IR 05000461/2024012
| ML24138A051 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 05/20/2024 |
| From: | Robert Ruiz NRC/RGN-III/DORS/RPB1 |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2024012 | |
| Download: ML24138A051 (1) | |
Text
SUBJECT:
CLINTON POWER STATION - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000461/2024012
Dear David P. Rhoades:
On April 26, 2024, 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 Norha Plumey, 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 to confirm that the station was complying with NRC regulations and licensee standards. Based on the samples reviewed, the team determined that your program complies with NRC regulations and applicable industry standards such that the Reactor Oversight process can continue to be implemented.
The team also evaluated the stations effectiveness in identifying, prioritizing, evaluating, and correcting problems, reviewed licensee audits and self-assessments, and its use of industry and NRC operating experience information. The results of these evaluations are in the enclosure.
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.
May 20, 2024 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, 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:
05000461/2024012 Enterprise Identifier:
I-2024-012-0013 Licensee:
Constellation Nuclear Facility:
Clinton Power Station Location:
Clinton, IL Inspection Dates:
April 08, 2024 to April 26, 2024 Inspectors:
M. Garza, Senior Project Engineer N. Shah, Senior Project Engineer M. Stafford, Senior Resident Inspector J. Steward, Senior 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 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 five-year review of the Essential Service Water System. The corrective actions for selected non-cited violations were evaluated as part of the assessment.
- 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 Corrective Action Program 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 was appropriately entering 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.
The team noted that issues were being identified by all levels of the organization and with varying degrees of safety significance. Some deficiencies were identified by external organizations, including the NRC, and they were subsequently entered into the CAP for resolution. The licensee also utilized a number of CAP support processes to identify problems, including the self-assessment and audit processes and the Operating Experience (OE) Program. Any identified deficiencies or improvement opportunities were entered into the CAP for resolution.
The team performed a 5-year review of the Essential Service Water System. As part of this review, the team reviewed plant health reports, selected corrective action and condition evaluation documents, and interviewed the system engineer. The team also performed a system walkdown to assess the material condition of system piping, selected components, and surrounding areas. The team concluded that, in general, deficiencies and concerns were identified and entered into the CAP at a low threshold. Corrective actions appeared to be adequate and timely, commensurate with their safety significance. it During interviews, workers were familiar with how to enter issues into the CAP and stated that they were encouraged to use the CAP to document issues. During plant walkdowns, the team observed numerous action tags, indicating that workers were identifying issues in the field.
The team determined that the station was generally effective at identifying negative trends that could potentially impact nuclear safety. For the areas reviewed, the team did not identify any issues of significance in problem identification.
Effectiveness of Prioritization and Evaluation of Issues:
Based on the samples reviewed, the team determined that licensee performance was generally effective at prioritizing and evaluating issues commensurate with the safety significance of the identified problem.
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.
The inspectors also did a selective review of issues identified by the NRC either documented as observations, or for which findings or other enforcement was issued. These issues were properly documented and screened in the CAP.
In general, the licensee thoroughly evaluated issues to ensure that resolutions address causes and extent of condition evaluations commensurate with their safety, security, and radiological significance in accordance with their CAP procedure. However, the team noted a few examples of CAP Evaluations, where the associated extent of condition reviews were lacking details on the depth of the evaluation and were not stand-alone. After discussion with licensee staff, in some of these examples, the team learned that a thorough review was completed but it was not documented. The team also determined that the corrective actions to address the issues found from the extent of condition reviews were in place. Therefore, there are no findings or violations associated with this assessment. The licensee wrote AR 04769599 to document and review this observation.
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 requiring the performance of a root cause evaluation or other causal evaluation methodologies were resolved in accordance with CAP requirements. The team sampled assignments associated with violations that were previously identified by the NRC and with licensee event reports.
The team determined that the corrective actions sampled were generally effective and timely.
For the areas reviewed, the team did not identify any issues of significance in the effectiveness of corrective actions.
Assessment 71152B Use of Operating Experience Based on the samples reviewed, the team determined that the licensee's performance in the use of operating experience (OE) was generally effective. The licensee screened industry and NRC OE information for applicability to the station. When applicable, condition reports were written, and actions were developed and implemented to prevent similar issues from occurring. Overall, OE lessons learned were communicated and incorporated into plant operations. The team observed OE information being used in daily activities, such as pre-job briefs, as well as issue reviews and investigations.
During the review, the team identified some examples of operating experience evaluations that were limited in scope, lacked detail, and did not fully evaluate the operating experience.
Further, the team also noted that although the operating experience program procedure required that inadequate evaluations be documented in the CAP, no such issues had been recorded in the past two years. Finally, the team also noted that there was no specific guidance, either formal or informal, regarding what constituted an acceptable operating experience evaluation; instead, this was supposed to be reinforced via the CAP as inadequate reviews were documented. While the majority of the evaluations the team reviewed were adequate, the lack of specific procedural guidance and lack of evidence that the evaluations were being properly reviewed by the licensee, was a concern. The licensee wrote AR 04769599 to document and review this observation.
