IR 05000254/2020002

Integrated Inspection Report 05000254/2020002 and 05000265/2020002

ML20225A008
Person / Time
Site:	Quad Cities
Issue date:	08/11/2020
From:	Kenneth Riemer NRC/RGN-III/DRP/B1
To:	Bryan Hanson Exelon Generation Co
References
IR 2020002
Preceding documents:	ML20021A034 (17 January 2020)
Download: ML20225A008 (24)

Text

August 11, 2020

SUBJECT:

QUAD CITIES NUCLEAR POWER STATION - INTEGRATED INSPECTION REPORT 05000254/2020002 AND 05000265/2020002

Dear Mr. Hanson:

On June 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Quad Cities Nuclear Power Station. On July 7, 2020, the NRC inspectors discussed the results of this inspection with Mr. K. Ohr, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

One Severity Level IV violation without an associated finding is documented in this report. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

No NRC-identified or self-revealing findings were identified during this inspection.

A licensee-identified violation which was determined to be of very low safety significance is documented in this report. We are treating this violation as a non-cited violation (NCV)

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 Quad Cities Nuclear 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,

/RA/

Kenneth R. Riemer, Chief Branch 1 Division of Reactor Projects Docket Nos. 05000254 and 05000265 License Nos. DPR-29 and DPR-30

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000254 and 05000265 License Numbers: DPR-29 and DPR-30 Report Numbers: 05000254/2020002 and 05000265/2020002 Enterprise Identifier: I-2020-002-0037 Licensee: Exelon Generation Company, LLC Facility: Quad Cities Nuclear Power Station Location: Cordova, IL Inspection Dates: April 01, 2020 to June 30, 2020 Inspectors: J. Cassidy, Senior Health Physicist N. Feliz Adorno, Branch Chief C. Matthews, Illinois Emergency Management Agency R. Murray, Senior Resident Inspector J. Park, Reactor Inspector E. Sanchez Santiago, Senior Reactor Inspector D. Tesar, Resident Inspector Approved By: Kenneth R. Riemer, Chief Branch 1 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Quad Cities Nuclear 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

Inadequate Design Change Control Resulted in Unplanned Unavailability of the Safety-Related Train of the Control Room Emergency Ventilation System Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71153 Systems NCV 05000254,05000265/2020002-01 Open/Closed The licensee identified a Green finding and associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion III, Design Control, when the licensee failed to incorporate design changes into controlled documents per Engineering Change 387649, "Refrigeration Condensing Unit (RCU) 0-9400-102 (B CREV) Circuit Breaker At 1-7800-18-4-D1 is Nuisance Tripping," resulting in unplanned unavailability/inoperability of the safety-related train of the control room emergency ventilation system (CREVS).

Violation of Technical Specification 3.5.1.H for Inoperable Automatic Depressurization System Valve Cornerstone Significance Cross-Cutting Report Aspect Section Not Applicable NCV 05000265/2020002-02 Not Applicable 71153 Open/Closed A self-revealed Severity Level (SL) IV non-cited violation of Technical Specification (TS) 3.5.1,

Emergency Core Cooling System - Operating, was identified when it was discovered, following shutdown for a scheduled refueling outage, that during performance of them TS Surveillance Requirement (SR) 3.5.1.10, the 2-0203-3D electromatic relief valve (ERV) failed to actuate. The licensee determined the 3D automatic depressurizing system (ADS) valve was inoperable for the entire cycle, which was a violation of Limiting Condition for Operation (LCO) 3.5.1, Condition H for one ADS valve inoperable, which required that the valve is restored to an operable condition within 14 days.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000265/2020-002-00 LER 2020-002-00 for Quad 71153 Closed Cities Nuclear Power Station, Unit 2, Electromatic Relief Valve 3D Did Not Actuate Due to Out of Specification Plunger LER 05000254,05000265/20 LER 2020-001-00 for Quad 71153 Closed 20-001-00 Cities, Unit 1, Control Room

Emergency Ventilation Air Conditioning System Inoperable Due to Incorrect Breaker Setting LER 05000265/2020-001-00 LER 2020-001-00 for Quad 71153 Closed Cities Nuclear Power Station, Unit 2, Loss of Both Divisions of Residual Heat Removal Low Pressure Coolant Injection Due to Swing Bus Failure to Transfer

PLANT STATUS

Unit 1 The unit began the inspection period at full-rated thermal power, where it remained for the entire inspection period, with the exception of planned power reductions for turbine testing, scram timing testing, control rod pattern adjustments, and other short-term power reductions as requested by the transmission system operator.

Unit 2 The unit began the inspection period shut down for Refueling Outage Q2R25. Startup on Unit 2 was commenced on April 13, 2020, and the unit was synchronized to the grid on April 15, 2020.

