IR 05000461/2022010

Design Basis Assurance Inspection (Teams) Inspection Report 05000461/2022010

ML22147A065
Person / Time
Site:	Clinton
Issue date:	06/06/2022
From:	Karla Stoedter NRC/RGN-III/DRS/EB2
To:	Rhoades D Constellation Energy Generation
References
IR 2022010
Download: ML22147A065 (26)

Text

June 6, 2022

SUBJECT:

CLINTON POWER STATION-DESIGN BASIS ASSURANCE INSPECTION (TEAMS) INSPECTION REPORT 05000461/2022010

Dear Mr. Rhoades:

On May 5, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Clinton Power Station and discussed the results of this inspection with Mr. T. Chalmers, Site Vice President and other members of your staff. The results of this inspection are documented in the enclosed report.

Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations or the significance or severity of the violations 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 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. 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, Signed by Stoedter, Karla on 06/06/22 Karla K. Stoedter, Chief Engineering Branch 2 Division of Reactor Safety Docket No. 05000461 License No. NPF-62

Enclosure:

As stated

Inspection Report

Docket Number: 05000461 License Number: NPF-62 Report Number: 05000461/2022010 Enterprise Identifier: I-2022-010-0026 Licensee: Constellation Nuclear Facility: Clinton Power Station Location: Clinton, IL Inspection Dates: February 14, 2022 to March 04, 2022 Inspectors: J. Corujo-Sandin, Senior Reactor Inspector B. Daley, Senior Reactor Inspector M. Domke, Reactor Inspector I. Hafeez, Reactor Inspector M. Jones, Reactor Inspector E. Magnuson, Reactor Inspector D. Melendez-Colon, Reactor Inspector E. Rosario, Reactor Inspector E. Sanchez Santiago, Senior Reactor Inspector Approved By: Karla K. Stoedter, Chief Engineering Branch 2 Division of Reactor Safety Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a design basis assurance inspection (teams) 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 Follow Procedure When Implementing ASME Code Case N-513-4 for Through-Wall Flaw Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.9] - Training 71111.21M Systems NCV 05000461/2022010-01 Open/Closed The inspectors identified a Green finding and an associated Non-Cited Violation of Title 10 Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion V, Instructions,

Procedures, and Drawings, for the licensees failure to follow the instructions of procedure ER-AA-330-009 when implementing American Society of Mechanical Engineers (ASME)

Code Case (CC) N-513-4. Specifically, the licensee failed to follow the steps requiring volumetric re-examinations and daily walkdowns to validate the leakage was bounded by the conditions used in the original engineering evaluation.

Failure to Correct a Non-Conservative Technical Specification Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21M Systems NCV 05000461/2022010-02 Open/Closed The inspectors identified a finding of very low safety significance (Green) and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (CFR) Part 50,

Appendix B, Criterion XVI, Corrective Actions, for the licensee's failure to correct a condition adverse to quality identified in 1999. Specifically, the licensee failed to correct a non-conservative Technical Specification value for the minimum diesel generator (DG)starting air receiver pressure after testing revealed the DG starting times exceeded the required 12 second fast start criteria when air receiver pressure was 140 psig.

Additional Tracking Items

Type Issue Number Title Report Section Status URI 05000461/2022010-03 Questions Regarding the 71111.21M Open Licensing Bases for Undervoltage Conditions and the Impact on Safety Related Motors Stalling

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.

REACTOR SAFETY

===71111.21M - Design Bases Assurance Inspection (Teams) The inspectors evaluated the following components and listed applicable attributes, permanent modifications, and operating experience:

Design Review - Risk-Significant/Low Design Margin Components (IP Section 02.02)

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For each component sample, the inspectors reviewed the licensing bases including:

(1) the Updated Safety Analysis Report (USAR);

(2) the Technical Specification (TS); and

(3) the Technical Requirements Manual (TRM). The inspectors reviewed a sample of operating procedures (including normal, abnormal, and emergency procedures), overall system/component health (including condition reports and operability evaluations, if any)and associated maintenance effectiveness (e.g., Maintenance Rule, procedures). The inspectors performed visual inspections of the accessible components to identify potential hazards and/or signs of degradation. Additional component specific design attributes reviewed by the inspectors are listed below.

(1) Residual Heat Removal (RHR) A Room Cooler (1VY02S)1. Modifications 2. Translation of vendor specifications 3. Protection against external events:

a. Flooding, including sump pump b. Seismic c. High Energy Line Break (HELB)d. Fire 4. Design calculations and considerations:

a. Minimum cooling water flowrate b. Maximum cooling water temperature c. Minimum working fluid flowrate d. Maximum working fluid temperature e. Tube plugging limit 5. Test/inspection procedures, acceptance criteria, and recent results:

a. Flowrates b. Inspection and/or thermal performance test c. Eddy current

(2) RHR A Minimum Flow Valve (1E12F064A)1. Modifications 2. Environmental qualification 3. Protection against external events:

a. Flooding, including sump pump b. Seismic c. HELB d. Fire 4. Mechanical design:

a. Pressure locking and/or thermal binding b. Closure/Opening time c. Maximum differential pressure 5. Test/inspection procedures, acceptance criteria, and recent results:

a. Leakage b. Inservice Testing (IST)

(3) Division 1 Diesel Generator (DG) (1DG01KA)1. Modifications 2. Translation of vendor specifications 3. Environmental qualification 4. Protection against external events:

a. Flooding, including sump pump i. Operation's Field Validation b. Seismic 5. Mechanical design calculations and considerations:

a. Engine sizing b. Room heat-up calculations and environmental considerations c. Lube oil cooler d. Jacket water cooler e. Fuel oil volume consumption f. Fuel oil available volume/level g. Fuel oil transfer design (e.g., flow capacity, Net Positive Suction Head)h. Starting air design, including station blackout recovery capability i. Governor control j. Engine lubrication 6. Test/inspection procedures, acceptance criteria, and recent results:

a. Engine b. TS surveillances c. Jacket water cooler d. Fuel oil volume e. Fuel oil quality f. Starting air 7. Electrical design calculations and considerations:

a. Loss of Voltage Relaying b. Output breaker control logic c. Station Blackout 8. Implementation of American Society of Mechanical Engineers (ASME) Code Case N-513-4

(4) Circuit Breaker 21A1 (1AP07EK)1. Translation of vendor specifications

2. Test/inspection procedures, acceptance criteria, and recent results:

a. TS surveillance b. Relay calibration 3. Electrical design calculations and considerations:

a. Loading calculations b. Short circuit calculations c. Protective relay calculations

