Text

95001 Supplemental Inspection Report 05000265/2023040 and Follow-Up Assessment Letter
	ML23167B172
Person / Time
Site:	Quad Cities
Issue date:	06/16/2023
From:	Robert Ruiz; NRC/RGN-III/DORS/RPB1
To:	Rhoades D; Constellation Energy Generation, Constellation Nuclear
References
	IR 2023040
	Download: ML23167B172 (1)
	v • d • e

June 16, 2023

David P. Rhoades

Senior Vice President

Constellation Energy Generation, LLC

President and Chief Nuclear Officer (CNO)

Constellation Nuclear

4300 Winfield Road

Warrenville, IL 60555

SUBJECT: QUAD CITIES NUCLEAR POWER STATION - 95001 SUPPLEMENTAL

INSPECTION SUPPLEMENTAL REPORT 05000265/2023040 AND

FOLLOW-UP ASSESSMENT LETTER

Dear David Rhoades:

On May 4, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed a supplemental

inspection using Inspection Procedure 95001, "Supplemental Inspection Response to Action

Matrix Column 2 (Regulatory Response) Inputs, and discussed the results of this inspection

with you and other members of your staff.

The NRC performed this inspection to review your stations actions in response to a White

finding in the Mitigating Systems cornerstone which was documented and finalized in NRC

Inspection Report 05000254/2022090 and 05000265/2022090 respectively. On March 28, 2023,

you informed the NRC that your station was ready for the supplemental inspection.

The NRC determined that your staffs evaluation identified the cause of the White finding.

Specifically, Quad Cities Nuclear Power Station (the licensee) conducted a root cause analysis

and determined that there were two root causes. The first was "Inadequate Human Performance

(HU) behaviors during the planning and execution of the ERV rebuild," and the second was

"The stations Preventive Maintenance (PM) structure does not ensure that all components for

OPCC [Operationally Critical Components] work are tied to PMIDs that facilitate effective OPCC

screening." The licensee determined that there was inadequate level of detail in the procedures

used to rebuild the electromatic relief valve. In addition, the craft failed to stop when unsure and

proceeded in the face of uncertainty. Because the first root cause was associated with human

performance behaviors; however, there was no corrective action to preclude repetition assigned

to this root cause. The second root cause was associated with preventive maintenance

structure which did not identify operationally critical components to ensure an adequate level of

detail in work documents and supervisory oversight. The corrective actions associated with the

causes identified include actions to improve nuclear professionalism behaviors as well as

reviews of maintenance items to ensure they are structured appropriately with the correct

classification to ensure the appropriate levels of detail and oversight.

The inspectors concluded that the licensee had adequately determined the root and contributing

causes and had appropriate actions in place to address the causes identified.

D. Rhoades 2

The NRC determined that completed or planned corrective actions were sufficient to address

the performance issue that led to the White finding previously described. Therefore, the

performance issue will not be considered as an Action Matrix input following the conclusion of

the debrief conducted on May 4, 2023.

No findings or violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection

and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document

Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public

Inspections, Exemptions, Requests for Withholding.

Sincerely,

Signed by Ruiz, Robert

on 06/16/23

Robert Ruiz, Chief

Reactor Projects Branch 1

Division of Operating Reactor Safety

Docket No. 05000265

License No. DPR-30

Enclosure:

As stated

cc w/ encl: Distribution via LISTSERV

ML23167B172

Non-Sensitive Publicly Available

SUNSI Review

Sensitive Non-Publicly Available

OFFICE RIII

NAME RRuiz:mb

DATE 06/16/2023

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number: 05000265

License Number: DPR-30

Report Number: 05000265/2023040

Enterprise Identifier: I-2023-040-0004

Licensee: Constellation Nuclear

Facility: Quad Cities Nuclear Power Station

Location: Cordova, IL

Inspection Dates: May 01, 2023 to May 04, 2023

Inspectors: C. St. Peters, Senior Resident Inspector

D. Tesar, Senior Resident Inspector

Approved By: Robert Ruiz, Chief

Reactor Projects Branch 1

Division of Operating Reactor Safety

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees

performance by conducting a 95001 supplemental 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

No findings or violations of more than minor significance were identified.