The unit reached full-rated thermal power on April 17, 2020. There was an unplanned down power to 23 percent on April 21, 2020, for troubleshooting of a generator protective relay. Unit 2 returned to full-rated thermal power on April 22, 2020. On April 27, 2020, there was an unplanned down power to 85 percent rated thermal power to facilitate repairs to the 2B reactor feed pump drain line. Unit 2 returned to full-rated thermal power on April 28, 2020, where it remained for the duration of the inspection period, with the exception of planned power reductions for turbine testing, control rod pattern adjustments, and other short-term power reductions as requested by the transmission system operator.

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.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week and during that time conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities, and completed on-site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on-site. The inspections documented below met the objectives and requirements for completion of the IP.

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather (summer/hot weather) conditions prior to the onset of extreme temperatures for the following systems:

• Unit 1/2 control room heating ventilation and air conditioning

• Units 1 and 2 service water systems

External Flooding Sample (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated flood protection barriers, mitigation plans, procedures, and equipment for both Unit 1 and Unit 2 to verify they are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Units 1 and 2 fuel pool cooling systems on April 8, 2020

(2) Unit 2 4kV and 480V safety-related electrical plant lineup on April 8, 2020

(3) Common Unit 1/2 'B' standby gas treatment on April 27, 2020

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the Unit 2 standby liquid control system on April 27, 2020.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Fire Zone 1.1.1.5, reactor building, elevation 666'-6", [Unit 1 and Unit 2] stand-by liquid control 4th floor east/west on April 27, 2020

(2) Fire Zone 1.1.2.5, reactor building, elevation 666'-6", [Unit 1 and Unit 2] stand-by gas treatment 4th floor east/west on April 27, 2020

(3) Fire Zone 8.2.8.B and C, Unit 1 and Unit 2 turbine building, elevation 639'-0", Motor Generator Set 1A and 2B on April 30, 2020

(4) Fire Zones 1.1.1.5A and 1.1.1.6A, Unit 1/2 turbine building, elevation 658'-0"/678'-0",

reactor building vent floors, 4kV Swgr. 13-1/24-1, MG Sets 1A and 2B on April 30, 2020

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Units 1 and 2 service water internal flooding on May 4, 2020

71111.08G - Inservice Inspection Activities (BWR)

BWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding

Activities (IP Section 03.01)

(1) The inspectors verified the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary were appropriately monitored for degradation and repairs and replacements were appropriately fabricated, examined and accepted by reviewing documentation for the following activities from March 31, 2020 to April 9, 2020:

03.01.a - Nondestructive Examination and Welding Activities.

1. Ultrasonic volumetric examination of vessel-to-nozzle weld N5A-NOZ, Category B-D, Item B3.90 using procedure GEH-UT-300 2. Ultrasonic volumetric examination of vessel nozzle inner radius N5A-IRS, Category B-D, Item B3.100 using procedure GEH-UT-311 3. Ultrasonic volumetric examination of weld 30B-S24, Category R-A, Item R1.20-4 using procedure GEH-PDI-UT-1 4. Ultrasonic volumetric examination of weld 1012A-1, Category R-A, Item R1.11-5 using procedure GEH-PDI-UT-1 5. Ultrasonic volumetric examination of weld 1012A-2, Category R-A, Item R1.11-5 using procedure GEH-PDI-UT-1 6. Magnetic particle surface examination of saddle-to-nozzle weld N8A-F2 RHRHX, Category C-B, Item C2.31 using procedure ER-AA-335-003 7. Magnetic particle surface examination of support-to-shell weld 1003A-W-201A, Category C-C, Item C3.10 using procedure ER-AA-335-003 8. Visual examination of pipe hanger support 2305-W-214, Category F-A, Item 1.20A using procedure ER-AA-335-016 9. Visual examination of IWE Interfaces of Drywell Head Bolting 2DWH-Bolting, Category E-G, Item E8.10 using procedure ER-AA-335-018 10. Report No. Q2R24-R-10, Component ID RPV-THHF, Category B-A, Item B1.40 with relevant indications identified during prior outage accepted for continued service 11. Pressure boundary weld numbers 1 through 6 for Work Order 00783623-01

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(2 Samples)

(1) The inspectors observed and evaluated licensed operator performance in the control room during Unit 2 startup from Refueling Outage Q2R25 on April 13, 2020.

(2) The inspectors observed and evaluated licensed operator performance in the control room during Unit 2 turbine-to-grid synchronization on April 15, 2020.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated licensed operator requalification training in the simulator on June 8, 2020.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components remain capable of performing their intended function:

(1) service water system on June 2, 2020

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed;

(1) E-2 Certification and Work Week Risk Evaluation for week of May 17, 2020

(2) Work Week Risk for safe shutdown pump planned maintenance and 2A and 2B residual heat removal pumps planned maintenance during week of May 26, 2020

(3) E-2 Certification and Work Week Risk Evaluation for week of June 22, 2020

(4) E-2 Certification and Work Week Risk Evaluation for week of June 29, 2020

(5) Work Week Risk assessment associated with impending severe weather (thunderstorms), hot weather readiness, reactor core isolation cooling work window and emergent scope, and 1/2 emergency diesel generator concurrent activities during the week of June 22, 2020

