IR 05000254/2022002
| ML22221A202 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 08/09/2022 |
| From: | Ruixiang S, Robert Ruiz NRC/RGN-III/DRP/B1 |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2022002 | |
| Download: ML22221A202 (24) | |
Text
SUBJECT:
QUAD CITIES NUCLEAR POWER STATION - INTEGRATED INSPECTION REPORT 05000254/2022002 AND 05000265/2022002
Dear Mr. Rhoades:
On June 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Quad Cities Nuclear Power Station. On July 19, 2022, the NRC inspectors discussed the results of this inspection with Mr. B. Wake, Site Vice President, and other members of your staff.
The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. 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 violation or the significance or severity of the violation 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.
If you disagree with a cross-cutting aspect assignment 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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Quad Cities Nuclear Power Station.
August 9, 2022 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 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:
Report Numbers:
05000254/2022002 and 05000265/2022002
Enterprise Identifier:
I-2022-002-0055
Licensee:
Constellation Nuclear
Facility:
Quad Cities Nuclear Power Station
Location:
Cordova, IL
Inspection Dates:
March 28, 2022 to June 30, 2022
Inspectors:
J. Cassidy, Senior Health Physicist
Z. Coffman, Resident Inspector
C. Hunt, Senior Resident Inspector
C. Mathews, Illinois Emergency Management Agency
Approved By:
Robert Ruiz, Chief
Branch 1
Division of Reactor Projects
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
Failure to Identify a Condition Adverse to Quality During 2-0203-3B ERV Actuator Rebuild Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000254,05000265/2022002-01 Open/Closed
[H.14] -
Conservative Bias 71152A The inspectors identified a very low safety significance (Green) finding and associated non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," for the licensee's failure to identify that the bowing of the upper guide bracket introduced by technicians during the actuator rebuild of the 2-0203-3B ERV was a condition adverse to quality. The failure to enter the condition into the corrective action program (CAP) prevented the condition from being properly addressed by the licensee prior to the valve being placed in service on April 7, 2020. The valve failed to cycle during as-found testing 2 years later on March 21, 2022.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000254/2022-002-00 LER 2022-002 Quad Cities Nuclear Power Station, Unit 1, Low Pressure Coolant Injection Manually Isolated Due to Valve Test Equipment Issue 71153 Closed
PLANT STATUS
Unit 1 On April 1, 2022, the unit performed a planned downpower to approximately 60 percent to perform power suppression testing. The unit returned to full-rated thermal power on April 4, 2022. On June 30, 2022, the unit performed an unplanned downpower to approximately 60 percent following a stator water cooling leak where it remained for the rest of the inspection period. All other times, the unit was at full-rated thermal power, with the exception of short-term power reductions for control rod sequence exchanges, testing, and as requested by the transmission system operator.
Unit 2 The unit began the inspection period shut down for the Q2R26 refueling outage. The unit began power ascension following the Q2R26 outage on April 23, 2022. The unit reached full-rated thermal power on April 25, 2022, where it remained for the rest of the inspection period, with the exception of short-term power reductions for control rod sequence exchanges, testing, and 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 performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. 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.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe hot weather June 13-17, 2022.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (1 Sample)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)2A core spray system during a planned loop 2A residual heat removal work window on May 25, 2022
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (2 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 8.2.7.C, Unit 1/2 turbine building, elevation 611', adjustable speed drive oil coolers on May 9, 2022
- (2) Fire Zone 8.2.7.E, Unit 2 north mezzanine floor on May 17, 2022
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, heat up, and post-maintenance testing following refueling outage Q2R26 on April 24, 2022.
- (2) The inspectors observed and evaluated licensed operator performance in the control room during plant response to a grid disturbance on June 30, 2022.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator requalification simulator drills on May 23, 2022.