Additional Tracking Items

Type Issue Number Title Report Section Status

NOV 05000265/2022090-01 02-0203-3B Electromatic 95001 Closed

Relief Valve Failed to

Operate During As-Found

Testing During Refueling

Outage Q2R26

2

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in

effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with

their attached revision histories are located on the public website at http://www.nrc.gov/reading-

rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared

complete when the IP requirements most appropriate to the inspection activity were met

consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection

Program - Operations Phase. The inspectors reviewed selected procedures and records,

observed activities, and interviewed personnel to assess licensee performance and compliance

with Commission rules and regulations, license conditions, site procedures, and standards.

OTHER ACTIVITIES - TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

95001 - Supplemental Inspection Response to Action Matrix Column 2 (Regulatory Response)

Inputs

The inspectors reviewed and selectively challenged aspects of the licensees problem

identification, causal analysis, and corrective actions in response to the Unit 2, 2-203-3B

electromatic relief valve failure to operate on March 21, 2023, as documented in NRC

Inspection Reports 05000254/2022090 and 05000265/2022090 and Licensee Event

Report (LER) 265/2022-001-00.

Supplemental Inspection Response to Action Matrix Column 2 (Regulatory Response) Inputs

(1 Sample)

(1) SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) reviewed the licensees corrective

actions to address a White finding by performing a supplemental inspection using

Inspection Procedure 95001, Supplemental Inspection Response to Action Matrix

Column 2 Inputs, at Quad Cities, Unit 2 in accordance with the reactor oversight

process.

The inspectors determined that the licensees problem identification, causal analysis,

corrective actions in place, and incident reports (IR) entered into their corrective

action program (CAP) sufficiently addressed the performance issue that led to the

White finding.

INSPECTION RESULTS

Assessment 95001

1. Problem Identification

a. Identification: This issue was self-revealed when the 2-0203-3B electromatic

relief valves (ERV) (3B ERV) failed to operate during as-found surveillance testing

on March 21, 2022.

b. Exposure Time: The licensee determined that the 3B ERV was inoperable from

April 7, 2021 until March 21, 2022.

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c. Identification Opportunities: The inspectors determined that the licensee had a

missed opportunity to identify this issue when the 2-0203-3D ERV (3D ERV)

experienced binding and failed to operate correctly in March of 2020, shortly after

the original issue with the 3B ERV occurred. The inspectors identified other

potential opportunities to identify the issue as documented in the report.

d. Risk and Compliance: The licensee conducted a risk evaluation and a review of

Technical Specification (TS) impacts of the 3B ERV failure. Their risk evaluation

determined that the failure of the 3B ERV was a maintenance rule functional

failure (MRFF) and was reportable under Title 10 of the Code of Federal

Regulations (10 CFR) 50.73(a)(2)(i)(B) - Any operation or condition which was

prohibited by the plants Technical Specifications. The licensees risk evaluation

determined a slightly elevated change in core damage frequency (delta CDF).

The NRC also conducted a risk evaluation (utilizing the Standardized Plant

Analysis Risk (SPAR) Model) accounting for the ERV failure over the exposure

time and determined that the delta CDF was consistent with a White finding of low

to moderate safety significance.

NRC Assessment:

The inspectors determined that the licensee had completed the risk evaluation as

required. The difference in the outcome between the licensee risk evaluation and

the NRC evaluation was due to differences in the models used as well as the

exposure time (12 months) used by the NRC in the SPAR model. The licensees

corrective actions were based upon the NRC determination of White, low to

moderate safety significance. Therefore, the inspectors determined that the

actions taken and/or planned adequately addressed the safety significance of the

issue.