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Issue Report 4323520, "[Unit 1] HPCI [high pressure coolant injection] FIC [flow indicating controller] Stuck at Max Flow," on March 4, 2020

(2) Issue Report 4328207, "[Unit 1] LPCI [low pressure coolant injection] Loop Select," on March 20, 2020

(3) Issue Report 4333200, "[Unit 2] Vibrations and Current Swings on #2 125 Vdc Charger," on April 7, 2020

(4) Issue Report 4327393, "[Unit 1] LPCI Loop Select Operability Following QCOS 1000-03," on April 29, 2020

(5) Issue Report 4347201 "EO [equipment operator] ID'd Excessive No Flow Time During

[Unit 1] HPCI Venting," on June 1, 2020

(6) Issue Report 4350782, "Unit 2 HPCI Room Temp High," on June 16, 2020

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)

The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:

(1) total as-left local leak rate test results following outage work on April 13, 2020

(2) QOS 6500-04, "Bus 23-1 Undervoltage Test," following UAT T-21 replacement on April 21, 2020

(3) Unit 2, 2A standby liquid control pump flow test following pump overhaul on May 11, 2020

(4) QCOS 1400-1, "Unit 2 Core Spray Pump Flow Rate Test," following cubicle inspection and relay testing on May 18, 2020

(5) QCOS 1000-28, "[Unit 2] 2A Residual Heat Removal Service Water Pump Comprehensive/PerformanceTest," following pump outboard seal and wear ring replacement on May 23, 2020

(6) Unit 1/2 safe shutdown makeup pump post-maintenance testing following planned maintenance on May 26, 2020

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Partial)

(1) (Partial)

The inspectors evaluated the Unit 2 Refuel Outage Q2R25 activities that continued into the second quarter (began on March 30, 2020 and completed on April 15, 2020).

In accordance with the memo from Ho Nieh, Director of the Office of Nuclear Reactor Regulation, dated May 28, 2020 (ML 20141L66), this inspection was considered partially completed. Inspection Procedure 71111.20, REFUELING AND OTHER OUTAGE ACTIVITIES, had 18 high level requirements to complete the IP. Section

.03.0 2.d.2, "Containment Closure," requires, in part, that If containment is opened,

conduct a walkdown of containment just before closure." The inspectors were unable to perform a physical walkdown of containment due to the NRC's response to COVID-19. The inspectors performed a review of video footage of the licensee's complete walkdown of the containment prior to closure of the containment, just before the startup from Refueling Outage Q2R25. Inspection Manual Chapter 2515 states that the inspector is to perform the inspection requirements most appropriate to the activity being inspected in order to declare an activity (sample) as being satisfactorily completed. Inspectors that do not complete a high-level requirement when it is available to be completed will need to document the IP as partially completed.

For IP 71111.20, there was no means to go back and complete the missed requirement. The inspectors determined that while the requirement was not completed (and considered "partial" or not complete), the objective of the walkdown was completed and the inspection procedure objective was completed.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) QCOS 2300-05, "[Unit 2] HPCI Pump Operability Test," on April 14, 2020

(2) QCOS 1000-20, "[Unit 2B] RHR [residual heat removal]/RHR Service Water Pump Breaker Local Control Test for Appendix R," on April 30, 2020

(3) QCOS 6620-10, "[Unit 1] SBO [station blackout] DG [diesel generator] Endurance/

Margin and Full Load Reject Test," on April 30, 2020

(4) QCOS 6500-09, "Functional Test of Unit 1 Second Level Undervoltage," on

June 24, 2020 Inservice Testing (IP Section 03.01) (1 Sample)

(1) QCOS 1000-6, "[Unit 2] RHR Pump/Loop Operability Test," on April 30, 2020

Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)

(1) Unit 2 main steam isolation valve local leak rate test (continued from last quarter) on April 1,

71124.01 - Radiological Hazard Assessment and Exposure Controls

Instructions to Workers (IP Section 03.02) (1 Partial)

(1) (Partial) The inspectors evaluated radiological protection-related instructions to plant workers.

71124.04 - Occupational Dose Assessment

Source Term Characterization (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.

External Dosimetry (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to external dosimetry that is used to assign occupational dose.

Internal Dosimetry (IP Section 03.03) (1 Sample)

The inspectors evaluated the following internal dose assessments for actual internal exposures:

(1) Dose assessment for an individual who alarmed a portal monitor after supporting main steam isolation valve work in the drywell on March 27, 2019 (Issue Report

4233376) Special Dosimetric Situations (IP Section 03.04)

The inspectors evaluated the following special dosimetric situations:

(1) Dose assessment for one declared pregnant worker

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

BI02: RCS Leak Rate Sample (IP Section 02.11) ===

(1) Unit 1 (04/01/2019-03/31/2020)

(2) Unit 2 (04/01/2019-03/31/2020)

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Issue Report 4129537, "Potential Single Point Vulnerability HPCI Aux Oil Pump PS,"

Action Item 04 completed on May 22, 2020

71153 - Followup of Events and Notices of Enforcement Discretion Event Followup (IP Section 03.01)

(1) The inspectors evaluated Issue Report 4335396, "Unit 2 Main Generator Negative Sequence," (also Issue Reports 4335468 and 4335834) and the licensees response on April 15, 2020.

