IR 05000254/2022002

Integrated Inspection Report 05000254/2022002 and 05000265/2022002

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

August 9, 2022

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. 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, Signed by Ruiz, Robert on 08/09/22 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: DPR-29 and DPR-30 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 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

Failure to Identify a Condition Adverse to Quality During 2-0203-3B ERV Actuator Rebuild Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.14] - 71152A Systems NCV 05000254,05000265/2022002-01 Conservative Open/Closed Bias 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 71153 Closed Cities Nuclear Power Station, Unit 1, Low Pressure Coolant Injection Manually Isolated Due to Valve Test Equipment Issue

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.

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

(2) Work Order (WO) 4498920, "MOV 1-1001-28B Did Not Meet the Required C-14 Thrust"

(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

(9) Electromatic relief valve (ERV) PMT following installation on April 20, 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,

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 Report Aspect Section Mitigating Green [H.14] - 71152A Systems NCV 05000254,05000265/2022002-01 Conservative Open/Closed Bias 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 71152A MOV 1-1001-28B 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 Type Designation Description or Title Revision or

Procedure Date

71111.01 Procedures QCOP 0010-10 Required Hot Weather Inspections 26

71111.05 Fire Plans FZ 8.2.7.E Unit 2 TB 615'-6" Elev. North Mezzanine Floor February

22

FZ 8.2.7C Unit 1/2 TB 611'-6" Elev. Turbine Building Oil Reservoirs February

22

71111.12 Calculations QC-MISC-007 Quad Cities Time Sensitive Operator Actions 3

Corrective Action AR 4453721 U0 DGCW Outboard Bearing Degrading 10/18/2021

Documents AR 4479617 EO ID: 1/2 EDG Cooling Water Pump Not Starting 02/21/2022

AR 4480517 Follow Up to IR 4479617 for the 1/2 EDGCWP 02/24/2022

Troubleshooting.

Corrective Action AR 4508875 Inaccurate Initial MRFF Screening Identified 07/01/2022

Documents

Resulting from

Inspection

Miscellaneous DBD-QC-009 Quad Cities Design Basis Document Unit 1 and 2 Diesel A

Generator System

Maintenance DG6600-01

Rule System

Basis Document

Procedures QCAN 2212-45 Diesel Cooling Water Pump Failure or Diesel Cooling Water 7

C-3 Pump Locked Out

71111.13 Corrective Action AR 4508500 U1 Stator Cooling ALTEREX Rectifier Filter Leak 06/30/2022

Documents

Procedures OP-AA-201-012- Operations On-Line Fire Risk Management 4

1001

QCOP 1000-20 RHR Service Water Operations Using Loop B Cross-Tie 17

Header

71111.15 Corrective Action AR 4492862 AQ Valve Diaphragm Used in Safety Related 04/13/2022

Documents 1-2399-15 Valve

AR 4498920 MOV 1-1001-28B Did Not Meet the Required C-14 Thrust

AR 4501081 U2 Alt 125V Battery Quarterly PM to Exceed Late Date 05/20/2022

AR 4503693 U2 SJAE Rad Monitors Trending/Reading Lower than 06/03/2022

Inspection Type Designation Description or Title Revision or

Procedure Date

Expected

AR 4506489 0-5205B 1/2B Fire Diesel Tripped on Overspeed 06/20/2022

Corrective Action AR 4501702 Grade 3 Grease in MOV 1-1001-28B 05/24/2022

Documents

Resulting from

Inspection

Engineering EC 629270 Determination of Appendix J Maximum Allowable Leakage 00

Changes EC 636553 AQ Valve Diaphragm Installed on HPCI SR 1-2399-15 PCV 00

ECR 0454652 Review of 1-1001-28B As-Found Torque Value 05/10/2022

Miscellaneous ANS-56.8-1994 American National Standard for Containment System

Leakage Testing Requirements

EQ-51Q Installation Requirements for MOV Grease 10

NEI 94-01 Nuclear Energy Institute - Industry Guideline for July 2012

Implementing Performance-Based Option of 10 CFR Part 50,

Appendix J

Procedures CY-QC-130-404 SJAE and MSL Monitor Alarm Setpoint Calculation 10

QCTP 0130-01 Containment Boundary Repair Deferral 31

QOS 0005-01 Operations Department Weekly Summary of Daily 171

Surveillance

Work Orders WO 5046628 (EQ)(IST) (MOV) Prog Diagnostic Test 05/10/2022

71111.18 Corrective Action AR 4339766 Q2R25 LL OPS Group 3 04/03/2020

Documents AR 4487476 WO 4965846-03 Low Reading Found at Cut Line Location 03/25/2022