Assessment 95001

2. Causal Analysis

a. Methodology: The licensee initially conducted an equipment causal analysis,

then subsequently conducted a root cause analysis to determine the root and

contributing causes of the event. Analytical tools implemented included event and

causal factors, cause and effects analysis, and TapRoot methodologies. In

addition, interviews and anonymous surveys were used to solicit information from

plant staff. The inspectors review concluded that the root cause analysis was the

appropriate level of evaluation and that the methodologies implemented were

appropriate.

b. Level of Detail: In general, the inspectors determined that the causal evaluation

was conducted with an appropriate level of detail commensurate with the safety

significance of the issue. Inspectors identified additional potential opportunities as

discussed within this report. The results of the licensees evaluation were clearly

documented in the report with root and contributing causes identified and what

actions were put in place to correct each of the causes.

c. Operating Experience: The licensee adequately identified and addressed

operating experience associated with the failure of the 2-0203-3B ERV. Other

events considered during this analysis included, but were not limited to:

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Quad Cities, "2-0203-3D Electromatic Relief Valve did not Operate"

(2020)(IR478917)

Quad Cities, "Electromatic Relief Valve Failed to Stroke"

Quad Cities, "Inadequate Maintenance Risk Assessment" (incident reports

(IR) 4506936)

Quad Cities, "Carousel Lift Over Spent Fuel Pool" (IR 4442806)

Quad Cities, "Forced Normal Reactor Shutdown due to Failure of

Bearings/Bushings and Plunger in Main Steam Relief Valve"

(2006)(IR 219321)

Dresden, "Electromatic Relief Valve Actuator Failed to Actuate During

Surveillance"

Oyster Creek, "EMRV Failed to Open When Operated from the MCR"

Waterford, "Automatic Reactor Trip Occurred While Attempting to Synchronize

a Second Motor Generator Set"

There were some similarities in many of these events, however, the licensee

determined that the issue was not operating experience (OE) preventable due to

differences in the failure mechanism, differences in the equipment, or lack of detail

associated with the previous industry event. The inspectors determined that the

licensee had reasonably considered OE with one potential opportunity when

considering the ERV failure to operate identified in 2020. As identified below, the

licensee entered this potential missed opportunity into their corrective action

program (CAP).

d. Extent of Condition and Cause: The inspectors reviewed the extent of condition

and the extent of cause conducted by the licensee. The inspectors did not identify

any issues associated with the extent of condition review but did question the

scope of the extent of cause. The extent of cause was determined to apply to the

three maintenance groups and the planners as they were the ones who utilized

the engineering change request (ECR) process; therefore, the corrective actions

were restricted to these groups. The inspectors questioned whether engineering

should also be included in this population, as the engineers also initiate and

disposition ECRs as well. This issue was entered into the CAP as IR 04675488,

NRC ID 95001: Formal Engineering Training for ECR Process."

e. Safety Culture: The inspectors reviewed the safety culture evaluation that was

conducted for the root cause and performed an independent assessment by

interviewing plant personnel. These interviews revealed that some plant personnel

believed there is an over emphasis placed on production at the station. One

example shared with inspectors demonstrated that, while senior station leadership

discussed appropriate nuclear safety culture behaviors during plant meetings and

pre-job briefs, they appeared to reward achieving success (i.e., job completion)

regardless of contrary behaviors that were exhibited to achieve that goal. Licensee

staff further stated that supervisory presence in the field was less than ideal, which

results in decreased opportunity for supervisors to set and reinforce standards and

appropriate behaviors.

Although the production-focused mentality was not discussed in the root cause

evaluation associated with the 3B ERV failure, at the time of the 95001 inspection,

the licensee was conducting an additional root cause evaluation associated with

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CAP 4669057, "Loss of U1 Reactor Vessel System Inventory through CRD

System Vent Valves, which identified the same production-focused mentality that

was raised to the inspectors. This second root cause evaluation has since been

completed and incorporates actions to address the safety culture aspects

identified during the 95001 inspection. Actions to address the mindset of being

overly focused on production are being taken in Root Cause 4669057

documented in corrective actions CA 4669057-51 and CA 4669057-56, both

assigned to the plant manager.

