IR 05000461/2024012

Biennial Problem Identification and Resolution Inspection Report Report 05000461/2024012

ML24138A051
Person / Time
Site:
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

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

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 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 Type Designation Description or Title Revision or

Procedure Date

71152B Corrective Action 1594407 Automatic Trip of Breaker 1AP07EJ

Documents 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

4392368 Unexpected MCR Alarm 5067-6K Drywell RF Leak Rate

Inspection Type Designation Description or Title Revision or

Procedure 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 2022 DBAI Self-Assessment Gap

Inspection Type Designation Description or Title Revision or

Procedure 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 2023 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 Type Designation Description or Title Revision or

Procedure 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 2023 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 2024 PI&R Self-Assessment Gaps - 1

4750432 2024 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 Type Designation Description or Title Revision or

Procedure Date

4764752 A1 Action Plans Were not Completed by Procedural Deadline

Engineering 639173 4002.01, Abnormal RPV Level Loss of Feedwater at 0

Changes Power - Defeat/Override Parameter 'FW-RCIC-BANDC-TRIP

Shown on WNA-CB-00187-GCLN1 Sheet 324

Procedures 1893.01 CPS Administrative Requirements for Fire Protection 26

CC-AA-4006 Preparation for NRC Comprehensive Engineering Team 7

Inspection

ER-AA-2003 System Performance Monitoring and Analysis 17

ER-AA-2030 Conduct of Equipment Reliability Manual 30

PI-AA-115 Operating Experience Program 5

PI-AA-115-1003 Processing of Level 3 OPEX Evaluations 7

PI-AA-120 Issue Identification and Screening Process 13

PI-AA-125 Corrective Action Program Procedure 8

PI-AA-125-1001 Root Cause Analysis Manual 7

PI-AA-125-1003 Corrective Action Program Evaluation Manual 7

PI-AA-125-1004 Effectiveness Review Manual 2

PI-AA-125-1006 Investigation Techniques Manual 7

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