Assessment 71152B Self-Assessments and Audits Based on the samples reviewed, the team determined that the licensee's performance of self-assessments and audits was generally effective. The licensee performed department self-assessments and Quality Assurance audits throughout the organization on a periodic basis. These self-assessments and audits were generally effective at identifying issues and enhancement opportunities at an appropriate threshold. The team did not identify any issues of significance in the area of self-assessments and audits.
Assessment 71152B Safety Conscious Work Environment 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 recent safety culture self-assessments and had a discussion with the site Employee Concerns Program (ECP) Coordinator. The team also conducted one-on-one interviews with 29 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 ECP, 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 did not identify, nor were any examples provided, 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.
From the team's reviews and discussions with licensee staff, several examples were identified of low-level issues that are not being addressed. These issues are in the CAP process; however, the resolution of the issues have been delayed several times. From our interviews and discussions with licensee staff, the inspectors received feedback that delaying the resolution of these issues creates a perception that these particular groups that are affected by the low-level issues are being pushed aside or that the site doesnt care about them and what affects them. Despite this feedback from licensee staff, these individuals confirmed that they would not hesitate to raise safety concerns if needed. The licensee wrote AR 04769599 to document and review this observation.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On April 26, 2024, the inspectors presented the biennial problem identification and resolution inspection results to Norha Plumey, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
1594407
Automatic Trip of Breaker 1AP07EJ
3960913
WS Requires Maintenance Rule A1 Evaluation
3967921
1LL69BP01E Needs Replaced
3967922
1LL69BP02E Needs Replaced
20569
Manual Reactor SCRAM due to Loss of Feedwater Heating
22176
Div 3 SX Pump Tripped During Startup of 9069.01
4075431
NCV 2017007-01 Failure to Evaluate Defeating RCIC
Interlocs/Trips
4082490
Reactor Scram from Trip of 1AP07EJ
4157274
Unexpected Entry Into Off-Normal 4004.01
214037
Update FP Panel 1FP03J for CDA
215290
EOID: Div 1, 2 Temperature Controllers Not within 5 Degrees
of Room
216180
1LL69BP03E Green Light Failed
21273
EOID Several Through Wall Pinhole Leaks Downstream of
1SX013D
22556
ASME Code Case N-513-3 Augmented Volumetric Exam of
1SX063A
27129
9053.04C033 Not Performed for 1SX027C
248044
PI&R Identified Minimum Wall Reading on 1SX21AB Below
Acceptable
250932
1AP07EK Main Feed Breaker Failed to Close during Bus
Shift
256159
1SX01PC: Results of the Division III SX Pump Inspection
284526
SRV 51B Actuates Instead of 41B
4373833
1DG616PA Rubber Coupling Insert Degrading
4374885
1SX156A and B Lifted During Valve Stroking of 1SX041B
4380910
EFR 4022176-73 Determined Action to Be Not Effective
4386305
Part 21 - Impact of Ex-Core Flux on Control Rod Lifetime
Limit
71152B
Corrective Action
Documents
4392368
Unexpected MCR Alarm 5067-6K Drywell RF Leak Rate
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Increase
4411326
Reactor Coolant System Reactor Sulfates Action Level >
AL-2 Conductivity > AL-1
21018
OE: Underground Piping Leak on Plant Service Water
System
4435861
NOSA CPS 21-05, Clinton Corrective Action Program Audit
4435978
SA(ENG): (Pre-NRC) Design Basis Assurance Insp. (Team)
4437251
OE: Rx FW Pump Turbine Trip and 8 Percent Power
Reduction
4450045
1SX014A Failed Leak Rate
4452166
Fuel Bundle Inadvertent Contact
4452524
SRM 'A' INOP
4459749
1E31-R552 Channel 1 Reading Value Lower than Normal
4460431
Observed Reactor Water Clean Up Efficiency Not as
Expected
4464995
Room Cooler Cleanings Not Completed by PM due Date
4474333
Generate WO to Re-Inspect 1SX01AB-30"
4475069
Outage Performance Resulted in Extended Outage Duration
over Business Plan and Two Additional Maintenance
Outages
4475235
Trend IR: Multiple 9030.05 Failures
4476014
DBAI FASA - Apparent SFCP Missed Impact to Calc
CI-CPS-704
4476101
Maintenance Failed to Maintain Control of the Measurement
