IR 05000461/2021012
| ML21179C287 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 06/28/2021 |
| From: | Kenneth Riemer Division Reactor Projects III |
| To: | Rhoades D Exelon Generation Co, Exelon Nuclear |
| References | |
| EPID I-2021-012-0015 IR 2021012 | |
| Download: ML21179C287 (16) | |
Text
June 28, 2021
SUBJECT:
CLINTON POWER STATION - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000461/2021012
Dear Mr. Rhoades:
On May 21, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your 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.
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews, the team found no evidence of challenges to your organizations safety-conscious work environment.
Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
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-2021-012-0015
Licensee:
Exelon Generation Company, LLC
Facility:
Clinton Power Station
Location:
Clinton, IL
Inspection Dates:
May 03, 2021 to May 21, 2021
Inspectors:
J. Kutlesa, Physical Security Inspector
V. Meghani, Reactor Inspector
R. Ng, Project 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 a biennial problem identification and resolution 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.
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 Disease (COVID-19), regional inspectors were directed to begin telework. During this time regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. In some cases, portions of an IP were completed remotely and on-site.
The inspection documented below was determined that the objectives and requirements stated in the IP could be completed remotely.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)
- (1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.
- Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a 5-year review on shutdown service water piping leakage and FLEX related issues. Note that the inspectors did not review the corrective actions related to a White NOV in the Security cornerstone since the Inspection Procedure 95001 Supplemental Inspection has not been completed.
- Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits, and self-assessments.
- Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B Based on the samples reviewed, the team concluded that the licensee's implementation of the Corrective Action Program was generally effective and supported nuclear safety.
Effectiveness of Problem Identification:
Based on the samples reviewed, the team concluded that the licensee continued to identify issues at a low threshold and appropriately entered these issues into the Corrective Action Program. The team determined that the licensee usually entered problems into the Corrective Action Program completely and accurately. However, the team identified a condition adverse to quality that should have been entered into the Corrective Action Program for resolution. Additional details of this issue are discussed in the Minor Violation section of this report.
The team also noted that some deficiencies were identified by external organizations, including the NRC, that had not been previously identified by licensee staff and were subsequently entered into the Corrective Action Program. In addition, the licensee also utilized a number of Corrective Action Program support processes to identify problems, including the self-assessment and audit process and the Operating Experience Program. For example, the licensee performed department self-assessments and quality assurance audits to identify issues in station processes. Similarly, the licensee screened issues from both NRC and industry operating experience and entered them into the Corrective Action Program when they were applicable to the station.
The team determined that the licensee was generally effective at trending low-level issues and taking appropriate corrective actions to prevent more significant problems from developing. In addition, the licensee used the Corrective Action Program to document instances in which previous corrective actions were ineffective or were inappropriately closed.
The team performed a 5-year review of the shutdown service water piping leakage issues.
As part of this review, the team interviewed the system engineer, reviewed the plant health report, and reviewed selected corrective actions and condition evaluation documents. In addition, the team performed a partial system walkdown to assess the material condition of the system piping and surrounding areas. The team concluded that the shutdown service water system piping degradation and leakage concerns were identified and entered into the Corrective Action Program at a low threshold and were resolved in a timely manner commensurate with their safety significance. For the areas walked down, the team did not identify any additional issues.
Effectiveness of Prioritization and Evaluation of Issues:
Based on the samples reviewed, the team determined that licensee performance was generally effective at prioritizing and evaluating issues commensurate with the safety significance of the identified problem. The Ownership Screening Committee and the Management Review Committee meetings were generally thorough and intrusive in reviewing issues and prioritizing actions. In addition, the team observed a productive dialogue between the members of these committees and the members challenged each other when dispositioning issues.
In general, once a degraded or non-conforming condition was identified, the Corrective Action Program directed that an equipment operability or functionality review be performed. As a result, the majority of the samples reviewed were evaluated in a timely manner.