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 (SSCs) remain capable of performing their intended function:
- (1) Unit 1/2 diesel generator system on June 23, 2022
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 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) Risk management actions for QCOP 1000-20, "RHR Service Water Operation Using Loop 'B' Cross-Tie Header," on April 5, 2022
- (3) E-2 certification meeting and risk management for work week June 20, 2022
- (4) Site response to a grid disturbance on June 30, 2022
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) Action Request (AR) 4501081, "U2 Alt 125V Battery Quarterly PM [preventative maintenance] to Exceed Late Date"
- (2) AR 4498920, "MOV 1-1001-28B Did Not Meet the Required C-14 Thrust"
- (3) AR 4486439, "Q2R26 LLRT [local leak rate test] On 2-1301-17 Exceeded Admin Alarm Limit"
- (4) AR 4492862, "AQ [augmented quality] Valve Diaphragm Used in Safety Related 1-2399-15 Valve"
- (5) AR 4126495, "Quad Cities Unqualified Coatings in Containment for U2"
- (6) AR 4503693, "U2 SJAE [steam jet air ejector] Rad Monitors Trending/Reading Lower Than Expected"
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Temporary configuration change associated with QCAP 1000-43, "Bypassing Reactor Shutdown Cooling Isolation," on March 22, 2022
- (2) Emergency core cooling system room cooler mod on March 22, 2022
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (12 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:
- (1) WO 5025149-06, "LLRT 'C' Line Only," on April 4, 2022
- (2) QCOS 0100-18, "RHR [residual heat removal] Suppression Chamber Spray Local Leak Rate Test MO 1(2)-1001-37 A/B," Revision 0, following repairs to 2-1001-37B on April 4, 2022
- (3) QCOS 0201-08, "Reactor Vessel Class 1 and Associated Class 2 System Leak Test,"
Revision 75, on April 4, 2022
- (4) WO 5076964-03, "LLRT MSIV [main steam isolation valve] 'A' Partial," on April 4, 2022
- (5) WO 4930743, "LLRT for 2-1201-5 following repairs" on April 4, 2022
- (6) QCOS 0300-27, "Control Rod SCRAM Timing During Vessel System Leak Test,"
Revision 16, on April 4, 2022 (7)2B loop residual heat removal service water restoration following planned work on April 7, 2022 (8)2B core spray pump surveillance following planned work and troubleshooting on April 7, 2022
- (10) High pressure coolant injection testing and surveillances following maintenance in refueling outage Q2R26 on April 22, 2022 (11)1/2 emergency diesel generator cooling water pump (EDGCWP) PMT on May 25, 2022 (12)1/2 EDGCWP following emergent repairs on June 21, 2022
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated Q2R26 activities from March 21, 2022 to April 23, 2022.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:
Surveillance Tests (other) (IP Section 03.01) (3 Samples)
(1)1/2 emergency diesel generator load test following EDGCWP PMT on May 25, 2022 (2)1A core spray flow rate surveillance on June 22, 2022 (3)2A core spray flow rate surveillance on June 28, 2022
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated:
- (1) Emergency preparedness drill on June 13,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated instructions to workers including radiation work permits used to access high radiation areas and the labeling of radioactive material in containers.
Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)
The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:
- (1) Licensee surveys of potentially contaminated material leaving the radiologically controlled area (RCA), and workers exiting the RCA at the Unit 1 Trackway Control Point during a refueling outage
- (2) Licensee surveys of potentially contaminated material leaving the RCA, and workers exiting the RCA at the Unit 2 Trackway Control Point during a refueling outage
Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)
The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:
- (1) Unit 2 'C' reactor water cleanup heat exchanger leak repair
- (2) Reactor building corner room cooler isolation valve modification
- (3) Torus diving activities High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (3 Samples)
The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:
- (1) Unit 1 'A' clean up pump room
- (2) Unit 1 'A' clean up heat exchanger room
- (3) Unit 2 'A' clean up pump room Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
- (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Temporary Ventilation Systems (IP Section 03.02) (1 Sample)
The inspectors evaluated the configuration of the following temporary ventilation systems:
- (1) Temporary ventilation established for work in the Unit 2 reactor water cleanup heat exchanger room
Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees use of respiratory protection devices.
