IR 05000461/2019004
| ML20044D295 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 02/12/2020 |
| From: | Dave Hills NRC/RGN-III/DRP/B1 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2019004 | |
| Download: ML20044D295 (27) | |
Text
February 12, 2020
SUBJECT:
CLINTON POWER STATION - INTEGRATED INSPECTION REPORT 05000461/2019004
Dear Mr. Hanson:
On December 31, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Clinton Power Station. On January 16, 2020, the NRC inspectors discussed the results of this inspection with Mr. T. Chalmers, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Clinton Power Station. 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/
David E. Hills, Chief Branch 1 Division of Reactor Projects
Docket No. 05000461 License No. NPF-62
Enclosure:
As stated
Inspection Report
Docket Number:
05000461
License Number:
Report Number:
Enterprise Identifier: I-2019-004-0066
Licensee:
Exelon Generation Company, LLC
Facility:
Clinton Power Station
Location:
Clinton, IL
Inspection Dates:
October 01, 2019 to December 31, 2019
Inspectors:
B. Bartlett, Senior Operations Engineer
J. Beavers, Senior Resident Inspector
S. Bell, Health Physicist
M. Domke, Reactor Inspector
M. Holmberg, Senior Reactor Inspector
C. Mathews, Illinois Emergency Management Agency
D. Sargis, Resident Inspector
W. Schaup, Senior Resident Inspector
J. Seymour, Reactor Ops Engineer
D. Szwarc, Senior Reactor Inspector
L. Torres, Illinois Emergency Management Agency
Approved By:
David E. Hills, Chief
Branch 1
Division of Reactor Projects
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
Failure to Establish Adequate Breaker Maintenance Frequency Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000461/2019004-01 Open/Closed None (NPP)71153 A self-revealed Green finding and associated non-cited violation (NCV) of 10 CFR Part 50,
Appendix B, Criterion III, "Design Control," was identified when the licensee failed to review for suitability of application of materials that were essential to the safety-related functions of the 4160 V breakers. Specifically, the licensee extended the maintenance frequency for 4160 V breakers without reviewing the suitability of the lubricant for the extended time frame, which caused the failure of the Division 1 main feed breaker.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000461/2019003-01 Unresolved Item Regarding the Primary Calibration of the Heating, Ventilation, and Air Conditioning Effluent Monitor Noble Gas Channel 71124.06 Closed URI 05000461/2019010-01 Fuses Subject to Part 21 Potentially Installed in Safety-Related Circuits 71152 Closed LER 05000461/2019-001-00 LER 2019-001-00 for Clinton Power Station, Unit 1, Main Feed Breaker Failed to Close During Bus Shift 71153 Closed LER 05000461/2019-001-01 LER 2019-001-01 for Clinton Power Station, Unit 1, Main Feed Breaker Failed to Close During Bus Shift 71153 Closed LER 05000461/2019-003-00 LER 2019-003-00 for Clinton Power Station, Unit 1,
Reactor Water Cleanup System Differential Flow Instrumentation Inoperable 71153 Closed
LER 05000461/2019-002-00 LER 2019-002-00 For Clinton Power Station, Unit 1, Turbine Driven Reactor Feed Pump Hydraulic Control Failure Results in Automatic SCRAM 71153 Closed
PLANT STATUS
The unit began the inspection period shut down for Refueling Outage C1R19. Startup was commenced on October 15, 2019, and the unit was synchronized to the grid on October 17, 2019. The unit reached full rated thermal power (approximately 99 percent power)and approximately 1120 MWe on October 21, 2019. The unit remained at full rated thermal power 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.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.02) (1 Sample)
Winter Readiness
The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures for the following systems:
- shutdown service water
- cycled condensate
- fire protection
71111.04Q - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)
'B' control room ventilation on November 19, 2019 (2)high pressure core spray system on November 20, 2019
71111.05Q - Fire Protection
Quarterly Inspection (IP Section 03.01) (2 Samples)
The inspectors evaluated fire protection program implementation in the following selected areas:
- (1) Fire Zone A-3a, RHR 'B' pump and heat exchanger room, elevation 702' on October 3, 2019
- (2) Fire Zone C-2, containment, elevation 755' on October 31, 2019
71111.08G - Inservice Inspection Activities (BWR)
BWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding
Activities (IP Section 03.01)
- (1) 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 October 17, 2019:
03.01.a - Nondestructive Examination and Welding Activities. (The first part of this inspection sample is listed in NRC Inspection Report 05000461/2019003)
1. Visual examination (VT-1 and VT-3) of fuel cooling system components
1FC14008A-WA and 1FC14008A, weld attachment and anchor, ASME category D-A and F-A located in the fuel building
2. Visual examination (VT-1 and VT-3) of essential service water components
1SX19008R-WA and 1SX19008R, weld attachment and rigid support, ASME category D-A and F-A located in the control building
3. Visual examination (VT-1) of reactor head upper vessel penetration
component 1-NB-1-1-2Q1-FB, flange bolting, ASME category B-G-2 located in the containment building
4. Surface magnetic particle examination of residual heat removal heat
exchanger "A" component HEA-3, nozzle-to-head weld, ASME category C-B located in the A/B residual heat removal room
