IR 05000461/2021004
| ML22034A977 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 02/04/2022 |
| From: | Kenneth Riemer NRC/RGN-III/DRP/B1 |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2021010 | |
| Download: ML22034A977 (25) | |
Text
SUBJECT:
CLINTON POWER STATION - INTEGRATED INSPECTION REPORT 05000461/2021004
Dear Mr. Rhoades:
On December 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Clinton Power Station. On January 13, 2022, 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.
Two findings of very low safety significance (Green) are documented in this report. One of these findings 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.
If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Clinton Power Station.
February 4, 2022 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, 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-2021-004-0075
Licensee:
Constellation Nuclear
Facility:
Clinton Power Station
Location:
Clinton, IL
Inspection Dates:
October 01, 2021 to December 31, 2021
Inspectors:
J. Beavers, Senior Resident Inspector
J. Cassidy, Senior Health Physicist
R. Elliott, Resident Inspector
J. Kutlesa, Physical Security Inspector
V. Meghani, Reactor Inspector
A. Muneeruddin, Reactor Engineer
J. Murphy, Illinois Emergency Management Agency
J. Nance, Operations Engineer
J. Park, Reactor Inspector
D. Sargis, Health Physicist
L. Torres, Nuclear Safety Engineer, Illinois Emergency Management
Agency
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
Damaged Fuel Bundle During Core Alterations Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green FIN 05000461/2021004-01 Open/Closed
[H.5] - Work Management 71153 A self-revealed Green finding was identified when the licensee failed to adhere to the core alterations instruction provided by Clinton Power Station (CPS) 3703.01, "Core Alterations."
Specifically, the licensee failed to use manual (slow speed) when lowering a fuel bundle on the core edge past the steam dam per precaution 4.32 and ultimately contacted the steam dam and damaged the fuel bundle handle.
Core Alterations in Unmonitored Quadrant Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000461/2021004-02 Open/Closed
[H.5] - Work Management 71153 A self-revealed Green finding and associated non-cited violation (NCV) of TS 3.3.1.2, "Source Range Monitor Instrumentation," was identified when the licensee failed to suspend core alterations with a required source range monitor (SRM) inoperable in Mode 5. Specifically, two fuel bundles were loaded into the reactor core with the quadrant's source range monitor inoperable.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000461/2021002-00 LER 2021-002-00 for Clinton Power Station, Unit 1, Core Alteration with Source Range Monitor Inoperable Results in Condition Prohibited by Technical Specifications 71153 Closed
PLANT STATUS
Unit 1 began the inspection period in refueling outage C1R20. On October 27, 2021, the unit was restarted and synchronized to the grid. On October 28, 2021, the unit was shut down and entered maintenance outage C1M24 to address a redundant reactor pressure control issue. On October 30, 2021, the unit was restarted, synchronized to the grid, and restored to full power for the remainder of the year.
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 activities described in IMC 2515, Appendix D, Plant Status, conducted routine reviews using IP 71152, Problem Identification and Resolution, observed risk significant activities, and completed on-site portions of IPs. 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.
On February 1, 2022, the operating license for Clinton held by Exelon Generation Company, LLC was transferred to Constellation Energy Generation, LLC (Constellation) as documented in the associated license amendments (ML22021B660). While some or all of the inspection documented in this report was performed while the license was held by Exelon Generation Company, LLC, this report will refer to the licensee as Constellation throughout.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of winter and seasonal cold temperatures for the following systems:
(1)auxiliary power, fire, shutdown safety water, and FLEX systems on November 18, 2021
71111.04 - Equipment Alignment
Complete Walkdown Sample (IP Section 03.02) (2 Samples)
- (1) The inspectors evaluated system configurations during a complete walkdown of the 4kV shutdown safety system after a Division 2 maintenance outage on October 10, 2021.
- (2) The inspectors evaluated system configurations during a complete walkdown of the 4kV shutdown safety system after a Division 1 maintenance outage on October 15, 2021.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (1 Sample)
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)drywell on October 22, 2021
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 27 to October 8, 2021:
03.01.a - Nondestructive Examination and Welding Activities.