71124.06 - Radioactive Gaseous and Liquid Effluent Treatment
Walkdowns and Observations (IP Section 03.01) (3 Samples)
The inspectors evaluated the following radioactive effluent systems during walkdowns:
- (1) Main chimney monitoring system
- (2) Unit 1 reactor building vent monitoring system
- (3) Unit 2 reactor building vent monitoring system
Sampling and Analysis (IP Section 03.02) (5 Samples)
Inspectors evaluated the following effluent samples, sampling processes and compensatory samples:
- (1) Unit 1 drywell particulate sample
- (2) Unit 2 drywell particulate sample
- (3) Unit 1 reactor building vent particulate sample
- (4) Unit 2 reactor building vent particulate sample
- (5) Main chimney particulate sample
Dose Calculations (IP Section 03.03) (2 Samples)
The inspectors evaluated the following dose calculations:
- (1) Gaseous Discharge, Permit Number G2022568, Unit 1 Reactor Building Vent Noble Gas
- (2) Gaseous Discharge, Permit Number G2022580, Main Chimney (Unit 1 and Unit 2)
Particulate and Iodine
Abnormal Discharges (IP Section 03.04) (1 Sample)
The inspectors evaluated the following abnormal discharges:
- (1) On March 10, 2021, groundwater sample results from wells located in the condensate storage tank and ancillary piping area identified a potential leak with elevated tritium concentration up to 3.2 million pico-curies per liter (pCi/L). Five additional groundwater monitoring wells were installed for assistance with leak detection location and groundwater monitoring. A new remediation well was installed (MW-R-2D2) and remediation commenced on March 15, 2021. Removal of groundwater contamination from the remediation well continued through 2021, into 2022, substantially lowering residual tritium levels to 15,700 pCi/L in May 2022.
As part of the investigation to identify the source, the 'B' condensate storage tank was drained and inspected. During the inspection a hole measuring 0.25" x 0.3125" (approximately the width of a pencil) was discovered on the tank floor which allowed water to seep into the surrounding groundwater. The tank bottom plate was repaired and returned to service.
Temporary FRAC tanks were used to support emptying of the 'B' condensate storage tank for repair. On April 14, 2021, one of the tanks was being moved from a satellite RCA to Trackway 1 to support internal decontamination prior to shipment. During the move, the tank drain isolation valve failed, resulting in approximately 10 gallons of fluid leaking onto an impermeable surface. Less than 1 gallon reached a site storm drain that routes rainwater to the discharge bay.
71124.07 - Radiological Environmental Monitoring Program
GPI Implementation (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees implementation of the Groundwater Protection Initiative program to identify incomplete or discontinued program elements.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10)===
- (1) Unit 1 (July 1, 2021 through April 30, 2022)
- (2) Unit 2 (July 1, 2021 through April 30, 2022)
BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)
- (1) Unit 1 (April 1, 2021 through March 31, 2022)
- (2) Unit 2 (April 1, 2021 through March 31, 2022)
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
(1)
(July 1, 2021 through April 30, 2022)
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
(1)
(July 1, 2021 through April 30, 2022)
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) AR 4498920, "MOV 1-1001-28B Did Not Meet the Required C-14 Thrust,"
on May 27, 2022
- (2) Failure to identify a condition adverse to quality during 2-0203-3B ERV actuator rebuild on June 19, 2022 71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02) (1 Sample 1 Partial)
The inspectors evaluated the following licensee event reports (LERs):
(1)
(Partial)
LER 05000265/2022-001-00, "Electromatic Relief Valve 3B Did Not Actuate Due to Incorrectly Oriented Plunger Well Plastic Guides," (ADAMS Accession No. ML22140A128). The inspection conclusions associated with this LER are documented in Inspection Report 05000265/2022090.
- (2) LER 05000254/2022-002-00, "Low Pressure Coolant Injection Manually Isolated Due to Valve Test Equipment Issue," (ADAMS Accession No. ML22189A029). The inspection conclusions associated with this LER are documented in this report under Inspection Results Section
INSPECTION RESULTS
Failure to Identify a Condition Adverse to Quality During 2-0203-3B ERV Actuator Rebuild Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000254,05000265/2022002-01 Open/Closed
[H.14] -
Conservative Bias 71152A The inspectors identified a very low safety significance (Green) finding and associated non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," for the licensee's failure to identify that the bowing of the upper guide bracket introduced by technicians during the actuator rebuild of the 2-0203-3B ERV was a condition adverse to quality. The failure to enter the condition into the corrective action program (CAP) prevented the condition from being properly addressed by the licensee prior to the valve being placed in service on April 7, 2020. The valve failed to cycle during as-found testing 2 years later on March 21, 2022.
Description:
On March 21, 2022, the licensee attempted to cycle the 2-0203-3B electromatic relief valve (ERV) for as-found testing at the beginning of refueling outage Q2R26, but the valve did not stroke as expected. Later investigation by the licensee determined that the valves solenoid actuator was binding during operation, preventing the 2-0203-3B ERV from opening. The licensee documented the condition in the CAP under AR 4486294.
