IR 05000461/2020002
| ML20224A242 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 08/11/2020 |
| From: | Kenneth Riemer NRC/RGN-III/DRP/B1 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2020002 | |
| Preceding documents: |
|
| Download: ML20224A242 (16) | |
Text
August 11, 2020
SUBJECT:
CLINTON POWER STATION - INTEGRATED INSPECTION REPORT 05000461/2020002
Dear Mr. Hanson:
On June 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Clinton Power Station and 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.
No findings or violations of more than minor significance were identified during this inspection.
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/
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:
Report Number:
Enterprise Identifier: I-2020-002-0025
Licensee:
Exelon Generation Company, LLC
Facility:
Clinton Power Station
Location:
Clinton, IL
Inspection Dates:
April 01, 2020 to June 30, 2020
Inspectors:
J. Beavers, Senior Resident Inspector
T. Go, Health Physicist
C. Mathews, Illinois Emergency Management Agency
L. Rodriguez, Operations Engineer
D. Sargis, Resident Inspector
Approved By:
Kenneth R. Riemer, 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
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
PLANT STATUS
The unit operated at full achievable power (approximately 99 percent power) and approximately 1120 MWe for the duration 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 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.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week and during that time conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities, and completed on-site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on-site. The inspections documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of summer readiness for the following systems:
Chilled water, switch gear heat removal, and emergency core cooling system equipment cooling on June 30, 2020
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather for approaching thunderstorms on May 13, 2020
71111.04 - 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) Low pressure core spray system on April 16, 2020
- (2) Standby gas treatment 'A' train on May 11, 2020
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Fire Zone CB-4, Division 1 cable spreading room, elevation 781', on April 13, 2020
- (2) Fire Zone A-2c, low pressure core spray room, elevation 707'-712', on April 16, 2020
- (3) Fire Zone F-1e, fuel building equipment drain tank room, elevation 712', on June 8, 2020
- (4) Fire Zone A-3c, auxiliary building floor drain pump room, elevation 712', on June 8, 2020
71111.07T - Heat Sink Performance Triennial Review (IP Section 03.02)
- (1) High pressure core spray pump room cooler 1B (1VY08SB), cooled by the service water system, Section 02.02.b
- (2) Ultimate heat sink, Sections 02.02.d.5 and 02.02.d.6
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 control rod testing and power restoration following 30 percent down power on May 31, 2020
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated operator requalification simulator performance on April 23, 2020
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (4 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components remain capable of performing their intended function:
- (1) Periodic evaluation of maintenance rule program in accordance with 10 CFR 50.65(a)(3) completed on October 15, 2019
- (2) Residual heat removal suction valve failure on September 30, 2019 (3)
'B' source range monitor restoration to operable on April 30, 2020
- (4) Control room heating, ventilation, and air conditioning 'B' head pressure controller failure on May 12, 2020
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Division 2 NS4-5 card replacement for emergency work with primary containment isolation system risk, Work Order 5030527 (emergent)
(2)elevated risk due to Division 2 shutdown service water annunciator repair, Work Order 5026425 (emergent)
(3)planned Yellow risk window for Division 3 emergency diesel generator, on June 9, 2020 (planned)
- (4) Emergency yellow risk due to residual heat removal cooler cooling coil, on June 24, 2020 (emergent)
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Action Request 4321732, "1VX06CB Oil Low Out of Sight Glass"
- (2) Action Request 4335455, "RWCU [reactor water cleanup] Division 2 Isolation"
- (3) Action Request 4337100, "1C11-F010/F011 Open Delay Time Out-of-Service During 9012.01"
- (4) Action Request 4340652, "Drywell Inleakage Rise"
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Power Recovery Via BELSIM Data Validation & Reconciliation Methodology Permanent Modification 0000622157
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
- (1) Post-maintenance test after replacement of 1DO005C, Work Order 4791497-02
- (2) Post-maintenance test after replacement of Division 2 NS4-5 card, Work Order 5030527
- (3) Post-maintenance test after maintenance of 1C1 diesel generator feeder breaker, Work Order 1724627
- (4) Post-maintenance test after replacement of 1A1 feeder breaker, Work Order 4734530