(2) The inspectors evaluated Issue Report 4337161, "Received 902-8 A-11 U2 Main Generator Negative Sequence," (also Issue Report 4337157) and the licensees response on April 22, 2020.

Event Report (IP Section 03.02) (3 Samples)

The inspectors evaluated the following licensee event reports (LERs):

(1) Licensee Event Report 05000265/2020-001-00, Loss of Both Divisions of Residual Heat Removal Low Pressure Coolant Injection Due to Swing Bus Failure to Transfer (ADAMS Accession No. ML20140A093). The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER; therefore, no performance deficiency was identified. The inspectors did not identify a violation of NRC requirements.

(2) Licensee Event Report 05000265/2020-002-00, Electromatic Relief Valve 3D Did Not Actuate Due to Out of Specification Plunger (ADAMS Accession No. ML20149K600).

The inspection conclusions associated with this LER are documented in this report under Inspection Results Section 4OA3.

(3) Licensee Event Report 2020-001-00 for Quad Cities, Unit 1, Control Room Emergency Ventilation Air Conditioning System Inoperable Due to Incorrect Breaker Setting (ADAMS Accession No. ML20163A145). The inspection conclusions associated with this LER are documented in this inspection report under Inspection Results Section 4OA3.

INSPECTION RESULTS

Observation: Review of High Pressure Core Injection Single Point Vulnerability 71152 Identified in Issue Report 4129537 The inspectors identified a corrective action item which was Action Item 04 under Issue Report 4129537 that was completed on May 22, 2020. Issue Report 4129537, "Potential Single Point Vulnerability for HPCI Logic," documented that a failed pressure switch in the HPCI start logic could prevent automatic HPCI initiation. On March 21, 2018, during Refueling Outage Q2R24, while performing a HPCI system logic functional test, the Unit 2 HPCI auxiliary oil pump failed to auto-start due to pressure switch 2-2341-4 contacts stuck in the open position as documented under Issue Report 4117639, "Unit 2 HPCI Logic Test Discrepancy." The licensee also reviewed the Unit 1 HPCI logic and pressure switch 1-2341-4 for extent of condition and noted the failure of pressure switch 1-2341-4 would prevent the Unit 1 HPCI auxiliary oil pump from auto-starting. For both units, HPCI would be able to be manually started by placing the associated auxiliary oil pump control switch to manual which would allow HPCI injection. The issue was reviewed by engineering for potential single-point vulnerability in that a failure of pressure switch 1(2)-2341-4 contacts to open would prevent the HPCI auxiliary oil pump from starting and prevent subsequent automatic actions for HPCI initiation from occurring as well (i.e. HPCI would not auto-start and inject into the reactor pressure vessel). Engineering determined that the current design of the logic circuit was acceptable, and planned follow-up actions for future outages to perform one-time inspections of the pressure switch contacts, wiring, and terminal connections. This one-time inspection was intended to verify the corrective actions from Issue Report 4117639 and the extent of condition on Unit 1. The inspectors verified the pressure switches used in this application were classified as safety-related in the licensee's Passport system. The inspectors did not identify any issues of concern.

Inadequate Design Change Control Resulted in Unplanned Unavailability of the Safety-Related Train of the Control Room Emergency Ventilation System Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71153 Systems NCV 05000254,05000265/2020002-01 Open/Closed The licensee identified a Green finding and associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion III, Design Control, when the licensee failed to incorporate design changes into controlled documents per Engineering Change 387649, "Refrigeration Condensing Unit (RCU) 0-9400-102 (B CREV) Circuit Breaker At 1-7800-18-4-D1 is Nuisance Tripping," resulting in unplanned unavailability/inoperability of the safety-related train of the control room emergency ventilation system (CREVS).

Description:

The licensee performed an equipment apparent cause evaluation (EACE) (AT 01322407-02)in February 2012, after a series of nuisance trips for the 'B' train CREVS RCU 0-9400-102 breaker. The findings of the EACE concluded that due to the type of equipment supported by the breaker and its cyclic operation, the breakers instantaneous thermal trip settings needed to be increased to the maximum manual setting

(10) to avoid continued nuisance trips. The trip setting of 8.8 was acceptable, but due to the high importance of the system, the trip setting of 10 was recommended for additional margin to ensure continuity of service.

The licensee approved, based on the findings of the EACE, Engineering Change 387643, "Refrigeration Condensing Unit (RCU) 0-9400-102 (B CREV) Circuit Breaker At 1-7800-18-4-D1 is Nuisance Tripping," on February 7, 2012, and under Work Order 1511315, "'B' Control Room HVAC [heating, ventilation, and air conditioning] RCU BKR Found Tripped," the breaker trip setting was set to 10 in order to prevent nuisance trips of the breaker.