1. Nondestructive Examinations:
ultrasonic (UT) examination, residual heat removal, 10" pipe to elbow weld, 1-RH-14-13-2
UT examination, reactor core isolation cooling, 6" pipe weld, 1-RI-13-6-3
magnetic particle (MT) examination, low pressure core spray pipe welded attachments, 1LP-1-1A
MT examination, low pressure core spray pipe to penetration weld, 1LP04001R
visual VT-3 examination, rigid seismic support, M-1RH07002X
visual VT-3 examination, rigid support, M-1RH07057R
visual VT-3 examination, rigid support, M-1SX16012R
visual VT-3 examination, rigid support, 1LP04001R
MT examination, reactor pressure vessel head to flange weld, CH-C-2
MT examination, residual heat removal heat exchanger shell to nozzle weld, HEA-4
UT examination, residual heat removal heat exchanger shell to nozzle weld, HEA-4
UT examination, low pressure core spray pipe to valve weld, 1LP-1-1
UT examination, reactor pressure vessel top head dollar plate weld, CH-C-1
2. Examination records with relevant indications accepted for continued service:
none available
3. Pressure boundary welds:
Welds 1 and 2; Work Order 4833210-01, "1SX21AA Replace Thinning Pipe at 4" Elbow"
Welds 1 through 4; Work Order 5064232, "Replace Div 1 SX Strainer Piping and Elbow"
Weld Repair; Work Order 4967105-11, "1SX83B 3" Pipe to Valve 1SX082B"
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 tests and biennial written examinations administered from November 3, 2021 to December 9, 2021.
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 from November 3, 2021 through December 9, 2021.
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 24, 2021.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated annual simulator requalification on November 4, 2021.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
(1)low pressure core spray minimum flow valve and piping replacement on October 13, 2021 (2)reactor core isolation cooling inboard steam isolation valve on October 17, 2021
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:
(1)emergency reserve auxiliary transformer automatic load tap changer failure on October 9, 2021
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)loss of 138kV offsite power source on October 9, 2021
- (2) Division 1 integrated shutdown safety power test on October 12, 2021 (3)residual heat removal common suction window maintenance on October 14, 2021
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Action Request 4452024, "ERAT [emergency reserve auxiliary transformer]
Transformer Breaker 8m 0AP164EH Will Not Stay Closed"
- (2) Action Request 4453301, "1SX011A LRT [leak rate testing] Was Not Performed in Accordance with IST [in-service test] Code"
- (3) Action Request 4445844, "1SX011A Not Stroked Per WO [work order] 4964708-01"
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Engineering Change 625049, "Division 1 Diesel Generator Under Voltage Relay CV-2 Replacement"
- (2) Clinton Power Station Maximum Extended Operating Domain Expansion (MEOD2.0)
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the following post-maintenance test (PMT) activities to verify system operability and functionality:
- (1) Work Order 4961668-06, "Replace Defective Sections of Low-Pressure Core Spray Piping"
- (2) Work Order 5199491-01, "Replace and Calibrate Pressure Regulator Amplifier"
- (3) Work Order 5178584-03, "FLEX 1FX-1LB DG [diesel generator] Functional"
- (4) Work Order 5198662-03, "SLC [standby liquid control] Pump A Operability"
- (5) Work Order 5121970-09, "1E51-F063 PMT"
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated refueling outage C1R20 activities from October 1, 2021 to October 27, 2021.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) Work Order 4985706-01, "Diesel Generator 1A ECCS [emergency core cooling system] Integrated Test"
- (2) Work Order 5169040-01, "Reactor Core Isolation Cooling Operability"
- (3) CPS 9000.06D001, "Heat up/Cooldown, Inservice Leak and Hydrostatic Testing 30-minute Temperature Log," on October 24, 2021
- (5) Work Order 5199265-01, "Standby Liquid Control System Operability"
Inservice Testing (IP Section 03.01) (1 Sample)
- (1) CPS 9059.01, "Reactor Pressure Test," on October 24, 2021
RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)
- (1) CPS 4001.01, "Reactor Coolant System Leakage," on December 31, 2021
Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)
- (1) Work Order 4989131-01 and Work Order 5003082-01 "LRT RHR [residual heat removal] SDC [shutdown cooling] Common Suction"
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)
(1)emergency preparedness drill on November 4,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated instructions to workers including radiation work permits used to access high radiation areas and labeling of radioactive material in containers.
Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)
The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:
- (1) Observed workers exiting the radiologically controlled area (RCA) and licensee surveys of potentially contaminated material leaving the radiologically controlled area RCA at the main control point during the Unit 1 refueling outage.
- (2) Observed workers exiting the RCA and licensee surveys of potentially contaminated material leaving the RCA at the east service building control point during the Unit 1 refueling outage.
Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)
The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities.
- (1) CL-1-21-00601; C1R20 Outage Reactor Water Cleanup Area Activities
- (2) CL-1-21-00518; C1R20 Drywell Bioshield In-Service Inspection (ISI) Activities
- (3) CL-1-21-00513; Drywell Control Rod Drive Exchange Activities High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (2 Samples)
The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:
- (1) Unit 1 drywell entrance
- (2) Unit 1 reactor water cleanup pump room Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
- (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.
71124.02 - Occupational ALARA Planning and Controls
Implementation of ALARA and Radiological Work Controls (IP Section 03.03) (3 Samples)
The inspectors reviewed as low as reasonably achievable practices and radiological work controls for the following activities:
- (1) C1R20 Outage Reactor Water Cleanup Area Activities; Radiation Work Permit (RWP)
CL-1-21-00601
- (2) C1R20 Drywell Bioshield In-Service Inspection Activities; RWP CL-1-21-00518
- (3) Drywell Control Rod Drive Exchange Activities; RWP CL-1-21-00513
Radiation Worker Performance (IP Section 03.04) (1 Sample)
(1)control rod drive exchange activities
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10)===
- (1) July 1, 2020 through September 30, 2021
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) April 1, 2020 through September 30, 2021 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) July 1, 2020 through September 30, 2021
71152 - Problem Identification and Resolution (PI&R)
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the licensees corrective action program (CAP) for potential adverse trends in the shutdown risk management program that might be indicative of a more significant safety issue.
Annual Follow-Up of Selected Issues (IP Section 02.03) (3 Samples)
The inspectors reviewed the licensees implementation of its CAP related to the following issues:
(1)reactor coolant sulfate increased following downpower (2)reactor core isolation cooling motor-operated valve failures (3)emergency reserve auxiliary transformer static volts-reactive (VAR) compensator elimination modification
71153 - Follow-Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensee event reports (LERs):
- (1) LER 05000461/2021-002-00, Core Alterations with Source Range Monitor Inoperable Results in Condition Prohibited by Technical Specifications (ADAMS Accession No. ML22010A207)
The inspection conclusions associated with this LER are documented in this report under Inspection Results Section 71153.
Personnel Performance (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated fuel handling and damaged bundle on October 10, 2021.
The inspection conclusions associated with this inspection are documented in this report under Inspection Results Section
INSPECTION RESULTS
Observation: Reactor Core Isolation Cooling Valve Issues 71152 The inspectors observed that the reactor core isolation cooling (RCIC) system experienced several issues related to motor-operated valves (MOVs) over the previous year. This included the failure of containment isolation valve 1E51-F077 to operate due to torque switch and thermal overload issues, failure of control power fuses for containment isolation valve 1E51-F064 and cycling of minimum flow valve 1E51-F019. None of the issues caused the RCIC system to become inoperable; however, the issues together could indicate a lowering of the reliability of the components within the RCIC system. The inspectors did not identify any violations of NRC requirements.
Observation: Emergency Reserve Auxiliary Transformer Static Var Compensator Elimination Mod Issues 71152 The inspectors observed the issues associated with the emergency reserve auxiliary transformer (ERAT) leading up to, during, and after a significant modification from a static volts reactive compensator to an automatic load tap changer. Initially scheduled as pressing and imminent maintenance effort using the risk informed completion time process in July, change issues with the work order and subsequently with parts extended the short-term solution work with the actual limiting condition for operation for implementing the Technical Specification (TS) on August 28, 2021. Operations declared the ERAT operable on September 1, 2021. The inspectors tracked the movement of the modification over a 2-month period. Each addition and change of scheduled work had an impact on other planned maintenance during those work weeks. The inspectors reviewed over a dozen CAP entries and their corrective actions taken related to the planning and execution of this modification.
The inspectors provided the observations regarding impact on scheduled work and determined that the corrective actions taken were adequate. The inspectors did not identify any violations of NRC requirements.
Observation: Potential Adverse Trends in Implementation of the Licensees Shutdown Risk Management Program 71152 The inspectors reviewed the licensees CAP over the previous year for potential adverse trends in the implementation of the licensees shutdown risk management program. Several key safety functions were noted to be insufficient for risk informing the regulator's inspection samples. The first example was the electrical power key safety function was based on the number of grid sources and not the number of available safety-related electrical buses. Only two of the three primary safety buses were available with four offsite grid sources, but the unavailable source deenergized an entire division of ECCS. The shutdown for the electrical key safety function risk was identified as Green. The second example was the reactivity control key safety function for monitoring identified three of the four source range monitors was identified as Green for this key safety function. In the unmonitored quadrant, core alterations are prohibited by TS or maximum risk. The inspectors did not identify any violations of NRC requirements in the shutdown risk program but did communicate the key safety function areas that were lacking for regulatory practice.