Effectiveness of Corrective Actions:
Based on the samples reviewed, the team determined that the licensee was generally effective in corrective action implementation. In general, corrective actions for deficiencies that were safety significant were implemented in a timely manner. Problems identified using a root cause or other cause methodologies were resolved in accordance with Corrective Action Program requirements. The corrective actions assignments that were sampled by the team for selected NRC documented violations and for licensee event reports (LERs) were generally effective and timely.
The team performed a 5-year review of the stations diverse and flexible coping strategies (FLEX). As part of this review, the team reviewed corrective action documents, the plant health report, the licensee's responses to various industry operating experiences and previously identified NRC findings related to FLEX. In addition, the team performed a partial system walkdown to assess the material condition and proper storage and staging of FLEX equipment. The team concluded that FLEX system deficiencies were identified and entered into the Corrective Action Program at a low threshold and were generally resolved in a timely manner commensurate with their safety significance. The inspectors did not identify any violations of NRC requirements.
Assessment 71152B Based on the samples reviewed, the team determined that licensee's performance in the use of operating experience was generally effective. The licensee's corporate office screened industry and NRC operating experience information for applicability to Clinton Power Station.
Based on these initial screenings, the licensee-initiated actions in the Corrective Action Program to fully evaluate the impact, if any, to the station. When applicable, actions were developed and implemented to prevent similar issues from occurring. Operating experience lessons learned were communicated and incorporated into plant operations. The team observed the information being used in daily activities, such as pre-job briefs, as well as issue reviews and investigations.
Assessment 71152B Based on the samples reviewed, the team determined that the licensee's performance of self-assessments and audits was generally effective. The licensee performed department self-assessments and quality assurance audits throughout the organization on a periodic basis. These self-assessments and audits were generally effective at identifying issues and enhancement opportunities at an appropriate threshold. The self-assessments and audits reviewed by the team identified issues that were not previously known, including issues within the Corrective Action Program itself. Nuclear Oversight (NOS) identified deficiencies with the licensee's processes and those issues were addressed by the station through the Corrective Action Program.
Assessment 71152B Based on a review of documents and interviews with licensee staff, the team did not identify any impediment to the establishment of a safety conscious work environment. The team reviewed the results from the 2020 Safety Culture Assessment, the culture survey from first quarter of 2021 performed by the licensee, and the Nuclear Safety Culture Monitoring Panel meeting minutes. The team also conducted one-on-one interviews with 20 licensee staff concerning the effectiveness of the Corrective Action Program, the ability to raise issues, and the freedom from potential retaliation for raising issues.
In general, the licensee's staff was aware of and familiar with the Corrective Action Program and other processes, such as the Employee Concerns Program, to raise nuclear safety concerns. Licensee staff indicated they could raise safety concerns without a fear of retaliation. Through the interviews and document reviews, the team was not provided or identified any examples of retaliation for raising nuclear safety concerns. The staff interviewed believed that operational issues and issues with high safety significance were being appropriately addressed in a timely manner.
Minor Violation 71152B Minor Violation: In 2019, the licensee added a section in Procedure 3309.01, High Pressure Core Spray (HPCS), to maintain HPCS availability using the recycle condensate system should the waterleg pump not be available to keep the system full of water. This portion of the procedure would direct the operators to open the isolation valves between the two systems and use the recycle condensate system to fill and vent the HPCS system. In June of 2019, an operator identified the potential of over-pressurizing the recycle condensate system if HPCS auto starts during this activity because the low pressure recycle condensate system would be opened to the high-pressure HCPS system. The issue was screened as a non-corrective action program (NCAP) item and not resolved or evaluated until the inspectors reviewed this issue during this inspection.
When questioned by the inspectors about the consequences of the over-pressurization, the licensee stated that it could cause piping failure or leakage in the recycle condensate system.
In addition, it would also divert the needed HPCS injection to the recycle condensate system.
The licensee did not have a formal engineering evaluation of the potential consequences.
The licensee agreed that this issue is a condition adverse to quality and should have screened as a corrective action program item. The licensee has issued a Daily Order to suspend the use of this section of the procedure.