The licensee also created Engineering Change 387649, "Update The Passport Parameters Panel For 1-7800-18-4-1D," on February 7, 2012, for the purpose of updating the thermal trip settings of Motor Control Center (MCC) 18-4-1D in the Passport parameters panel for future work orders. This engineering change was not assigned to any individual to complete until February 25, 2013, over a year later.

Design engineering assumed that the preventive maintenance (PM) for the breaker would be credited to the work done under troubleshooting Work Order 1511315, thus resetting the due date for the next PM performance to 8 years. However, the work performed under Work Order 1511315 did not include the full scope of the PM, and the only work performed was changing the trip setting dial. Therefore, maintenance did not take credit for completing the PM and the normal PM due date remained, with the next PM due 18 months after the trip setting was adjusted.

In preparation for the normal 8Y PM of the breaker (PMID 33380-01), planners prepared Work Order 1503327-01 using the setting of 8.8 which was in the Passport parameters panel. This work order was set to ready on August 10, 2013. Design engineering implemented Engineering Change 387649 and the Passport parameters were updated on August 14, 2013, 4 days after the PM work order was set to ready.

During execution of Work Order 1503327-01, Section 4.3.2, on October 15, 2013, electrical maintenance personnel found the trip setting to be 10, which was unexpected. No issue report was written to document the unexpected as found condition. Standard PM process would have electrical maintenance contact the first-line supervisor who would look to the previous PM, verify those calculations were accurate, and test the trip settings from the previous PM. Since the EACE and Engineering Change 387643 were performed under a troubleshooting work order, this information would not be referenced during the PM. Electrical maintenance proceeded with the PM and set the breakers instantaneous thermal trip setting to 8.8. There was also no additional documentation of the "As-Found" condition of the breaker or what was done to resolve the difference.

On April 14, 2020, at 4:45 p.m., operations noticed that there was no indicating light for the 'B' train control room heating, ventilation, and air conditioning RCU 0-9400-102 on the main control room panel 912-5. At 5:00 p.m., an operator was dispatched and found that local indications also showed the RCU to have no power and that the breaker, MCC 18-4-1D, was in a tripped condition. Per the unit supervisor, at 5:05 p.m., the breaker was reset, and light indication was restored. Electrical maintenance personnel performed a breaker and cubicle inspection on April 16, 2020, and found that the thermal overload trip setting on the breaker was set at 8.8. A review of the breaker parameters showed that the trip setting should have been set at 10. Electrical maintenance department performed a post-maintenance test on the breaker and cubicle, under Work Order 5030410, setting the thermal trip setting to 10. The

'B' CREVS was run as part of the post-maintenance test (-02 task) from 03:45-04:49 on April 16, 2020, satisfactorily. The 'B' CREVS was run on April 19, 20, and 22, 2020, satisfactorily, satisfying the post-maintenance test requirements.

This instance of the MCC 18-4-1D breaker trip was a reportable event under 10 CFR 50.73(a)(2)(v)(D) - Any event of condition that could have prevented the fulfillment of the safety function of structures or systems that are needed to mitigate the consequences of an accident. This was also a Maintenance Rule Functional Failure: VC5795-02, 'B' train, provide temperature control.

Corrective Actions: Corrective actions included a corrective action program evaluation to determine cause, procedure revisions to specify initiation of an issue report if unexpected conditions are found during the performance of PM, and case studies to discuss verifying assumptions and the result and findings of Issue Report 4335536.

Corrective Action References: Issue Report 4335536, "Lost Light Indication for Control Room

'B' Train RCU," and Issue Report 1322407, "'B' Control Room HVAC RCU BKR Found Tripped"

Performance Assessment:

Performance Deficiency: The licensee failed to maintain proper design control for implementation of Engineering Change 387649 as required by 10 CFR 50 Appendix B, Criterion III, resulting in unplanned unavailability/inoperability of the safety-related train of the CREVS.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors determined that the Performance Deficiency was similar to examples found in IMC 0612, Appendix A, Section 3, specifically 3b and 3i in that: The Performance Deficiency adversely affected the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to incorporate design changes into controlled documents resulted in the safety-related train of the CREVS becoming inoperable when the breaker to the 'B' CREVS RCU tripped inadvertently.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined the finding was Green using IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, Section A, "Mitigating SSCs [structures, systems, and components] and PRA

[probabilistic risk assessment] Functionality (except Reactivity Control Systems)," because the finding did not result in the loss of the probabilistic risk assessment function of a single train TS system for greater than its TS-allowed outage time.

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 50, Appendix B, Criterion III, Design Control, requires in part, that Measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in § 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions. And that, Measures shall be established for the identification and control of design interfaces and for coordination among participating design organizations. These measures shall include the establishment of procedures among participating design organizations for the review, approval, release, distribution, and revision of documents involving design interfaces. In addition, Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design Contrary to the above, on February 7, 2012, the licensee failed to control design interfaces and coordination among participating design organizations for the review, approval, release, distribution, and revision of documents involving design interfaces for a design change.