Observation: Reactor Coolant Sulfate Increase Following Plant Downpower Issues 71152 The inspectors reviewed the licensees CAP over the previous year for potential adverse trends in reactor coolant sulfate increases following plant downpowers. The inspectors found the condensate polisher system operational changes and reduction of component flow rates and differential pressure, combined with the modification of the vessel resin trap internals have demonstrated appropriate actions for the conditions identified. Subsequent component inspection and chemistry analysis have also demonstrated the effectiveness of these efforts.
The inspectors have determined the corrective actions taken were timely and appropriate for the conditions identified.
Damaged Fuel Bundle During Core Alterations Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green FIN 05000461/2021004-01 Open/Closed
[H.5] - Work Management 71153 A self-revealed Green finding was identified when the licensee failed to adhere to the core alterations instruction provided by Clinton Power Station (CPS) 3703.01, "Core Alterations."
Specifically, the licensee failed to use manual (slow speed) when lowering a fuel bundle on the core edge past the steam dam per precaution 4.32 and ultimately contacted the steam dam and damaged the fuel bundle handle.
Description:
On October 10, 2021, CPS was in Mode 5 with core alterations in progress. During C1R20 fuel moves, Clinton Fuel Assembly YLT173, which is an edge fuel bundle, contacted the steam dam (the circumferential support ledge) during the attempted loading of the edge fuel bundle loading into the reactor core and contacted it again on the recoil. No indication of clad failure through visual or gaseous release was immediately identified, and the damaged edge fuel bundle was placed in the emergency set-down location. Core alterations were suspended, and an event stand-down was held. During the event recovery, the destined edge fuel bundle was placed in the fuel inspection stand for visual inspection and then returned to the upper storage pool. No indication of damage was identified beyond a bent bail handle on the assembly. In this instance, contact with the steam dam caused the bundle to tilt and exert horizontal force on the bundle bail handle causing deformation. The steam dam was inspected and found to have minor scuffing at the impact location. A different twice-burned fuel bundle was selected from the spent fuel to replace the damaged bundle and was placed into the edge core position. The stations Nuclear Fuels group provided a transmittal of design information dated October 11, 2021, dispositioning Clinton Fuel Assembly YLT173. It stated that during C1R20 fuel moves, bundle YLT173 made inadvertent contact with the steam dam (core shroud), as documented in Action Request 4452166. After the inadvertent contact, the bail handle for this bundle was observed to be bent. Video footage of the fuel bundle contacting the steam dam was also reviewed. The Fuel Reliability group reviewed the information available and discussed it with the fuel vendor (GNF). The conclusion was to not use YLT173 in any fuel cycles due to potential damage or susceptibility to future damage. The bundle may be discharged to the spent fuel pool; bent bail handles may cause an issue with grappling/releasing the bundle during fuel moves but that dry cask storage suitability should not be impacted. The inspectors were offsite but immediately notified upon their arrival early that morning and prior to recommencing core alterations. CPS 3703.01, "Core Alterations," has several precautions regarding the placement controls regarding edge bundle locations. Specifically, the licensee must use manual (slow speed)when lowering a fuel bundle on the core edge past the steam dam to prevent damaging any part of the fuel bundle or bail handle. The immediate investigation by the licensee determined that the operator had failed to change the mode from automatic to slow prior to operating the controls while positioning the edge fuel bundle.
Corrective Actions: Immediate corrective actions included suspension of core alterations and required notifications. No indication of clad failure through visual or gaseous release was immediately identified. A stand-down was held for all crews on the events. The damaged bundle was placed in the fuel inspection stand and then returned to the upper storage pool following a visual inspection. All crews were required to use manual for any peripheral locations as noted on the core alteration move sheets. All crews were directed to have the fuel assembly biased towards the center of the core and jogged over to its final location once above the top guide plate. All crews were directed to announce when the bridge is being placed in auto. Targeted observations were performed on these actions for the peripheral moves in the southwest core quadrant. A different twice-burned bundle was selected from the spent fuel to be placed into that edge core location. Related Action Request 4452331 was generated for recommendations on bridge software modifications to eliminate the potential for automatic operation near the edge/peripheral locations. A process for manual operation to core edge locations has been implemented to prevent bundle travel near the top of the steam dam.