Since the revision of the procedure in 2019, the licensee has not executed this section of the procedure. Given the isolation valves between the two systems was a safety related class 2 piping and an operator would be present and in communication with the main control room during this activity, the inspectors determined that the operator could close the isolation valves promptly even if HPCS auto starts and damage occurs in the recycle condensate system.
The inspectors determined that the failure to identify a condition adverse to quality and promptly correct the condition is a performance deficiency and a violation of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Actions."
Screening: The inspectors determined the performance deficiency was minor. The inspectors determined that this issue is minor because this issue is similar to IMC 0612, Appendix E, Example 4.g. This performance deficiencies did not adversely affect the mitigating systems cornerstone objective because this is a failure to identify the issue and implement a corrective action that had little safety impact. This activity has never been performed since the procedure revision and the isolation valves were accessible and could be closed to recover the HPCS system by the operator standing by in the area during the activity.
Enforcement:
This failure to comply with 10 CFR 50, Appendix B, Criterion V, "Corrective Actions," constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy. The licensee issued a Daily Order to prevent the utilization of that section of the procedure and entered the issue in their CAP as AR
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On May 21, 2021, the inspectors presented the biennial problem identification and resolution 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
3514.01C012 480V Unit Sub 1D Bus Outage Checklist
Impacts
2/01/2011
1PL12JA-A1: Re-Evaluate EDG Voltage Regulator R3
Replacement
2/20/2012
Protective Relay Tolerances Require Fleet Review
07/19/2012
Received Unexpected Annunciator 5050-5H, Trouble SGTS
Elect
08/22/2012
NRC Question MRFR for 1VX06CA / 1SX024A,
AR 1383458-03
01/09/2013
Maintenance ATV-Systematic Approach to Training - 2019
01/01/2020
Enhancement for Protective Relay Calculations
03/04/2013
Automatic Trip of Breaker 1PA07EJ
2/09/2013
1DC05E Has More Than Half of Cells Weeping
2/28/2014
Failure of the Outer/Upper Motor Bearing for 1SX01PC
09/16/2014
Enhancement Maintaining Valid Control Rod Position
09/17/2015
SX DIV 1 Supply Header Low Point Drain Leak
09/25/2015
UT Results On 1sx01ab-30" Are Near Code Allowable
Min-Wall
2/09/2015
UT Results On 1SX203AB-2"
2/15/2015
RWCU Isolation Due to Failed Temperature Instrument
01/10/2016
1FC004B Failed Stroke Time
01/04/2016
(2016 CDBI FASA) Calc 19-AJ-18 Weakness
04/14/2016
NRC Question on Operability of Div 1 SX During
Maintenance
07/21/2016
WO Required for Inspection of Weld Overlay on SX Piping
10/27/2016
WO Required for Inspection of Weld Overlay on SX Piping
10/27/2016
CDBI: Inappropriate Calculation Method for CR Habitability
11/17/2016
NRC NCV 2016003-04 Fail to Prevent Recurrence of a
11/22/2016
NRC NCV 2016009-02 SFP Temp and Level Not in MRULE
2/01/2017
Procedure Revisions for EC 618355, 1CO04J
03/21/2017
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