5. Volumetric ultrasonic examination (UT-1) of residual heat removal heat
exchanger "A" component HEA-3, nozzle-to-head weld, ASME category C-B located in the A/B residual heat removal room
6. Volumetric ultrasonic examination (UT-1) of high pressure core spray
component 1-HP-5-1, valve-to-pipe weld, ASME category R-A located in the fuels building
7. Field welds FW1 and FW2 and FW3 and FW4 and 4R1 for residual heat
removal bravo train minimum flow line gate valve 1E12-F018B and check valve 1E12-F046B repairs described by ASME Section XI repair/replacement plan in work order 01230601 task 39
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
- (1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam administered from November 6, 2019 through December 12, 2019.
71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)
- (1) Biennial Requalification Written Examinations
The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered on November 8, 2019.
Annual Requalification Operating Tests
The inspectors evaluated the adequacy of the facility licensees annual requalification operating test.
Administration of an Annual Requalification Operating Test
The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.
Requalification Examination Security
The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.
Remedial Training and Re-examinations
The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.
Operator License Conditions
The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.
Control Room Simulator
The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.
Problem Identification and Resolution
The inspectors evaluated the licensees ability to identify and resolve problems associated with licensed operator performance.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during reactor startup on October 15, 2019.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator requalification simulator exam ESG-LOR-19 on November 13, 2019.
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness Inspection (IP Section 02.01) (4 Samples)
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
(1)main steam system safety relief valve replacement during refueling outage on October 29, 2019 (2)containment isolation valve local leak rate failures during refueling outage on December 20, 2019 (3)
'A' residual heat removal suppression pool suction valve failure during refueling outage on November 21, 2019 (4)
'A' switch gear heat removal condensing unit hydramotor failure on November 19, 2019
Quality Control (IP Section 02.02) (1 Sample)
The inspectors evaluated maintenance and quality control activities associated with the following equipment performance activities:
- (1) Part 21 for emergency diesel generator fuel injectors issued on October 24, 2019
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 02.02) (2 Samples)
The inspectors evaluated the following operability determinations and functionality assessments:
- (1) Action Request 4281606, "MCR [main control room] Alarm: 5060-3E, Ground 125 Vdc MCC [motor control center] 1A" on October 3, 2019
- (2) Action Request 4296225, "RHR [residual heat removal] 'C' Room Cooler South Cooling Coil Leakage" on November 14, 2019
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors reviewed the 50.59 and modification package for the accident tolerant fuel lead test assemblies that were installed during the 2019 refueling outage. The inspectors reviewed the composition of the limited number of lead test assemblies, placement of lead test assemblies in non-limiting core locations, and Technical Specification (TS) 5.6.5, Core Operating Limits Report, including the analytical methods that were previously reviewed and approved by the NRC.
- (1) Engineering Change 627786, "Accident Tolerant Fuel (ATF) at Clinton (IronClad and ARMOR)"
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the following post-maintenance tests:
(1)
'B' reserve auxiliary transformer following maintenance on October 8, 2019 (2)
'A' residual heat removal suppression pool suction valve following valve repair on October 10, 2019
- (3) Division 1 solenoids for safety relief valves B21-F041B and B221-F051B following wiring corrections on October 17, 2019
- (4) Division 1 diesel generator run following governor replacements on October 29, 2019 (5)
'C' residual heat removal cooler south cooling coil after replacement on November 22, 2019 (6)
'A' plant service water to shutdown service water valve test following valve replacement on December 3, 2019
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated Refueling Outage C1R19 activities from October 1-17, 2019.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Inservice Testing (IP Section 03.01)
- (1) Division 1 shutdown service water pump inservice test on November 20, 2019
RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)
- (1) reactor coolant system leakage testing on October 11, 2019
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated:
- (1) The inspectors observed the annual licensed operator requalification drill with drill and exercise program opportunity on November 20,
RADIATION SAFETY
71124.06 - Radioactive Gaseous and Liquid Effluent Treatment
Calibration and Testing Program (Process & Effluent Monitors) (IP Section 02.02) (1 Partial)
The inspectors reviewed the following gaseous and liquid effluent monitor instrument calibrations and tests:
(1)
(Partial)0RIX-PR001/2; station heating, ventilation, and air conditioning exhaust effluent monitor (HVAC).