AR 4491321 EOID: PSU: 2B RHR Room Cooler not Receiving DGCWP 04/07/2022

Flow

Engineering EC 404390 Perform Documented Technical Evaluation of QCOP 0

Changes 1000-43 Verify Compliance with CC-AA-112

EC 407243 U-2 Install 5 Isolation Valves in SR Service Water Piping on 10

Each ECCS Room Cooler Supply Piping

Procedures QCOP 1000-43 Bypass Reactor Shutdown Cooling Isolation 14

QCOS 0005-04 RHR 'A' Loop Non-Outage Valve Position Indication 29

Verification Checklist

Work Orders WO 4965846-03 Install New 2-3999-883 Valve Per EC 407243 04/03/2022

71111.19 Corrective Action AR 4486442 Q2R26 LLRT 2-0203-1A Exceeded Tech Spec Limit <78 scfh 03/22/2022

Documents AR 4486462 2-0203-1A Manifold PM Scope Add to Q2R26 03/22/2022

Inspection Type Designation Description or Title Revision or

Procedure Date

AR 4490144 PSU Q2R26 RCS Boundary Leakage Test Results 04/04/2022

AR 4490235 Missing RPIS on Scram Report: H-09 04/05/2022

AR 4490237 Missing RPIS on Scram Report: G-10 04/05/2022

AR 4490238 Missing RPIS on Scram Report: N-04 04/05/2022

AR 4490239 Missing RPIS on Scram Report: J-15 04/05/2022

AR 4490240 Missing RPIS on Scram Report: H-06 04/05/2022

AR 4490243 PSU: Control Rod E-03 Slow Scram Time 04/05/2022

AR 4506342 1/2 EDGCWP Failed to Swap to Bus 18 from Bus 28 06/19/2022

AR 4506538 Troubleshooting Findings from 1/2 EDGCWP Failure 06/20/2022

AR 4506551 U1/2 CCW EDG Showing Signs of Needing Replacement 06/20/2022

WO 5076964-03 MM Overhaul the 2-0203-1A MSIV 04/01/2022

Engineering ECR 454984 QCEPM 0400-15 Mechanical Interlock Clearance 06/20/2022

Changes Acceptance Criteria

Miscellaneous Quad Cities U2 Control Rod Scram Timing Full Report 04/05/2022

Quad Cities U2 Control Rod Scram Timing Single Rod 04/24/2022

Report

Procedures QCEPM 0400-15 Emergency Diesel Generator Feed Transfer Panel 18

Maintenance

QCOP 6600-14 Emergency Diesel Generator Cooling Water Pump Manual 18

Operation

QCOS 0100-05 Main Steam Isolation Valve Local Leak Rate Test 4

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 4

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 0

MO 1(2)-1001-37A/B

QCOS 0100-19 Reactor Water Clean-Up System Local Leak Rate Test 1

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 75

Test

QCOS 0300-23 Control Rod Scram Timing in the Hot Condition 27

QCOS 0300-24 Control Rod Scram Timing in the Cold Condition 9

QCOS 0300-27 Control Rod Scram Timing During Vessel System Leak Test 15

Inspection Type Designation Description or Title Revision or

Procedure Date

(J.7.a)