Corrective Action References: Action Request 4451809, "F15 Main Grapple (Unloaded)
Contacted LPCS [low pressure core spray system] Sparger" Action Request 4452166, "Fuel Bundle Inadvertent Contact with Steam Dam" Action Request 4452331, "Remap Data Base on F15"
Performance Assessment:
Performance Deficiency: Refueling outage reactivity management, that is the systematic and philosophical direction given to controlling evolutions with the potential to affect the reactivity and/or integrity of nuclear fuel, was insufficient to prevent damaging an edge destined fuel bundle during core alterations as identified in multiple CPS 3703.01, "Core Alterations,"
precautions 4.24, 4.32, and 4.33.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events.
The inspectors compared the issue to the examples and guidance in IMC 0612, Appendix E, Examples of Minor Issues. Though no specific example matched, the question of, "Is the performance deficiency associated with one of the cornerstone attributes listed at the end of this attachment and did the performance deficiency adversely affect the associated cornerstone objective" was answered "yes." The barrier integrity cornerstones areas to measure (to maintain functionality of fuel cladding) attribute of human performance procedure adherence was impacted.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Per IMC 0609, Attachment 4, Table 3, question A, the finding related to fuel handling issues, which then directs the process to IMC 0609, Appendix A. Per IMC 0609, Appendix A, Exhibit 3, Barrier Integrity Screening question 4, the finding resulted from fuel handling errors, but was evaluated to not challenge fuel cladding integrity or result in a release of radionuclides. The question screened the finding as Green.
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. This fuel handling issue occurred 7 days after the October 3, 2021, core alterations in an unmonitored quadrant fuel handling issue and 2 days after the fuel handling issue where bridge main grapple came into contact with the low-pressure core spray sparger. OP-AA-300, "Reactivity Management," directs planned reactivity changes to be conducted in a controlled and conservative manner. "Core Alterations," CPS 3703.01, step 4.24 states, When lowering a fuel bundle into a target location, use a slow speed to prevent damaging a fuel bundle, bail handle, or blade guide if contact is made with the target bundle"; step 4.25 states, Because of close design tolerances of the fuel and channels never apply excess force which might bend, break, distort, or in any way damage any part of a fuel bundle or channel"; step 4.32 states, On the periphery of the reactor vessel it is possible for the grapple or suspended items to contact the Steam Dam. DO NOT use AUTO when lowering a fuel bundle or the grapple on the core edge past the steam dam"; and step 4.33 states, While moving fuel on the periphery for core-to-core moves, DO NOT use AUTO because of the risk of the fuel or suspended items swinging laterally into the Steam Dam due to the speed that AUTO operations moves the main mast. Given the event precursors and existing procedural precautions, the planning, controlling, and executing work activity processes were inadequate to prevent this human performance event from occurring.
Enforcement:
Inspectors did not identify a violation of regulatory requirements associated with this finding.
Core Alterations in Unmonitored Quadrant Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000461/2021004-02 Open/Closed
[H.5] - Work Management 71153 A self-revealed Green finding and associated non-cited violation (NCV) of TS 3.3.1.2, "Source Range Monitor Instrumentation," was identified when the licensee failed to suspend core alterations with a required source range monitor (SRM) inoperable in Mode 5.
Specifically, two fuel bundles were loaded into the reactor core with the quadrant's source range monitor inoperable.
Description:
On October 3, 2021, CPS was in Mode 5 with core alterations in progress. CPS TS 3.3.1.2, "Instrumentation - Source Range Monitor (SRM) Instrumentation," requires an SRM in the reactor core quadrant and an adjacent quadrant be operable during core alterations within the quadrant. The northwest reactor core quadrant was monitored by SRM 'A'. SRM A was inoperable and shutdown reactivity key safety function of reactivity control remained Green as the total number of operable SRMs was three out of four. On move 6 and 7 of F11 Recovery Plan, two fuel bundles were placed into the northwest reactor core quadrant. Prior to completing move 7, the reactor operator at the controls realized the quadrant was not monitored and informed the control room supervisor and fuel handling supervisor. Limiting Condition for Operation (LCO) 3.3.1.2 - Action E.1, "Immediately Suspend Core Alterations Except Control Rod Insertion," and LCO 3.3.1.2 - Action E.2, "Immediately Initiate Action to Fully Insert All Insertable Control Rods in Cells Containing One or More Fuel Assemblies,"
were immediately initiated and completed. These actions met LCO 3.3.1.2. The unmonitored core alterations were evaluated for shutdown margin per CPS 9811.01 (Work Order 4995999-01). The inspectors were onsite and immediately notified. The inspectors verified the LCO actions were completed.