Specifically, the licensee failed to ensure the review, approval, release, distribution, and revision to documents associated with Engineering Change 387649 which revised the thermal overload setpoint for the 'B' train control room HVAC RCU 0-9400-102 breaker.

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

Violation of Technical Specification 3.5.1.H for Inoperable Automatic Depressurization System Valve Cornerstone Severity Cross-Cutting Report Aspect Section Not Severity Level IV Not 71153 Applicable NCV 05000265/2020002-02 Applicable Open/Closed A self-revealed Severity Level (SL) IV non-cited violation of Technical Specification (TS)3.5.1, Emergency Core Cooling System - Operating, was identified when it was discovered, following shutdown for a scheduled refueling outage, that during performance of the TS Surveillance Requirement (SR) 3.5.1.10, the 2-0203-3D electromatic relief valve (ERV) failed to actuate. The licensee determined the 3D automatic depressurizing system (ADS) valve was inoperable for the entire cycle, which was a violation of Limiting Condition for Operation (LCO) 3.5.1, Condition H for one ADS valve inoperable, which required that the valve is restored to an operable condition within 14 days.

Description:

On March 30, 2020, with Unit 2 in shutdown for Refueling Outage Q2R25, during performance of the TS SR 3.5.1.10, the 2-0203-3D ERV failed to actuate. Technical Specification SR 3.5.1.10 required each ADS valve actuator stroke when manually actuated.

All other ADS valves on Unit 2 were found to stroke successfully. The licensee reported this issue in LER 05000265/2020-002, in accordance with 10 CFR 50.73(a)(2)(i)(B), any operation or condition which was prohibited by the plant's TS. The licensee determined the 3D ADS valve was inoperable for the entire cycle.

Technical Specification LCO 3.5.1 requires that each emergency core cooling system injection/spray subsystem and the ADS function of five relief valves shall be OPERABLE.

Limiting Condition for Operation 3.5.1, Condition H for one ADS valve inoperable requires that the valve is restored to an operable condition within 14 days. Limiting Condition for Operation 3.5.1, Condition I states the required action and associated completion time for Condition H was not met, which requires the licensee to be in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The failed actuator for the 2-0203-3D ERV was originally installed in March 2018 after having been rebuilt in February 2018 in preparation for Refueling Outage Q2R24. The actuator was rebuilt in accordance with the site maintenance rebuild procedure. On April 5, 2018, during an auto blowdown functional test operating surveillance and post-maintenance test, the 2-0203-3D ERV did not initially actuate as expected with the ERV remaining in the closed position. Issue Report 4123272, "AO [Air Operated] 2-0203-3D ERV Solenoid Issue During Logic Test," was generated, and troubleshooting and maintenance were performed to smooth the actuator plunger sides to correct the actuator sticking. The valve was subsequently cycled three times successfully and was returned to service. The next test of the ERV was on March 30, 2020, when it failed during Refueling Outage Q2R25.

Following the 2020 failure, the removed 2-0203-3D ERV actuator was dissembled and inspected to determine the cause of the failure. The initial observations and stroking of the actuator with the cover removed noted that the upper guide bracket was tilted down on the left end. As the actuator was stroked and returned to the standby state, the tilt of the upper guide bracket would vary from stroke to stroke, causing the sticking of the actuator to be intermittent. Observation of the plunger during testing noted that it would intermittently rub with the lever arm on the left side. The plunger width was found to be different from the top to mid-length, indicating the legs were splaying. This plunger width was outside the manufacturer's tolerance for plunger width. The measured width of 2.592" is 0.027" larger than the manufacturer's tolerance for plunger width of 2.565". The plunger width was not a parameter that was measured during vendor dedication until 2019, after the rebuild of the actuator that occurred in 2018.

The inspectors determined that the licensee's actions in 2018 were appropriate; they attempted to implement corrective actions for the failed testing and performed three successful strokes of the valve as a post-maintenance test prior to returning the valve to service. The inspectors concluded that the issues that led to the failure in 2020 were not foreseeable and correctable by the licensee.

Corrective Actions: The 2-0203-3D actuator was replaced and stroked (10 times)successfully prior to completion of Refueling Outage Q2R25, restoring the system to operable. The additional number of valve strokes was one of the procedural corrective actions generated by the licensee.

Corrective Action References: Issue Report 4330737, "ERV 2-0203-3D Relief Valve Did Not Actuate"

Performance Assessment:

The NRC determined this violation was not reasonably foreseeable and preventable by the licensee and therefore is not a performance deficiency.

Enforcement:

Enforcement Policy Section 2.2.4 states that violations with no associated performance deficiency will be dispositioned using traditional enforcement. Therefore, operating reactor violations with no associated performance deficiencies should be assigned a severity level as long as the violation meets the criteria described in Section 2.3.2 of the Policy for disposition as a NCV.