NRC Cited Violation for Design Control
04/21/2017
Error in Calc 3C10-0485-001 Associated with Flood Level
09/13/2017
Error in Calc 3C10-0485-001 Associated with Flood Level
09/13/2017
1SX019A Has Valve Erosion at The Lower Disc Pin Area
2/19/2018
Root Cause for NRC Div 3 SX Pump White Finding
03/01/2018
11AA: 2018 UT Results Lower Than Expected
04/12/2018
1SX111AA: 2018 UT Results Lower Than Expected
04/12/2018
1SXB5BA: 2018 UT Results Lower Than Expected
07/25/2018
ECAPE 4116223 Extent of Condition Work Orders Cancelled
08/24/2018
NRC INFO NOTICE 2018 Kobe Steel QA Falsification
09/26/2018
Mechanical Snubbers Removed Without EQ Review
10/19/2018
EP OE: Offsite Notification Due to Inadvertent Siren Activate
2/15/2019
NOS: EP ID: Evacuation Route Signs are Illegible
2/15/2019
EP ID: 2019 NRC Pre-Exercise - OSC Performance
2/20/2019
NRC IN 2019-01: Inadequate Evaluation of Temp Alterations
03/19/2019
05/13/2019
1AP07EK Main Feed Breaker Failed to Close During Bus
Shift
05/22/2019
NRC ID: Paragon Risk Incorrect
05/22/2019
EP ID: ERO Focus Area Drill Rescheduled
05/23/2019
Entered 4002.01, Abnormal RPV Level/Loss of FW at Power
05/24/2019
PCRA 3209.01 HPCS CY Float Start
06/10/2019
2SXA9AA: UT Results Lower Than Acceptance Criteria
06/21/2019
2SXA9AA: UT Results Lower Than Acceptance Criteria
06/21/2019
SEC ID: Complete Loss of Power to CAS and SAS
06/28/2019
EP ID: Trend IR: Multiple CPS Siren Failures
07/08/2019
Flex Diesel Generator Phase Rotation
07/11/2019
NRC NCV 2019040-01: Fail to Complete EFR for CAPR
08/02/2019
Root Cause Investigation Report; TDRFP B Turbine LVDT
Failure Results in an Automatic RPS SCRAM on RPV
Level 3
09/11/2019
NRC FIN 2019002-01 Fail Prop Eval Plant Risk
08/19/2019
NRC IN 2019-05: Overpressurization of Alpha Sources
09/06/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Arc Flash Event
09/11/2019
TDRFP B Scram Lessons Learned: LVDT/Torque Arm
Strategies
09/18/2019
EOID SRV 51B Actuates Instead of 41B
10/02/2019
1E22F015 HPCS Suction Valve Did Not Open During Valve
Stroke
10/10/2019
NRC IN 2019-08 OPEX Regarding FAC Causing RX Scrams
10/19/2018
Root Cause Report: FLEX Diesel Generator 1FX01KA
Incorrect Phase Rotation
11/15/2019
CAPE: Fire Protection System and Program Health
2/04/2019
SLC Pressure Regulator 1C41-F351 Reads Above Full Scale
01/03/2020
Contraband Introduced into the Protected Area (PA)
03/12/2020
EP-IEMA EMNET Phones Inoperable
01/24/2020
CAPE: Entered Loss of Feedwater Heating 4A Heater
Restoration
03/24/2020
CAPE: Personnel Entered Precautionary Posted HRA
Without HRA Brief
05/04/2020
NRC FIN 2020001-01 FLEX Diesel Generator Phase
Rotation
05/28/2020
CAPE: FLEX Diesel Generator Breaker Settings
06/26/2020
1SX29BB-3", Div II SX Strainer Backwash Pipe Replacement 08/19/2020
EP: Clinton 2020 Off-Year Exercise - TSC Issues
08/26/2020
NRC IN 2020-02 - Flex Diesel Operational Challenges
09/16/2020
NRC IN 2020-01 - Electr. Equip. Issues After COVID
Cleaning
09/18/2020
Need Procedure Revision on 9433.23 ECCS HPCS Pump
E22-N051
10/06/2020
NRC IN 2020-03 Recall of Edwards 135 Degree Heat
Detectors
11/09/2020
CAPE: 0VC21YB 0VC24YB & 0VC27YB Lost Power
11/16/2020
Sec AA/FFD Clinton Security Training Inst CG Requirements
Expired
2/15/2020
NRC IN 2020-04 - FP Mn Yard Buried Cast Iron Piping
Failures
2/23/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
