IR 05000461/2022011
| ML23027A235 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 01/27/2023 |
| From: | Robert Ruiz NRC/RGN-III/DORS/RPB1 |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2022011 | |
| Download: ML23027A235 (1) | |
Text
January 27, 2023
SUBJECT:
CLINTON POWER STATION - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000461/2022011
Dear David Rhoades:
On December 2, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Clinton Power Station and discussed the results of this inspection with T. Chalmers, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations problem identification and resolution program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for problem identification and resolution programs.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
No findings or violations of more than minor significance were identified during this inspection. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Signed by Ruiz, Robert on 01/27/23 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: NPF-62 Report Number: 05000461/2022011 Enterprise Identifier: I-2022-011-0043 Licensee: Constellation Nuclear Facility: Clinton Power Station Location: Clinton, IL Inspection Dates: November 14, 2022 to December 02, 2022 Inspectors: T. Hartman, Senior Project Engineer E. Magnuson, Reactor Inspector A. Muneeruddin, Resident Inspector E. Rosario, Reactor Inspector Approved By: Robert Ruiz, Chief Reactor Projects Branch 1 Division of Operating Reactor Safety Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at Clinton Power Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)
- (1) The inspectors performed a biennial assessment of the effectiveness of the licensees Problem Identification and Resolution program, use of operating experience, self-assessments and audits, and safety-conscious work environment.
Problem Identification and Resolution Effectiveness: The inspectors assessed the effectiveness of the licensees Problem Identification and Resolution program in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a 5-year review of the reactor core isolation cooling system. In addition, the inspectors reviewed any corrective actions related to the White Notice of Violation (NOV) in the Security cornerstone that were completed since the Inspection Procedure 95001 Supplemental Inspection was completed.
Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience.
Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through audits and self-assessments.
Safety-Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B Based on the samples reviewed, the team concluded that the licensee's implementation of the Corrective Action Program (CAP) was generally effective and supported nuclear safety.
Effectiveness of Problem Identification:
Based on the samples reviewed, the team concluded that the licensee continued to identify issues at a low threshold and appropriately entered these issues into the CAP. The team determined that the licensee usually entered problems into the CAP in a timely manner and with adequate information. However, the team identified a condition adverse to quality that should have been identified and entered into the CAP for resolution. Additional details of this issue are discussed in the Minor Violation section of this report.
The team also noted that some deficiencies were identified by external organizations, including the NRC, that had not been previously identified by licensee staff and were subsequently entered into the CAP. In addition, the licensee also utilized a number of CAP support processes to identify problems, including the self-assessment and audit process and the operating experience program. For example, the licensee performed department self-assessments and quality assurance audits to identify issues in station processes. Similarly, the licensee screened issues from both NRC and industry operating experience and entered them into the CAP when they were applicable to the station.
The team determined that the licensee was generally effective at trending low-level issues and taking appropriate corrective actions to prevent more significant problems from developing. In addition, the licensee used the CAP to document instances in which previous corrective actions were ineffective or were inappropriately closed.
The team performed a 5-year review of the reactor core isolation cooling (RCIC) system issues. As part of this review, the team interviewed engineers, reviewed the system health and maintenance rule information, and reviewed selected corrective actions and condition evaluation documents. The team concluded that issues with RCIC were identified and entered into the CAP at a low threshold and were resolved in a timely manner commensurate with their safety significance. For the areas walked down, the team did not identify any additional issues.
Effectiveness of Prioritization and Evaluation of Issues:
The inspectors reviewed items in the CAP to ensure thorough and timely evaluation of identified issues, including disposition of operability and reportability issues. Causal products were evaluated for consideration of extent of condition and cause associated with identified root and contributing causes. These products were also reviewed for consideration of potential generic implications, common-cause concerns, and evaluation of previous occurrences of issues.
Based on the samples reviewed, the team determined that licensee performance was generally effective at prioritizing and evaluating issues commensurate with the safety significance of the identified problem. The station ownership committee and the management review committee meetings were generally thorough and intrusive in reviewing issues and prioritizing actions. In addition, the team observed a healthy dialogue between the members of these committees and the members challenged each other when dispositioning issues.
In general, once a degraded or non-conforming condition was identified, the CAP directed that an equipment operability or functionality review be performed. As a result, most of the samples reviewed were evaluated appropriately and in a timely manner.