Severity: Traditional Enforcement is being used to disposition this violation with no associated Reactor Oversight Process performance deficiency, per NRC Enforcement Manual, Revision 11, Section 3.10. The inspectors determined the severity of the violation using Section 6 of the NRC Enforcement Policy and determined this issue was a SL IV because it most represented the examples in Section 6.1.d. The failure to meet the TS LCO and Action Statement was unknown to the licensee until they performed the required surveillance test during Refueling Outage Q2R25, while the plant was no longer in the condition of applicability.

Violation: Technical Specification LCO 3.5.1 requires that each emergency core cooling system injection/spray subsystem and the ADS function of five relief valves shall be OPERABLE. Limiting Condition for Operation 3.5.1, Condition H for one ADS valve inoperable requires that the valve is restored to an operable condition within 14 days.

Limiting Condition for Operation 3.5.1, Condition I states the required action and associated completion time for Condition H was not met, which requires the licensee to be in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Contrary to the above, from March 2018 until March 2020, the Unit 2 3D ERV ADS function was inoperable, was not restored to an operable condition, and the licensee did not enter Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

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

EXIT MEETINGS AND DEBRIEFS

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

• On July 7, 2020, the inspectors presented the integrated inspection results to Mr. K. Ohr, Site Vice President, and other members of the licensee staff.

• On April 9, 2020, the inspectors presented the inservice inspection results to Mr. K. Ohr, Site Vice President, and other members of the licensee staff.

• On April 16, 2020, the inspectors presented the radiation protection inspection results to Mr. W. K. Akre, Radiation Protection Manager, and other members of the licensee staff.

• On June 18, 2020, the inspectors presented the radiation protection inspection results to Mr. W. K. Akre, Radiation Protection Manager, and other members of the licensee staff.

THIRD PARTY REVIEWS The resident inspectors reviewed the World Association of Nuclear Operators (WANO) report from the Peer Review evaluation that was completed in July 2019.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Drawings FL-1 Flood Barriers Basement Floor D

71111.01 Procedures QCAP 0250-06 Control of In-Plant Flood Barriers and Watertight Submarine 15

Doors

71111.01 Procedures QCOA 0010-16 Flood Emergency Procedure 29

71111.04 Procedures QCOP 1100-01 Standby Operation of Standby Liquid Control System 13

71111.04 Procedures QCOP 7500-01 Standby Gas Treatment System (SBGTS) Standby 22

Operation and Start Up

71111.04 Procedures QOM 2-1100-01 Unit 2 SBLC Valve Checklist 8

71111.05 Fire Plans Fire Zone 1.1.1.5 Fire Zone 1.1.1.5 RB 666'-6" Elev. Stand-by Liquid Control July 2009

4th Floor East/West

71111.05 Fire Plans Fire Zone 1.1.2.5 Fire Zone 1.1.2.5 RB 666'-6" Elev. Stand-by Gas Treatment July 2009

4th Floor East/West

71111.08G Corrective Action IR 4114472 Recordable Indication on ISI Hanger 2305-W-214 (M-1017D- 03/13/2018

Documents 256)

71111.08G Corrective Action IR 4121523 Q2R24 ISI RPV Closure Head Flange Weld UT Exam 03/31/2018

Documents Results

71111.08G Procedures ER-AA-335-003 Magnetic Particle (MT) Examination 9

71111.08G Procedures ER-AA-335-016 VT-3 Visual Examination of Component Supports, 12

Attachments, and Interior of Reactor Vessels

71111.08G Procedures ER-AA-335-018 Visual Examination of ASME IWE Class MC and Metallic 14

Liners of IWL Class CC Components

71111.08G Procedures GEH-PDI-UT-1 PDI Generic Procedure for the Ultrasonic Examination of 12

Ferritic Welds

71111.08G Procedures GEH-UT-300 Procedure for Manual Examination of Reactor Vessel 12

Assembly Welds In Accordance with PDI

71111.08G Procedures GEH-UT-311 Procedure for Manual Ultrasonic Examination of Nozzle 19

Inner Radius, Bore and Selected Nozzle to Vessel Regions

71111.08G Work Orders WO 4761281-01 CM Replace Top Plate Anchors of 2305-W-214 (M-1017D- 04/03/2018

256)

71111.08G Work Orders WO 783623-01 CM Replace 2-1001-1B RHRSW Valve 03/29/2018

71111.15 Corrective Action IR 4323520 HPCI FIC Stuck at Max Flow 03/03/2020

Documents

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.15 Corrective Action IR 4328207 LPCI Loop Select 03/20/2020