This inspection activity augments the inspection results contained within NRC inspection report 05000461/2019003.
OTHER ACTIVITIES - BASELINE
71152 - Problem Identification and Resolution
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in control of measurement and test equipment that might be indicative of a more significant safety issue.
Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) The inspectors reviewed the licensees implementation of its corrective action program related to emergency core cooling system sump in leakage.
71153 - Followup of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensee event reports (LERs):
- (1) LER 05000461/2019-001-00 and LER 05000461/2019-001-01, Main Feed Breaker Failed to Close During Bus Shift (ADAMS Accession: ML19322A109)
The circumstances surrounding this LER are documented in the Results section.
- (2) LER 05000461/2019-002-00, Turbine Driven Reactor Feed Pump Hydraulic Control Failure Results in Automatic SCRAM (ADAMS Accession: ML19277E367)
The circumstances surrounding this LER are documented in the Results section.
- (3) LER 05000461/2019-003-00, Reactor Water Cleanup System Differential Flow Instrumentation Inoperable (ADAMS Accession: ML19333B814)
The circumstances surrounding this LER are documented in the Results section.
INSPECTION RESULTS
Unresolved Item (Closed)
Unresolved Item Regarding the Primary Calibration of the Heating, Ventilation, and Air Conditioning Effluent Monitor Noble Gas Channel URI 05000461/2019003-01 71124.06
Description:
The licensee was unable at the time of the inspection (NRC inspection report 05000461/2019003) 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. Following that inspection, the licensee then located and provided the primary calibration for this monitor to the inspectors for review. The inspectors reviewed the provided documentation and did not identify any performance deficiency or compliance issues.
Corrective Action Reference(s): Action Request 4282015
Unresolved Item (Closed)
Fuses Subject to Part 21 Potentially Installed in Safety-Related Circuits URI 05000461/2019010-01 71152
Description:
The NRC issued an unresolved item (URI) when the inspectors identified that the licensee did not evaluate the impact of a Part 21 for Gould Shawmut TR30R fuses. The inspectors noted that the licensee was susceptible to the same failure mechanism described in Part 21. At the time, it was not known if any fuses from the affected lot number were installed in safety-related circuits. The licensee identified all of the circuits in the plant that used TR30R fuses, and they determined how potential fuse failures would impact the safety functions of plant equipment. The licensee performed inspections to determine if fuses from the affected lot were installed in the plant, and they determined that they were not installed in the plant. The inspectors reviewed the licensee's determinations and verified that the work tasks associated with the fuse replacements were completed. The inspectors also observed the fuse replacements for a safety-related circuit and reviewed the licensee's risk mitigation plan associated with the work.
None of the licensee's fuses were from the affected lot number. Therefore, there was no impact on any electrical circuits. The inspectors did not identify any violations of NRC requirements.
Corrective Action Reference(s): Action Request 4250520, "NRC Question: P21 Fuse" and Action Request 4251536, "Part 21 Assessment Results for TR30R Fuses"
Observation: Control of Measurement and Test Equipment 71152 The inspectors reviewed recent corrective action documents regarding measurement and test equipment that failed post-use calibration and that were reported damaged. During the inspection period, the licensee issued three issue reports that documented adverse trends in control of measurement and test equipment. The inspectors noted that two of the issue reports were placed in the non-corrective action program. Control of measurement and test equipment is a requirement for quality assurance programs. Therefore, the inspectors determined that the trends identified should not have been placed in the non-corrective action program, but should have been placed in the licensee's corrective action program. The licensee revised the issue reports to place them in the corrective action program. The inspectors determined that this issue was of minor significance.
Observation: Emergency Core Cooling System Sump in Leakage 71152 The inspectors reviewed the licensee's problem identification and resolution activities associated with emergency core cooling system sump in leakage. Sump alarm issues and cooling water leakage items were reviewed, the cooling water leakage ultimately led to the inoperability of the high pressure core spray system. Although the inspectors determined there were earlier opportunities to resolve this issue, neither deviations from the corrective action program standards nor previous system operability issues were identified.