NRC Assessment:

The licensee causal evaluation determined the following root and contributing

causes:

Root Cause 1: Inadequate human performance (HU) behaviors were evident

during the planning and execution of the ERV rebuild.

Root Cause 2: The stations preventive maintenance (PM) structure does not

ensure that all components for OPCC work are tied to PMIDs that facilitate

effective OPCC screening.

Contributing Cause 1: The solenoid actuator rebuild procedure did not contain

adequate procedure guidance or acceptance criteria for correction of upper guide

bracket warping or installation of plunger well plastic guides.

Contributing Cause 2: Lack of communication between electrical

maintenance (EM) first line supervisors (FLS), EM technicians, and EM planners

regarding incorporation of ECR into the work package.

Contributing Cause 3: EM supervisors failed to provide effective oversight of

work affecting quality of safety-related components.

Based upon discussions with licensee staff, there is evidence of a prevailing

mindset which overemphasizes production over the demonstration of nuclear

safety culture behaviors at the station. Personnel also expressed that there is a

lack of supervisors in the field setting and reinforcing high standards and

appropriate behaviors.

While not addressed in the root cause evaluation for the failure of the 3B ERV, as

mentioned above, this was identified by the licensee in Root Cause 4669057

Loss of U1 Reactor Vessel System Inventory through CRD System Vent Valves,

which was ongoing for a subsequent issue. Actions to correct the condition are

being taken in that root cause.

The inspectors identified additional questions in the following areas:

The inspectors questioned whether it would be appropriate to incorporate

design/dimensional clearance checks into the actuator rebuild procedure to

eliminate the possibility of binding. The revisions which had already been

incorporated into the applicable procedures focused on the proper orientation

of the guides. Although this was a contributing cause (Contributing Cause 1)

due to the lack of symmetry in the construction of the guides, it may not

completely address the issue when considering the manufacturing tolerances

of the various components. The licensee entered this into their CAP as

IR 4675310.

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The inspectors questioned the actions taken by plant maintenance personnel

utilizing Action Verbs used in the actuator rebuild procedures. Based upon

questions from the inspectors, it was determined that Constellation does not

have a corporate procedure, nor does Quad Cities have a site-specific

procedure in which action verbs are defined. This may have contributed to a

maintenance technician taking inappropriate action based upon the individual's

understanding of what the action verb in the procedure was specifying (verify

vs. ensure). This issue was entered into the licensees CAP as IR 4675200.

The inspectors provided the above feedback to the licensee. All items identified by the

inspectors have been entered into the licensee's CAP. Overall, the inspectors

determined that the causes identified, corrective actions taken by the licensee, and

with the additional items identified by the inspectors, were appropriate for the safety

significance of the issue. The inspectors noted that although the production-focused

mindset at the station was missing from the initial causal evaluation, it was identified

in the subsequent root cause analysis with actions included to correct the condition.

Based upon the initial causal evaluations and the actions from the subsequent root

cause, the inspectors determined that the licensee response was appropriate for the

safety significance of the white finding.

Assessment 95001

3. Corrective Actions

a. Corrective Actions to Preclude Repetition: The inspectors concluded that

corrective actions planned or taken to preclude repetition of the Quad Cities White

performance issue were appropriate, timely, and commensurate with the safety

significance of the issue.

(1) Completed

The corrective actions to preclude repetition have not yet been completed.

(2) Planned

(a) Root Cause #2 for this event was The stations Preventive Maintenance

(PM) structure does not ensure that all components for Operational Critical

Component (OPCC) work are tied to PMIDs that facilitate OPCC

screening. Specifically, the Preventive Maintenance Identification

number (PMID) for ERV actuator rebuild was a standalone PMID which

was not coded as OPCC work. The actuator install was a different PMID

which was screened and coded as OPCC work. The significance being

that OPCC work has additional oversight and reviews performed to ensure

the appropriate quality of work for operationally significant components.