(5) Emergency Reserve Auxiliary Transformer (ERAT) (0AP03E)1. Modifications 2. Translation of vendor specifications 3. Electrical design calculations and considerations:

a. Loading calculations b. Short circuit calculations c. Degraded voltage protection d. Loss of voltage 4. Breaker settings and ratings to prevent spurious tripping a. Breaker control voltage b. Grounding c. Cable ampacity d. Protective devices 5. Protective relay calculations a. Load testing b. TS surveillance 6. Load Tap Changer (LTC) protective relay settings 7. LTC Controls 8. Capacitor Bank Protective Relays 9. Capacitor Bank Controls

Design Review - Large Early Release Frequency (LERFs) (IP Section 02.02) (1 Sample)

(1) Division 1 Battery Charger (1DC06E)1. Translation of vendor specifications 2. Environmental qualification (EQ)3. Protection against external events:

a. HELB b. Fire c. Test/inspection procedures, acceptance criteria, and recent results:

4. Electrical design calculations and considerations:

a. Sizing b. Current limiting setting c. Duty cycle d. Contribution to short circuit fault current e. Sizing of protective fuses/breakers/relays f. Voltage drop calculation g. Configuration of electrical distribution 5. Operation during a Station Blackout a. Direct current (DC) load shedding requirements i. Operation's Field Validation b. EQ consideration in the Reactor Core Isolation Cooling room for DC

Loads Modification Review - Permanent Mods (IP Section 02.03) (5 Samples)

(1) Engineering Change (EC) 355405 - Replace Division 2 Diesel Generator Governor Actuators

(2) EC 625047 - Division 1 Diesel Generator Differential Relay SA-1 Circuit Modification

(3) EC 622614 - Reactor Core Isolation Cooling Tank (1RI01T) Drain/Overflow Changes Including Eliminating Tank Drain Valve 1E51F387

(4) EC 624194 - Replace 1E12F046A and 1E12F018A with Alternate Designs and 1RH19AA and 1RH19BA with Stainless Steel

(5) EC 628200 - CALC 19-AK-13 20210416 005 Approved Analysis of Load Flow, Short Circuit & Motor Starting Using ETAP Power station EC 627131 / 628200

Review of Operating Experience Issues (IP Section 02.06) (3 Samples)

(1) Information Notice (IN) 2019-01 - Inadequate Evaluation of Temporary Alterations

(2) IN 2017-06 - Battery and Battery Charger Short-Circuit Current Contributions to a Fault on the Direct Current Distribution System

(3) Operating Experience (OE) 14127 - Flow Accelerated Corrosion (FAC) Program Did Not Predict FAC Induced Pin-Hole Leak in RHR Min-Flow Piping

INSPECTION RESULTS

Failure to Follow Procedure When Implementing ASME Code Case N-513-4 for Through-Wall Flaw Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.9] - Training 71111.21M Systems NCV 05000461/2022010-01 Open/Closed The inspectors identified a Green finding and an associated Non-Cited Violation of Title 10 Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to follow the instructions of procedure ER-AA-330-009 when implementing American Society of Mechanical Engineers (ASME)

Code Case (CC) N-513-4. Specifically, the licensee failed to follow the steps requiring volumetric re-examinations and daily walkdowns to validate the leakage was bounded by the conditions used in the original engineering evaluation.

Description:

On February 16, 2022, while observing an operability run of Diesel Generator (DG) 1A, the inspectors observed through-wall leakage from safety-related shutdown service water pipe component 1SX04AA-8" a few inches downstream of DG 1A heat exchanger outlet valve 1SX063A. The licensee previously identified this leakage on November 19, 2021.

Following identification of the leakage in November 2021, the licensee invoked ASME CC N-513-4, Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping Section XI, Division 1. This CC allows temporary acceptance of flaws, including through-wall flaws, without performing an ASME Code Section XI repair/replacement activity until the next scheduled refueling outage. The licensee performed engineering change (EC) 635584, revision 0 to evaluate the through-wall leak in pipe 1SX04AA-8" and its applicability to CC N-513-4. The through-wall and erosion degradation affect an ASME Class 3 pipe component.

The licensee implements the requirements of CC N 513-4 via procedure ER-AA-330-009, ASME Section XI Repair/Replacement Program. CC N-513-4 requires, in part, for through-wall leaking flaws that leakage be monitored daily to confirm the analysis conditions used in the evaluation remain valid. This same requirement appeared as Step 2.6 of procedure ER-AA-330-009, Attachment 6. The inspector requested documentation demonstrating the daily monitoring was completed. This request revealed at least 14 instances from November 19, 2021, to February 21, 2022, when the licensee failed to complete the daily monitoring to confirm the analysis conditions provided in EC 635584 remained valid. The licensee documented the incompletion of the daily monitoring in corrective action report AR 4479775.

The CC also requires periodic inspections at no more than 30-day intervals to determine if flaws are growing or to establish the time which the flaw will exceed the allowable size. The licensee provides this CC requirement in Step 2.5 of procedure ER-AA-330-009,

6. The licensee determined these periodic inspections were also not performed

since the initial volumetric examination on November 22, 2021, and captured the incompletion of these volumetric exams in corrective action report AR 4481604.

The November 22, 2021, ultrasonic examination of 1SX04AA-8" also determined another thinned piping region above code allowable thickness but below administrative limits, located approximately 1 inch from the through-wall flaw. Since discovery, at least three inspections have been missed to ensure this thinned area remained within the bounds of the associated engineering evaluation. The licensee performed an ultrasonic field examination of the flaw on March 4, 2022, and determined this thinned region adjacent to the through-wall flaw was still within acceptable limits.

Corrective Actions: The licensee re-emphasized requirements to observe leakage from 1SX04AA-8" with Operations personnel even when 1SX04AA-8" is depressurized. The licensee completed a volumetric exam March 4, 2022, to ensure the conclusions of the engineering analysis were bounded by current 1SX04AA-8" wall thicknesses.