Failure to Establish Adequate Breaker Maintenance Frequency Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000461/2019004-01 Open/Closed None (NPP)71153 A self-revealed Green finding and associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," was identified when the licensee failed to review for suitability of application of materials that were essential to the safety-related functions of the 4160 V breakers. Specifically, the licensee extended the maintenance frequency for 4160 V breakers without reviewing the suitability of the lubricant for the extended time frame, which caused the failure of the Division 1 main feed breaker.
Description:
On May 22, 2019, the licensee was establishing initial conditions to perform a Division 1 emergency diesel generator surveillance test. The Division 1 4160 V bus had three available power sources. The offsite sources were the reserve auxiliary transformer 'B' (RAT B) and the emergency reserve auxiliary transformer (ERAT), which were powered from separate offsite electrical sources. The onsite power source was the Division 1 emergency diesel generator. The licensee attempted to shift the power source to the Division 1 bus from the ERAT to the RAT B. When the licensee attempted to close the feed breaker from RAT B to the Division 1 bus, the feed breaker failed to close. The licensee declared the RAT B feed to the Division 1 bus inoperable and unavailable, and restored the electrical configuration so that the ERAT was supplying power to the bus. The licensee removed and replaced the breaker, verified proper operation of the new breaker, and declared the RAT B feed to the Division 1 bus operable.
The licensee reported this event to the NRC in LER 2019-001-00 and in LER 2019-001-01.
The licensee noted that the last time the breaker was successfully operated was April 17, 2019. The licensee determined that the breaker was inoperable from that date until the breaker was replaced and tested on May 22, 2019. This exceeded the allowed outage time in TS 3.8.1, Condition A.2, which required restoring an inoperable offsite circuit to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
The licensee performed a causal evaluation. As part of the evaluation, the licensee sent the breaker to its vendor for a failure analysis. The failure analysis identified that the lubricant in the breaker was dry and tacky. The tacky lubricant was found throughout the breaker, indicating that it was an age-related degradation. The analysis determined that the dried lubricant prevented free movement of the internal mechanisms in the breaker, which caused it to fail to close. The licensee reviewed the preventive maintenance frequency and identified that it was changed in 2015. The breaker maintenance that cleans and lubricates the breaker had its frequency changed from every 4 years to every 8 years. The breaker that failed was last cleaned and lubricated 7 years before the failure.
The inspectors reviewed the licensee's causal evaluation and the paperwork associated with changing the maintenance frequency from 4 years to 8 years. Service Request 90522 documents the licensee's justification for changing the maintenance frequency. The maintenance template for the breaker stated, "The condition of the lubricant is essential to proper operation. Inadequate lubrication is by far the dominant cause of breaker failures...
The lubricant can be expected to harden if a breaker is cycled scarcely at all in a period approaching six years." The feed breakers to the safety buses are cycled approximately once per month for emergency diesel generator testing. Service Request 90522 did not address how the lubricant would be affected by remaining in service for the extended period of time.
The inspectors determined that the maintenance frequency extension to 8 years did not ensure the circuit breaker could perform its safety function. The inspectors also identified that when the licensee changed the maintenance frequency, they did not review the materials, parts, or equipment inside the breaker to determine if they were suitable to perform their safety-related function for the period between maintenance.
Corrective Actions: The licensee replaced the failed breaker, changed the breaker preventive maintenance frequency, and revised the maintenance procedure to incorporate a different grease.
Corrective Action References: Action Request 4250932, "1AP07EK Main Feed Breaker Failed to Close During Bus Shift"
Performance Assessment:
Performance Deficiency: The failure to establish a maintenance frequency that ensured medium voltage circuit breakers would perform their safety function was a performance deficiency. Specifically, the licensee extended the maintenance frequency for circuit breakers without reviewing the suitability of the lubricant for the extended time frame, as required by 10 CFR Part 50, Appendix B, Criterion III, "Design Control."
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the performance deficiency caused the Division I main feed breaker to fail to close, which rendered a required source of offsite power inoperable and unavailable.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors used Inspection Manual Chapter 0609, Appendix A, Exhibit 2, "Mitigating Systems Screening Questions," to determine significance. The inspectors answered "Yes" to question 3 because the failure created a loss of function for a required source of offsite power for greater than its TS-allowed outage time. Therefore, the NRC performed a detailed risk evaluation.
