IR 05000461/2022003
| ML22305A686 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 11/10/2022 |
| From: | Ruiz E NRC/RGN-III/DORS/RPB1 |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2022003 | |
| Download: ML22305A686 (1) | |
Text
SUBJECT:
CLINTON POWER STATION - INTEGRATED INSPECTION REPORT 05000461/2022003
Dear Mr. Rhoades:
On September 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Clinton Power Station. On October 20, 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.
November 10, 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, Robert Ruiz, Chief Reactor Projects Branch 1 Division of Operating Reactor Safety Docket No. 05000461 License No. NPF-62
Enclosure:
As stated
Inspection Report
Docket Number:
05000461
License Number:
Report Number:
Enterprise Identifier:
I-2022-003-0046
Licensee:
Constellation Nuclear
Facility:
Clinton Power Station
Location:
Clinton, IL
Inspection Dates:
July 01, 2022, to September 30, 2022
Inspectors:
J. Beavers, Senior Resident Inspector
S. Bell, Health Physicist
J. Cassidy, Senior Health Physicist
G. Hansen, Senior Emergency Preparedness Inspector
C. Mathews, Illinois Emergency Management Agency
A. Muneeruddin, Resident Inspector
Approved By:
Robert Ruiz, Chief
Reactor Projects Branch 1
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Clinton Power Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Perform Radioactive Effluent Sampling Required by the Offsite Dose Calculation Manual Cornerstone Significance Cross-Cutting Aspect Report Section Public Radiation Safety Green NCV 05000461/2022003-01 Open/Closed
[H.3] - Change Management 71124.06 An NRC-identified finding of very-low safety significance (Green) and associated non-cited violation (NCV) of Technical Specification (TS) 5.5.4(c) was identified concerning the licensees failure to have implementing procedures for the sampling and analysis of liquid radioactive effluents specified within the Offsite Dose Calculation Manual (ODCM).
Specifically, the ODCM (revision 24, January 2015) contained the requirement to sample and analyze the service water effluent for tritium (H-3), which the licensee failed to have procedures or to perform.
Protective Features of Emergency Reserve Auxiliary Transformer Not Fully Translated to Procedures and Training Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green FIN 05000461/2022003-02 Open/Closed
[H.3] - Change Management 71152A A self-revealed Green finding was identified when the licensee failed to completely translate the design protective features of the emergency reserve auxiliary transformer automatic load tap changer and manually switched capacitor bank. Specifically, the licensee failed to ensure the design change of emergency reserve auxiliary transformer automatic load tap changer and manually switched capacitor bank were completely translated into operating processes and training, which is contrary to CC-AA-10, Configuration Control Process Description, section 1.1, revision 10 that states, "Changes made to the plant and to the plant operations are accurately recorded in documents such as drawings and procedures. This process description establishes the framework for the interface of configuration control with other plant processes and identifies sub-tier processes."
Additional Tracking Items
None.
PLANT STATUS
Unit 1 began the inspection period at rated thermal power and 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 performed activities described in IMC 2515, Appendix D, Plant Status, 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.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)
'C' residual heat removal list system/train on September 6, 2022 (2)
'A' control room ventilation system/train on September 19, 2022 (3)division 1 shutdown service water system on September 19, 2022
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the standby gas treatment system on August 24, 2022.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Fire Zone CB-1(c)-1b, elevation 719', heating, ventilation, and air conditioning (HVAC) equipment area prefire plant on August 23, 2022
- (2) Fire Zone F-1(a,b,c,d,e,f,g,h,i,p), elevation 712', fuel building basement on September 1, 2022
- (3) Fire Zone F-1(j,k,m,n,o,p), elevation 737', fuel building grade level on September 6, 2022
- (4) Fire Zone F-1(p), elevation 755', fuel building fuel handling floor on September 9, 2022
- (5) Fire Zone M-1, elevation 699', screen house division 1 shutdown service water (SX)sump room on September 15, 2022
- (6) Fire Zone M-2(c), elevation 699', screen house general area on September 15, 2022
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 data validation and reconciliation implementation on August 24, 2022.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator requalification simulator training on July 19, 2022.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
(1)implementation of data validation reconciliation on August 24, 2022
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (2 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 (WO) 5139610, "Division 1 Diesel Generator System Outage Window"
- (2) WO 5138437, "Division 1 Shutdown Service Water System Outage Window"
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 (AR) 4509990, "1E51F026 RHR [residual heat removal] and RCIC [reactor core isolation cooling] Steam Supply Valve Second Drain Valve Found Closed"