The automatic depressurization subsystem (ADS) of the emergency core cooling system (ECCS) is an alternate to the high-pressure coolant injection subsystem meant to depressurize the reactor pressure vessel in the event of a small break loss of coolant accident to allow the low-pressure coolant injection subsystem to inject into the reactor vessel. The ADS contains five valves, four ERVs, and one Target Rock valve that functions as an ADS valve and code safety-relief valve.
The inspectors reviewed the circumstances surrounding the rebuild of the solenoid actuator for the 02-0203-3B ERV which started on January 22, 2020, under WO 4804706 using QCEM 0200-13, Dresser Electromatic Solenoid Actuator Rebuild Instructions, Revision 10.
The rebuild would take several months to complete. The inspectors noted that during the rebuild, technicians were directed per procedure to replace the old actuator plunger due to not passing a wear inspection. The removal of the old plunger and installation of a new plunger on the upper guide bracket were done per Attachment 2 of QCEM 0200-13. As written in the work order notes, the technicians retrieved two new plungers from stores, but noted that both new plungers were narrower than the plunger that was removed from service. The first attempt at installing a new plunger resulted in the bowing of the upper guide bracket when the plunger and the upper guide bracket were torqued in accordance with
2. The bow resulted in the plunger being bound in the plunger well when the
technicians manually actuated the assembly. The technicians returned the first plunger to stores and then attempted to install the second plunger which also caused bowing of the upper guide bracket when torqued per procedure, again resulting in binding during manual actuation. The technicians took a picture of the bow for the work package but did not document the condition in the CAP.
On March 20, 2020, technicians manually straightened the upper guide bracket without procedural guidance or instruction, and without acceptance criteria to determine that the activity was accomplished satisfactorily, noting that they achieved smooth movement when manually actuating the plunger on the bench. The solenoid actuator was installed on April 7, 2020, under WO 4812170, prior to startup of from the Q2R25 refueling outage, where it was cycled several additional times. The valve failed to cycle during as-found testing 2 years later on March 21, 2022.
The licensee performed a failure analysis on the 2-0203-3B solenoid actuator and determined that one of the causes of the failure was due to a warped upper guide bracket that caused increased friction in the plunger well. Inspectors questioned the licensee on why the bowed upper guide bracket was not entered into the CAP at the time the technicians realized that bowing of the upper guide bracket was not an expected condition. The licensee stated QCEM 0200-13, Step 5.1, directs the technicians to write issue reports to correct discrepancies that were not corrected during the course of the rebuild. Since the technicians were able to achieve smooth operation of the actuator on the work bench after incorrectly straightening the upper guide bracket, the licensee stated that an issue report would not have been not required to be generated.
Corrective Actions: Actions created out of the licensee's corrective action program evaluation associated with AR 4486294, "ERV 2-0203-3B Relief Valve Failed to Actuate," created enhancements to the ERV rebuild procedure giving more explicit direction to technicians to generate issue reports when issues during the rebuild are encountered.
Corrective Action References: AR 4486294, "ERV 2-0203-3B Relief Valve Failed to Actuate"
Performance Assessment:
Performance Deficiency: The inspectors determined that the failure to identify a condition adverse to quality was a performance deficiency. Specifically, the bowing of the upper guide bracket during the 2-0203-3B ERV actuator rebuild was a condition adverse to quality that prevented the actuator from operating correctly and, therefore, not an expected condition. As such, per licensee procedure PI-AA-125, Corrective Action Program (CAP) Procedure, technicians should have entered the issue into the CAP.
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, a warped upper guide bracket can cause increased friction between the plunger and the plunger well and adversely affect the ability of the 2-0203-3B ERV to perform its design basis function.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors screened the finding in accordance with IMC 0609, Appendix A, exhibit 2, and answered "No" to all six screening questions. Therefore, the finding screens to very low safety significance (Green).
Cross-Cutting Aspect: H.14 - Conservative Bias: Individuals use decision making-practices that emphasize prudent choices over those that are simply allowable. A proposed action is determined to be safe in order to proceed, rather than unsafe in order to stop. Specifically, the technicians failed to generate an issue report on the bowed upper guide bracket during the 2-0203-3B ERV rebuild because the rebuild procedure did not explicitly direct them to do so.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures be established to ensure that conditions adverse to quality, such as deficiencies, defective material and equipment, and nonconformances, are promptly identified.
