IR 05000461/2020003
| ML20315A244 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 11/09/2020 |
| From: | Kenneth Riemer NRC/RGN-III/DRP/B1 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2020003 | |
| Download: ML20315A244 (14) | |
Text
November 9, 2020
SUBJECT:
CLINTON POWER STATION - INTEGRATED INSPECTION REPORT 05000461/2020003
Dear Mr. Hanson:
On September 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. J. Kowalski, Plant Manager, 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-2020-003-0023
Licensee:
Exelon Generation Company, LLC
Facility:
Clinton Power Station
Location:
Clinton, IL
Inspection Dates:
July 01, 2020 to September 30, 2020
Inspectors:
J. Beavers, Senior Resident Inspector
S. Bell, Health Physicist
C. Mathews, Illinois Emergency Management Agency
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
Unit 1 began the inspection period at rated thermal power. On September 5, 2020, the unit was down powered to 70 percent for a control rod sequence exchange. The unit remained at or near rated thermal power for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors 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
External Flooding Sample (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (1 Sample)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)
'A' residual heat removal train on August 31, 2020
Complete Walkdown Sample (IP Section 03.02) (2 Samples)
- (1) The inspectors evaluated system configurations during a complete walkdown of the carbon dioxide system on September 2, 2020
- (2) The inspectors evaluated system configurations during a complete walkdown of the 4-kilovolt safety bus and supply system on September 10, 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 F-1i, fuel pool cooling pump room, elevation 712', on July 15, 2020
- (2) Fire Zone F-1b, high pressure core spray pump room, elevation 712', on August 18, 2020
- (3) Fire Zone M-4, screen house 'A' fire pump room, elevation 699', on September 2, 2020
- (4) Fire Zone A-3f, Division 2 essential switchgear room on September 17, 2020
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (2 Samples)
The inspectors evaluated internal flooding mitigation protections in the:
- (1) High pressure core spray pump room
- (2) Division 1 shutdown service water pump room
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 the power restoration Data Reconciliation & Validation Implementation Plan on July 22, 2020
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator requalification training in the simulator on July 21, 2020
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (3 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) Work Order 5064232-05, "Division 1 Shutdown Service Water Strainer Piping Elbow Emergent Maintenance"
- (2) Power reduction and condensate polisher swap for troubleshooting on August 20, 2020
- (3) Yellow risk condition due to planned maintenance on Division 1 emergency diesel generator on September 17, 2020
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 4357056, "Packing Leak on 1B21-F019"
- (2) Action Request 4361015, "Unplanned Power Change"
- (3) Action Request 4362498, "Digital Feed Water Level Control Fault"
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) Division 1 shutdown service water strainer piping elbow emergent maintenance
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
- (1) Work Order 4915968, "3D Monicore Update Due to GEH [General Electric Hitachi]
Part 1 Notification"
- (2) Work Order 5047632, "1TD25AA Temporary Leak Seal Installation"
- (3) Work Order 5064232-01, "Division 1 SX [shutdown service water] Piping Elbow Fabrication"
- (4) Work Order 5068733-05, "Digital Feedwater Level Control Drop 5 Repair"
- (5) Work Order 497422-04, "Division 1 Diesel Generator Output Breaker"
- (6) Work Order 4624505, "Division 1 Diesel Generator"
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) Work Order 4994541, "'B' FLEX Pump Semiannual Run"
- (2) Work Order 5045136, "Reactor Water Level 1B21-N681B Channel Functional"
Inservice Testing (IP Section 03.01) (3 Samples)
- (1) Work Order 5039567, "'B' Fuel Pool Cooling Pump in Service Test"
- (2) Work Order 4899284, "'C' Residual Heat Removal (RHR) Pump Comprehensive Pump Test"
- (3) Work Order 5056584, "'A' RHR Pump in Service Test"
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)
- (1) Full participation emergency preparedness drill on August 25, 2020
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated:
- (1) Licensed operator requalification out-of-the-box evaluation on September 29,
RADIATION SAFETY
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (5 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:
- (1) Area radiation monitors in the auxiliary building and fuel handling building
- (2) Continuous air monitors in the auxiliary building
- (3) Portable Geiger Mueller survey instruments in the auxiliary building
- (4) Portable ionization chamber survey instruments in the instrumentation laboratory facility in the control building
- (5) Radiologically controlled area exit personnel contamination monitors and small article monitors
71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &
Transportation
Radioactive Material Storage (IP Section 03.01)
- (1) Inspectors evaluated the licensees performance in controlling, labelling, and securing radioactive materials
Radioactive Waste System Walkdown (IP Section 03.02 (1 Sample)
- (1) Inspectors walked down accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality
Waste Characterization and Classification (IP Section 03.03) (2 Samples)
- (1) The inspectors evaluated the licensees characterization and classification of spent resin radioactive waste
- (2) The inspectors evaluated the licensees characterization and classification of irradiated hardware radioactive waste
Shipment Preparation (IP Section 03.04) (1 Sample)
- (1) The inspectors observed that a shipment containing radioactive material is prepared according to requirements
Shipping Records (IP Section 03.05) (3 Samples)
The inspectors evaluated the following non-excepted radioactive material shipments through a record review:
- (1) Radioactive waste shipment W18-012 of spent resin radioactive waste shipped for disposal on August 1, 2018
- (2) Radioactive waste shipment W19-007 of irradiated hardware radioactive waste shipped for disposal on April 23, 2019
- (3) Radioactive waste shipment W20-009 of mixed radioactive waste shipped for disposal on July 15,
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 (07/01/2019 - 06/30/2020)
MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)
- (1) Unit 1 (07/01/2019 - 06/30/2020)
MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)
- (1) Unit 1 (07/01/2019 - 06/30/2020)
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (1 Sample)
- (1) Unit 1 (10/01/2019 - 06/30/2020)
BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)
- (1) Unit 1 (07/01/2019 - 06/30/2020)
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) Unit 1 (01/01/2019 - 06/30/2020)
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 shutdown service water leaks 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) Incorrect air regulator installed on high pressure core spray room cooler flow control valve
71153 - Followup of Events and Notices of Enforcement Discretion Event Followup (IP Section 03.01)
- (1) The inspectors evaluated an unplanned power change and licensees response on August 4,
INSPECTION RESULTS
Minor Violation 71152 Minor Violation: The inspectors reviewed the operation of valves 1SX041A and 1SX041B because the licensee documented in multiple action requests that the valves would not fail open when operators bled air from the air operator. This was contrary to the design of the valves, which should have failed open upon losing air pressure. The inspectors identified a minor violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," when the licensee failed to ensure that the high-pressure core spray room cooler flow isolation valves 1SX041A and 1SX041B would fail open on a loss of instrument air. The flow isolation valves are air operated valves that have an air regulator to control air pressure to the valves. The station installed an air regulator that would not cause the flow isolation valves to fail open if instrument air lost pressure. The flow isolation valves also have a solenoid valve that vents the air operator whenever the high-pressure core spray room cooler was operating. The components were arranged so that the flow isolation valves would still be able to open whenever there was a demand signal for the room cooler to start. In the case of a loss of instrument air pressure, the valves would initiate flow only if the high-pressure core spray pump was started. The inspectors determined that the high-pressure core spray room cooler would be able to perform its function to support high pressure core spray pump operability.
Screening: The inspectors determined the performance deficiency was minor. The inspectors determined that the performance deficiency was minor because it did not adversely affect the mitigating systems cornerstone. Specifically, the room cooler flow isolation valve was still able to open when room cooling was required.
Enforcement:
This failure to comply with 10 CFR Part 50, Appendix B, Criterion III, "Design Control," constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
Observation: Adverse Trend in Shutdown Service Water Components 71152 The inspectors identified a negative trend in the integrity of components in the shutdown service water system Specifically, over the previous year, the licensee experienced through-wall leaks in the shutdown service water strainer drain piping, the 'A' RHR room cooler, and the 'C' RHR room cooler. Each leak resulted in the licensee declaring the associated systems inoperable and entering the Technical Specification Limiting Conditions for Operations action statements. As corrective action, the licensee replaced each component that was leaking and created actions to address components identified in their extent of condition evaluation. The licensee determined that the failures of the room coolers were due to erosion of the piping and that the failure of the strainer drain piping was due to microbiological induced corrosion. The inspectors noted that drain piping was not required to be included in the licensee's Generic Letter 89-13 program and that the licensee did not add the section of piping to the program for continued monitoring. The inspectors noted that although it was not required to add the section of piping to the GL 89-13 program, it would have been a conservative action since the piping experienced a failure. The inspectors did not identify any violations of NRC requirements while evaluating this trend.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On September 30, 2020, the inspectors presented the integrated inspection results to Mr. J. Kowalski, Plant Manager, and other members of the licensee staff.