Corrective Action References: AR 4479775, Comp Action for 1SX063A Not Meeting Intent of Op Eval 635584 AR 4481604, Issues with Code Case Adherence

Performance Assessment:

Performance Deficiency: The licensee failed to follow the instructions of procedure ER-AA-330-009 for implementing ASME CC N-513-4. Specifically, the licensee failed to follow the steps requiring volumetric re-examinations and daily walkdowns to validate the leakage was bounded by the conditions used in EC 635584. This was contrary to Title 10 CFR 50 Appendix B, Criterion V, Instructions, Procedures, and Drawings, and was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, absent inspector intervention the incorrect application of CC N-513-4 monitoring would have likely continued without application of the required flaw growth assessments and resulted in an increased likelihood for inservice failure. This failure would have affected operation of the plant and could prevent safety-related structures, systems, and components from performing their design bases function (e.g., lack of service water cooling resulting in an inoperable DG).

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Specifically, the inspectors answered all Inspection Manual Chapter 0609, Appendix A, Exhibit 2, mitigating systems screening questions "no."

Cross-Cutting Aspect: H.9 - Training: The organization provides training and ensures knowledge transfer to maintain a knowledgeable, technically competent workforce and instill nuclear safety values. Inspector interviews with licensee personnel revealed this was the first CC N-513-4 evaluation for one of the preparers.

Enforcement:

Violation: Title 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

The licensee established ER-AA-330-009, ASME Section XI Repair/Replacement Program, Revision 18, as the implementing procedure when applying ASME CC N-513-4, an activity affecting quality. Attachment 6 to the procedure provides the instructions for the use of CC N-513-4.

Procedure ER-AA-330-009, Attachment 6, Implementation of Code Case N-513-x, requires, in part, that all applicable requirements specified in the CC shall be implemented until the CC is no longer needed to provide temporary flaw acceptance of flaws in Class 2 and 3 piping/tubing.

Procedure ER-AA-330-009, Attachment 6, Step 2.5. requires: Periodic volumetric re-examinations or physical measurement shall be performed at least once every 30-days to monitor flaw growth to satisfy the requirements of paragraph 2.0(e) of N-513-x. Alternatively, a flaw growth analysis based on flaw growth data from the degraded location may be used to predict time to reach T allow in which case the periodic NDE may be extended to no more than the lesser of time to reach T allow or 90 days between examinations.

Procedure ER-AA-330-009, Attachment 6, Step 2.6 requires, in part: For through-wall leaking flaws, in addition to the periodic volumetric re-examination, daily walkdowns (i.e., paragraph 2.0(f) of N-513-x) shall be performed to validate that the leakage is bounded by the conditions used in the engineering evaluation.

Contrary to the above, from November 19, 2021 to March 4, 2022, the licensee failed to accomplish activities affecting quality in accordance with instructions, procedures or drawings. Specifically, the licensee failed to follow Step 2.5 and 2.6 from Attachment 6 of procedure ER-AA-330-009, Revision 18 when they:

1. Failed to perform volumetric re-examinations/physical measurements at least once every 30-days or perform the flaw growth analysis.

2. Failed to perform 14 of the required daily walkdowns to validate the leakage was bounded by the conditions used in the engineering evaluation.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Correct a Non-Conservative Technical Specification Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21M Systems NCV 05000461/2022010-02 Open/Closed The inspectors identified a finding of very low safety significance (Green) and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion XVI, Corrective Actions, for the licensee's failure to correct a condition adverse to quality identified in 1999. Specifically, the licensee failed to correct a non-conservative Technical Specification value for the minimum diesel generator (DG)starting air receiver pressure after testing revealed the DG starting times exceeded the required 12 second fast start criteria when air receiver pressure was 140 psig.

Description:

Each DG at Clinton Station (Divisions 1, 2, and 3) has a starting air system which consists of two full-capacity air starting subsystems. Each subsystem has its own dedicated starting air receiver.

Title 10 CFR 50.36 "Technical Specifications," requires, in part, that each Technical Specification Limiting Condition for Operation (LCO) specify, at a minimum, the lowest functional capability or performance levels of equipment required for safe operation of the facility.

Clinton Power Stations (CPS) Technical Specification (TS) LCO 3.8.3 requires, in part, the starting air subsystem shall be within the limits for each required DG.

TS Surveillance Requirement (SR) 3.8.3.4 requires the licensee verify each required DG air start receiver pressure is greater than or equal to 200 psig.

TS 3.8.3, Condition E establishes, for one or more DGs with required starting air receiver pressure less than 200 psig and greater than or equal to 140 psig, the licensee has 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to restore the affected starting air receiver pressure to greater than or equal to 200 psig.

On March 12, 1999, the licensee documented the identification of a condition adverse to quality (CAQ) and generated Issue Reports (IR) 1-99-03-171, "Division 1 DG Start Times for CPS 2802.00, Section 8.1 and 8.2 Unacceptable, and IR 1-99-03-097, Division 1 DG Start Times for CPS 2802.00, Section 8.1 Unacceptable. These IRs were initiated following the failure of the Division 1 DG to meet the acceptance criteria to achieve required frequency and voltage within 12 seconds with the A and B air receivers at the TS minimum required pressure of 140 psig. The test procedures stated the acceptance criteria was, "One (1)successful DG start at a minimum air receiver pressure of 140 psig." During the test, it was noted the DG reached the required frequency and voltage in 13.5 seconds using the A air receiver and 12.2 seconds using the B air receiver. Per the Investigation Results section of the IR, "A successful start is defined as the diesel reaching rated speed and rated voltage within 12 seconds."

Also, on March 12, 1999, CPS licensing staff generated Internal Memo Y-218792, titled "Amplification/Clarification of Technical Specification Requirement Regarding Diesel Generator Air Systems." The intent of the memo was to provide a summary or restatement of the requirements for the DGs air start systems. The memo noted, in part, The lower limit of 140 psig under ITS [Improved Technical Specification] 3.8.3 is based on the minimum pressure at which DG fast-start capability is assumed to exist. Thus, as noted in the Bases for TS 3.8.3, it is assumed that "as long as the receiver pressure = 140 psig, there is adequate capacity to for at least one start attempt. This one attempt is assumed to be capable of yielding a start that, if successful, would result in a fast start of the DG.

As part of their corrective actions, circa 1999, the licensee initially determined a License Amendment Request (LAR) was required, and a revision to TS 3.8.3.E was proposed.

IR 424375 was generated to track completion of the LAR. Additionally, the licensee implemented administrative controls, via annunciator response procedure changes, directing operators to declare the DG (Division 1, 2, or 3) inoperable if the pressure in both of its associated air start receivers was below 200 psig.