- (2) AR 4512899, "Division 3 Shutdown Service Water Door Not Dogged"
- (3) AR 4516835, "Leak Downstream of 0SX009"
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)permanent modification and replacement of 'A' diesel driven fire pump
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:
- (1) WO 5274924-07, "Operations Post Maintenance Test for RCIC DC [direct current]
Load Driver P661-C-A14-A127 Replacement"
- (2) WO 5016222-11, "Operations Post Maintenance Test for 0FP01PA Replace Fire Pump 'A' EC 630948"
- (3) WO 5069616-07, "Operations Post Maintenance Test for 'A' Standby Gas Treatment Heater"
- (4) WO 5139610-02, "Operations Post Maintenance Test for Division 1 Diesel Generator"
- (5) WO 5072797-04, "Operations Post Maintenance Test 1SX008A Stroke/Verify Operation"
- (6) WO 5043178-13, "CMO 0Vc07SA Charcoal Analysis Review 9866.03" for 'A' Control Room HVAC"
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:
Surveillance Tests (other) (IP Section 03.01) (4 Samples)
(1)standby gas treatment system train flow heater operability on August 23, 2022 (2)shutdown service water pump 'C' operability on September 22, 2022 (3)shutdown service water pump 'A' operability on September 16, 2022 (4)emergency diesel 'A' override, load reject operability, and idle speed override on September 17, 2022
71114.02 - Alert and Notification System Testing
Inspection Review (IP Section 02.01-02.04) (1 Sample)
- (1) The inspectors evaluated the following maintenance and testing of the alert and notification system:
annual siren inspection and maintenance records for the period from April 2020 to July 2022
monthly alert notification system (siren) tests for the period from April 2020 to July 2022
71114.03 - Emergency Response Organization Staffing and Augmentation System
Inspection Review (IP Section 02.01-02.02) (1 Sample)
- (1) The inspectors evaluated the readiness of the emergency preparedness organization.
71114.05 - Maintenance of Emergency Preparedness
Inspection Review (IP Section 02.01 - 02.11) (1 Sample)
- (1) The inspectors evaluated the maintenance of the emergency preparedness program.
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated:
- (1) control room simulator facility drill on July 20,
RADIATION SAFETY
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (8 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:
(1)non-portable radiation monitoring instrumentation located at the radiologically controlled area exit at the 737' control building
- (2) JL Shepherd Model 89 instrumentation calibrator (3)ion chamber survey instruments available for use located in the calibration facility within the 737' control building (4)observed the response checking of a MGP Telepole WR radiation survey instrument (5)observed the response checking of the Eberline PM12 portal monitor located in the security exit facility (6)gamma spectroscopy instrumentation located within the 737' control building (7)continuous air monitors in the control building (8)liquid scintillation counting equipment located within the 737' control building
Calibration and Testing Program (IP Section 03.02) (14 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection instruments:
- (1) Thermo Scientific small article monitor (SAM), serial number 298
- (2) MGP AMP 100, serial number 5011-110
- (3) Eberline AMS-4, serial number 13031/12888
- (4) Bicron Microrem, serial number B171Y
- (5) Radeco H-809C, serial number 4671
- (6) Ludlum 3030P, serial number 339577
- (7) Ludlum 177, serial number 327152
- (8) JL Shepherd Model 89, serial number 9042
- (9) Eberline RO20AA, serial number 01660
- (10) MGP Telepole WR, serial number 6605-040 (11)1RIXCM062 containment/drywell high range gamma monitor
- (12) Mirion Accuscan II whole body counter (13)1RIXPR038 area radiation monitor (14)gamma spectroscopy equipment, system F Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (2 Samples)
The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:
(1)0RIX-PR012 HVAC exhaust accident range gaseous effluent monitor (2)1RIX-PR039 shutdown service water effluent monitor
71124.06 - Radioactive Gaseous and Liquid Effluent Treatment
Walkdowns and Observations (IP Section 03.01) (3 Samples)
The inspectors evaluated the following radioactive effluent systems during walkdowns:
(1)liquid radwaste discharge process radiation monitor 0RIX-PR040 and associated sample lines (2)plant service water effluent process radiation monitor 1RIX-PR040 and associated sample lines (3)shutdown service water effluent process radiation monitors, 1RIX-PR039 and 1RIX-PR039, and associated sample lines
Sampling and Analysis (IP Section 03.02) (4 Samples)
Inspectors evaluated the following effluent samples, sampling processes and compensatory samples:
(1)pre-treatment off-gas noble gas radiation monitor 1RIX-PR034 (2)continuous liquid effluent service water (3)liquid batch release tank
- (4) HVAC and standby gas treatment system ventilation
Dose Calculations (IP Section 03.03) (2 Samples)
The inspectors evaluated the following dose calculations:
(1)first quarter 2022 gaseous effluent (2)second quarter 2022 gaseous effluent
71124.07 - Radiological Environmental Monitoring Program
Environmental Monitoring Equipment and Sampling (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated environmental monitoring equipment and observed collection of environmental samples.