- (5) Post-maintenance test after maintenance of 1E51-N636A reactor core isolation cooling suppression pool level instrument, Work Order 5044253-07
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) Clinton Power Station (CPS) 9333.34, "Division II 4.16kV Bus Undervoltage Relay Calibration," on April 30, 2020
on May 21, 2020
- (3) CPS 9054.01C002, "RCIC [reactor core isolation cooling] 1E51-C001 High Pressure Operability Check," on June 29, 2020
RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)
- (1) CPS 4001.01, "Reactor Coolant Leakage," on May 15,
RADIATION SAFETY
71124.05 - Radiation Monitoring Instrumentation
Calibration and Testing Program (IP Section 03.02) (13 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection instruments:
- (1) Eberline AMS-4; S/N 2176/2175; Calibration Date 12/03/2020
- (2) Mirion Technologies; Accuscan II Whole Body Counter System Model 2280; Calibration Date 01/17/2020
- (3) Ludlum 3030P; S/N 328887; Calibration Date 04/26/2019
- (4) ARGOS-5 Personnel Contamination Monitor; S/N 1012-341; Calibration Date 03/04/2020
- (5) Mirion Technologies; Fast Scan Whole Body Counter; Calibration Date 01/16/2020
- (6) Eberline Ion Chamber; RO-2A; S/N 350; Calibration Date 04/08/2020
- (7) Perkin Elmer; Liquid Scintillation Counter (LSC-102); S/N 427980; H3 Quench Curve; Calibration Date 01/10/2020
- (8) Thermo Fisher Scientific; PM-12 Personnel Contamination Monitor; S/N 117; Calibration Date 01/14/2020
- (9) Eberline Ion Chamber; RO-20; S/N 005239; Calibration Date 02/25/2019
- (10) Ludlum Frisker: Model 177; S/N 319976; Calibration Date 10/31/2019
- (11) Radeco Air Sampler; S/N 20110801007; Calibration Date 11/09/2019
- (12) Canberra HpGe Detector A; Efficiency and Source Verification Date 11/24/2018
- (13) Area Radiation Monitor; S/N ARM-1R1X-AR016; Calibration Date 06/04/2018
Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (2 Samples)
The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:
- (1) Heating, Ventilation, and Air Conditioning System Exhaust Process Radiation Monitor; S/N PRM-0RIX-PR001; Calibration Date 01/08/2019
- (2) Drywell High Range Gamma Monitor; S/N 1RZX-CM059; Calibration Date 01/14/2019
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS06: Emergency AC Power Systems (IP Section 02.05)===
- (1) Unit 1 (04/01/2019 - 03/31/2020)
MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)
- (1) Unit 1 (04/01/2019 - 03/31/2020)
MS08: Heat Removal Systems (IP Section 02.07) (1 Sample)
- (1) Unit 1 (04/01/2019 - 03/31/2020)
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) Unit 1 (07/01/2019 - 03/31/2020)
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 the system health for the control room ventilation 'B' train 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 licensee's implementation of its corrective action program related to repeated lock alarms for the rod control and information system
INSPECTION RESULTS
Observation: Repetitive Alarms from Rod Control and Information System 71152 The inspectors evaluated the licensee's corrective actions related to repetitive alarms from the rod control and information system. The inspectors selected this issue because the lockup alarms for the system can prevent normal rod motion and present a challenge to precise control of the reactor.
The inspectors did not identify any violations of NRC requirements.
Observation: Negative Trend in Control Room Ventilation 'B' Train Performance 71152 The inspectors reviewed the performance of the control room ventilation (VC) 'B' chiller and identified a negative trend in equipment performance. The most recent issues included the following:
- VC 'B' head pressure controller failed to control pressure at the set point on May 12, 2020, which made the chiller inoperable
- VC 'B' chiller flow control valve 1SX019B was found partially open, and should have been closed, while the chiller was shut down on April 1, 2020, which did not impact operability
- VC 'B' chiller flow control valve 1SX019B was found half open, and should have been closed, while the chiller was shut down on January 15, 2020, which did not impact operability
- VC 'B' chiller tripped due to a failure of 1SX019B on August 1, 2018, which made the chiller inoperable
The licensee was able to restore the system function following each failure. The inspectors noted a weakness in the licensee's assessments of the failures. Specifically, the licensee was not able to determine the cause for the issues on April 1, 2020, or January 15, 2020.
Also, the licensee identified that the failure on May 12, 2020, was caused by a failed controller but was not able to determine why the controller failed. The problems with the control of the 1SX019B flow control valve have been intermittent. The inspectors did not identify any violations of NRC requirements.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On June 30, 2020, the inspectors presented the integrated inspection results to Mr. T. Chalmers, Site Vice President, and other members of the licensee staff.
- On April 10, 2020, the inspectors presented the Heat Sink Performance inspection results to Mr. T. Chalmers, Site Vice President, and other members of the licensee staff.