A regional senior reactor analyst evaluated the significance of the finding using the Clinton Standardized Plant Analysis Risk model, version 8.59. The model was first modified by the Idaho National Laboratory because the plants normal offsite power alignment during the exposure period was different from the current version of the model. The 'A' and 'C' 4 kV Divisions were normally fed from the ERAT, while the 'B' Division was normally fed from the RAT.
The senior reactor analyst modeled the degraded condition as a failure of the 'A' breaker from the RAT to the bus. The failure mode of the breaker was a failure to close. The exposure time was approximately 31 days. The change in risk was less than 1E-6/yr. because each 4 kV division has three sources of power - RAT, ERAT, and a diesel generator, and the finding affected only one source to one of the buses for a limited period of time.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance. The change to the breaker maintenance frequency occurred greater than three years ago.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion III, "Design Control," requires, in part, that measures shall be established for the selection and review for suitability of application of materials that are essential to the safety-related functions of the structures, systems, and components.
Contrary to the above, from December 2015 to May 22, 2019, the licensee failed to review for suitability of application of materials that were essential to the safety-related functions of the components. Specifically, the licensee extended the maintenance frequency for 4160 V breakers without reviewing the suitability of the lubricant for the extended time frame, which caused the failure of the Division 1 main feed breaker.
Additionally, because the licensee was not aware of the Division 1 main feed breaker inoperability, the licensee failed to take the actions required by TS 3.8.1, Condition A.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Minor Violation 71153 Minor Violation: On August 3, 2019, the initial NRC event notification for an automatic low reactor level SCRAM did not include all reportable conditions for the event. On August 4, 2019, securing high pressure core spray injection was added per 10 CFR 50.72(b)(3)(v)(D). On August 6, 2019, an unanalyzed condition that could have prevented the fulfillment of the primary containment function due to being outside the initial conditions to ensure that drywell and containment pressures remain within design values during a loss of coolant accident, 10 CFR 50.72(b)(3)(ii)(B) and 10 CFR 50.72(b)(3)(v)(C).
The latter two notifications were late.
Screening: The inspectors determined the performance deficiency was minor. The inspectors determined the initial, on time notification triggered the appropriate Agency event response. Additionally, all necessary notifications were eventually made with those on August 4, 2019, and August 6, 2019, beyond the time requirements of NRC regulations.
Enforcement:
This failure to comply with 10 CFR 50.72(b)(3)(ii)(B) and 10 CFR 50.72(b)(3)(v)(C) constitute a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
Observation: Reactor Water Cleanup System Differential Flow Instrumentation Inoperable 71153 The inspectors determined that it was not reasonable to foresee or correct the cause discussed in LER 05000461/2019-003-00; therefore, no performance deficiency was identified. The inspectors also concluded that no violation of NRC requirements occurred.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On January 16, 2020, the inspectors presented the integrated inspection results to Mr. T. Chalmers, Site Vice President, and other members of the licensee staff.
- On October 17, 2019, the inspectors presented the Inservice Inspection Exit inspection results to Mr. D. Shelton, Regulatory Assurance Manager, and other members of the licensee staff.
- On November 8, 2019, the inspectors presented the Biennial inspection of the licensed operator requalification program inspection results to Mr. J. Kowalski, Plant Manager, and other members of the licensee staff.
- On December 13, 2019, the inspectors presented the Biennial inspection of the requalification examination security portion of the licensed operator requalification program inspection results to Mr. T. Dean, Training Director, and other members of the licensee staff.