The corrective action to preclude repetition (CAPR) for root cause #2 is to

review PMIDs for critical components which are not appropriately flagged

and either tie them to a parent PMID or to tie them appropriately ensuring

that they are screened and coded properly. (These reviews are being

tracked via separate Action Item Tracking (ACIT) actions for each

department.) The site is tracking this CAPR under action request (AR)

assignment numbers 4539936-33 and 4539936-34, with a due date of

August 10, 2023. The action items tied to the CAPR are to review a list of

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work item PMIDs for critical components with no Equipment Identification

number (EPN) tagged and add PMID to respective parent PMID via

Preventive Maintenance Modification Request (PMMR), or to generate a

PMMR to tie an EPN with no parent PMID.

An effectiveness review associated with this CAPR is to be completed by

October 27, 2023. The site will conduct a pre-outage (Q2R27)

self-assessment of OPCC screening to determine if all pre-outage and

outage PMIDs for critical components have been screened for potential

OPCC work.

The inspectors determined that implementation of this CAPR was timely

based upon the number of items to be reviewed, as well as completion

time prior to subsequent outages. The timeliness of these actions is related

to the resources needed to complete each item. The action items that feed

into the CAPR have varying due dates reflective of the different work

groups involved. The inspectors determined that the corrective actions

planned or implemented adequately addressed the root and contributing

causes.

When complete, the NRC plans to inspect and assess the planned

corrective action to preclude repetition as identified in ARs 4539936-33

and 4539936-34, which are scheduled for completion on August 10, 2023.

b. Other Corrective Actions:

(1) Completed

(a) The site had already completed some corrective actions prior to the root

cause report being finalized, including corrective actions from the previous

CAP evaluation (CAPE) as well as interim actions from the CAP

associated with the root cause. Those corrective actions included marking

up procedures QCEM 0200-13 and QCEMS 0250-13 to include improved

upper guide bracket installation, inspection, and alignment criteria, as well

as implementing purchase requirements ensuring new plungers meet the

vendor specifications for Cat ID 1441792. These corrective actions were

completed in AR 4330737.

Completed corrective actions related to root cause 1 included submitting

training requests for development of nuclear professionalism training for

delivery to all site personnel and development of targeted training for ERV

rebuilds for electrical maintenance personnel. Due to root cause 1 being

HU related, the site performed a risk assessment and determined no

CAPRs were required. However, the nuclear professionalism training is

intended to address the human performance behaviors for all site

personnel, with additional targeted training for the specific groups involved.

The action to develop the training has been completed although actual

delivery of the training has not yet been completed.

Another completed corrective action was maintenance managers

reinforcing with supervisors and planners their specific roles and

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responsibilities in implementing the ECR process. This action addressed

contributing cause 2.

To address contributing cause 3, actions were taken to develop a matrix

for review of completed work packages to ensure proper closure

(IRs written, feedback provided). Included in the matrix is a supervisory

peer check and manager review for a period of 2 years.

(2) Planned

(a) The root cause for this event was determined to be inadequate HU

behaviors. No corrective action to preclude repetition (CAPR) was created

for root cause 1 in accordance with licensee procedure PI-AA-125-1001,

Root Cause Analysis Manual, and in alignment with human performance-

based root cause precedent (2443241-04 and 2646772-11), based upon

the following:

i. The root cause is human performance based.

ii. INPO Good Practice 07-006, Human Performance Tools for Managers

and Supervisors, states that there are no reliable corrective actions

that can absolutely prevent recurrence of human error.

iii. Due to the inherent risk of human fallibility, future error cannot be

totally eliminated.

iv. Actions are assigned to strengthen and reinforce the set of tools that

manager, supervisors, and individual contributors can use to help

minimize the frequency and severity of events triggered by active

errors.

v. Effectiveness review is assigned to review results from the corrective

action plan.