Licensee procedure NO-AA-10, "Quality Assurance Topical Report (QATR)," Revision 98, Chapter 16, Section 16.2, states that the licensee implements a CAP to promptly identify and correct items or occurrences that are adverse to quality or might adversely affect safe operation of a nuclear generating station.
Contrary to the above, from January 24, 2020, to March 20, 2020, the technicians failed to identify that the bowing of the upper guide bracket during the 2-0203-3B ERV rebuild was a condition adverse to quality. Specifically, the condition prevented the actuator from performing its design function and was not an expected condition per the rebuild procedure.
Although the technicians documented the deficiency in the work order notes, they failed to document the condition in the CAP, thus preventing the site from properly addressing the condition before the actuator was installed for service on April 7, 2020.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Minor Violation 71152A Minor Violation: The Inspectors identified that during WO 5082605 for the inspection of MOV 2-1001-28B, performed in accordance with MA-AA-723-301, Periodic Inspection of Limitorque Model SMB/SB/SBD-000 Through 5 Motor Operated Valves, technicians recorded grade 3 quality grease for the valve stem on the data sheet provided in 2 of MA-AA-723-301, but failed to generate an issue report per procedural guidance.
Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality be prescribed by documented procedures of a type appropriate to the circumstances, and be accomplished in accordance with these procedures. The licensee established MA-AA-723-301, Periodic Inspection of Limitorque Model SMB/SB/SBD-000 Through 5 Motor Operated Valves, Revision 15, as the implementing procedure for performing safety-related, motor-operated valve inspections, an activity affecting quality.
Procedure MA-AA-723-301, step 4.9.2, states:
Record As-Found Stem Lubrication grade on Attachment 2 utilizing the guidance provided in
1. MA-AA-723-301, Attachment 1, states that for grade 3 grease:
Notify Supervision. Initiate an issue report to evaluate change in stem lubrication interval.
Contrary to the above, on February 21, 2022, technicians failed to follow step 4.9.2 of procedure MA-AA-723-301. Specifically, the technicians recorded a grade 3 grease in 2 of the procedure but failed to initiate an issue report prompting an evaluation of the stem lubrication interval.
The inspectors determined that the failure to initiate an issue report per procedural direction was a performance deficiency. The licensee captured this issue under AR 4504364 in the CAP.
Screening: The inspectors determined the performance deficiency was minor. Specifically, the inspectors screened the performance deficiency in accordance with Inspection Manual Chapter 0612, Appendix B, and determined that the performance deficiency did not adversely affect the valve's operability or availability, it was not viewed as a precursor to a significant event, and it did not have the potential to lead to a more significant safety concern.
Enforcement:
This failure to comply with 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
Observation: Motor-Operated Valve Grease Inspection Issues on MOV 1-1001-28B 71152A On May 10, 2022, the licensee determined that motor operated valve (MOV) 1-1001-28B was inoperable following environment qualification testing per WO 5046628. Specifically, the as-found thrust for the MOV was below the minimum calculated thrust for the testing. In addition, the licensee determined that the valve did not have the expected volume of grease when inspected by technicians and an assessment of the grease that was present determined that there was some grease degradation. The licensee entered the condition of the MOV into the CAP as AR 4498920 and took the appropriate actions per the site Technical Specifications (TS). The licensee also transmitted ENS [emergency notification system]
Notification 55891 for both trains of low-pressure coolant injection being inoperable.
Immediate actions by the licensee included adding grease to the MOV and performing troubleshooting which ultimately determined that the quick stem sensor on the MOV was defective. The defective sensor resulted in poor data acquisition during the original testing.
Once the sensor was replaced, follow-on testing determined that the as-found thrust was within the expected range and acceptable. The valve was declared operable on May 11, 2022.
When inspectors were notified about the 1-1001-28B being inoperable on May 10, the licensee stated that the valve did not pass diagnostic testing, the grease in the valve was not at the expected level, and the quality of the grease found in the valve was degraded. On May 23, 2022, the inspectors noted that the CAP products generated by the licensee did not address the unexpected volume loss of the grease in the valve nor did they address the quality of the grease discovered during the original inspection.