- On December 17, 2019, the inspectors presented the radiation protection baseline inspection results to Mr. D. Shelton, Regulatory Assurance Manager, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
CPS 1860.01
Cold Weather Operation
9d
71111.04Q Drawings
Drawing
M05-1074
P&ID High Pressure Core Spray (HP)
AH
Procedures
3309.01E001
High Pressure Core Spray Electrical Lineup
8b
3309.01V001
High Pressure Core Spray Valve Lineup
11b
3309.01V002
High Pressure Core Spray Instrument Valve Lineup
3402.01E001
Control Room HVAC Electrical Lineup
10e
3402.01V001
Control Room HVAC Valve Lineup
17a
3402.01V002
Control Room HVAC Instrument Valve Lineup
6a
71111.05Q Corrective Action
Documents
1FP052 - PCIV Will Not Operate - Breaker Trips
08/03/2019
Motor Tests Bad for 1FP052
08/03/2019
Procedures
CPS 1893.01
Fire Protection Impairment Reporting
20f
1893.04M104
707 Auxiliary: RHR 'B' Pump and Heat Exchanger Room
Prefire Plan
5a
1893.04M220
755 Containment: Prefire Plan
FSI Log Number:
001-08-2019
"Sample" Manual Fire System Impairment (FSI) Permit
Work Orders
1FP052 - PCIV will not Operate - Breaker Trips
08/30/2019
71111.08G Corrective Action
Documents
4135343
Erosion on 1E12F018B Valve Internals
05/07/2018
283694
C1R19 Pitting Identified on RHR-B Min Flow Line Elbow
09/30/2019
Corrective Action
Documents
Resulting from
Inspection
288995
NRC ISI Exit Meeting -Minor Violations
10/18/2019
289811
NRC ID'd ASME Code Requirements used in EC 629521
10/21/2019
Engineering
24182
Evaluation of 1E12F046B and 1E12F018B Valve Body
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Evaluations
Degradation
Procedures
Exelon Nuclear Welding Program Repair of Welds and Base
Metal
Work Orders
230601
When Required, Replace Eroded RHR B Pump Minimum
Flow Line
05/13/2018
Corrective Action
Documents
04189731
Reactor Water Level Controller Challenges
10/31/2018
04190336
4.0 Critique Reactor SCRAM on High IRM Flux
11/01/2018
238238
White Finding for Division 2 Diesel Generator Event
04/10/2019
269480
4.0 Critique Reactor SCRAM
08/04/2019
272315
4.0 Critique for 4010.02 Plant Chemistry Off-Normal Entry
08/15/2019
Miscellaneous
ESG-LOR-01
Loss of Coolant Accident - Simulator Exercise Guide
004
ESG-LOR-092
Loss of RPS Solenoid Inverter - Restoration of High
Pressure Feed
003
ESG-LOR-106
RR Pump High Vibrations - RHR C Suction Leak (Simulator
Exercise Guide)
000
N-08NASIM
Simulator Based NRC Annual Operating Exam after Crew
Remediation
2/01/2017
N-08NASIM
Simulator Based NRC Annual Operating Exam - Crew
Failure
11/30/2017
PRCDS for an
Individual
Operator
NRC Written Exam Failure Review
11/06/2017
Procedures
Operator Response Time Program
OP-CL-102-106-
1001
Operator Response Time Master List at Clinton Power
Station
8c
Self-Assessments 04219981
Pre-NRC 71111.11 Inspection Licensed Operator
Requalification Training Assessment
06/06/2019
Corrective Action
Documents
File Transfer Not in Compliance With TQ-AA-201
10/15/2018
Reactor Scram on High IRM Flux
10/28/2018
Single Data Point Not Retained for Test-Simulator
10/17/2019
Corrective Action
Documents
Resulting from
Inspection
NRC ID: Steady State Test Does Not Include CRD Flow and
Temp
11/07/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
10-28-2018 IRM
Post Event Simulator Test
04/08/2019
2017 LORT
Written Exam
Question Usage
Biennial Written Exam Data
11/07/2019
2018 LORT
Annual Exam
Information
Tables
Annual Operating Exam Data
2/05/2019
2018 LORT
Annual Exam
Lineups
Annual Operating Exam Data
2/05/2019
2019 LORT Exam
JPM Distribution
Annual Operating Exam Data
2/05/2019
2019 NRC
Biennial Exam
Validation Matrix
Exam Validation Plan
2/05/2019
2019 Written
Exam Sample
Plan
Biennial Written Exam Data
2/05/2019
Crew and
Individual
Evaluation Forms
Various
11/06/2019