Radiological Environmental Monitoring Program (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the implementation of the licensees radiological environmental monitoring program.
GPI Implementation (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees implementation of the Groundwater Protection Initiative program to identify incomplete or discontinued program elements.
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 (July 1, 2021, through June 30, 2022)
MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)
- (1) Unit 1 (July 1, 2021, through June 30, 2022)
MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)
- (1) Unit 1 (July 1, 2021, through June 30, 2022)
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (1 Sample)
- (1) Unit 1 (October 1, 2021, through June 30, 2022)
BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)
- (1) Unit 1 (July 1, 2021, through June 30, 2022)
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) Unit 1 (October 1, 2021, through June 30, 2022)
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 (October 1, 2021, through June 30, 2022)
EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)
- (1) Unit 1 (July 1, 2021, through March 31, 2022)
EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)
- (1) Unit 1 (July 1, 2021, through March 31, 2022)
EP03: Alert and Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)
- (1) Unit 1 (July 1, 2021, through March 31, 2022)
71152A - Annual Follow-Up Problem Identification and Resolution Annual Follow-Up of Selected Issues (Section 03.03)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
(1)review and assessment of the corrective actions emergency reserve auxiliary transformer protective features issues from October 1, 2021, through September 30, 2022 71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02) (1 Partial)
The inspectors evaluated the following licensee event reports (LERs):
(1)
(Partial)
LER 05000461/2021-001-00, "Core Monitoring System Software Modeling Error Results in Condition Prohibited by Technical Specification," ML21351A167. The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER; therefore, no performance deficiency was identified. The inspection conclusions associated with this LER are documented in this report under Inspection Results Section 71153. This sample will be completed in NRC integrated inspection report 05000461/2022004.
INSPECTION RESULTS
Failure to Perform Radioactive Effluent Sampling Required by the Offsite Dose Calculation Manual Cornerstone Significance Cross-Cutting Aspect Report Section Public Radiation Safety Green NCV 05000461/2022003-01 Open/Closed
[H.3] - Change Management 71124.06 An NRC-identified finding of very-low safety significance (Green) and associated non-cited violation (NCV) of Technical Specification (TS) 5.5.4(c) was identified concerning the licensees failure to have implementing procedures for the sampling and analysis of liquid radioactive effluents specified within the Offsite Dose Calculation Manual (ODCM).
Specifically, the ODCM (revision 24, January 2015) contained the requirement to sample and analyze the service water effluent for tritium (H-3), which the licensee failed to have procedures or to perform.
Description:
Technical Specification 5.5.1 established that the ODCM shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents and in the calculation of gaseous and liquid effluent monitoring alarm and trip setpoints. Technical Specification 5.5.4 further states that the ODCM shall also contain the radioactive effluent control program.
The effluent controls program specified in the licensees ODCM included plant service water and shutdown service water systems as part of the licensee's liquid effluent management program. Since January 2015, the ODCM (revision 24) included the requirement to sample and analyze plant service water and shutdown service water for tritium (H-3), in addition to the previously implemented requirement to sample and analyze for principle gamma emitting radionuclides.
During reviews of program documents, the inspectors identified that the licensee performed the sampling and analysis for the principle gamma emitting radionuclides; however, the sampling and analysis of tritium (H-3), as specified in the ODCM, was not contained in its procedures and was not being performed. Upon identification to the licensee, the licensee revised its procedures to perform the required sampling and analysis.
Corrective Actions: The licensee revised procedures for sampling and analysis to include tritium for the service water effluent streams as specified within the ODCM.