Subsequently, in 2002, the licensee canceled the planned corrective actions (i.e., the LAR)without changing the values in TS 3.8.3. Per IR 424375-01, dated November 15, 2002, the licensee stated, in part, "Based upon further review of the TS Bases and Updated Safety Analysis Report (USAR), there's no need to revise the TS or Bases. This is based on the statements in USAR Section 9.5.6 that states the DG air receiver tanks are capable of starting the DGs five successive times, without recharging the receiver, when fully charged to their rated capacities. Also, the DGs are fully capable of starting multiple times when the air pressure is greater than 200 psig and capable of starting at least once above 140 psig (test results, IR 1-99-03-171). The 200 and 140 psig values are the values that are reflected in the TS and do not need to be revised."

During the 2022 Design Bases Assurance Inspection at CPS, inspectors selected a DG as an inspection sample and reviewed corrective action program documents, preoperational test reports, technical specification change history, previous work orders, and surveillance test documents. When reviewing the 1999 DG test results, the inspectors noted the same DG failure to meet the 12 seconds fast start requirement (when starting at 140 psig) and questioned the licensees basis for maintaining the 140 psig value in TS 3.8.3.E. At the time, the inspectors were unaware this CAQ had been previously identified.

On March 7, 2022, as a result of the inspectors questions, the licensee generated IR 4483234, NRC DBAI - Non-Conservative Tech Spec Not Resolved. In this IR, the licensee recognized that the non-conservative TS condition, Condition 3.8.3.E, which was previously identified in 1999, had been incorrectly dispositioned as acceptable in 2002. As a result, the licensee had not submitted the LAR to correct the non-conservative TS and resolve the CAQ. The inspectors noted the licensees administrative controls, which directed the operators to declare the DG inoperable if the pressure in both of its respective starting air receivers went below 200 psig, were still in effect. The licensee also validated TS Condition 3.8.3.E had not been entered since the CAQ was identified in 1999. Based on the above, the inspectors concluded the license had failed to correct a previously identified CAQ, in that at the TS minimum pressure of 140 psig the DG would not reach rated frequency and voltage within the 12 second fast start requirement.

Corrective Actions: At the time the inspectors left the site, the licensee was evaluating its planned corrective actions. However, the inspectors determined the non-conservative TS did not present an immediate safety concern because the annunciator response procedures for all three DGs (Division 1, 2, and 3) directed the operators to declare the DG inoperable if the pressure in both its air start receivers was below 200 psig.

Corrective Action References: IR 4483234, NRC DBAI - Non-Conservative Tech Spec Not Resolved

Performance Assessment:

Performance Deficiency: The inspectors determined the failure to correct a condition adverse to quality was contrary to 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Actions,"

and was a performance deficiency. Specifically, the licensee failed to correct non-conservative TS Condition 3.8.3.E after identifying the DG 12 second fast start criteria was exceeded when DG starting air receiver pressure was at the TS minimum pressure of 140 psig.

Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, in 2002, the licensee incorrectly determined a TS air receiver pressure of 140 psig was sufficient to ensure the lowest functional capability required for the safe operation of the facility. Therefore, it was not unreasonable to assume the current administrative controls, which prevented operation of the DGs when the pressure in both of the respective starting air receivers was less than 200 psig, could have been removed, if not for inspector involvement.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding screened as very low safety significance (Green) because it did not result in the loss of operability or Probabilistic Risk Assessment functionality of mitigating systems. Specifically, the DGs were never in a condition, related to this performance deficiency, where they would not be able to fulfill their safety function (e.g., both starting air receivers did not go below 200 psig and/or TS Condition 3.8.3.E was never entered).

Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion XVI, requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.

USAR Section 9.5.6.1.1.b., [Diesel-Generator Starting System] Safety Design Bases, states that the starting system initiates an engine start so that within 12 seconds after receipt of the start signal the diesel-generator is operating at rated speed, voltage, and frequency.

Contrary to the above, from March 12, 1999 to March 7, 2022, the licensee failed to establish measures to assure that a condition adverse to quality was corrected. Specifically, the licensee identified that at the TS 3.8.3 minimum air receiver pressure of 140 psig the DGs would not reach rated frequency and voltage within 12 seconds. This is a condition adverse to quality because it did not ensure that at the lowest air pressure the functional capability of the DGs would be maintained. Although the licensee initially planned to correct this condition by revising TS 3.8.3, Condition E via a LAR, the LAR actions were cancelled in 2002 resulting in TS 3.8.3, Condition E remaining unchanged until this issue was identified by the inspectors in 2022.

Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.

Unresolved Item Questions Regarding the Licensing Bases for Undervoltage 71111.21M (Open) Conditions and the Impact on Safety Related Motors Stalling URI 05000461/2022010-03

Description:

The Clinton Power Station (CPS) Technical Specification (TS) Bases states the operation of required emergency core cooling system (ECCS) safety functions is dependent upon the availability of adequate power sources for energizing the various components such as pump motors, motor operated valves, and the associated control components. The preferred source of power to the ECCS components is offsite power provided by the electrical grid.

When voltage on the electrical grid is insufficient to ensure the proper operation of ECCS equipment, power is provided by onsite diesel generators (DG).

Determining the adequacy of offsite power is performed by using loss of power (LOP)instrumentation. The LOP instrumentation monitors voltage provided to the 4.16 kV emergency buses to ensure safety equipment, including the ECCS, remain able to perform their safety functions. The LOP instrumentation is discussed in TS 3.3.8.1, including Table 3.3.8.1-1 and its associated TS Bases (B.3.3.8.1). Each 4.16 kV emergency bus has its own independent LOP instrumentation and associated trip logic. The voltage for the Division 1, 2, and 3 buses is monitored at two levels, which can be considered as two different undervoltage functions: loss of voltage and degraded voltage.

The purpose of the degraded voltage relays (DVR), commonly referred to as the second level undervoltage protection, is to ensure 1E Engineered Safety Features (ESF) equipment, including the ECCS, has enough voltage to be able to perform their function during a Loss of Coolant Accident (LOCA) and that the equipment will not be damaged or trip unnecessarily due to low voltage. The TS Allowable Values for the DVR (greater than or equal to 4,051 volts for Divisions 1 and 2) are intended to be low enough to prevent inadvertent power supply transfer but are also intended to be high enough to ensure sufficient power is available to the required equipment. In addition to the voltage values, the DVR have an associated time delay. For the DVR, TS Bases 3.3.8.1, state, in part, The Time Delay Allowable Values are long enough to provide time for the offsite power supply to recover to normal voltages, but short enough to ensure that sufficient power is available to the required equipment. The TSs allow this time delay to be 14 to 16 seconds. At the time of the inspection, the DVR time delay was approximately 15 seconds.