Crew E/S1 (RO
Exam)
2019 Comprehensive Biennial Written Exam
10/27/2019
Crew E/S1 (SRO
Exam)
2019 Comprehensive Biennial Written Exam
10/27/2019
ESG-LOR-10
Simulator Exercise Guide
ESG-LOR-16
Simulator Exercise Guide
ESG-LOR-21
Simulator Exercise Guide
ESG-LOR-92
Simulator Exercise Guide
Guide 1.02
Simulator Stability Test
08/27/2018
Guide 5.01
Manual Scram Transient Test
08/27/2018
Guide 5.04
Simultaneous Trip of All Recirculation Pumps
08/27/2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Guide 5.08
Design Basis Accident with Loss of All Offsite Power
08/27/2018
ILT 17-1 NRC
Exam S-1
Scenario-Based Training Report
08/17/2018
ILT 17-1 NRC
Exam S-3
Scenario-Based Training Report
08/18/2018
JPM 007
JPM 205
JPM 215
JPM 223
JPM 225
JPM 273
JPM 277
JPM 289
JPM 455
JPM 524
Medical Records
Licensed Operator Medical Records, Various
N/A
Reactivation of License Log
03/26/2018
Reactivation of License Log
04/26/2018
Reactivation of License Log
09/20/2019
Reactivation of License Log
03/21/2018
Reactivation of License Log
08/21/2019
Reactivation of License Log
03/19/2018
Reactivation of License Log
09/03/2019
Simulator Work Request 133464
EC 401727 - Power Supply 1IA005 and 1IA008 (Div I) and
1IA006 and IA007 (Div 2)
08/14/2017
Simulator Work Request 133576
Loss of Div 3 Power - E22F015, E22F011 & F036 Did Not
Lose Power
09/21/2017
Simulator Work Request 133593
3D Monicore Values Do Not Match the Plant
09/26/2017
Simulator Work Request 133595
Evaluate Simulator Response to the Loss of DC MCC 1F
09/27/2019
Simulator Work Request 133598
RHR SDC Warming the RHR Loop Does Not Work Properly
09/28/2017
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Simulator Work Request 133615
Defeating LPCS Injection Valve Seal-in Remote Does Not
Work Properly
10/05/2017
Simulator Work Request 133632
Review/Evaluate EC 402156 Turbine Testing Switch Mod for
Simulator Impacts
10/12/2017
Simulator Work Request 133661
07/10/2018
Simulator Work Request 133690
Verify RAT B to ERAT 4160v 1B1 Bus Transfer Indications
11/02/2017
Simulator Work Request 134422
Simulator Model/Coding Leading to Some Inconsistent ANSI
Test Results
07/05/2018
Simulator Work Request 134864
2/13/2018
Simulator Work Request 134933
OPEX: RCIC Will Not Trip on Overspeed
01/15/2019
Simulator Work Request 135258
CRD Pump Run Out After Scram Reset
05/15/2019
Simulator Work Request 135348
DFW FW003B Valve Would Not Operate in Manual
06/26/2019
Simulator Work Request 135607
Collect and Establish Baseline for Suppression Pool
Temperature
10/17/2019
Simulator Work Request 135649
Post Event Analysis of 8/3/19 Reactor Scram
11/05/2019
Examination Security and Administration
TQ-AA-224-F-100 Remedial Training Notification and Action on Failure
10/25/2018
TQ-AA-224-F-100 Remedial Training Notification and Action on Failure
05/17/2019
TQ-AA-306-F-06
BWR Critical Conditions for Cold Startup
05/16/2018
TQ-AA-306-F-07
BWR Power Coefficient of Reactivity and Control Rod Worth
05/16/2018
TQ-AA-306-F-08
05/16/2018
TQ-AA-306-F-09
BWR Site Specific Shutdown Margin and Reactivity Anomaly
Tests
05/16/2018
Training
Attendance
Records
Various
2017-2019
Procedures
Operator Training Programs
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Conduct of Simulator Training and Evaluation
7, Simulator SWR Prioritization
20, Operability Testing Parameters and Criteria
Self-Assessments AR 04219981
Pre-NRC 71111.11 Inspection Licensed Operator Training
Assessment
06/05/2019
71111.11Q Procedures
CPS 3001.01
Preparations for Startup and Approach to Critical
29b
CPS 3002.01
Heatup and Pressurization
33b
Corrective Action
Documents
1VX04CA Tripped Breaker Twice
2/13/2017
5050-3E Trip of Div 1 VX Cond Unit 1VX06CA
07/14/2019
1E12-F004A Failed to Stroke Closed
09/30/2019