Corrective Action References: AR 4512570
Performance Assessment:
Performance Deficiency: The inspectors determined that the failure to implement the liquid effluent sampling and analysis requirements contained within the ODCM was within the licensee's ability to foresee and correct and should have been prevented.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Program & Process attribute of the Public Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain as a result of routine civilian nuclear reactor operation. Specifically, the failure to implement tritium effluent sampling and analysis (as specified within the ODCM) may impact the licensees ability to adequately identify an otherwise unknown release of tritium to the environment (e.g., system leakage into service water) and to determine the quantity and impacts of the liquid radioactive effluents on the environment.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix D, Public Radiation Safety SDP. The violation was of very-low safety significance (Green) because it was not a substantial failure to implement the Effluent Program, nor did dose exceed Appendix I or 10 CFR 20.1301(e) criteria.
Cross-Cutting Aspect: H.3 - Change Management: Leaders use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority.
The licensee amended the ODCM to require tritium sampling and analysis of the service water systems effluents, however, the licensee failed to incorporate this requirement into implementing procedures.
Enforcement:
Violation: TS 5.5.4 Radioactive Effluent Controls Program states, in part, the program shall be contained in the ODCM, shall be implemented by procedures, and shall include remedial actions to be taken whenever the program limits are exceeded. The program shall include monitoring, sampling, and analysis of radioactive liquid and gaseous effluents in accordance with 10 CFR 20.1302 and with the methodology and parameters in the ODCM.
Section 2.2 of the Clinton ODCM (revisions 24 and 25) states, in part, "service water effluent grab samples will be obtained anytime water is flowing through the plant service water system and analyzed to determine the identity and quantity of principal gamma-emitting radionuclides and tritium. Section 2.3, states, in part, "SX (shutdown service water) effluent sampling, analysis and setpoint establishment will be performed as discussed for the plant service water system in Section 2.2."
Contrary to the above, between January 2015 and September 2022, the licensee failed to implement its radioactive effluent control program by procedures that included the sampling and analysis of radioactive liquid and gaseous effluents in accordance with the methodology and parameters in the ODCM. Specifically, the licensee did not have procedures for the sampling and analysis of the plant service water and shutdown service water effluents for tritium (H-3) as specified in Sections 2.2 and 2.3 of the ODCM and did not perform the specified sampling/analysis.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Protective Features of Emergency Reserve Auxiliary Transformer Not Fully Translated to Procedures and Training Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green FIN 05000461/2022003-02 Open/Closed
[H.3] - Change Management 71152A A self-revealed Green finding was identified when the licensee failed to completely translate the design protective features of the emergency reserve auxiliary transformer automatic load tap changer and manually switched capacitor bank. Specifically, the licensee failed to ensure the design change of emergency reserve auxiliary transformer automatic load tap changer and manually switched capacitor bank were completely translated into operating processes and training, which is contrary to CC-AA-10, Configuration Control Process Description, section 1.1, revision 10 that states, " Changes made to the plant and to the plant operations are accurately recorded in documents such as drawings and procedures. This process description establishes the framework for the interface of configuration control with other plant processes and identifies sub-tier processes."
Description:
On December 17, 2021, the division 1 electrical safety bus voltage rose above 4300 volts.
The crew placed the emergency reserve auxiliary transformer (ERAT) load tap changer (LTC)in manual and declared the 138kV offsite power source inoperable and completed TS Limiting Condition for Operation (LCO) actions 3.8.1 A.1 and A.2. Action was taken to manually tap the transformer down to restore voltage below 4300 volts, which is the continuous upper voltage operability limit. The ERAT LTC and supported offsite power source was restored to operable and LCO actions exited. The cause was not identified, and the troubleshooting work order remained open.
On February 19, 2022, the division 1 electrical safety bus voltage rose above 4300 volts. The crew placed the ERAT load tap changer in manual and declared the 138kV offsite power source inoperable and completed TS LCO actions 3.8.1 A.1 and A.2. Action was taken to manually tap the transformer down to restore voltage below 4300 volts, which is the continuous upper voltage operability limit. The offsite power source was restored to operable and LCO actions exited. The cause was determined to be inadequate rigor when selecting and setting the voltage regulation relay. Indications at the local control panel identified a local protective feature for reverse power which removed the automatic load tap feature from the ERAT. At this point the operation staff became aware of this designed protective feature.