The Loss of Voltage (LOV) relays, commonly referred to as the first level undervoltage protection, utilize relays with an inverse relationship between voltage and time. This means that the lower the voltage is at the 4.16 kV safety buses, the quicker the relay will actuate.

For the LOV relays, TS Bases 3.3.8.1, states, in part, Allowable Values are low enough to prevent inadvertent power supply transfer, but high enough to ensure power is available to the required equipment. The Time Delay Allowable Values are long enough to provide time for the offsite power supply to recover to normal voltages, but short enough to ensure that power is available to the required equipment. The TS Allowable Values for voltage are greater than or equal to 2,345 V and less than or equal to 3,395 V (or approximately 56 percent to 81.5 percent of normal voltage). The TS Allowable Value for the associated time delay (for Divisions 1 and 2) is less than or equal to 5 seconds. It is important to note the 5-second time delay allowable value specifically applies when the voltage at the 4.16 kV bus is 0 Volts. At the time of the inspection, the LOV time delay was approximately 2.2 seconds when 4.16 kV bus voltage was 0 volts.

Calculation 19-AN-19, Calculation for Functional Requirements for 1st and 2nd Level Undervoltage Relays at 4kV Buses 1A1, 1B1, and 1C1, establishes the setpoints for the DVR and LOV relays. Because of the relationship between voltage and time for the LOV relays, any voltage greater than 0 volts would result in an actuation time delay greater than 2.2 seconds. Per Calculation 19-AN-19, some voltage conditions would result in the time delay for the LOV relays to exceed 10 seconds. This large time delay concerned the inspectors because when voltage levels are below a motors specified voltage rating the motor will take longer to start and may stall. In addition, the insulation on the motor windings will heat up causing potential damage to the motor. Because of this known condition, most motors are equipped with overcurrent relays which will actuate to shut off the motor before damage occurs. The inspectors reviewed additional plant information and found the Low Pressure Core Spray (LPCS) and Residual Heat Removal (RHR) pump motor ratings were approximately 75 percent voltage. The inspectors also found the LPCS and RHR pump motor overcurrent relays are set such that the overcurrent trip can occur as quickly as 7 or 8 seconds after the motor receives a start signal. This overcurrent trip time can be quicker than both the actuation times of the DVR and LOV relays. As a result, the inspectors were concerned the RHR and LPCS pumps may trip when attempting to start if an ESF signal is received while voltage on the electrical grid is less than the pumps motor rating.

The licensee performed coordination calculations for the LPCS and RHR A pump motors (both Division I equipment). The postulated events involved sustained undervoltage conditions (i.e., voltage does not recover to its normal operating band), nor does it go immediately to 0 volts (i.e., assumed voltage levels were between 55 percent to 70 percent of normal voltage concurrent with a LOCA). For voltages between 55 percent and 65 percent of normal voltage, the results showed the RHR A and LPCS pump motors would trip on overcurrent. The inspectors noted the susceptibility window (i.e., the voltage range) is likely larger. If the motors were to trip while trying to start after receiving a LOCA signal, the associated pumps would not be able to be immediately powered by the DGs after the DG synched to the 4160 kV bus. Specifically, operator action would be needed to reset the overcurrent relays and to restart the pumps.

The inspectors performed a review of CPS Updated Safety Analysis Report (USAR). The following sections were of note.

USAR Section 6.3.2.2, Equipment and Component Descriptions states, in part, the ECCS is actuated automatically and requires no operator action during the first 10 minutes following an accident.

USAR Section 1.2.1.1.2 Safety Design Criteria states, in part, [item z.] Operation of the emergency core cooling systems is initiated automatically when required, regardless of the availability of offsite power supplies and the normal generating system of the station.

USAR Section 1.2.1.2.7, Nuclear Safety Systems and Engineered Safety Features Criteria states, in part, Principal design criteria for nuclear safety systems and engineered safety features are as follows: [item c.] Standby electrical power sources are provided as necessary for support of all engineered safety feature functions (e.g., decay heat removal)under all circumstances where normal auxiliary power is not available.

USAR Section 8.3.1.1.2, Unit Class 1E A-C Power System states, in part, During sustained low grid voltage conditions which cause Class 1E equipment to operate at voltages outside their recommended continuous operating limits, a second level of relays is provided which will automatically disconnect offsite power sources and start diesel generators whenever the voltage setpoint and time delay limits have been exceeded.

Based on reviewing the above information, the inspectors' position was that CPSs licensing bases assumes the ECCS pumps will operate automatically without operator action, regardless of the availability of off-site power, for the first 10 minutes of an accident. Because of the lack of coordination between the DVR and LOV relays, during a sustained undervoltage condition with a LOCA event, the ECCS pumps at CPS could trip off due to experiencing an overcurrent condition and result in the need for operator action to reset the pump motor overcurrent relays and to restart the ECCS pumps within the first 10 minutes of an accident.

In addition to the RHR A and LPCS pumps, the inspectors were concerned the identified condition (i.e., lack of relay coordination) also affected other safety related equipment. In particular, the other RHR pumps, the High Pressure Core Spray (HPCS) pump and the safety-related service water pumps.

Due to the inspectors concern, the licensee performed EC 636544, "Loss of Voltage Relays

Analysis.

" The licensee ran multiple cases involving various voltage conditions and different transformer loadings. This evaluation confirmed there is a lack of coordination between the LOV relays and the motor protective overcurrent relays for various safety related pumps.

Affected pumps include:

1. Shutdown Service Water Pump 1A (1SX01PA)2. Shutdown Service Water Pump 1B (1SX01PB)3. LPCS Pump (1E21C001)4. RHR Pump 1A (1E12C002A)5. RHR Pump 1B (1E12C002B)6. RHR Pump 1C (1E12C002C)7. HPCS Pump (1E22-C001)

The evaluation also identified that depending on the assumed transformer loading the susceptible voltage bands can range reach as low as 57.59 percent up to 78.30 percent of normal 1E Operating bus voltage. In addition, the evaluation determined the overcurrent relay trip times would range from approximately 5 to 10 seconds and the LOVs could take up to 13+ seconds to trip. For some scenarios the HPCS LOV relays would not even pick up before the overcurrent relay trip.