As discussed in the section above, training requests were made to deliver nuclear

professionalism training to site personnel to address root cause 1. The site has staggered

completion dates for this training to be delivered to all site personnel to include those already

hired and with consideration for future hires. The site is also tracking a training evaluation

effectiveness review following the initial rollout of the training with a due date of

November 30, 2023.

Additional corrective actions are planned to address root cause 2. One CA is to ensure each

task for ERV actuator rebuild is included as a pre-outage support activity under the outage

work for the actuator installation to ensure correct OPCC screening. Ensuring both the ERV

and the actuator are denoted as critical components along with flagging the respective tasks

for additional OPCC reviews is also planned.

NRC Assessment:

The inspectors determined that the licensees proposed corrective actions were

adequate to address the cause and that these actions are scheduled for completion

by August 10, 2023.

The inspectors determined that overall, the licensees problem identification, causal

analysis, corrective actions taken, corrective actions planned, and IRs entered into

their CAP sufficiently addressed the performance issue that led to the White finding

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and met the objectives of the IP. While the site does not have a formal completion

plan for the CAPR (Root Cause 2), it is being tracked under AR 4539936. The

inspectors discussed with the licensee the potential for the action items associated

with the CAPR to be resolved with no action taken, which could result in a CAPR with

no actions to correct the significant condition adverse to quality (SCAQ). The licensee

identified in procedure, PI-AA-125, Corrective Action Program Revision 8, that if a

CAPRs scope is changed, which would be the case if no actions were to be taken,

then it is subject to review by MRC and the root cause qualified investigator or

responsible manager. The inspectors identified several potential gaps which the

licensee has entered into their CAP to evaluate and take actions as deemed

necessary. The potential gaps identified include those mentioned previously as well

as the following:

a. IR 4675473 ERV rebuild procedure level of use evaluation - The procedure

utilized to perform the rebuild of the safety-related ERV actuators is reference

use. Inspectors questioned why this would not be a Continuous Use procedure.

The licensee response was that it met the criteria for being a reference use

procedure. Inspectors pointed out that it also appeared to meet the criteria for a

continuous use procedure which would be more limiting and provide additional

controls. The inspectors also pointed out the significant impacts from performing

the work incorrectly (White finding). The licensee initiated the above issue

resolution to evaluate the condition and revise the procedure level of use as

deemed necessary.

b. IR 4675449 NRC ID 95001: ECR Process Gap - The inspectors identified a

potential gap in the ECR process where there is no procedural requirement to tie

a generated ECR to the product needing to be changed. In the example

associated with this event, an ECR was processed and approved, but never

incorporated into the work documents. Relying solely on individuals to

communicate that an ECR was initiated and where it is in the process appears to

be a human performance error trap. The licensee entered this into their CAP as

indicated above.

c. IR 4675446 NRC ID 95001: Incomplete Documentation of Work - the inspectors

identified that Work Order (WO) 4804706-01 indicated that work was performed

on the ERV actuator. However, this was not documented in the work package as

required by attachment 2, and the maintenance procedures. This failure to

document work minimizes the effectiveness of the work package closeout reviews

and downstream work management processes. The licensee entered this issue

into their CAP as indicated above.

d. IR 4675254 NRC ID 95001: Missed Rework Investigation for WO 4768996,

inspectors identified that in March of 2020 when the 3D ERV failed to operate, the

licensee missed a potential opportunity to learn from the event by failing to

recognize that the process required a rework investigation when the 3D failed to

stroke. The licensee performed troubleshooting and additional maintenance on

the 3D ERV valve. This event occurred on the same day as the rework on the 3B

ERV. In both instances, a rework investigation could have provided additional

insights into the issue. The licensee entered this issue into their CAP as indicated

above.

