose savings 09/10/2019

AR 4278446 RPID: ALARA Plan Under 25% original estimate 09/11/2019

Miscellaneous C1R19 Station Alara Committee Meeting Notes 09/25/2019

C1R18 RP/ALARA Refueling Outage Report

71124.03 Calculations RWP 1900901 C1R19 FF RX Disassembly/Reassembly Activities 08/20/2019

TEDE ALARA

Evaluation

Screening

Worksheet

Calibration 0VG015B Standby Gas Treatment System Charcoal Absorber B Test 02/14/18

Records 0VG08FA Standby Gas Treatment System Charcoal Adsorber A 03/20/2018

0VQ01SC Drywell Purge Filter Train C Absorber and HEPA Filter Test 05/11/2017

Corrective Action AR 4156414 Incorrect Redon Protocol Selected During Respirator Fit 07/17/2018

Documents Test

Miscellaneous Posi3 USB Test MSA Ultralite Complete SCBA Test 08/16/2019

Results

0Y244871

Posi3 USB Test MSA Ultralite Complete SCBA Test 08/16/2019

Results 0Y33112

71124.04 Calculations RWP 1900622 C1R18 AB/CT Insulation Activities ECCS Insulation 09/28/2018

TEDE ALARA Removal HEPA or Wet

Evaluation

Screening

Worksheet

RWP 1900903 C1R19 Cavity Platform IVVI and Associated Activities 08/20/2019

TEDE ALARA

Evaluation

screening

Inspection Type Designation Description or Title Revision or

Procedure Date

Worksheet

Calibration RP-AA-210-1001 Multiple Dosimetry EDE Evaluation Sheet 09/19/2019

Records

Miscellaneous NISP-RP-006 Personnel Contamination Event Log on PCE #3 09/21/2019

NVLAP Landauer, Scope of Accreditation to ISO/IEC 17025:2005 NVLAP Code 01/01/2019

Inc. 100518-0

RP-AA-210-1001 Multiple Dosimetry Issue Log Single Entry on a GE Hitachi 09/27/2019

Personnel

RP-AA-270 Declaration of Pregnancy Paperwork from 04/24/2017

through 05/10/2019

71124.06 Calibration WO 04666126-02 HVAC System Exhaust PRM CC (PR001) 01/08/2019

Records WO04660214-01 SGST Flow Monitor 0FT-VG001 11/27/2018

WO04682965-01 Main Stack Flow Mon 0FT-VR500 02/25/2019

WO04686837-01 Calibration of Liquid PRM 1RIX-PR036 02/20/2019

Corrective Action AR 04133155 ODCM: Chem Unable to Obtain VR/VQ Sample due to 05/01/2018

Documents Equipment Issue

AR 04220189 Missed ODCM NG and Tritium Sample due to Equipment 02/14/2019

Malfunction

AR 04222110 IRIX-PR036 Comp, Grab Sample Analysis Missed 02/21/2019

Miscellaneous 2018 Annual Land Use Census Evaluation and Summary 10/10/2018

2017 Annual Radioactive Effluent Release Report;

04/23/2018

2018 Annual Radioactive Effluent Release Report;

04/25/2019

Offgas Pre-Treatment Gamma Spectroscopy Analysis 08/20/2019

Procedures CY-CL-6949-01 Off-gas Pre Treatment Sampling and Analysis 9

CY-CL-6954-01 HVAC Stack Effluent Noble Gas and Tritium 4

CY-CL-6954-02 HVAC Stack Effluent - Iodine and Particulates 5

Self-Assessments AR 04203312 NRC Inspection: Radioactive Gaseous and Liquid Effluent 06/28/2019

Treatment

Work Orders 01930276-04 Standby Gas Treatment Train A Charcoal/Heater/HEPA 03/20/2018

Testing

71124.07 Calibration Serial Number Field Rotameter Calibration 02/05/2019

Records 3K620000007433

Inspection Type Designation Description or Title Revision or

Procedure Date

Serial Number Field Rotameter Calibration 05/06/2019

3K620000007433

Corrective Action AR 04104312 ODCM Air Samplers CL-7, CL-8, CL-15 & CL-94 Timer 02/14/2018

Documents Shortages

AR 04112366 ODCM Environmental Area TLDS CL-35 Missing 03/07/2018

AR 04125532 ODCM: Air Samplers CL-3, CL-4 and CL-6 Timer Shortages 04/11/2018

AR 04128517 ODCM Water Compositor Cl-91 Sample Line or Header 04/18/2018

Clogged

AR 04163281 REMP: Weekly Air Particulate and Iodine Cartridges 08/10/2018

Missing

Miscellaneous Annual Radiological Environmental Operating Report; 04/25/2019

January 01, 2018 - December 31, 2018

2018 Annual Land Use Census Evaluation and Summary 10/18/2018

Monthly Report on the Meteorological Monitoring Program at 04/11/2018

the Clinton Power Station February 2018

Monthly Report on the Meteorological Monitoring Program at 10/22/2018

the Clinton Power Station August 2018

Monthly Report on the Meteorological Monitoring Program at 04/15/2019

the Clinton Power Station February 2019

Procedures CY-AA-170-1001 Environmental Dosimetry - Performance Specifications, 1

Testing, and Data Analysis

Self-Assessments AR 4203308 NRC Inspection: Radioactive Effluent Monitoring Program 06/28/2019

(IP 71124.07)

71153 Corrective Action AR 4278245 Arc Flash Event 09/11/2019

Documents

24