With respect to the grease level, the licensee indicated that one possible cause for the grease not being at the anticipated volume was that procedural guidance contained in the MOV inspection procedure MA-AA-723-301, Periodic Inspection of Limitorque Model SMB/SB/SBD-000 Through 5 Motor Operated Valves, does not specifically address the differences in design of MOV 1-1001-28B versus other types of valve models and therefore technicians may not have been inspecting the valve for grease level correctly during previous MOV inspections. As such, the grease in 1-1001-28B may have been slowly being used up over the course of many years without being identified.
MOV 1-1001-28B has a Limitorque model SMB 5 actuator. There are four total valves of this model at the site. The licensee determined that for an extent of condition, the remaining SMB 5 model valves should be inspected for grease quality and level. ARs 4501024, 4501026, and 4501031, were generated to perform these inspections. MA-AA-723-301 addresses grease levels during MOV inspections by directing the technicians to add or remove grease as required. Therefore, a low grease level, although unexpected, does not immediately adversely impact the operability of the MOV.
With respect to grease quality, the licensee determined that the quality of grease was grade 3, based on the inspection performed on May 10, 2022. According to MA-AA-723-301, 1, grade 3 grease requires the technicians to notify supervision and initiate an issue report to evaluate scheduling re-greasing of the valve prior to the next scheduled inspection interval. The inspectors noted that the licensee had not generated an issue report for the degraded grease nearly 2 weeks after the grease was initially discovered to be grade 3. Following discussions with the licensee, the licensee generated AR 4501702.
Additionally, the inspectors reviewed work orders from previous grease inspections for the remaining SMB 5 model valves in the extent of condition population. Inspectors identified in WO 5082605, for MOV 2-1001-28B completed on February 21, 2022, the technicians recorded grade 3 quality grease for the valve stem on the data sheet provided in 2 of MA-AA-723-301, but failed to generate an issue report per procedural guidance.
According to MA-AA-723-301, Attachment 1, grade 3 grease still has acceptable lubrication properties and therefore continues to support valve operation. The generation of an issue report for a grade 3 grease allows the MOV program engineers to effectively trend the health of the MOV and adjust the maintenance strategy as necessary to ensure optimal performance. While grade 3 grease does not make the valve inoperable, failure to follow procedural guidance prevents the organization from effectively maintaining the long-term health of a safety-related component over its service life in the plant.
The inspectors identified one minor violation during this inspection sample.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On July 19, 2022, the inspectors presented the integrated inspection results to Mr. B. Wake, Site Vice President, and other members of the licensee staff.
On April 1, 2022, the inspectors presented the radiation protection inspection results to Mr. W. K. Akre, Radiation Protection Manager, and other members of the licensee staff.
On July 19, 2022, the inspectors presented the radiation protection inspection results to Mr. D. Carrick, Operations Director, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
QCOP 0010-10
Required Hot Weather Inspections
FZ 8.2.7.E
Unit 2 TB 615'-6" Elev. North Mezzanine Floor
February
22
Fire Plans
FZ 8.2.7C
Unit 1/2 TB 611'-6" Elev. Turbine Building Oil Reservoirs
February
22
Calculations
QC-MISC-007
Quad Cities Time Sensitive Operator Actions
U0 DGCW Outboard Bearing Degrading
10/18/2021
EO ID: 1/2 EDG Cooling Water Pump Not Starting
2/21/2022
Corrective Action
Documents
Follow Up to IR 4479617 for the 1/2 EDGCWP
Troubleshooting.