Effectiveness of Corrective Actions:
Based on the samples reviewed, the team determined that the licensee was generally effective in corrective action implementation. In general, corrective actions for deficiencies that were safety significant were implemented in a timely manner. Problems identified using a root cause or other cause methodologies were resolved in accordance with CAP requirements. The corrective actions assignments that were sampled by the team for selected NRC documented violations and for licensee event reports (LERs) were generally effective and timely.
Assessment 71152B Based on a review of documents and interviews with licensee staff, the team did not identify any impediment to the establishment of a safety-conscious work environment. The team reviewed the results from the 2021 Safety Culture Assessment, the culture survey from the first quarter of 2021 performed by the licensee, and the Nuclear Safety Culture Monitoring Panel meeting minutes. The team also conducted one-on-one interviews with 21 licensee staff concerning the effectiveness of the CAP, the ability to raise issues, and the freedom from potential retaliation for raising issues.
In general, the licensee's staff was aware of and familiar with the CAP and other processes, such as the Employee Concerns Program, to raise nuclear safety concerns. Licensee staff indicated they could raise safety concerns without a fear of retaliation. Through the interviews and document reviews, the team was not provided or identified any examples of retaliation for raising nuclear safety concerns. The staff interviewed believed that operational issues and issues with high safety significance were being appropriately addressed in a timely manner.
Assessment 71152B The inspectors reviewed the licensees operating experience program to ensure items are adequately evaluated for applicability, and applicable lessons learned are communicated to appropriate organizations and implemented as appropriate.
Based on the samples reviewed, the team determined that the licensee's performance in the use of operating experience was generally effective. The licensee screened industry and NRC operating experience information for applicability to the station. When applicable, actions were developed and implemented to prevent similar issues from occurring. Operating experience lessons learned were communicated and incorporated into plant operations. The team observed the information being used in daily activities, such as pre-job briefs, as well as issue reviews and investigations.
The team did identify that the licensee has a tendency to use a narrow scope when evaluating whether the operating experience applies to the station or not. This can lead to missing valuable insights from across the industry.
Assessment 71152B The inspectors reviewed a sample of completed self-assessments and audits conducted by licensee personnel, corporate personnel, the nuclear oversight group, and external organizations. The products reviewed included assessments of each of the cornerstone areas and CAP specific items.
Based on the samples reviewed, the team determined that the licensee's performance of self-assessments and audits was generally effective. The licensee performed department self-assessments and nuclear oversight audits throughout the organization on a periodic basis. These self-assessments and audits were generally effective at identifying issues and enhancement opportunities at an appropriate threshold. The self-assessments and audits reviewed by the team identified issues that were not previously known, including issues within the CAP itself. The team did not identify any concerns in this area.
Minor Violation 71152B Minor Violation: On November 16, 2022, while performing a plant tour, the NRC inspectors identified a valve inside containment, which was labeled as "Locked Open," without a locking device. The valve is associated with the 'B' train of the H2/O2 monitoring system and is also associated with containment penetration 153. This valve is locked open to ensure a flow path is available from the containment and drywell areas to the monitoring portion of the system.
The licensee acknowledged that the valve was required to be locked open, entered the issue into their CAP, and promptly locked the valve in the open position.
The last known operation of this component was after a local leak rate test in December 2019. After the licensee completed required local leak rate testing of penetration 153, the procedure directs the operator to realign the system in accordance with CPS 3315.01V001, "Containment Monitoring Valve Lineup," which directs the valve to be restored to the "Locked Open" position. This component, as well as the procedures are all identified as safety-related.
This means the valve has potentially been in the incorrect position (not locked) for 3 years and not identified by the licensee. However, the licensee had previously stopped using this train of H2/O2 monitoring and no longer took credit for it in their analyses.
The inspectors determined that the failure to perform a safety-related procedure, as written, was a performance deficiency and a violation of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings."
Screening: The inspectors determined the performance deficiency was minor. This performance deficiency did not adversely affect the mitigating cornerstone objective because the valve was still open and would allow process flow (as required). In addition, this train of the system is no longer in use nor credited for use.