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e. IR 4675273 NRC ID 95001: WO Missing Key Steps/Critical Steps, the

inspectors determined that the Licensee failed to follow their process and missed

additional potential opportunities to prevent or mitigate the event when they failed

to identify key/critical steps within their work documents. Even though the

licensee failed to identify this work as OPCC work, their process would still

require them to identify key/critical steps in the work instructions, that if performed

incorrectly could have direct consequences and impact the operability of the

component. During their review of the work documents, the inspectors identified

that there were no key/critical steps identified. The licensee entered this issue into

their CAP as indicated above.

Assessment 95001

4. Conclusion:

Inspectors reviewed the licensees corrective actions to address a White finding by

performing a supplemental inspection utilizing Inspection Procedure 95001,

Supplemental Inspection Response to Action Matrix Column 2 Inputs, at Quad

Cities, Unit 2 in accordance with the reactor oversight process.

During the inspection, inspectors identified 4 potential additional issues of concern

associated with 10 CFR 50, Appendix B, Criterion V; however, these were further

examples similar to, and associated with, those already captured in the White finding

and notice of violation (NOV) documented in NRC Inspection

Report 05000254/2022091 and 05000265/2022091. Therefore, it was determined that

no additional inspection was required to further assess those examples as they were

already covered by the existing documented NOV.

The inspectors determined that the licensees problem identification, causal analysis,

corrective actions in place, and the IRs entered into their CAP sufficiently addressed

the performance issues that were identified. The inspectors determined that the

inspection objectives as listed in IP 95001 were met, and that the corrective actions

taken and planned adequately addressed the White finding and associated NOV.

Therefore, in accordance with IMC 0305, this action matrix input will be CLOSED and

no longer considered.

EXIT MEETINGS AND DEBRIEFS

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

On May 4, 2023, the inspectors presented the 95001 supplemental inspection results to

Drew Griffith, Plant Manager, and other members of the licensee staff.

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DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

95001 Corrective Action CAPE 4330737 ERV 2-0203-3D Did Not Actuate 04/24/2020

Documents CAPE 4486294 ERV 2-0203-3B Relief Valve Failed to Actuate 04/18/2022

RCR 04669057 Loss of U1 Reactor Vessel System Inventory through CRD 05/24/2023

System Vent Valves

RCR 4539936 Quad Cities Unit 2 3B ERV Failure Event 01/31/2023

Engineering QDC-76517 Failure Analysis of: 3B Electromatic Relief Valve Solenoid 1

Evaluations Actuator

Procedures CC-AA-101 ENGINEERING CHANGE REQUESTS (ER) 7

HU-AA-101 HUMAN PERFORMANCE TOOLS AND VERIFICATION 14

PRACTICES

HU-AA-104-101 PROCEDURE USE AND ADHERENCE 7

MA-AA-1000- KEY STEP PROCESS 0

1001

MA-AA-716-003 TOOL POUCH / MINOR MAINTENANCE 13

MA-AA-716-010- OPERATIONAL CRITICAL COMPONENT WORK (OPCCW) 9

1015 PROCESS

PI-AA-125 CORRECTIVE ACTION PROGRAM (CAP) PROCEDURE 8

PI-AA-125-1003 ROOT CAUSE ANALYSIS MANUAL 6

QCEM 0200-13 DRESSER ELECTROMATIC SOLENOID ACTUATOR 0

REBUILD INSTRUCTIONS

QCEM 0200-13 DRESSER ELECTROMATIC SOLENOID ACTUATOR 10

REBUILD INSTRUCTIONS

QCEM 0200-13 DRESSER ELECTROMATIC SOLENOID ACTUATOR 11

REBUILD INSTRUCTIONS

QCEM 0200-13 DRESSER ELECTROMATIC SOLENOID ACTUATOR 12

REBUILD INSTRUCTIONS

QCEM 0200-13 DRESSER ELECTROMATIC SOLENOID ACTUATOR 13

REBUILD INSTRUCTIONS

QCEMS 0250-13 DRESSER ELECTROMATIC SOLENOID ACTUATOR 30