- On September 23, 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
Corrective Action
Documents
1CO609 (1CO01T Tank Outlet) Found Shut during Tagout
Hang
07/28/2020
Drawings
M05-9014
C02 Fire Protection Diesel Gen's & Turbine-Gen Exciter
N
Procedures
3312.01V001
Residual Heat Removal Valve Lineup
17c
Fire Plans
1893.04M130
781 - 790 Auxiliary: Div 2 Switchgear Prefire Plan
5b
1893.04M400
2 Fuel: Basement Prefire Plan
5a
1893.04M803
699 Screen House: 'A' (North) Fire Pump Room Prefire Plan 6a
71111.11Q Engineering
Changes
Power Recovery Via BELSIM Data Reconciliation &
Validation (DVR) Methodology
Corrective Action
Documents
MCR Alarm 5002-3P for P612 Hardware Fault on Drop 5
Corrective Action
Documents
HK: Steam Leak at 737 Heater Bay F-116 on 2in Pipe
06/04/2020
Shipping Records WO 4624505
Division 1 Diesel Generator
Work Orders
Division 1 Diesel Generator Output Breaker
MM 1TD25AA Temp Leak Seal Installation
07/01/2020
Replace Div 1 SX Pipe and Elbow
Digital Feed Water Level Control Drop 5 Repair
Procedures
CPS 9061.10
Fuel Pool Cooling Valve Operability
48c
Work Orders
9053.07, 1E12C002C Comprehensive Pump Test
09/02/2020
FLEX - 1FX01PB Hale Pump Functional
08/05/2020
Fuel Pool Cooling Pump 1B and 1A Valve IST Testing
07/15/2020
9030.01C05 CF ATM - (NS4 Reactor Water Level B21-
N681A-D) C005
09/15/2020
9052.01A21 OP RHR 'A' Pump Operability
09/16/2020
Miscellaneous
LOR Simulator
Scenario
September 29, 2020 Licensed Operator Requalification Out
of the Box Simulator Scenario
09/29/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Self-Assessments None
Clinton Off-Year Exercise Evaluation Report
Corrective Action
Documents
Truck Breakdown During Shipment
2/05/2019
Delays in Shipping TN - RAM Cask
04/24/2019
Defective Drums
01/17/2020
Corrective Action
Documents
Resulting from
Inspection
NRC Observation - Shipping Enhancement
09/21/2020
Miscellaneous
White Paper: RP-AA-1003 Compliance Program
03/06/2017
Training Qualification Records for Radioactive Material
Transportation Individuals
Various
L76417
CFR 61 Analysis for Spent Resin
01/17/2018
L80526
CFR 61 Analysis for Dry Active Waste (DAW)
2/01/2018
L81020
CFR 61 Analysis for Fuel Building Skimmer Smear
01/16/2019
L82415
CFR 61 Analysis for Fuel Pool Filter Demineralizer
04/10/2019
L86412
CFR 61 Analysis for Spent Resin
2/14/2020
Procedures
CFR Part 37 Material Accountability Program
Radioactive Material/Waste Shipments
Radioactive Material and Non-Disposal Site Waste
Shipments
Shipment of Category 1 Quantities of Radioactive Material or
Waste (Category 1 RAMQC)
Self-Assessments 4297181
NRC Inspection 71124.08 Radioactive Solid Waste
Processing and Radioactive Material Handling, Storage and
Transportation
07/02/2020
Shipping Records W18-012
Radioactive Waste Shipment of Spent Resin
08/01/2018
W19-007
Radioactive Waste Shipment of Irradiated Hardware
04/23/2019
W20-009
Radioactive Waste Shipment of Mixed Radioactive Waste.
07/15/2020
71151
Miscellaneous
Chemistry Reactor Coolant Summary Data 10/01/2019
through 06/30/2020
Radioactive Effluent Release Summary Data 01/01/2019
through 06/30/2020
Dose Equivalent Iodine Determination
07/29/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
AOV 1SX041A Failed to Open When Air Bled Off
03/22/2014
Could Not Bleed Air Off 1SX041A Per 3211.01C003
2/23/2017
EOID: RHR 'C' Room Cooler South Cooling Coil Leakage
11/11/2019
CCP: 1SX041A/B Will Not Fail Open Per 3211.01C003
2/29/2020
EOID: 1VY03S RHR 1A Room Cooler Thru Leak
06/24/2020
Emerging Trend For ECCS Room Cooler Tubing Leaks
06/25/2020
Large Leak Div 1 SX Strainer Piping Elbow
07/26/2020