IR 05000254/2023004

Integrated Inspection Report 05000254/2023004 and 05000265/2023004

ML24036A290
Person / Time
Site:	Quad Cities
Issue date:	02/05/2024
From:	Robert Ruiz NRC/RGN-III/DORS/RPB1
To:	Rhoades D Constellation Energy Generation
References
IR 2023004
Download: ML24036A290 (1)

Text

SUBJECT:

QUAD CITIES NUCLEAR POWER STATION - INTEGRATED INSPECTION REPORT 05000254/2023004 AND 05000265/2023004

Dear David Rhoades:

On December 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Quad Cities Nuclear Power Station. On January 9, 2024, the NRC inspectors discussed the results of this inspection with Brian Wake, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

Five findings of very low safety significance (Green) are documented in this report. Five of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Quad Cities Nuclear Power Station.

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.

February 5, 2024 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 Reactor Projects Branch 1 Division of Operating Reactor Safety 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:

05000254/2023004 and 05000265/2023004

Enterprise Identifier:

I-2023-004-0057

Licensee:

Constellation Nuclear

Facility:

Quad Cities Nuclear Power Station

Location:

Cordova, IL

Inspection Dates:

October 01, 2023, to December 31, 2023

Inspectors:

B. Bergeon, Senior Operations Engineer

J. Cassidy, Senior Health Physicist

Z. Coffman, Resident Inspector

G. Hansen, Sr. Emergency Preparedness Inspector

T. Henning, Senior Operations Engineer

C. Hunt, Senior Resident Inspector

C. Mathews, Illinois Emergency Management Agency

J. Steward, Senior Resident Inspector

Approved By:

Robert Ruiz, Chief

Reactor Projects Branch 1

Division of Operating Reactor Safety

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 Implement a Preventive Maintenance Strategy for 2A Core Spray Flexible Rubber Cooling Line Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000265/2023004-01 Open/Closed

[H.14] -

Conservative Bias 71111.12 A self-revealed Green finding and associated non-cited violation (NCV) of Technical Specification 5.4.1.a, Procedures, was identified for the licensees failure to establish a preventive maintenance schedule associated with the replacement of the flexible rubber cooling line for the 2A core spray pump upper bearing oil cooler. As a result, on October 20, 2023, the cooling line ruptured during surveillance testing due to age-related degradation of the line.

Loss of Design Control on 2B Residual Heat Removal Pump Associated with a Nonconforming Flexible Rubber Cooling Line Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000265/2023004-02 Open/Closed

[H.6] - Design Margins 71111.12 The inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion III, Design Control, when the licensee failed to maintain the design margins of the Unit 2 residual heat removal system. Specifically, the licensee was not able to provide reasonable assurance that a 2B residual heat removal pump flexible rubber cooling line installed in the mid-1980s continued to meet its design qualification given its time in service and lack of qualification documentation. The line was discovered in service following an extent-of-condition walkdown stemming from the failure of a similar flexible rubber cooling line on the 2A core spray pump during surveillance testing on October 20, 2023.

Failure to Adequately Control Radiological Work Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000254,05000265/2023004-03 Open/Closed

[H.4] -

Teamwork 71124.03 A self-revealed finding of very low safety significance (i.e., Green) and an associated non-cited violation (NCV) of 10 CFR 20.1701 use of process or other engineering controls was reviewed by inspectors when the licensee failed to use, to the extent practical, process or other engineering controls (e.g., containment, decontamination, or ventilation) to control the concentration of radioactive material in air. Specifically, the licensee failed to establish appropriate controls before authorizing high-energy work using a grinder on a pipe with 15 mRad/hour of fixed contamination, which resulted in a worker that received or likely received greater than 10 mrem committed effective dose equivalent (CEDE).

Unit 2 Reactor Scram Due to Improperly Tuned Emergency Feedwater Heater Level Control Valve Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000265/2023004-04 Open/Closed

[H.14] -

Conservative Bias 71152A A self-revealed Green finding and an associated non-cited violation (NCV) of Technical Specification 5.4.1. Procedures, was identified for the licensees failure to have general operating procedures, appropriate for the circumstances, to ensure that systems required for startup and power operations were configured as required. Specifically, the feed water heater emergency level control valve for the 2A moisture separator drain tank was improperly tuned for at-power operations following a reactor start up. As a result, on August 11, 2023, following an electrical transient, the emergency level control valve failed to respond as expected and the Unit 2 main turbine generator tripped on a high-level condition in the 2A moisture separator drain tank. The turbine trip subsequently initiated an automatic scram of the Unit 2 reactor.

Failure to Maintain Unit 1 Station Blackout Diesel in a Standby Lineup During Chemistry Sampling Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000254/2023004-05 Open/Closed

[H.14] -

Conservative Bias 71152S The inspectors identified a Green finding and associated non-cited violation (NCV) of Technical Specification 5.4.1.a, Procedures, for the licensees failure to implement the station annunciator response procedure for low lubricating oil temperature on the Unit 1 station blackout diesel. As a result, lubricating oil temperature reached 75 degrees Fahrenheit, below that which the station blackout diesel could be considered functional and available for operation.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000265/2023-001-00 LER 2023-001-00 for Quad Cities Nuclear Power Station, Unit 2, Turbine Trip and Automatic Reactor Scram due to High Moisture Separator Level 71153 Closed LER 05000265/2023-001-01 LER 2023-001-01 for Quad Cities Nuclear Power Station, Unit 2, Turbine Trip and Automatic Reactor Scram due to High Moisture Separator Level 71153 Closed

PLANT STATUS

Unit 1

The unit began the inspection period at full-rated thermal power, where it remained for the rest of the inspection period, except for 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 at full-rated thermal power. On December 15, 2023, the unit experienced an unplanned reduction in power to approximately 30 percent due to a failure of the 2B adjustable speed drive. The unit returned to full-rated thermal power on December 18, 2023, where it remained for the rest of the inspection period, except for 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.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (2 Samples)