2/24/2022
Corrective Action
Documents
Resulting from
Inspection
Inaccurate Initial MRFF Screening Identified
07/01/2022
DBD-QC-009
Quad Cities Design Basis Document Unit 1 and 2 Diesel
Generator System
A
Miscellaneous
Maintenance
Rule System
Basis Document
DG6600-01
Procedures
QCAN 2212-45
C-3
Diesel Cooling Water Pump Failure or Diesel Cooling Water
Pump Locked Out
Corrective Action
Documents
U1 Stator Cooling ALTEREX Rectifier Filter Leak
06/30/2022
OP-AA-201-012-
1001
Operations On-Line Fire Risk Management
Procedures
QCOP 1000-20
RHR Service Water Operations Using Loop B Cross-Tie
AQ Valve Diaphragm Used in Safety Related
1-2399-15 Valve
04/13/2022
MOV 1-1001-28B Did Not Meet the Required C-14 Thrust
U2 Alt 125V Battery Quarterly PM to Exceed Late Date
05/20/2022
Corrective Action
Documents
U2 SJAE Rad Monitors Trending/Reading Lower than
06/03/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Expected
0-5205B 1/2B Fire Diesel Tripped on Overspeed
06/20/2022
Corrective Action
Documents
Resulting from
Inspection
Grade 3 Grease in MOV 1-1001-28B
05/24/2022
Determination of Appendix J Maximum Allowable Leakage
AQ Valve Diaphragm Installed on HPCI SR 1-2399-15 PCV
Engineering
Changes
ECR 0454652
Review of 1-1001-28B As-Found Torque Value
05/10/2022
ANS-56.8-1994
American National Standard for Containment System
Leakage Testing Requirements
EQ-51Q
Installation Requirements for MOV Grease
Miscellaneous
Nuclear Energy Institute - Industry Guideline for
Implementing Performance-Based Option of 10 CFR Part 50,
Appendix J
July 2012
CY-QC-130-404
SJAE and MSL Monitor Alarm Setpoint Calculation
QCTP 0130-01
Containment Boundary Repair Deferral
Procedures
QOS 0005-01
Operations Department Weekly Summary of Daily
Surveillance
171
Work Orders
(EQ)(IST) (MOV) Prog Diagnostic Test
05/10/2022
04/03/2020
WO 4965846-03 Low Reading Found at Cut Line Location
03/25/2022
Corrective Action
Documents
EOID: PSU: 2B RHR Room Cooler not Receiving DGCWP
Flow
04/07/2022
Perform Documented Technical Evaluation of QCOP
1000-43 Verify Compliance with CC-AA-112
Engineering
Changes
U-2 Install 5 Isolation Valves in SR Service Water Piping on
Each ECCS Room Cooler Supply Piping
QCOP 1000-43
Bypass Reactor Shutdown Cooling Isolation
Procedures
QCOS 0005-04
RHR 'A' Loop Non-Outage Valve Position Indication
Verification Checklist
Work Orders
Install New 2-3999-883 Valve Per EC 407243
04/03/2022
Q2R26 LLRT 2-0203-1A Exceeded Tech Spec Limit <78 scfh
03/22/2022
Corrective Action
Documents
2-0203-1A Manifold PM Scope Add to Q2R26
03/22/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
PSU Q2R26 RCS Boundary Leakage Test Results
04/04/2022
Missing RPIS on Scram Report: H-09
04/05/2022
Missing RPIS on Scram Report: G-10
04/05/2022
Missing RPIS on Scram Report: N-04
04/05/2022
Missing RPIS on Scram Report: J-15
04/05/2022
Missing RPIS on Scram Report: H-06
04/05/2022
PSU: Control Rod E-03 Slow Scram Time
04/05/2022
1/2 EDGCWP Failed to Swap to Bus 18 from Bus 28
06/19/2022
Troubleshooting Findings from 1/2 EDGCWP Failure
06/20/2022
U1/2 CCW EDG Showing Signs of Needing Replacement
06/20/2022
MM Overhaul the 2-0203-1A MSIV
04/01/2022
Engineering
Changes
ECR 454984
QCEPM 0400-15 Mechanical Interlock Clearance
Acceptance Criteria
06/20/2022
Quad Cities U2 Control Rod Scram Timing Full Report
04/05/2022
Miscellaneous
Quad Cities U2 Control Rod Scram Timing Single Rod
Report
04/24/2022
QCEPM 0400-15
Emergency Diesel Generator Feed Transfer Panel
Maintenance
QCOP 6600-14
Emergency Diesel Generator Cooling Water Pump Manual
Operation
QCOS 0100-05
Main Steam Isolation Valve Local Leak Rate Test
AO 1(2)-0203-1A/B/C/D, AO 1(2)-0203-2A/B/C/D
QCOS 0100-05
Main Steam Isolation Valve Local Leak Rate Test
AO 1(2)-0203-1A/B/C/D, AO 1(2)-0203-2A/B/C/D
QCOS 0100-18