The pumps listed above are credited by CPS to automatically mitigate LOCAs of different break sizes and other events not involving LOCAs.

Based on the above information, the inspectors believe the loss of power relays (DVR and LOV) at CPS did not ensure multiple safety related pumps remained powered during an accident concurrent with a sustained undervoltage condition from the grid. The postulated sustained undervoltage does not recover to its normal operating band, nor drop all the way to 0 volts. This condition could result in the tripping of the motors' overcurrent protective relays.

As a result, operator action would be required to restart the affected ECCS pumps within the first 10 minutes of an accident. This would be contrary to CPS' USAR.

The licensee has expressed the sustained undervoltage condition in question was outside of CPS current licensing bases, and that the licensing bases for the LOV relay is to detect a complete loss of offsite power (0 volts). Therefore, this issue is being documented as an unresolved item (URI) until the licensing bases for CPS can be further clarified.

Planned Closure Actions: The NRC has determined the unresolved item does not represent an immediate safety concern. This conclusion was based on: 1) offsite power voltages are monitored by operations allowing for action to restore proper voltage, if time allows, before safety equipment is demanded to operate; 2) the postulated set of conditions has a low likelihood of occurrence; and 3) equipment that is postulated to trip would be recoverable.

The inspectors will continue to work with their regional and headquarters counterparts to independently review Clinton's licensing basis and design basis requirements. The results of this review will be used to determine whether NRC enforcement action is warranted.

Licensee Actions: The licensee performed EC 636544, "Loss of Voltage Relays Analysis" to address concern raised by the NRC. The licensee entered the inspectors initial concern into the corrective action program. Since the licensee's position is that the postulated event is outside CPS' licensing bases, they have assessed the potentially affected equipment as remaining operable.

Corrective Action References: AR 04486814; NRC DBAI Potential PD Related to Loss of Voltage Relays

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On March 4, 2022, the inspectors presented the Interim Technical Debrief inspection results to Mr. B. Franzen, Engineering Director and other members of the licensee staff.

On March 22, 2022, the inspectors presented the Second Technical Debrief inspection results to Mr. B. Franzen, Engineering Director and other members of the licensee staff.

On March 23, 2022, the inspectors presented the Interim Exit Meeting inspection results to Mr. T. Chalmers, Site Vice President and other members of the licensee staff.

On May 4, 2022, the inspectors presented the Final Technical Debrief inspection results to Mr. T. Chalmers, Site Vice President and other members of the licensee staff.

On May 5, 2022, the inspectors presented the design basis assurance inspection (teams) inspection results to Mr. T. Chalmers, Site Vice President and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.21M Calculations 017589(EMD) Foundation Loads for Coil Housing Unit Assembly (1VY01S, 0

2S, 06S, 08SA, 08SB, 03S, 05S)

019893(CQD) Dynamic Qualification of American Air Filter Coolers 0

19-AJ-16 Overload Heater Sizing for Alternating Current (AC) Motor 3

Operated Valves

19-AJ-46 Circuit Breaker Sizing for AC Motor Operated Valves 1

19-AK-13 Analysis of Load Flow, Short Circuit and Motor Starting 5

Using ETAP Power Station

19-AN-19 Calculation for Functional Requirements of 1st and 2nd 5

Level Undervoltage Relays at 4kV Buses 1A1, 1B1, & 1C1

19-BD-38 Failure Modes & Effects of Motor Operated Valve Control D

Circuits Modified for NRC IN 92-18 Resolution

19-D-49 Class 1E 125 VDC System Analysis 0

1P-E-0025 Voltage at the New ERAT Control Cabinet (EIN# 0AP03E) 0

3C10-C485-001 Internal Flooding Analysis 10-A

IP-C-0006 Diesel Fuel Oil Storage Tanks Div I, II, III Tank Volume and 0

Level Calculations, Alarm Setpoints and Indicator Limits

IP-C-006 Diesel Fuel Oil Storage Tanks Division I, II, and III Tank 6

Volume and Level Calculation, Alarm Setpoints, and

Indicator Limits

IP-C-0111 DG Day Tank Level and Volume Calculations, Level 11/23/2011

Setpoint & Required Indications

IP-CL-032 Seismic Qualification of MOVs 1E12-F064A, B, and C, A/D, 1

4-300# Gate with SB-00-10 Operator

IP-M-005 Water Hammer Calculation for RHR System GL 89-10 1

Valves

IP-M-0129 RHR Loop A & B Differential Pressure Calculations for 4

GL 89-10

IP-M-0486 Shutdown Service Water (SX) System Hydraulic Network 6

Analysis Model and Flow Balance Acceptance Criteria

IP-M-0513 Division I, II, and III SX Pipe Wall Thinning Analysis 0-M

IP-O-0122 Tech Spec Loop Uncertainty Evaluation for DG Air Receiver 04/15/1999

Inspection Type Designation Description or Title Revision or

Procedure Date

Pressure SR 3.8.3.4

NES-MS-03.1 Piping Minimum Wall Thickness Calculation 6

VY-01 VY System Cooling Load Calculation (ECCS/MSIV) 9

(Post-LOCA, Shutdown, and Normal Modes)

Corrective Action 04231346 NRCID: DBAI Question Regarding RPV Blowdown During 03/20/2019

Documents SBO

04480017 ERAT Load Tap Changer REV PWR LED Lit 02/22/2022

1-99-03-097 Division 1 DG Start Times for CPS 2802.00, Section 8.1 03/12/1999

Unacceptable

1-99-03-171 Division 1 DG Start Times for CPS 2802.00, Section 8.1 and 03/12/1999