On February 22, 2022, the crew identified that the reverse power LED was lit on the local control panel for the ERAT LTC. The division 1 electrical safety bus voltage was less than 4300 volts and the support safety bus remained operable. The cause of the alarm and protective feature was determined to be the monthly paralleling of the division 1 electrical safety bus to the standby source. During this evolution, a small reverse power potential exists and could initiate the reverse power protection. Further inspection revealed that the restoration of the safety bus lineup to a split grid operation would not clear the reverse power protection until greater than 100 amps of load were detected. Normal bus load was less than the reset value so the local alarm and protective feature would remain active if initiated. Had a total loss of power occurred with the reverse power protection active, the subsequent loading of safety equipment would have automatically reset the protective feature and allowed restoration of ERAT automatic LTC operation and return to operable voltages.
On May 31, 2022, the control room staff noted breaker 0AP104E for ERAT manually switched capacitor (MSC) was tripped open on control room panel P870 with no alarms received during routine panel walkdowns. The staff entered 4200.01 LOSS OF AC off-normal procedure. The crew declared the 138kV offsite power source inoperable and completed TS LCO actions 3.8.1 A.1 and A.2. Equipment repair was taken to restore MSC operation, the ERAT MSC and supported offsite power source restored to operable, and LCO actions exited. The cause was determined to be MSC breaker charging spring was not compressed and the associated hydraulic pump was not running due to a failed contactor.
The inspectors determined that the above issues, along with other minor issues evaluated during this inspection, were the result of the ERAT modification design not being completely translated into operation procedures and training such that unknown operability existed for short periods of time without control room staff awareness. Conversely, other unannounced and confusing local system alarms caused questions of operability with the system that ultimately did not impact operability.
Corrective Actions: LTC corrective actions included issuance of engineering calculation 636179 to change the voltage regulating relay setting to forward bias that was implemented under WO 5234503. Operating procedures CPS 3501.01 and 3505.03 were updated to reflect this change.
MSC corrective actions created EC 628200 to restore the alarm function associated with the MSC protective breaker positions 0AP103E and 0AP104E. The field change request has been issued and is scheduled for implementation when plant conditions allow. Interim actions include operations training and control board awareness verifications every shift.
Corrective Action References:
AR 4479303, "4160V 1 A 1 Bus Voltage Rose Above 4300 Volts" AR 4480017, "ERAT Load Tap Changer Revers Power LED Lit" AR 4503000, "Entered 4200.01 Loss of AC due to ERAT MSC Trip"
Performance Assessment:
Performance Deficiency: The licensee failed to ensure the design change of ERAT automatic LTC and MSC bank were completely translated into operating procedures and training, which is contrary to CC-AA-10, Configuration Control Process
Description.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors determined the performance deficiency was more than minor because it was associated with the equipment performance attribute of the initiating events cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, protective features not directly alarming in the control room could be present locally and make the transformer and supported safety system power inoperable.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Per IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power; exhibit 1, Initiating Events Screening Questions; section C, Support System Initiators; questions 1 and 2, both questions were answered "No" as grid stability supported operable voltages and split grid system lineup system provided redundancy to the 4kV safety busses. The questions screened the finding as Green.
Cross-Cutting Aspect: H.3 - Change Management: Leaders use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority.
Enforcement:
Inspectors did not identify a violation of regulatory requirements associated with this finding.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On October 20, 2022, the inspectors presented the integrated inspection results to Mr. T. Chalmers, Site Vice President, and other members of the licensee staff.
On August 25, 2022, the inspectors presented the emergency preparedness inspection results to Mr. J. Kowalski, Vice President of Operations East/West, and other members of the licensee staff.
