IR 05000461/2015003

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IR 05000461/2015003, on 07/01/2015 - 09/30/2015, Clinton Power Station, Unit 1; Operability Determinations and Functionality Assessments, Plant Modifications, and Follow Up of Events and Notices of Enforcement Discretion
ML15313A464
Person / Time
Site: Clinton Constellation icon.png
Issue date: 11/06/2015
From: Louden P
Division Reactor Projects III
To: Bryan Hanson
Exelon Generation Co, Exelon Nuclear
References
EA-15-203 IR 2015003
Download: ML15313A464 (44)


Text

November 6, 2015

SUBJECT:

CLINTON POWER STATION, UNIT 1 - NRC INTEGRATED INSPECTION REPORT 05000461/2015003 AND EXERCISE OF ENFORCEMENT DISCRETION

Dear Mr. Hanson:

On September 30, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Clinton Power Station, Unit 1. The enclosed report documents the results of this inspection, which were discussed on October 15, 2015, with Mr. D. Kemper and other members of your staff. The inspectors documented the results of this inspection in the enclosed inspection report.

Based on the results of this inspection, four NRC-identified findings of very low safety significance were identified. The findings involved a violation of NRC requirements. However, because of their very low safety significance, and because the issues were entered into your Corrective Action Program, the NRC is treating the issues as Non-Cited Violations (NCVs) in accordance with Section 2.3.2 of the NRC Enforcement Policy.

Separately, a violation involving a failure to establish secondary containment operability during operations with the potential to drain the reactor vessel (OPDRV) was identified during the last refueling outage. Specifically, from April 27, 2015, to May 2, 2015, and from May 6, 2015, to May 12, 2015, while all other Technical Specifications (TSs) were met, Clinton Power Station conducted several OPDRVs without establishing secondary containment operability, which is a violation of TS 3.6.4.1. The NRC issued Enforcement Guidance Memorandum (EGM) 11-003, Enforcement Guidance Memorandum on Dispositioning Boiling Water Reactor Licensee Noncompliance with Technical Specification Containment Requirements During Operations with a Potential for Draining the Reactor Vessel, Revision 2, on December 13, 2013, allowing for the exercise of enforcement discretion for such OPDRV-related TS violations, when certain criteria are met. The NRC concluded that, for this specific period, Clinton Power Station met the EGM criteria. Therefore, I have been authorized, after consultation with the Director, Office of Enforcement, and the Regional Administrator, to exercise enforcement discretion and refrain from issuing enforcement for the violation.

If you contest the subject or severity of these NCVs, 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, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Clinton Power Station. In addition, if you disagree with the cross-cutting aspect assigned to any finding 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 Regional Administrator, Region III, and the NRC Resident Inspector at the Clinton Power Station.

In accordance with Title 10, Code of Federal Regulations (CFR), Part 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS)

component of the NRC's Agencywide Documents Access and Management System (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Patrick Louden, Director Division of Reactor Projects Docket No. 50-461 License No. NPF-62

Enclosure:

Inspection Report 05000461/2015003

REGION III==

Docket No:

50-461 License No:

NPF-62 Report No:

05000461/2015003 Licensee:

Exelon Generation Company, LLC Facility:

Clinton Power Station Location:

Clinton, IL Dates:

July 1 through September 30, 2015 Inspectors:

W. Schaup, Senior Resident Inspector E. Sanchez-Santiago, Resident Inspector A. Shaikh, Reactor Inspector J. Bozga, Reactor Inspector M. Jones, Reactor Inspector C. Phillips, Project Engineer S. Mischke, Resident Inspector,

Illinois Emergency Management Agency Approved by:

P. Louden, Director Division of Reactor Projects

SUMMARY OF FINDINGS

......................................................................................................... 2

REPORT DETAILS

.................................................................................................................... 5

Summary of Plant Status

REACTOR SAFETY

1R04 Equipment Alignment

1R05 Fire Protection

1R06 Flooding

1R07 Annual Heat Sink Performance

==1R08 Inservice Inspection Activities (71111.08) 8

==

1R11 Licensed Operator Requalification Program

1R12 Maintenance Effectiveness

==1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)

==

1R15 Operability Determinations and Functional Assessments

==1R18 Plant Modifications (71111.18)

==

1R19 Post-Maintenance Testing

==1R22 Surveillance Testing (71111.22)

==

1EP6 Drill Evaluation

OTHER ACTIVITIES

4OA1 Performance Indicator Verification

4OA2 Identification and Resolution of Problems

4OA3 Follow-Up of Events and Notices of Enforcement Discretion

4OA6 Management Meetings

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

R. Bair, Chemistry Manager
M. Friedmann, Emergency Preparedness Manager
B. Brooks, Security Manager
J. Cunningham, Maintenance Director
C. Dunn, Training Director
N. Hightower, Radiation Protection Manager
T. Krawcyk, Shift Operations Superintendent
D. Kemper, Acting Plant Manager/Operations Director
J. Blount, Acting Senior Manager Design Engineering
M. Newcomer, Site Vice President
C. Propst, Work Management Director
J. Ward, Nuclear Oversight Manager
D. Shelton, Operations Services Manager
J. Smith, Engineering Director
S. Minya, Operations Training Manager
T. Stoner, Plant Manager
M. Heger, Acting Senior Manager Plant Engineering
G. Engelhardt, Engineering Programs Manager
D. Anthony, Exelon NDE Services
M. Baig, ISI Program Engineer

U.S. Nuclear Regulatory Commision

K. Stoedter, Chief, Reactor Projects Branch 1
W. Schaup, Clinton Senior Resident Inspector
E. Sanchez-Santiago, Clinton Resident Inspector

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

Opened and Closed

05000461/2015003-01 NCV Failure to Follow Procedure leaves Control Room Cabinet doors Unattended in Seismically Unanalyzed Condition (Section 1R15)
05000461/2015003-02 NCV Failure to Implement and Comply with Transient Equipment/Materials Program (Section 1R15)
05000461/2015003-03 NCV Failure to Obtain a License Amendment prior to Making Modifications to Secondary Containment (Section 1R18)
05000461/2015003-04 NCV Failure to enter appropriate TS action statement for inoperable radiation monitors during OPDRV activities (Section 4OA3)

Closed

05000461/2015002-01 URI Fuel Handling Building Railroad Bay Airlock Design and Licensing Basis Issues (Section 1R18)
05000461/2015-002-00 LER Implementation of Enforcement Guidance Memorandum (EGM)11-003, Revision 2 (Section 4OA3)

LIST OF DOCUMENTS REVIEWED