QCOS 1000-04 RHR Service Water Pump Operability Test 65

QCOS 1400-07 Core Spray Pump Comprehensive/Performance Test 16

Work Orders QO 5245043-02 EM EWP Inspect Spare (E) ERV 03/31/2022

WO 5019895 HPCI System Turbine Overspeed Test 04/23/2022

WO 5025149-03 MM Overhaul of 2-0203-2C MSIV 03/30/2022

WO 5075171 HPCI LP Low Rate Test 04/23/2022

WO 5181410-22 Q2R26 PMT's Required Prior To Mode 2 03/14/2022

WO 5245043 EM EWP Inspect Spare (B) ERV 03/31/2022

WO 5245043-03 Inspect/Repair Spare ERV Actuators Preoutage EOC 03/31/2022

WO 5245043-04 Inspect/Repair Spare ERV Actuators Preoutage EOC 03/31/2022

WO 5245043-05 Inspect /Repair Spare ERV Actuators Preoutage EOC 04/01/2022

WO 5245043-06 Inspect /Repair Spare ERV Actuators Preoutage EOC 04/01/2022

WO 5252398 HPCI Flor Rate Test Comprehensive Test (IST) 04/23/2022

71111.20 Corrective Action AR 4498151 NRC ID: Unique WHR Waiver/IR Not Created for Each Shift 05/06/2022

Documents AR 4498224 NRC ID WHR Waivers 05/06/2022

Resulting from

Inspection

71111.22 Procedures QCOS 1400-01 Core Spray System Flow Rate Test 52

71124.01 Miscellaneous Alpha Program Evaluation 2021 03/09/2022

Radiation Work QC-02-22-00626 Unit 2 'C' Reactor Water Cleanup Heat Exchanger Leak 00

Permits (RWPs) Repair

QC-02-22-00627 Reactor Building Corner Room Cooler Isolation Valve 1

Modification

QC-02-22-00701 Torus Diving Activities 0

71124.06 Corrective Action AR 4365367 Recommend Revision to Main Chimney Stack Testing 08/25/2020

Documents AR 4377954 U2 SJAE Rad Monitors Trending/Reading Lower Than 10/20/2020

Expected

AR 4499133 Main Chimney High Range Noble Gas Monitor Declared 05/11/2022

Inoperable

AR 4500461 Main Chimney High Range Noble Gas Monitor Inoperable 05/18/2022

AR 4502217 Issues Discovered During Review of 2020 Main Chimney 05/26/2022

Calibration

Inspection Type Designation Description or Title Revision or

Procedure Date

AR 4503693 U2 SJAE Rad Monitors Trending/Reading Lower Than 06/03/2022

Expected

Corrective Action AR 4504424 PMID 184216 and WO# 04890760 Need Partial Credit 06/08/2022

Documents AR 4506189 Main Chimney Sample Line Testing Discrepancies 06/17/2022

Resulting from

Inspection

Procedures CY-QC-110-204 Operation of the NMC AM-2B & AM-2D CAM, and Drywell & 11

Suppression Chamber Venting & Purging Sampling

CY-QC-110-605 Reactor Building Vent Gaseous & Particulate Sampling 13

CY-QC-110-606 Main Chimney Gaseous & Particulate Sampling 22

Self-Assessments AR 4401525 ODCM Program Health 04/22/2022

AR 4448834 Potentially Contaminated System Controls Program 12/15/2021

Work Orders WO 4890759 Document Unit 1 Reactor Building Exhaust Fan Flowrates 05/21/2021

WO 4890760 Document Unit 2 Reactor Building Exhaust Fan Flowrates 05/21/2022

WO 4959574 Main Chimney High Range Noble Gas Monitor Calibration 08/27/2020

WO 5012264 Removal of Charcoal Sample and Inspection of Filter 11/17/2021

WO 5012264-02 Removal of Charcoal Sample and Inspection of Filter 11/23/2021

WO 5012266 1/2A Stand-By Gas Treatment Charcoal Adsorber Test 11/18/2021

71124.07 Corrective Action AR 04509724 NRC ID: Increased Sampling on Monitoring Wells 07/07/2022

Documents

Resulting from

Inspection

71151 Miscellaneous CY-QC-120-720 Attachment 2; Actual Dose Data; Unit 1 and Unit 2 July 2021 -

April 2022

LS-AA-2090 Monthly Data Elements for NRC Indicator - Reactor Coolant July 2021 -

System (RCS) Specific Activity April 2022

SP-AA-3000 Attachment A; Site Performance Indicator Validation Sheet July 2021 -

April 2022

71152A Corrective Action AR 4486294 PSU: ERV 2-0203-3B Relief Valve Did Not Actuate 03/21/2022

Documents AR 4498920 MOV 1-1001-28B Did Not Meet the Required C-14 Thrust 05/10/2022

Corrective Action AR 4504364 NRC ID: IR Not Generated for MOV 2-1001-28A Degraded 06/08/2022

Documents Grease

Resulting from

Inspection

Inspection Type Designation Description or Title Revision or

Procedure Date

Work Orders WO 4804706 00175214-01, EQ, Inspect/Repair Spare ERV Actuators 01/22/2020

Preoutage (EQ)

21