- On May 8, 2020, the inspectors presented the Radiation Protection Baseline inspection results to Mr. T. Chalmers, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
CPS 4302.01
Tornado/High Winds
Station Housekeeping/Material Condition Program
Site Certification
Letter Template
for Summer
Readiness
Site Certification Letter Template for Summer Readiness
06/21/2020
Drawings
M05-1073, Sheet
P&ID Low-Pressure Core Spray
AH
M05-1105, Sheet
P&ID Standby Gas Treatment System
U
Procedures
3313.01E001
Low Pressure Core Spray Electrical Lineup
11b
3313.01V001
Low Pressure Core Spray Valve Lineup
13b
3319.01E001
Standby Gas Treatment Electrical Lineup
3319.01V001
Standby Gas Treatment Valve Lineup
Fire Plans
1893.04M101
707 to 712 Auxiliary: LPCS Pump Room Prefire Plan
5a
1893.04M106
2 Auxiliary: Floor Drain Pump Rooms Prefire Plan
5a
1893.04M352
781 Control: Div 1 Cable Spreading Room Prefire Plan
5d
1893.04M400
2 Fuel: Basement Prefire Plan
5a
71111.07T Calculations
IP-M-0816
Shutdown Service Water (SX) System Hydraulic Network
Analysis Model and Flow Balance Acceptance Criteria for
Div. 3
VY-01
VY System Cooling Load Calculation [ECCS/MSIV] Post-
Loss-of-Coolant-Accident [LOCA]
9-E
71111.07T Calculations
VY-45
Performance Evaluation of VY System Cooling Coils Under
SX Flow Acceptance Limits
Corrective Action
Documents
Guided Wave Indication Noted on Buried Line 1SX27AB-14
05/05/2014
DAH - 1VY08SB Reinstall Coils After Cleaning
01/09/2019
2SXA9AA: UT Results Lower Than Acceptance Criteria
06/21/2019
1SX014A LLRT Failure
09/18/2019
1SX011B Failed Leak Rate
10/04/2019
Hole in Pipe at Weld AT 1SX082B
10/09/2019
EOID: RHR C Room Cooler South Cooling Coil Leakage
11/11/2019
1SX01PB Motor HX Performance Test Data Trending
Toward Alarm
01/31/2020
1SX014A/B: Actions Due to Chronic LLRT Failures
03/23/2020
EACE 725079
1SX014A: Div 1 SX Sys. Isol. Vlv., Leaks by Seat
01/24/2008
Corrective Action
Documents
Resulting from
Inspection
NRC UHS Inspection: Procedure Enhancement for
2700.14D001
04/08/2020
NRC UHS VY-01 Revised HPCS Room Heat Load and
Missed Impacts
04/08/2020
NRC UHS: 2700.01 Data Sheet Completion Discrepancy
04/10/2020
Engineering
Evaluations
Action - Perform a Technical Evaluation of the 2014
BPRWCP Inspection Results of Line 1SX27AB-14" Including
any Proposed Follow-up Actions
Seat Leakage Across WS/SX Cross-Tie Valve 1SX014A
Miscellaneous
2019-01 Project
Eddy Current Results: 2019-01 Project - HPCS Room
Cooling Coil 1VY08AC
01/08/2019
Technical Report
AH1421-
40695325PIMS
Long Range Guided Wave Ultrasonic Pipe Screening
Results
09/03/2019
NDE Reports
UT Examination of 1SX98AA-3"
2/24/2018
07/25/2018
UT Examination of 1SX51AB-2-1/2"
04/04/2018
UT Examination of 1SX107BB-0.75"
04/30/2019
UT Examination of 1SX23AB-4"
10/31/2017
UT Examination of 1SX008B and 1SX06AB-20" Tee
03/08/2018
UT Examination of 0SX14AB-3"
01/28/2019
2/01/2019
UT Examination of 1SX07AB-2"
03/08/2019
UT Examination of 2SXA9AA-3"
06/21/2019
UT Examination of 1SXK1AB-3/4"
2/02/2019
01/17/2020
Procedures
CPS 9069.01
Shutdown Service Water Operability Test
50b
CPS 9861.09
Shutdown Service Water Boundary Valve Leak Testing
2a
Work Orders
Perform Div. III SX System Testing IAW 2700.14
07/14/2015
1VY08SB, Inspect, Clean and Eddy Current GL 89-13
01/13/2015
9861.09I20 LRT SX Boundary Valve Leak Testing
(1SX011B)
05/13/2017
Perform Div. I SX System Testing IAW 2700.12
04/17/2018
Test HPCS Pump Room Coil Cabinet 1VY08SB
07/23/2015
Obtain Air Flow Measurements for Room
10/09/2017
9069.01, 1SX01PC Comprehensive Pump Test
2/12/2018
1VY08SB, Inspect, Clean (Hydrolaze) & Eddy Current
01/08/2019
9861.09F20 LRT SX Boundary Valve Leak Testing
(1CC075A, 76A)