NRC ID: Observation on 30-Day Observations of Remote
Workers
2/09/2021
NRC Green FIN 2020004-01 FLEX DG Settings for Output
Breakers
2/24/2021
0WM118B Through Wall Leak
03/11/2021
AR 455060455060Closure of B.5.B Phase 1 NRC Issues
2/17/2016
AR 916815916815RCIC Tripped During Startup
05/07/2009
Corrective Action
Documents
Resulting from
Inspection
PCRA PI-AA-125-1003
05/05/2021
PCRA for PI-AA-125-1001
05/05/2021
PI&R 2021: RCR 4269353 Missing CA for Contributing
Cause
05/06/2021
WO for Digital Feedwater Testing Not Supervisory Reviewed
06/06/2021
Response to CA 4284526-29 Not Robust
05/11/2021
Lesson Learned IR 4280147 Action Canceled in Error
05/12/2021
NRC ID: Operations S.O. for DHP Brkr List is Not Current
05/17/2021
Response to Action Under IR 4402535, Not Robust
05/18/2021
NRC ID: Action Cancellation Documentation
05/20/2021
NRC ID: IR Processed as NCAP in Error
05/20/2021
Actions for IR 2733400 Not Created
05/20/2021
Drawings
M05-1012 Sh. 2
P&ID Cycled Condensate (CY) (Turbine Building)
N
M05-1012 Sh. 6
P&ID Cycled Condensate (CY) (Aux. Fuel & Cont. Building)
X
M05-1074 Sh. 1
P&ID High Pressure Core Spray (HP)
AH
Engineering
Evaluations
CPS-1-2020-
262
DHP Breaker Risk Assessment
Miscellaneous
Operations Department Daily Order
05/17/2021
Nuclear Safety Culture Monitoring Panel Report
03/01/2021
Nuclear Safety Culture Survey #4
03/31/2021
2019-10
Unit 1 Standing Order - DHP Breaker Extent of Condition
Maintenance Rule System Basis Document - Fuel Pool
Cooling Functions
05/19/2021
FX-03
Maintenance Rule System Basis Document - Flex Spent Fuel
Pool Instruments
05/19/2021
PIAP 2019-0330
Performance Improvement Action Plan - Operations
06/15/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
3309.01
High Pressure Core Spray (HPCS)
18b
23.05
RCIC Steam Supply Turbine Governing Valve and Linkage
Maintenance (1E51F610)
0e
AD-40.01
Roles and Responsibilities
DBAI SA, EC 622677 Still at "Assigned" Status
2/12/2018
Employee Concerns Program
Employee Concerns Program Process
Safety Culture Monitoring
Issue Identification and Screening Process
Corrective Action Program (CAP) Procedure
Root Cause Analysis Manual
Corrective Action Program Evaluation Manual
Self-Assessments
Self-Assessments AR 1474231
Maintenance ATV-Systematic Approach to Training - 2019
01/01/2020
2018 Mid Cycle Org Effectiveness Survey Assessment
10/31/2018
2019 ALARA (Site Review)
2/31/2019
NOSA-CPS-19-05 Clinton Engineering Design Audit
05/22/2019
AR 4252830-02
SA Report - Exelon 10 CFR 50.59 Review Process
09/30/2019
20 Clinton Clearance and Tagging Self-Assessment
11/22/2020
NOSA-CPS-20-03 Clinton Station Emergency Preparedness
Audit
03/05/2020
AR 4338593-04
SA(EP) NRC Emergency Preparedness Program Inspection
08/21/2020
Preparation for NRC Problem Identification and Resolution
(PI&R) Inspection
03/11/2021
20 Clinton Safety Culture Assessment
03/19/2021
NOSA-COMP-19-
2019 Operations Comparative Audit Report
11/07/2019
NOSA-CPS-19-
Corrective Action Program Audit Report
03/01/2019
NOSA-CPS-19-
Radiation Protection Audit Report
07/24/2019
NOSA-CPS-20-
Maintenance Functional Area Audit Report
03/11/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
NOSA-CPS-20-
Security Programs Audit Report
2/26/2020
NOSA-CPS-20-
Fitness-for-Duty and Access Authorization Program Audit
Report
08/28/2020