Documents

71111.15 Corrective Action IR 4333200 Vibrations and Current Swings on #2 125VDC Charger 04/06/2020

Documents

71111.19 Corrective Action IR 4334613 During QOS 6500-4 One Recorder Point Failed due Blown 04/11/2020

Documents Fuses

71111.19 Procedures QCOS 1000-28 RHR Service Water Pump Comprehensive/Performance 25

Test

71111.19 Procedures QCOS 1400-1 OP QCOS 1400-1 B Core Spray Pump Flow Rate GP B 50

PMP Test

71111.19 Work Orders WO 4762015 MM Overhaul 2A Standby Liquid Control Pump 05/07/2020

71111.19 Work Orders WO 4775349 4 kV Undervoltage Functional Test 04/10/2020

71111.19 Work Orders WO 4806048 ECCS Simul Auto Actuation and DG Auto Start 04/11/2020

71111.19 Work Orders WO 5029567 EO ID: 2A RHRSW Pump High Pressure Outboard Seal 02/23/2020

Leak

71111.20 Miscellaneous NF-AA-330 Physical Inventory Report; Q2R25 Core Verification 04/09/2020

71111.20 Work Orders WO 5004798 B Loop RHR LPCI Mode Flow Rate 04/30/2020

71111.22 Corrective Action IR 4330970 PSU Q2R25 Outbd MSIV 2-0203-2B Exceeded TS LLRT 03/30/2020

Documents Limit

71111.22 Corrective Action IR 4330975 PSU Q2R25 Outbd MSIV 2-0203-2C Admin Warning Limit 03/30/2020

Documents for LLRT

71111.22 Procedures QCOS 1000-6 RHR Pump / Loop Operability Test 63

71111.22 Work Orders WO 5004802 RHR D Pump Flow Rate (IST) 04/30/2020

71111.22 Work Orders WO 5004803 RHR C Pump Flow Rate (IST) 04/30/2020

71124.01 ALARA Plans QC-02-20-00508, DW Nuclear Instrumentation Activities 03/26/2020

Task 1

71124.01 ALARA Plans QC-02-20-00508, DW Nuclear Instrumentation IRM/SRM Removal (Q2R25) 03/26/2020

Task 2

71124.01 ALARA Plans QC-02-20-00513, DW Control Rod Drive Exchange 03/26/2020

Task 1

71124.01 ALARA Plans QC-02-20-00513, Control Rod Drive Bullpen Support 03/25/2020

Task 2

71124.01 ALARA Plans QC-02-20-00513, DW Undervessel Prep and Restore Activities 03/25/2020

Task 3

Inspection Type Designation Description or Title Revision or

Procedure Date

71124.01 ALARA Plans QC-02-20-00701, Torus Diving (Q2R25) 03/23/2020

Task 1

71124.01 ALARA Plans QC-02-20-00701, Torus Dive RP and Tender Activities (Q2R25) 03/24/2020

Task 2

71124.01 ALARA Plans QC-02-20-00701, Torus Filters (Q2R25) 03/24/2020

Task 3

71124.01 Corrective Action IR 4332878 Planned Dose Rate Alarm >150% 04/05/2020

Documents

71124.01 Corrective Action IR 4334908 RP Discontinues Work on Refuel Floor 04/12/2020

Documents

71124.01 Radiation Work QC-02-20-00508 DW Nuclear Instrumentation System 01

Permits (RWPs)

71124.01 Radiation Work QC-02-20-00513 DW Control Rod Drive Exchange 00

Permits (RWPs)

71124.01 Radiation Work QC-02-20-00701 Torus Diving 01

Permits (RWPs)

71124.04 Calculations RP-AA-220, Intake Investigation Form 03/31/2019

71124.04 Corrective Action IR 4233376 Positive Whole Body Count 03/27/2019

Documents

71124.04 Corrective Action IR 4332878 Planned Dose Rate >150% 04/05/2020

Documents

71124.04 Miscellaneous Dose Assessment for One Declared Pregnant Worker 03/25/2019

71124.04 Miscellaneous Neutron Field Characterization Study of Dry Cask Storage 02/01/2014

ISFSI Campaign

71124.04 Procedures RP-AA-203 Exposure Control and Authorization 5

71124.04 Procedures RP-AA-203-1001 Personnel Exposure Investigations 11

71124.04 Procedures RP-AA-210 Dosimetry Issue, Usage, and Control 29

71124.04 Procedures RP-AA-220 Bioassay Program 15

71124.04 Procedures RP-AA-222 Methods for Estimating Internal Exposure from In Vivo and In 6

Vitro Bioassay Data

71124.04 Procedures RP-AA-270 Prenatal Radiation Exposure 9

71152 Corrective Action IR 4328189 Part 21 Notification Received for EMD Fuel Injectors 03/20/2020

Documents

Inspection Type Designation Description or Title Revision or

Procedure Date

71152 Corrective Action IR 4341773 Unit Two Moisture Carryover Greater Than 0.1% 05/07/2020

Documents

71152 Corrective Action IR 4341995 Increased Moisture Carryover on U2 05/08/2020

Documents

71153 Corrective Action IR 4328207 LPCI Swing Bus (MCC 28/29-5) Did Not Transfer QCOS 03/20/2020

Documents 6700-02

71153 Engineering QDC-42228 Failure Analysis of Time Delay Relay 05/13/2020

Evaluations

71153 Miscellaneous LER 20-001-00 Loss of Both Divisions of Residual Heat Removal Low 05/19/2020

Pressure Coolant Injection Due to Swing Bus Failure to

Transfer

71153 Procedures QCAN 902-8 A- Unit 2 Main Generator Negative Sequence 04/22/2020

21