RHR Suppression Chamber Spray Local Leak Rate Test
MO 1(2)-1001-37A/B
QCOS 0100-19
Reactor Water Clean-Up System Local Leak Rate Test
MO 1(2)-1201-2, MO 1(2)-1201-5, RV 1(2)-1299-97
QCOS 0201-08
Reactor Vessel Class 1 and Associated Class 2 System Leak
Test
QCOS 0300-23
Control Rod Scram Timing in the Hot Condition
QCOS 0300-24
Control Rod Scram Timing in the Cold Condition
Procedures
QCOS 0300-27
Control Rod Scram Timing During Vessel System Leak Test
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
(J.7.a)
QCOS 1000-04
RHR Service Water Pump Operability Test
QCOS 1400-07
Core Spray Pump Comprehensive/Performance Test
QO 5245043-02
03/31/2022
HPCI System Turbine Overspeed Test
04/23/2022
MM Overhaul of 2-0203-2C MSIV
03/30/2022
04/23/2022
Q2R26 PMT's Required Prior To Mode 2
03/14/2022
03/31/2022
Inspect/Repair Spare ERV Actuators Preoutage EOC
03/31/2022
Inspect/Repair Spare ERV Actuators Preoutage EOC
03/31/2022
Inspect /Repair Spare ERV Actuators Preoutage EOC
04/01/2022
Inspect /Repair Spare ERV Actuators Preoutage EOC
04/01/2022
Work Orders
HPCI Flor Rate Test Comprehensive Test (IST)
04/23/2022
NRC ID: Unique WHR Waiver/IR Not Created for Each Shift
05/06/2022
Corrective Action
Documents
Resulting from
Inspection
NRC ID WHR Waivers
05/06/2022
Procedures
QCOS 1400-01
Core Spray System Flow Rate Test
Miscellaneous
Alpha Program Evaluation 2021
03/09/2022
QC-02-22-00626
Unit 2 'C' Reactor Water Cleanup Heat Exchanger Leak
Repair
QC-02-22-00627
Reactor Building Corner Room Cooler Isolation Valve
Modification
Radiation Work
Permits (RWPs)
QC-02-22-00701
Torus Diving Activities
Recommend Revision to Main Chimney Stack Testing
08/25/2020
U2 SJAE Rad Monitors Trending/Reading Lower Than
Expected
10/20/2020
Main Chimney High Range Noble Gas Monitor Declared
05/11/2022
Main Chimney High Range Noble Gas Monitor Inoperable
05/18/2022
Corrective Action
Documents
Issues Discovered During Review of 2020 Main Chimney
Calibration
05/26/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
U2 SJAE Rad Monitors Trending/Reading Lower Than
Expected
06/03/2022
PMID 184216 and WO# 04890760 Need Partial Credit
06/08/2022
Corrective Action
Documents
Resulting from
Inspection
Main Chimney Sample Line Testing Discrepancies
06/17/2022
CY-QC-110-204
Operation of the NMC AM-2B & AM-2D CAM, and Drywell &
Suppression Chamber Venting & Purging Sampling
CY-QC-110-605
Reactor Building Vent Gaseous & Particulate Sampling
Procedures
CY-QC-110-606
Main Chimney Gaseous & Particulate Sampling
ODCM Program Health
04/22/2022
Self-Assessments
Potentially Contaminated System Controls Program
2/15/2021
Document Unit 1 Reactor Building Exhaust Fan Flowrates
05/21/2021
Document Unit 2 Reactor Building Exhaust Fan Flowrates
05/21/2022
Main Chimney High Range Noble Gas Monitor Calibration
08/27/2020
Removal of Charcoal Sample and Inspection of Filter
11/17/2021
Removal of Charcoal Sample and Inspection of Filter
11/23/2021
Work Orders
1/2A Stand-By Gas Treatment Charcoal Adsorber Test
11/18/2021
Corrective Action
Documents
Resulting from
Inspection
NRC ID: Increased Sampling on Monitoring Wells
07/07/2022
CY-QC-120-720
2; Actual Dose Data; Unit 1 and Unit 2
July 2021 -
April 2022
Monthly Data Elements for NRC Indicator - Reactor Coolant
System (RCS) Specific Activity
July 2021 -
April 2022
71151
Miscellaneous
A; Site Performance Indicator Validation Sheet
July 2021 -
April 2022
PSU: ERV 2-0203-3B Relief Valve Did Not Actuate
03/21/2022
Corrective Action
Documents
MOV 1-1001-28B Did Not Meet the Required C-14 Thrust
05/10/2022
Corrective Action
Documents
Resulting from
Inspection
NRC ID: IR Not Generated for MOV 2-1001-28A Degraded
Grease
06/08/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Work Orders
00175214-01, EQ, Inspect/Repair Spare ERV Actuators
Preoutage (EQ)
01/22/2020