On September 29, 2022, the inspectors presented the radiation protection baseline inspection results to Mr. T. Chalmers, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
3312.01V001
Residual Heat Removal Valve Lineup
17c
1893.04M310
619 Control: HVAC Equipment Area Prefire Plan
6c
1893.04M4000
2 Fuel: Basement Prefire Plan
5a
1893.04M410
737 Fuel: Grade Level Prefire Plan
4c
1893.04M420
755 Fuel: Fuel Handling Floor Prefire Plan
4a
1893.04M800
699 Screen House: Division 1 SX Pump Room Prefire Plan
5a
Fire Plans
1893.04M804
699 Screen House: General Area Prefire Plan
4a
Division 1 Shutdown Service Water System Outage Window
09/16/2022
Work Orders
Division 1 Diesel Generator System Outage Window
09/17/2022
1E51F026 RHR and RCIC Steam Supply Valve Second
Drain Valve Found Closed
07/08/2022
Division 3 Shutdown Service Water Door Not Dogged
07/25/2022
Corrective Action
Documents
Leak Downstream of 0SX009
08/15/2022
Work Orders
0FP01PA Replacement Fire Pump 'A'
08/09/2022
Operations Post Maintenance Test for 0FP01PA Replace
Fire Pump 'A' EC 630948
08/09/2022
CMO 0Vc07SA Charcoal Analysis Review 9866.03" for 'A'
Control Room HVAC
09/19/2022
Operations Run VG A and Verify Heater Operation
08/23/2022
Operations Post Maintenance Test 1SX008A Stroke/Verify
Operation
09/15/2022
Operations Post Maintenance Test for Division 1 Diesel
Generator
09/17/2022
Work Orders
Operations Post Maintenance Test for RCIC DC Load Driver
P661-C-A14-A127 Replacement
07/09/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CPS 9067.01
Standby Gas Treatment System Train Flow Heater
Operability
2b
Procedures
CPS 9069.01
Shutdown Service Water Operability Test
50f
Off-Site Emergency Plan Alert and Notification System
Addendum for the Clinton Nuclear
Power Station
05/01/2013
- U.S. Department of Homeland Security, FEMA Letter;
Backup Alert and Notification System
2/10/2012
Alert Notification System (Sirens) Annual Maintenance
Reports
04/01/2020-
06/30/2022
Alert Notification System (Sirens) Test Records
04/01/2020-
06/30/2022
Miscellaneous
KLD-TR-987
Clinton Power Station Alert and Notification System (ANS)
Design Report
09/19/2018
Corrective Action
Documents
Maintenance Respirator Quals Below Procedure
Requirements
04/11/2022
Miscellaneous
Quarterly Unannounced Off-Hours Call-In Augmentation Drill
Results
04/01/2020-
04/31/2022
Addendum 1
On-Shift Staffing Technical Basis
Drills and Exercise Program
Emergency Response Organization (ERO) / Emergency
Response Facility (ERF) Activation and Operation
EP-AA-112-
100-F-06
ERO Notification or Augmentation
Z
Procedures
ERO Training and Qualification
OE: Loss of Emergency Plan Dose Assessment Capability
10/27/2020
E-Plan/Annex/Implementing Procedure Submittal to NRC
11/18/2020
Annual Update Station Letters of Agreement (PB Annex)
2/11/2020
Chem Tech ERO Function Procedure Conflict
08/27/2021
OE: Discrepancy - SPFLI Used for EAL
2/02/2020
EP ID: Gap Identified During Self-Assessment
2/30/2022
EP ID: Clinton 2021 Annual Medical Emergency/HP Drill
01/12/2022
Corrective Action
Documents
EP ID: Procedure Not Implemented as Required
04/28/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
20/2021 Emergency Planning for the Clinton Area
(Community Information Booklet
06/17/2020
Clinton Station Emergency Preparedness Program Drill and
Exercise Reports
04/01/2020-
06/30/2022
EP-CL-124-F-09
Clinton Monthly ENS Communications Test Records
04/01/2020-
06/30/2022
EP-CL-124-F-
Clinton Control Room/Simulator Inventory Records
04/01/2020-
06/30/2022
EP-CL-124-F-
Technical Support Center Inventory Records
04/01/2020-
06/30/2022
EP-CL-124-F-
Clinton Operations Support Center Inventory Records
04/01/2020-
06/30/2022
EP-CL-124-F-
CR/Simulator/TSC/OSC Equipment Test-TSC Software and
Reference Document Inventory Records
04/01/2020-
06/30/2022
EP-CL-124-F-
Monthly/Yearly NARS Communications Test Records
04/01/2020-
06/30/2022
EP-CL-124-F-
Clinton Hospital Cabinet Inventory Records