Enforcement:
This failure to comply with 10 CFR 50, App. B, Criterion V constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On December 2, 2022, the inspectors presented the biennial problem identification and resolution inspection results to T. Chalmers, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71152B Corrective Action AR 1040993 Perform PHC Presentation for RCIC Water Hammer 03/10/2010
Documents Solutions
AR 1594407 Automatic Trip of Breaker 1AP07EJ 12/09/2013
AR 4020569 Manual Reactor Scram due to Loss of Feedwater Heating 06/11/2017
AR 4082490 Reactor Scram from Trip of 1AP07EJ 12/09/2017
AR 4232132 DBAI. Calculation Updates Missed During LAR Impact 03/22/2019
Review
AR 4233486 DBAI. Missing Evaluation for RCIC Piping Stresses at EOP 03/27/2019
CO
AR 4233500 DBAI. Calc 01rI16 Contains Incorrect Reference and Value 03/27/2019
AR 4279730 Both Divisions of RT Differential Flow Failed Downscale 12/05/2019
AR 4284526 EOID SRV 51B Actuates Instead of 41B 10/03/2019
AR 4311701 Scheduled Work Could Not Be Performed 01/21/2020
AR 4313467 Out of Tolerance Trend for 4.16kV Degraded Voltage Relays 01/28/2020
AR 4329201 Entered Loss of Feedwater Heating 4A Heater Restoration 03/24/2020
AR 4361015 Reactor Power Increased About 8 MWth After CP Swap 08/04/2020
AR 4362498 MCR Alarm 5002-3P for P612 Hardware Fault on Drop 5 08/11/2020
AR 4365244 NOS Finding: Corrective Actions from 2018 ARMA 08/25/2020
Ineffective
AR 4371658 1E51-F077 Indicates Mid Position After Trying to Stroke 09/24/2020
AR 4376308 OE: Hand Injury Requiring Treatment Beyond First Aid 10/13/2020
AR 4378023 OE: Rx Wtr Clean Up Precoat Lost 02/04/2021
AR 4383622 OE: Truck Drives Over Trenches Breaking Covers 11/11/2020
AR 4384779 0VC21YB 0VC24YB & 0VC27YB Lost Power 11/16/2020
AR 4384784 Annunciator for 5050-8L is Dimly Lit 11/16/2020
AR 4385961 4.0 Critique 4008.01 Abnormal Reactor Coolant Flow 11/18/2020
AR 4390634 GNF 3 Transition for Cycle 21 Issue with TBSOOS Condition 12/16/2020
AR 4394349 Result of Closing 1E51F063 for Troubleshooting 01/05/2021
AR 4407380 Trend IR - ILT 19-1 Throughput 03/08/2021
AR 4409255 ILT Weekly Review Exam Compromise 03/15/2021
AR 4411326 RCS Reactor Sulfates Action Level > AL-2 Conductivity > 03/24/2021
Inspection Type Designation Description or Title Revision or
Procedure Date
AL-1
AR 4421018 OE: Underground Piping Leak on Plant Service Water 05/03/2021
System
AR 4425550 OE: HPCI - RCIC Not Aligned Prior to Entering Tech Spec 11/16/2020
App
AR 4426700 RR FCV 'B' 1B33F060B Drift and Saturation Issues 05/31/2021
AR 4428969 Div 3 Undervoltage Relays Fail As Found Testing 06/12/2021
AR 4444360 OE: Power Reduction After FW Pump Trip and RFCV 05/15/2021
Runback
AR 4447019 NOS ID: ARMA - MRule Program Requires Management 09/17/2021
Attention
AR 4450317 C1R20 Snubber 1RI18002S Failed Functional Test 10/02/2021
AR 4450450 A Fuel Bundle Was Placed in NW Quadrant with SRM A 10/03/2021
INOP
AR 4451945 Loss of ERAT 10/09/2021
AR 4452166 Fuel Bundle Inadvertent Contact with the Steam Dam 10/11/2021
AR 4460431 Observed Reactor Water Clean Up Efficiency not as 12/28/2021
Expected
AR 4464995 9443.04 Under WO# 4935743 was not Completed by PM 12/06/2021
Late Date
AR 4476101 NOS ID Finding Part 1 of 2: MD Failed to Maint Control 02/04/2022
AR 4478345 NRC Green NCV 2021004-02 Integrated Inspection Report 02/15/2022
AR 4478357 NRC Green Finding 2021004-01 Integrated Inspection 02/15/2022
Report
AR 4487680 NRC ID: Teletower in RCIC Room 03/27/2022
AR 4495747 WHR Violation Covered Worker Exceeded 54 Hours/Week 03/27/2022