Corrective Actions: Immediate corrective actions included suspension of core alterations and verification that all insertable control rods in cells containing one or more fuel assemblies were fully inserted. As noted above, the core alterations were evaluated for Shutdown Margin in accordance with CPS Procedure 9811.01, "Shutdown Margin Determination," and were determined to be part of the planned and analyzed sequence for the refuel shuffle within the northwest core quadrant. After evaluating the impact, Step 7 of F11 Recovery Plan was completed by releasing the second fuel bundle from the grapple in its correct destined position within the reactor core. Additional interim actions included adding quadrant information to the fuel move sheets, adding SRM status to fuel handling turnover sheet, and fixing the access database program used by operations to track fuel movements locally from the bridge. Additional corrective actions will be provided in a supplemental LER as appropriate and upon completion of the root cause investigation Action Request 4450450 scheduled for completion by February 28, 2022.
Corrective Action References: Action Request 4450450, "Fuel Bundle Placed in NW Quadrant with SRM 'A' Inop"
Performance Assessment:
Performance Deficiency: Refueling outage reactivity management, that is the systematic and philosophical direction given to controlling evolutions with the potential to affect the reactivity and/or integrity of nuclear fuel, as required by CPS OP-AA-300-1520, "Reactivity Management-Fuel Handling, Storage and Refueling," was insufficient to prevent the license basis violation of handling and loading nuclear fuel bundles into an unmonitored quadrant of the reactor core.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. The inspectors compared the issue to the examples and guidance in IMC 0612, Appendix E, Examples of Minor Issues. Though no specific example matched, the question of, "Is the performance deficiency associated with one of the cornerstone attributes listed at the end of this attachment and did the performance deficiency adversely affect the associated cornerstone objective," was answered "yes." The barrier integrity cornerstones areas to measure (to maintain functionality of fuel cladding) attribute of human performance procedure adherence was impacted.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Per IMC 0609, 4, Table 3, question A, the finding related to fuel handling issues, which then directs the process to IMC 0609, Appendix A. Per IMC 0609, Appendix A, Exhibit 3, Barrier Integrity Screening question 4, the finding resulted from fuel handling errors, but was evaluated to not challenge fuel cladding integrity or result in a release of radionuclides. The question screened the finding as Green.
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Of note and at the time of this issue, the inspectors were working on an issue of concern regarding control of reactor core alterations and control room monitoring. The Reactivity Management process, OP-AA-300, requires, All deliberate reactivity changes are planned and conducted in a controlled conservative manner. "Core Alterations," CPS 3703.01, step 6.8 states, The Main Control Room shall be informed when fuel bundles are inserted or removed from the core, and step 6.9 states, The Reactor Operator shall observe the Source Range Monitors (SRMs) for increasing count rate and possible inadvertent criticality during CORE ALTERATIONS and especially during fuel insertion. During the initial core alterations of the refueling outage, the inspectors observed behavior that was refuel bridge to control room communications occurring at the beginning and completion of the moves. No notifications were noted regarding the specific movement of bundles into and out of the core, which are those that would add and remove reactivity. The inspectors noted a general monitoring of all operable SRMs but not a specific response of the core quadrant affected SRM. These observations were provided to operations and management prior to this issue. The CPS C1R20 Shutdown Safety Management Program identified the SRM 'A' inoperability and determined no change of risk to the key safety function of reactivity control. The resultant Green risk condition was accompanied by the statement, The refueling shuffle has been built around the SRM 'A' out of service time to ensure that no fuel moves occur in the 'A' quadrant during this time. However, fuel bundle move 6 and 7 of F11 Recovery Plan scheduled fuel bundle moves into the quadrant with the inoperable SRM. Overall, reactivity management had performance deficiencies in various stages of the work management process. The decision to move fuel with an inoperable SRM and the risks associated with it were inadequately addressed and controls not established to prevent this event.