Hydramotor Improperly Quarantined Prior to Failure Analysis
10/01/2019
Part 21 - EMD Fuel Injectors Seized Plunger and Bushing
10/25/2019
Trend IR for Appendix J failures in C1R19
2/06/2019
Miscellaneous
Failure
Classification
Form
Issue Processed in Engage Health Under ER-AA-320
Maintenance Rule 2.0 Process as per IR 4263973
09/12/2019
Failure
Classification
Form
Failure of Breaker 1AP27E3E as per IR 4083820
2/09/2018
MR Function
Evaluation
VX-00, RPC Switchgear Heat Removal System
08/07/2019
Project: CPS-
91701
Failure Analysis of Actuator, Hydramotor Model NH91 Pull
Type-Spring
10/29/2019
Procedures
1305.01F001
Type "B" Local Leak Rate Summary Sheet
Work Orders
1E12F004A Failed to Stroke Closed
5050-3E Trip of Div 1 VX Cond Unit 1VX06CA
Corrective Action
Documents
MCR Alarm: 5060-3E, Ground 125 Vdc MCC 1A
09/24/2019
Drawings
Drawing
E02-1DG99
Diesel Generator Sys (DG), Diesel Generator 1, Governor
Control
R
Procedures
CPS 3503.01
Battery and DC Distribution (DC)
19b
3503.01P001
Battery and DC Distribution (DC) Ground Isolation
1b
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Calculations
GNF IronClad ATF Lead Test Assembly for Clinton Unit 1
GNF ARMOR ATF Lead Test Assembly for Clinton Unit 1
GNF IronClad ATF Lead Test Assembly for Clinton Unit 1
GNF ARMOR ATF Lead Test Assembly for Clinton Unit 1
Engineering
Changes
Accident Tolerant Fuel (ATF) at Clinton (IronClad and
ARMOR)
Miscellaneous
CL-2019-E-007
Use of GNF ARMOR and IronClad Lead Test Assemblies in
Clinton Cycles 20 through 22
Corrective Action
Documents
1SX014A LLRT Failure
09/18/2019
MCR Alarm: 5060-3E, Ground 125 Vdc MCC 1A
09/24/2019
EOID SRV 51B Actuates Instead of 41B
10/02/2019
Procedures
3506.01P001
Division 1 Diesel Generator Operations
5d
Work Orders
Perform Valve Inspection/Replacement if Necessary of 1SX0 09/23/2019
Perform Valve Inspection/Replacement if Necessary of 1SX0 09/22/2019
9861.09H20 LRT SX Boundary Valve Leak Testing
(1SX014A)
09/18/2019
9861.09H20 LRT SX Boundary Valve Leak Testing
(1SX014A)
09/18/2019
9861.09H20 LRT SX Boundary Valve Leak Testing
(1SX014A)
09/19/2019
MCR Alarm: 5060-3E, Ground 125 Vdc MCC 1A
09/26/2019
EOID SRV 51B Actuates Instead of 41B
10/04/2019
Drawings
Drawing
M05-1052
P&ID Shutdown Service Water (SX)
Procedures
CPS 9059.01
Reactor Coolant System Leakage Test
2a
9069.01A20 OP SX Pump Oper Test (SX Pump A)
11/20/2019
Calibration
Records
PR-033
Primary Calibration of Station Heating, Ventilation and Air
Conditioning Exhaust Monitor
01/28/1986
Corrective Action
Documents
Resulting from
Inspection
282015
NRC ID: Discrepancy with Primary Calibration
09/25/2019
Corrective Action
Documents
Adverse Trend - Torque Wrenches Damaged By Excessive
10/11/2019
Trend ID: Torque Wrench Damaged By Excessive Torque
10/21/2019
1SX149 LPCS Pump Room Cooler Relief Valve
Adverse Trend - Torque Wrench Damaged By Excessive
2/17/2019
Work Orders
NRC Question: P21 Fuse
11/09/2019
Corrective Action
Documents
1AP07EK Main Feed Breaker Failed to Close During Bus
Shift
05/22/2019
Both Division of RT Differential Flow Failed Downscale
TDRFP B Turbine LVDT Failure Results in an Automatic
Corrective Action
Program
Evaluation Report
1AP07EK Main Feed Breaker Failed to Close During Bus
Transfer
08/29/2019
Miscellaneous
PMCR Number:
90490
PM Change Review Form
PMCR Number:
90522
PM Change Review Form
Procedures
CPS 8410.12
Westinghouse Cubicle Inspection
6a
8410.21C001
Westinghouse DHP Circuit Breaker Checklist
CPS 8501.60
Bus 1A1 Main Feed Breaker Protective Relays Logic System
Functional Testing
0b
Work Orders
1AP07EK Main Feed Breaker Failed to Close During Bus
Shift
05/23/2019
1AP07EK Main Feed Breaker Failed to Close During Bus
Shift
05/23/2019
1AP07EK Main Feed Breaker Failed to Close During Bus
Shift
05/23/2019