and Test Equipment (M&TE) program
4476139
DBIA Self-Assessment Required Scope Not Completed
4476298
Small Increase Noted in DW RF Sump Pump Flow
4476597
Diesel Lube Oil Pump Coupling Trend Analysis
4477332
Concerns Conveyed by SRI
4478357
NRC Green Finding 2021004-01 Integrated Inspection
Report
4478554
Zip Ties Found on IA Line Near 1IA744A
4482053
22 DBAI Self-Assessment Gap
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
4487448
NRC Interview Regarding WO 4835532 Ventilation Test
4504335
VP Chiller A 0VP04CA Trip
4506336
Review 1SX019B Hydramotor for Trend
4509371
4010, Chemistry Off-Normal Event (Sulfates > AL1)
4511806
ENG ID: Trend IR for Meeting Attendance
4513789
SA: 2023 Pre-NRC Inspection Triennial Heat Sink
4518197
Concerns Regarding SCWE in Nuclear Training
23507
RF-BA303 Drywell Floor Drain Bubbler Indication Spike
25408
Part 21: GNF3 Raised Water Rod (SC-22-04)
4536163
1FX01PB Batteries Low Electrolyte Levels
4545247
Trend IR 1VT03CA and 1VT03CB Component Health
4549522
OE: Emergency Service Water Valve Fails to Reposition
4549919
Trend IR: Containment Exhaust Motors (1RIX-PR001B)
4551751
Trip of 4506 and 4510 Results in Reactor SCRAM
4556422
NRC Severity Level IV NCV 2022004-01 Integrated
Inspection
4560203
Div 3 NUS Modules Deenergized during 9080.23
4563429
Trend in Qualification System Maintenance for CY/RP
4564242
1E51-F010 RCIC Storage Tank Suction Torque Switch
4665910
1SXB2BB-3/4" UT Results Lower Than Expected
4667530
Operating Experience: NRC EA-22-099 Entergy ANO NOV -
Buried SW Piping Issues
4672450
23 10 CFR 50.59 Self-Assessment
4677378
NOSA-CPS-23-04 Clinton Engineering Programs Audit
4681345
4002.01 Abnormal RPV Level Loss of Feedwater at Power
4681758
Urgent Change Request to Support DFW Level Control
4683575
Vulnerability Identified in Clinton DFW
4689109
Clinton Safety Culture Assessment
4689613
OPEx Review Uptake Received during Filter Change
4691233
Self-Assessment: Prep for NRC PI&R Inspection
4694447
Manway Gasket Replacement on Condensate Polisher
4698382
CPS Buried Pipe Program ANO OpEx Review
4702393
Source Range Monitor D
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
4704085
As Found Internal Inspection Results of 1SX15AB-4"
4704289
Trip of 0SA01C, Service Air Compressor 0
4705811
Results of Clinton 2023 Biennial Fleet Safety Culture
Self-Assessment
4705955
SRM B Declared Inop due to Erratic Count Trend
4707932
SRM C Inoperable due to Erratic Indication
4708537
C1R21 Outage Analysis
4708616
Lessons Learned Reserve Auxiliary Transformer B
4708674
Security ID Camera 207 Degraded
4713918
Division I SX Flow Balance Testing--Low Flow Data for
1VY02S
4713919
Division 1 SX Flow Balance Testing--Low Flow Data for
1VY04S
4717578
Escalating Concerns Regarding SCWE at Clinton Power
Station
20972
23 50.59 SA: Adverse Trend in Timely 50.59
Implementation
25635
OPEX Implementation Gaps ion RAT B Modifications
4730409
Cat ID 1104346-4 Failed Bench Testing
4730581
FC B HX Valves 1CC075B and 1CC076B Potential Leak By
4731060
Long Standing Issue Complicates Compensatory Actions
4731096
Cold Weather Issues at SX Egress Building
4731175
SX Flushing Not Performed due to MISO Unavailability
4744556
Review OPEX #56938 High Pressure Core Spray Failure
4750430
24 PI&R Self-Assessment Gaps - 1
4750432
24 PI&R Self-Assessment Gaps - 2
4751710
Review OPEX #571153 Emergency DG Failed Surveillance
Test
4753918
Valve 1E12F025C Set Pressure Failure
4754194
NRC Green NCV 2023004-01 Integrated Inspection Report
4762053
1SX019B Minor Leakage with Valve Closed
4763759
SX Strainer 1B Timer (1KY-SK061B) Failed to Start
(8751-05C)
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
4764752
A1 Action Plans Were not Completed by Procedural Deadline
Engineering
Changes
639173
4002.01, Abnormal RPV Level Loss of Feedwater at
Power - Defeat/Override Parameter 'FW-RCIC-BANDC-TRIP
Shown on WNA-CB-00187-GCLN1 Sheet 324
1893.01
CPS Administrative Requirements for Fire Protection
Preparation for NRC Comprehensive Engineering Team
Inspection
System Performance Monitoring and Analysis
Conduct of Equipment Reliability Manual
Operating Experience Program
Processing of Level 3 OPEX Evaluations
Issue Identification and Screening Process
Corrective Action Program Procedure
Root Cause Analysis Manual
Corrective Action Program Evaluation Manual
Effectiveness Review Manual
Procedures
Investigation Techniques Manual
7