Enforcement:
Violation: CPS TS 3.3.1.2, Instrumentation - Source Range Monitor (SRM) Instrumentation, requires an SRM in the reactor core quadrant and an adjacent quadrant be operable during core alterations within the quadrant. Contrary to the above, on October 3, 2021, the licensee performed two core alterations within the affected reactor core quadrant with an inoperable SRM instrument.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On January 13, 2022, the inspectors presented the integrated inspection results to Mr. T. Chalmers, Site Vice President, and other members of the licensee staff.
On October 8, 2021, the inspectors presented the radiation protection inspection results to Mr. T. Chalmers, Site Vice President, and other members of the licensee staff.
On October 8, 2021, the inspectors presented the in-service inspection results to Mr. T Chalmers, Site Vice President, and other members of the licensee staff.
On November 24, 2021, the inspectors presented the biennial licensed operator requalification inspection results to Mr. G. Engelhardt, Organizational & Effectiveness Director, and other members of the licensee staff.
On December 13, 2021, the inspectors presented the review of the licensed operator requalification program annual summary inspection results to Mr. J. Nelson, Licensed Operator Requalification Training Lead Instructor, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
Certification of
22 Winter
Readiness
Certification of 2022 Winter Readiness
11/15/2021
9080.21E001
DG 1A ECCS Initial Electrical Lineup
24b
Procedures
9080.22E001
DG 1B ECCS Initial Electrical Lineup
Fire Plans
1893.04M200
23-778 Drywell: Prefire Plan
UT Pipe Wall Thinning at Elbow of Pipe 1SX21AA
09/20/2019
Small Coolant Leak Found on Division 1 Diesel Generator
2/19/2019
Evaluate Safety Related (but Not ASME Sec III) Bolting
01/10/2020
C1R20 ISI Contingency Repair/Replacement/Hanger
Adjustments
2/02/2020
VT-3 Identified a Loose Nut On 1H101C(A)
09/29/2021
Corrective Action
Documents
C1R20 - Hangers Setting not Meeting the Acceptance
Criteria
11/04/2021
Miscellaneous
Requalification
Program Annual
Testing Summary
Results
Licensed Operator Annual Examination Performance
Records for 2021
2/09/2021
ILT Exam Bank Questions Migrated to 2019 LORT Open
Exam Bank
2/19/2019
ILT Weekly Review Exam Compromise
03/16/2021
Clinton Training Elevation - Exam Security and ILT
Throughput
03/22/2021
Corrective Action
Documents
for IR 4409255
IR Subject: ILT Weekly Review Exam Compromise
04/21/2021
Corrective Action
Documents
Resulting from
NRC Question During 71111.11 Inspection on Potential
Coaching in Regard to Recognizing Conditions Requiring a
Review of Technical Specifications
11/19/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
NRC Question During 71111.11 Inspection on Simulator
Core Modeling and Testing Procedures
11/19/2021
Inspection
NRC Identified Discrepancy on License Tracking Log
11/19/2021
Simulator Core
Performance
Testing
BWR Critical Conditions for Cold Startup
04/30/2020
Simulator Core
Performance
Testing
BWR Power Coefficient of Reactivity and Control Rod Worth
04/30/2020
Simulator Core
Performance
Testing
04/30/2020
Simulator Core
Performance
Testing
Reactivity Anomaly Test
04/30/2020
Simulator Core
Performance
Testing
BWR Shutdown Margin Determination
04/30/2020
0133047: OPEX: RCIC Will Not Trip on Overspeed
01/15/2019
Alternate Boron Injection Using RCIC
03/19/2019
Post Event Analysis of 8-2-19 Reactor SCRAM
11/05/2019
1VQ003 Valve Does Not Shut on a LOCA Signal (Hi DW
Pressure or RPV Level 2)
06/16/2020
5063 - LPCS Injection Valve E21-F005 OPEN Position Does
Not Work Sometimes
11/30/2020
SLC Switch 'A' Not Clearing Switch Check
2/03/2021
5002-1M Annunciator Should Come in On FW004
Movement
03/04/2021
1B21-F028A Doesnt Work in the Close Test Position
03/04/2021