8.2 Unacceptable

1-99-07-088 Non-Conservative LCO 3.8.3.E (Minimum Air Start Pressure 07/16/1999

Requirements) for Division 3 DG

117504 OE 14127, Grand Gulf Pin Hole Leak, Min Flow Line, RHR 07/30/2002

1600935 Division 1 DG Output Breaker Failed to Close During 01/30/2014

Synch 26 DEC 13

198323 RHR A Pump Min Flow Piping Erosion 01/29/2004

2447922 Division II DG Output Breaker Failed to Close During Synch 03/02/2015

230952-07 NRC Information Notice 2019-01 - Inadequate Evaluation of 05/10/2019

Temporary Alterations

282747 NRC ISI: Wear Rate Methodology in EC 624182 09/27/2019

283049 NRC ID Questions on Work Order 1230601-01/39 09/28/2019

288995 NRC ISI Exit Meeting - Minor Violations 10/18/2019

289811 NRC ID'd ASME Code Requirements Used in EC 629521 10/21/2019

4352219 EOID 1VY03S RHR 1A Room Cooler Thru Leak 06/24/2020

4352621 Emerging Trend for Emergency Core Cooling System Room 06/25/2020

Cooler Tubing Leaks

4359497 Trend SX System Leaks 07/28/2020

4368479 1VY07AB: RHR Cooler RHR Eddy Current Results 09/10/2020

4461964 ~1/4 GPM Leak Downstream of 1SX063A 11/19/2021

4470876 1VY02S RHR A Cooling Cabinet Leaking ~30dpm 01/10/2022

451618 Found 1E12-F064A Shut 02/08/2006

948468 1E12F064A: RHR A Minimum Flow F064A Failed to Stroke 08/01/2009

Inspection Type Designation Description or Title Revision or

Procedure Date

Shut

Corrective Action 04483423 NRC DBAI: Potential Enhancement to 19-AK-13 03/08/2022

Documents 04483988 NRC DBAI: Design Enhancements 03/10/2022

Resulting from 04484000 NRC DBAI Communication - Enhancement Opportunity 03/10/2022

Inspection 04485768 NRC ID: ERAT Trip Data Sheet Not Completed 03/18/2022

4478550 Zip Ties Found on IA Line Near 1IA744A (IA Isol for 02/16/2022

1SX027A)

4479775 Compensatory Action for 1SX063A Not Meeting Intent of Op 02/21/2022

Eval 635584

4479909 Enhancement: PM Generation for RHR Minimum Flow 02/22/2022

Lines

4481369 NRC ID: Cyber Security Tamper Seal Found Unsecure 02/28/2022

4481373 NRC ID: Ladder Station #21 Found Empty 02/28/2022

4481604 Issues with Code Case Adherence 03/01/2022

4481908 Operating DG at > 100% Loading Allowed but Hours Not 03/02/2022

Tracked

4482210 NRC ID: Lesson Plan Not Updated after EC 355405 03/03/2022

4482444 DBAI - TS 3.8.1 Bases Enhancement 03/04/2022

4482532 NRC ID: 120V SR Solid-State Comp. Hi-Voltage Exposure 03/04/2022

Impacts

4483234 Incorrectly Closed Corrective Action to Resolve an Identified 03/07/2022

Non-Conservative Technical Specifications for Minimum

Required DG Starting Air Pressure

4483423 NRC DBAI - Potential Enhancement to 19-AK-13 03/08/2022

4483503 Revision to Note in 4200.01 03/08/2022

4483988 NRC DBAI - Design Enhancements 03/10/2022

4484000 NRC DBAI Communication - Enhancement Opportunity 03/10/2022

4484186 Temperature Discrepancy in 4200.01 03/11/2022

4485768 NRC ID: ERAT Trip Data Sheet Not Completed 03/18/2022

4486814 NRC DBAI Potential PD Related to Loss of Voltage Relays 03/23/2022

Drawings 1RI01 Sh 2 of 4 Reactor Core Isolation Cooling 08/25/1983

1RI01 Sh 3 of 4 Reactor Core Isolation Cooling 08/25/1983

1RI01 Sh 4 of 4 Piping Analytical & Physical Data 10

Inspection Type Designation Description or Title Revision or

Procedure Date

Reactor Core Isolation Cooling

1SX09 Service Service Water 5

486342 1E12F054A (RHR A MIN FLOW) Did Not Stroke Open 05/03/2006

When Expected

93-14626 4-300 Wend Ends, Carbon Steel Flex Wedge Gate Valve B

with SB-00 Limitorque

E02-1AP47-001 Auxiliary Building Motor Control Center 1A1 AF

E02-1AP99 Sheet ERAT SVC Annunciator Schematic and PLC AP120E Digital E

113 Inputs/Outputs

E02-1AP99 sheet ERAT SVC Freeze Signal C

115

E02-1DC01-001 125V DC MCC 1A AG

E02-1RH99, Residual Heat Removal Sys (RH) Pump 1A Min. Flow VLV N

SH511 1E12-F064A Heat EXCH. 1A Outlet Valve 1E12-F068A

Clinton Power Station Unit 1

M-1SX09021X SX SW Support Detail E

M05-1054 P&ID Diesel Generator Building Floor Drain D

M05-1077 Standby Liquid Control AC

M06-1075 Sh 14 Residual Heat Removal Piping Y

M06-1075 Sh 24 Residual Heat Removal Piping Z

M06-1079 Sh 2 Reactor Core Isolation Cooling Piping AD

M06-1079 Sh 3 Reactor Core Isolation Cooling Piping AT

M06-1079 Sh 5 Reactor Core Isolation Cooling Piping AF

RH-14 Residual Heat 12

RH-5 Residual Heat 12A

Engineering 0000453768 ERAT LTC Additional Evaluation for Rev PWR Block Reset 02/28/2022

Changes Delay

250 Change the Description of the 5 Start Requirement in the 3

Documents

30744 Replace Div. 1 DG Air Start Solenoid Operated Pilot Valves 11/06/1998

2233 Tube Repair for Room Cooler Coils, 1VY02AA/AB 0

353799 Revise VTIP to Provide Instructions for Cooling Coil 0

Replacement

Inspection Type Designation Description or Title Revision or

Procedure Date

353799 Supplemental Installation Details for Replacement Cooling 0

Coils for Cooling Coil Cabinets 1VY05S and 1VY06S

355405 Replace Division 2 Diesel Generator Governor Actuators 0

401924 RCIC Piping Evaluation for Extended Loss of AC Power 0

Temperatures

2614 RCIC Tank (1RI01T) Drain/Overflow Changes, Including 02/01/2019

Eliminating Tank Drain Valve 1E51F387

27704 Functionality Evaluation of Suppression Pool Temperature 000

During Station Blackout

27757 Evaluation of Station Blackout During Past Plant Conditions 000

635866 VTIP Update: Add Additional Coil Cabinet (EIN Applicability) 0

to EC 353799

635866 Add Additional Coil Cabinet (EIN Applicability) to EC 353799 01/23/2006

Supplemental Installation Details for 1VY02S

EC 351272 Remove Float Rod Collar from Diesel Generator Floor Drain 0

System Sump Pump Mechanical Alternators

EC 634793 Emergency Reserve Auxiliary Transformer (ERAT) 0

ON-LOAD TAP Changer (LTC) Motor Replacement

EC 636179 ERAT Voltage Regulator Relay Setting Enhancement 0

Engineering 5206687-20 Evaluation of [Ultrasonic Testing] Results on 3/4/2022 03/04/2022