AR 4504335 VP Chiller A (1VP04CA) Trip 08/16/2022
AR 4504884 NRC Green NCV 2022010-01 DBAI Inspection Report 06/10/2022
AR 4504887 NRC Green NCV 2022010-01 DBAI Inspection Report 06/10/2022
AR 4511806 ENG ID: Trend IR for Meeting Attendance 07/19/2022
AR 4522105 OE: Halon Actuation due to Human Performance Error 09/13/2022
AR 4524044 Trend: 1 Near Miss & 2 Ops CC Events in Less Than 09/22/2022
Inspection Type Designation Description or Title Revision or
Procedure Date
Months
AR 4537387 Spike in DW RF from Sump 11/15/2022
AR 4537476 MWPH: Upflow Filter Logic Error 11/15/2022
AR 521373 OE23020 Potential for RCIC Water Hammer - Nine Mile 08/18/2006
Point 2
Corrective Action AR 4537383 NRC Identified Missing Lock Wire on 1CM019 11/16/2022
Documents AR 4537468 NRC ID: PI&R Inspection: CAPE 4362498 Actions not 11/16/2022
Resulting from Generated
Inspection AR 4537691 PI&R NRC Found Damaged Insulation on Duct Work near 11/17/2022
1VX72Y
AR 4538360 NRC ID: Degraded Insulation CTMT (781', AZM 120) Line 11/21/2022
1CY28C
AR 4539619 NRC ID: EFR 4311763-73 Is Not Updated with MRC 11/29/2022
Comments
AR 4539625 NRC ID: OPEX Review Didn't have Proper Closure 11/29/2022
Documentation
AR 4539854 ATI Improper Closeout led to Revisions Not Being Issued 11/30/2022
Drawings M05-1034, Sheet P&ID Containment Monitoring System (CM) K
Miscellaneous On-Line WO Backlog 11/17/2022
Clinton Nuclear Safety Culture Review Meeting (NSCRM) 07/19/2022
Minutes
Root Cause: Fuel Bundle Placed in Core Without the 12/17/2021
LER 2021-001-00 Core Monitoring System Software Modeling Error Results in 08/19/2021
Condition Prohibited by Technical Specifications
LER 2021-002-01 Core Alterations with Source Range Monitor Inoperable 02/24/2022
Results in Condition Prohibited by Technical Specifications
NOSA-CPS-21- Corrective Action Program Audit Report 09/22/2021
Operability AR 4384720 0TSVC617A Output 2 OOT Trend Code B1 11/16/2020
Evaluations AR 4448556 ERAT LTC Failed to Control Voltage within Required Band 09/25/2021
AR 4461964 ~ 1/4 GPM Leak Downstream of 1SX063A 11/19/2021
Procedures CPS 3303.01 Reactor Water Cleanup (RT) 39C
Inspection Type Designation Description or Title Revision or
Procedure Date
CPS Containment Monitoring Valve Lineup 11D
3315.01V001
EI-AA-101 Employee Concerns Program 11
EI-AA-101-1001 Employee Concerns Program Process 15
ER-AA-320 Maintenance Rule Implementation per NEI 18-10 0
ER-AA-320-1001 Maintenance Rule 18-10 - Scoping 0
ER-AA-320-1003 Maintenance Rule 18-10 - Failure Definition 0
ER-AA-320-1004 Maintenance Rule 18-10 - Performance Monitoring and 1
Dispositioning Between (a)(1) and (a)(2)
ER-AA-320-1006 Maintenance Rule 18-10 - Expert Panel Roles and 0
Responsibilities
ER-AA-320-1007 Maintenance Rule 18-10 - Periodic (a)(3) Assessment 1
OP-AA-108-103 Locked Equipment Program 3
OP-CL-108-103- Locked Valve Lineup (Outside of Drywell) 2
1001
OP-CL-108-103- Locked Valve Lineup (Outside of Drywell) 3
1001
PI-AA-1012 Safety Culture Monitoring 4
PI-AA-115 Operating Experience Program 5
PI-AA-120 Issue Identification and Screening Process 12
PI-AA-125 Corrective Action Program (CAP) Procedure 8
PI-AA-125-1003 Corrective Action Program Evaluation Manual 7
PI-AA-126-1001 Self-Assessments 5
WC-AA-106 Work Screening and Processing 20
Self-Assessments AR 4296535 2020 Clinton Clearance and Tagging Self-Assessment 11/22/2020
AR 4425846 Ops Configuration Control Self Assessment 11/30/2021
AR 4459608 Clinton Operations Training Comprehensive 01/14/2022
Self-Assessment
Work Orders WO 4662767 MC153002 LLRT: H2/O2 Mon 1CM015B CT/DW Samp Rtrn, 12/28/2019
Test Set D
11