DFW Issue with Automatic POST SCRAM Actions
03/31/2021
DFW Issue with Level Control Post Blowdown
03/31/2021
SLC Switch 'B' Doesnt Pass Switch Check
05/11/2021
New Remote to Test EHC Pump
06/09/2021
Miscellaneous
HPCS Level 2 Initiation/Actuations
06/10/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
SM004 and Suppression Pool Level
07/14/2021
EC 632262 - MEOD2.0 Change to Power to Flow Map
08/03/2021
Several Hardware Issues Need Addressed
08/30/2021
Div 2 DC Voltmeter Low
09/01/2021
Back Leakage into RHR is Cold Water
09/08/2021
TQ-AA-224-F100
Remedial Training Notification and Action on Failure - RO
2/10/2019
TQ-AA-224-F100
Remedial Training Notification and Action on Failure - SRO
2/10/2019
TQ-AA-224-F100
Remedial Training Notification and Action on Failure - RO
11/21/2019
Operator Training Programs
Conduct of Simulator Training and Evaluation
TQ-AA-155-F108
Simulator Evaluation - Individual Competency Standards
004
Examination Security and Administration
Exelon Nuclear Training - Implementation Phase
TQ-AA-224-F100
Remedial Training Notification and Action on Failure
Procedures
Simulator Management
Self-Assessments AR 4379813
Pre-NRC 71111.11 Inspection Licensed Operator
Requalification Training Assessment Obj 4 Update ONLY
11/04/2021
Corrective Action
Documents
Loss of AC Result in Loss of Shut Down Cooling Systems
10/09/2021
Engineering
Changes
ERAT SVC Long Term Abandonment
1LP117A/17B: Replace Defective Sections of Piping
10/13/2021
Work Orders
1E51-F013 Will Not Stroke Electrically
10/26/2021
Procedures
C1R20 Shutdown
Safety
C1R20 Shutdown Safety Management Program
09/20/2021
1SX011A Not Stroked per WO 4964708-01
09/12/2021
ERAT Transformer Breaker 8M 0AP164EH Will Not Stay
Closed
10/10/2021
Corrective Action
Documents
1SX011A LRT Was Not Performed in Accordance with IST
Code
10/15/2021
Engineering
Evaluations
006N3212
Clinton Power Station Maximum Extended Operating
Domain Expansion (MEOD2.0)
Work Orders
DIV 1 DG UV Relay CV-2 Replacement - EC 625049
10/14/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
Resulting from
Inspection
1FX01KB B/U Flex Generator Fail to Start: Low Fuel
Pressure
11/13/2021
Replace Defective Sections of Piping
10/12/2021
10/17/2021
FLEX - 1FX01KB DG Performance Test
2/08/2021
SLC Pump 'A' Operability
2/22/2021
Work Orders
Replace and Calibrate Pressure Regulator Amplifier
10/28/2021
CPS 4001.01
Reactor Coolant Leakage
2c
9000.06D001
Heat up/Cooldown, Inservice Leak and Hydrostatic Testing
30-Minute Temperature Log
30b
CPS 9059.01
Reactor Pressure Test on October 24, 2021
2d
Procedures
CPS 9080.21
Diesel Generator 1A - ECCS Integrated
35e
DG 1A Integrated Test
10/12/2021
9843.01V06 LRT *CAT 'A' VLV LRT(1E12-F008) RHR SDC
SUC
10/14/2021
LRT CAT 'A' VLV LRT RHR SDC SUC
10/14/2021
Work Orders
9861.09B20 LRT *SX Boundary Valve Leak Testing
(1SX014B)
10/14/2021
Miscellaneous
Alpha Area Level Assessment
2/17/2020
CL-1-21-00513
Drywell Control Rod Drive Exchange Activities
CL-1-21-00518
C1R20 Drywell Bioshield In-Service Inspection Activities
Radiation Work
Permits (RWPs)
CL-1-21-00601
C1R20 Outage Reactor Water Cleanup Area Activities
CL-1-21-00513
Drywell Control Rod Drive Exchange Activities
CL-1-21-00518
C1R20 Drywell Bioshield In-Service Inspection Activities
ALARA Plans
CL-1-21-00601
C1R20 Outage Reactor Water Cleanup Area Activities
RWCU INF
Primary Chemistry Spreadsheet
Multiple
71151
Miscellaneous
A
Radiation Protection Performance Indicator Information
April 2020
through
September
21
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
1AP74E8C - F01 Blown Control Power Fuse on 1E51-F064
03/23/2021
RCS Reactor Sulfates Greater Than Action Level 2
03/04/2021
Lessons Learned from ERAT SVC Elimination Mod
Installation
09/29/2021
1E51-F077 Expanded Scope
09/30/2021
Corrective Action
Documents
RCIC Min Flow Valve Cycling During Low Pressure Test
10/26/2021