Evaluations 624113 Evaluate RHR "A" Min Flow Line Wall Thinning 1

24182 Evaluation of 1E12F046B and 1E12F018B Valve Body 1

Degradation

EPU-T0903 Extended Power Uprate Task T0903 Station Blackout 0D

GE-NE-A22- Clinton Power Station Extended Power Uprate 0

00110-59-01 Task T0903: Station Blackout

IP-Y-0001 Determine the Amount of Boric Acid Required to Mix in the 1

RCIC Storage Tank

Miscellaneous Surveillance Frequency Control Program 38

Test Summary CPS# 2802.00: Div.1 Diesel Air Capacity 03/13/1999

Test

04066250-02 OPEX Evaluation of NRC IN 2017-06: Battery and Battery 11/09/2017

Charger Short-Circuit Contribution to a Fault on the Direct

Current Distribution System

Inspection Type Designation Description or Title Revision or

Procedure Date

21A9443 Reactor Core Isolation Cooling Pump 4

21A9526 Turbine, Steam, Auxiliary Drive 3

DC-DG-01-CP Diesel Generator Design Criteria 8

DC-ME-09-CP Equipment Environmental Design Conditions Clinton Power 13

Station Unit 1 Illinois Power Company

K-2989-0001 Instruction Manual Three Phase Thyristor Controlled 04/25/1979

K2989-0001 Vendor Technical Manual for Power Conversion Products 10/28/2015

PTP-DG-D03 Div III Diesel Generator & Fuel Oil 01/03/1986

Woodward EGB Proportional Governor/Actuator N/A

Vendor Manual

2340C

NDE Reports 1133424-07 Eddy Current Examination Final Report 04/28/2010

1133425-07 Eddy Current Examination Final Report 04/28/2010

21-108 Ultrasonic Thickness Calibration Sheet 11/22/2021

2-025 Ultrasonic Thickness Calibration Sheet 03/04/2022

Operability 4461964-05 1SX04AA-8" 0

Evaluations

Procedures CL-PRA-006 Dependency Notebook 3

CPS 1003.10 Clinton Power Station (CPS) Program for NRC Generic 8b

Letter 89-13 (Service Water Problems Affecting

Safety-Related Equipment)

CPS 2802.00 Test Summary CPS #2802.00: Div. 1 Diesel Air Capacity 03/12/1999

Test

CPS 3220.01 Suppression Pool Makeup (SM) 12c

CPS 3317.01 Fuel Pool Cooling and Cleanup (FC) 34a

CPS 3318.01 Suppression Pool Cleanup/Transfer (SF) 10f

CPS 4200.01 Loss of AC Power 26e

CPS 4402.01 EOP-6 Primary Containment Control 31

CPS 4411.10 SLC Operation 6g

CPS 5007.05 Alarm Panel 5007 Annunciators - Row 5 30d

CPS 5008.05 Alarm Panel 5008 Annunciators - Row 5 32c

CPS 5013.07 Alarm Panel 5013 Annunciators - Row 7 26e

CPS 5013.08 Alarm Panel 5013 Annunciators - Row 8 25d

Inspection Type Designation Description or Title Revision or

Procedure Date

CPS Maintenance of Anchor/Darling Bolted Bonnet Gate Valves 16a

20.03C001 Checklist

CPS 8130.01 Heat Exchanger Maintenance/Repairs 8

CPS 9000.05 Suppression Pool Temperature Log 27c

CPS 9082.01 Offsite Source Power Verification 41a

DC-VY-01-CP Emergency Core Cooling System (ECCS) Equipment 5

Cooling System Design Criteria

ER-AA-330-009 ASME Section XI Repair/Replacement Program 18

ER-AA-335-1006 Heat Exchanger Electromagnetic Testing Methodology 6

HVAC-01-CP HVAC Systems and Chilled Water Systems Acceptance 8

Criteria

MA-AA-723-301 Periodic Inspection of Limitorque Model SMB/SB/SBD-000 13

Through 5 Motor Operated Valves

OP-AA-102-106 Operator Response Time Program 8

WC-AA-120 Preventative Maintenance (PM) Database Revision 6

Requirements

WC-AA-120-F-02 PM Modification Request (PMMR) E-Strategy PMMR Tool 1

Work Orders 00912092 Replace Capacitor C-1, Sensing, Amp, & Firing BD's 03/28/2012

01426769 Test DIV 1 DG Protective Relays 07/12/2012

01579812 125 VDC Charger Load Test 09/23/2014

04680099 125V DC Charger Load Test 03/16/2021

04820186 9080.13A20 OP DG 1A 24 Hr Run and Hot Restart 11/19/2020

0814120 125V DC Charger Load Test 02/20/2017

1133424 Inspect, Boroscope, Clean, Eddy Current and Hydrolase as 04/26/2010

Required

1133425 Inspect, Boroscope, Clean, Eddy Current, and Hydrolase as 04/26/2010

Required

1408026 Perform DIV I SX System Testing IAW 2700.12 07/16/2012

1561998 Test HX Performance ECCS RHR Room 1A Coil Cabinet 08/03/2012

1609464 Perform DIV 1 SX System Testing IAW 2700.12 07/14/2014

1650129 1DG01KB Governor, Speed Regulating Actuators, Replace 09/30/2019

1686023 1VY02AB - Inspect, Clean, Eddy Current, & Hydrolase as 06/28/2016

Required

Inspection Type Designation Description or Title Revision or

Procedure Date

1686097 1VY02AA - Disassemble, Inspect, Eddy Current and Clean 06/28/2016

1804388 Test HX Performance ECCS RHR Pump Room 1A Coil 05/28/2015

Cabinet

4713421 9080.22R20 DG 1B Integrated Test (All Sections) 10/08/2019

504082 Perform UT Inspection per CR 117504, Industry Operating 01/28/2004

Experience

CPS 2802.00 Verify Division II Diesel Starts 12/20/1998

N-CL-OPS- Diesel Generator/Diesel Fuel Oil Lesson Plan 8

264000

PTP-DG DO-01 Diesel Generator Preoperational Test 01/23/1986

23