04/01/2020-
06/30/2022
KLD-TR-1181
Clinton Power Station 2020 Population Update Analysis
09/05/2020
NOSA-CPS-20-
Emergency Preparedness Audit Report
04/22/2020
Miscellaneous
NOSA-CPS-22-
Emergency Preparedness Audit Report
05/11/2022
Exelon Nuclear Standardized Radiological Emergency Plan
Procedures
Addendum 2
Evacuation Time Estimates for Clinton Power Station Plume
Exposure Pathway Emergency Planning Zone
Gamma Spectroscopy System F
Various
Mirion Accuscan II Whole Body Counter
01/12/2022
01660
Eberline RO20AA
10/26/2021
13031/12888
Eberline AMS-4
05/02/2022
298
Small Article Monitor (SAM)
09/02/2021
27152
Ludlum 177
04/29/2022
339577
Ludlum 3030P
10/31/2021
Calibration
Records
4671
Radeco Air Sampler
03/01/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
5011-110
MGP AMP 100
05/05/2022
6605-040
MGP Telepole WR
04/29/2022
9042
JL Shepherd Model 89
01/01/2020
9042
JL Shepherd Model 89
08/09/2022
B171Y
Bicron Microrem
05/04/2022
IP-C-0007
Primary Calibration for Liquid Monitors
06/03/1991
1RIXCM062 Containment Drywell High Range Gamma
Monitor
2/04/2022
Corrective Action
Documents
4th Quarter 2019 Analytic Radiochemistry Cross-Check
Discrepancy
01/06/2020
Miscellaneous
Gamma Spectroscopy Cross Check Evaluation Data
(Second Quarter 2021 Through Second Quarter 2022)
Various
Self-Assessments 4297172
NRC Inspection Guide 71124.05 Radiation Monitoring
Instrumentation
04/10/2020
Work Orders
Area Radiation Monitor 1RIXPR038 Calibration
08/06/2013
Untimely Corrections to ODCM
07/22/2022
Corrective Action
Documents
Resulting from
Inspection
Missed ODCM Sample
07/23/2022
Clinton Power Station 2019 Annual Radioactive Effluent
Release Report
04/28/2020
Clinton Power Station 2020 Annual Radioactive Effluent
Release Report
04/21/2021
Miscellaneous
Clinton Power Station 2021 Annual Radioactive Effluent
Release Report
04/29/2022
CY-CL-170-301
Offsite Dose Calculation Manual
CY-CL-6949-01
Off-Gas Pre-Treatment Sampling and Analysis
CY-CL-6954-01
HVAC Stack Effluent Noble Gas and Tritium
CY-CL-6954-02
HVAC Stack Effluent - Iodine and Particulates
Procedures
CY-CL-9652-01
Liquid PRM Sampling and Analysis
Corrective Action
Documents
Electric Power Reliability Issues
05/09/2022
Miscellaneous
Clinton Power Station 2021 Annual Radiological
Environmental Operating Report
04/29/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Clinton Power Station 2020 Annual Radiological
Environmental Operating Report
04/29/2021
Clinton Power Station 2019 Annual Radiological
Environmental Operating Report
04/28/2020
Annual Report on the Meteorological Monitoring Program at
the Clinton Power Station - 2021
04/04/2022
Clinton Main Tower Meteorological Monitoring Tower Annual
Site/Tree Inspection Report
06/28/2021
Pump 805
Pump Maintenance Data Sheet
03/30/2023
Pump 808
Pump Maintenance Data Sheet
03/02/2022
Pump 822
Pump Maintenance Data Sheet
10/06/2021
SITE TREE
INSPECTION
REPORT
Site Tree Inspection Report for 2019 - Clinton Main Tower
Meteorological Monitoring Tower and Clinton Backup Tower
Meteorological Monitoring Tower
09/18/2019
CY-CL-170-301
Offsite Dose Calculation Manual
EMIL-SPM-1
Sampling Procedures Manual
Procedures
EN-CL-408-4160
RGPP Reference Material for Clinton Power Station
Corrective Action
Documents
EP ID: Incorrect Participation PI Data Submitted
2/18/2020
NRC Performance Indicator Data; Emergency Preparedness
- Drill/Exercise Performance
07/01/2021-
03/31/2022
NRC Performance Indicator Data; Emergency Preparedness
- ERO Readiness
07/01/2021 -
03/31/2022
NRC Performance Indicator Data; Emergency Preparedness
- Alert and Notification System Reliability
07/01/2021 -
03/31/2022
Unit 1 Dose Equivalent Iodine Data (Fourth Quarter 2021
through Second Quarter 2022
Various
Radiation Protection Occupational Dose Performance
Indicator Data Fourth Quarter 2021 through Second Quarter
22
Various
71151
Miscellaneous
Radioactive Effluent Dose Summary Data Fourth Quarter
21 through Second Quarter 2022
Various