07/18/2019
UT Examination of 1SX15AB-4"
10/03/2018
9861.09J20 LRT SX Boundary Valve Leak Testing
(VG/VC Deluge)
2/23/2019
Perform Valve Inspection / Replacement if Necessary of
1SX0
09/24/2019
9861.09I20 LRT SX Boundary Valve Leak Testing
(1SX011B)
10/04/2019
9861.09H20 LRT SX Boundary Valve Leak Testing
(1SX014A)
09/18/2019
9861.09C20 LRT SX Boundary Valve Leak Testing
(1SX011A)
10/04/2019
9861.09B20 LRT SX Boundary Valve Leak Testing
(1SX014B)
10/01/2019
9069.01B20 OP SX Pump Oper. Test (SX Pump B)
04/04/2018
Perform Annual RWCP Inspections at CPS per ER-AA-5400
2/21/2018
9069.01A20 OP SX Pump Oper. Test (SX Pump A)
11/15/2018
1SX082B Leaking Approx. 0.5gpm
10/10/2019
9069.01B20 OP SX Pump Test (SX Pump B)
2/30/2019
Measure Motors Amps and Coastdown Time
03/10/2020
Perform RHR B Valve Operability per 9053.04C002/D002
03/07/2020
9069.01A20 OP SX Pump Oper. Test (SX Pump A)
03/21/2020
Corrective Action
Documents
1E12-F004A Failed to Stroke Closed
09/30/2019
(A)(3) CDF Trend Exceeded PSA Application Guide
Threshold
01/14/2020
1E12-F004A Not Included in MRule RH-04-A Scope in
RH-00-H
05/29/2020
Miscellaneous
CPS-44539
Failure Analysis of a Moore 535 Digital Controller
06/05/2020
May 21, 2018
through October
15, 2019
CFR 50.65 (a)(3) Periodic Assessment of Maintenance
Rule Program
01/14/2020
Work Orders
9431.13B (B22) CC SRM C51K600B CC
Corrective Action
Documents
1VX06CB Oil Low Out of Sight Glass
2/26/2020
1C11-F010/F011 Open Delay Time OOS During 9012
Drywell Inleakage Rise
Operability
Evaluations
Operability of Safety-Related AC and DC Electric Power
Distribution Subsystems with VX Inoperable
Procedures
3412.01C002
Temporary Exhaust Fan Use with Switchgear HVAC Out of
Service (Div 2)
0b
Engineering
Evaluations
Power Recovery Via BELSIM Data Reconciliation &
Validation (DVR) Methodology
Work Orders
Maintenance of 1C1 Diesel Generator Feeder Breaker
1DO005C PM for Valve Replacement
Test Bus 1A1 Main Feeder Breaker System Check
Relay/Burnish Contact
03/22/2019
Replacement of Division 2 NS4-5 Card
Troubleshoot 1E51-N636A Reactor Core Isolation Cooling
Suppression Pool Level Instrument
Procedures
CPS 9071.09
Fire Protection Diesel Generator Bay 1A CO2 System Auto
Actuation Test
35a
CPS Procedure
4001.01
Reactor Coolant Leakage
2c
Work Orders
9071.09, FP CO2 Sys Auto Actuation (Div I DG) Puff Test
Only
05/21/2020
9333.34 CC DIV II 4.16KV Bus Undervoltage Relay
(Degraded Voltage) CC
04/30/2020
RCIC Pump Operability
07/12/2020
Calculations
Eckert & Ziegler
Results of Radiochemistry Cross Check Program for Exelon
Nuclear Clinton 3rd Quarter 2019
2/10/2019
Eckert & Ziegler
Analytics
Third Quarter Radio Chemistry Cross Check Program for
HpGe Detector
10/12/2019
Calibration
Records
0011151318
Power Labs; Ion Chamber RO-20; S/N 005239
2/25/2019
Drywell High Range Gamma Monitor Channel Calibration
01/14/2019
Accuscan II WBC
Mirion Technologies of Calibration of Accuscan II Whole
Body Counter
01/17/2020
PRM-ORIX-
PR001
HVAC System Exhaust Process Radiation Monitor
Calibration
01/18/2019
Personnel Contamination Monitor; S/N 117
01/14/2020
Miscellaneous
Out of Tolerance Report for Frisker RM-14; S/N 0076019
09/02/2020
71151
Miscellaneous
Turnover, Reviewed logs for Keys to LHRA Controlled Key
Lockers
07/01/2019
through
03/31/2020
Corrective Action
Documents
EOID VC 'B' Chiller Tripped Due to Failure of 1SX019B
08/01/2018
1SX019B Mid Position with Chiller Secured
01/15/2020
5006-3G RC&IS Inop
2/18/2020
EOID: 1SX019B Flow with Chiller Shut Down
04/01/2020
VC B Head Pressure Controller Not Controlling at Setpoint
05/12/2020
Engineering Evaluation of Degraded Conditions for 1SX019B 05/15/2020
Work Orders
5006-3G RC&IS Inop
2/21/2020