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

(1)1A core spray on November 8, 2023

(2) Unit 2 high-pressure coolant injection system (HPCI) on November 20, 2023

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 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 (FZ) 1.1.1.5, Unit 1 standby gas treatment and standby liquid control, on October 5, 2023

(2) FZ 5.0 and 8.1, clean and dirty oil room and safe shutdown makeup pump room, on October 6, 2023

(3) FZ 8.2.7.A, Unit 1 turbine building mezzanine floor, on October 26, 2023

(4) FZ 8.2.3.A, Unit 1 control rod drive pump level, on November 27, 2023

(5) FZ 9.1, Unit 1 emergency diesel generator room, on November 15, 2023

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the onsite fire brigade training and performance during an announced fire drill on October 12, 2023.

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

Requalification Examination Results (IP Section 03.03) (1 Sample)

(1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam administered on October 11, 2023, through October 12, 2023, and the biennial written examinations completed on October 13, 2023. No deficiencies were noted.

71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)

(1) Biennial Requalification Written Examinations The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered on October 13, 2023.

Annual Requalification Operating Tests The inspectors evaluated the adequacy of the facility licensees annual requalification operating test.

Administration of an Annual Requalification Operating Test The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.

Requalification Examination Security The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.

Remedial Training and Re-examinations The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.

Operator License Conditions The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.

Control Room Simulator The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples)

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

(1) Action Request (AR) 4687356, Lost Light Indications for 2A Core Spray, on September 15, 2023

(2) AR 4711200, 2A Core Spray Cooling Line Break During Run, on October 20, 2023

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (2 Samples)

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

(1) E-1 certification meeting and risk management for work week 10/30/2023 on November 3, 2023

(2) Unit 1 elevated risk due to emergency diesel generator exciter cabinet failure on December 11, 2023

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)

The inspectors evaluated the licensees justifications and actions associated with the following operability determinations and functionality assessments:

(1) AR 4692968, MOV [motor-operated valve] 2-1001-18A/B Incorrect Use of Close Control Scheme, on August 31, 2023

(2) AR 4704597, U1 SBO [station blackout] Emergency Stop Alarm Tile Locked In, on October 13, 2023

(3) AR 4707503, Control Room Envelope dP Less Than Expected on B HVAC [heating, ventilation, and air conditioning], on October 6, 2023

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:

Post-Maintenance Testing (PMT) (IP Section 03.01) (2 Samples)

(1) PMT following planned Unit 1 station blackout diesel work window on November 15, 2023

(2) PMT on the Unit 1 emergency diesel generator after emergent exciter cabinet work on December 18, 2023

Surveillance Testing (IP Section 03.01) (3 Samples)

(1) QCOS 7500-05, SBGTS [standby gas treatment system] Operability Test, on October 19, 2023

(2) QCOS 1100-07, SBLC [standby liquid control] Pump Flow Rate Test, on October 27, 2023

(3) QCOS 1300-05, RCIC [reactor core isolation cooling] PUMP OPERABILITY TEST, on December 8, 2023

71114.02 - Alert and Notification System Testing

Inspection Review (IP Section 02.01-02.04) (1 Sample)

(1) The inspectors evaluated the following maintenance and testing of the alert and notification system:

• Annual siren inspection and maintenance records for the period from October 2021 to October 2023

• Monthly alert notification system (siren) tests for the period from October 2021 to October 2023

71114.03 - Emergency Response Organization Staffing and Augmentation System

Inspection Review (IP Section 02.01-02.02) (1 Sample)

(1) The inspectors evaluated the readiness of the emergency preparedness organization.

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The inspectors completed an evaluation of emergency action level (EAL) and emergency plan changes on December 18, 2023. For the inspection period from July 1, 2022, through June 30, 2023, the licensee did not make any changes to the site emergency plan and EAL bases/matrix documents. The inspectors independently reviewed the current revisions of these documents to verify no changes were completed.

This evaluation does not constitute NRC approval.

71114.05 - Maintenance of Emergency Preparedness

Inspection Review (IP Section 02.01 - 02.11) (1 Sample)

(1) The inspectors evaluated the maintenance of the emergency preparedness program.

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

Temporary Ventilation Systems (IP Section 03.02) (1 Sample)

The inspectors evaluated the failure to provide temporary ventilation systems:

(1) Pipe end preparations on extraction steam piping in the Unit 1 steam tunnel; RWP QC-01-23-00826

71124.04 - Occupational Dose Assessment

Internal Dosimetry (IP Section 03.03) (1 Sample)

The inspectors evaluated the following internal dose assessments:

(1) Intake Investigation for RWP # QC-01-23-00826; EID CHAPP1407

71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling,

Storage, & Transportation

Radioactive Material Storage (IP Section 03.01)

The inspectors evaluated the licensees performance in controlling, labeling, and securing the following radioactive materials:

(1) Condensate Resin Liner PL-14-215-FEDX

(2) Fuel Channels PL-14-197-WM

Radioactive Waste System Walkdown (IP Section 03.02) (2 Samples)

The inspectors walked down the following accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality:

(1) Station interim radwaste storage facility

(2) Station advanced liquid processing system resin transfer area

Waste Characterization and Classification (IP Section 03.03) (2 Samples)

The inspectors evaluated the following characterization and classification of radioactive waste:

(1) Dry active waste (DAW)

(2) Condensate resin

Shipping Records (IP Section 03.05) (4 Samples)

The inspectors evaluated the following non-excepted radioactive material shipments through a record review:

(1) Radioactive Waste Shipment QC-22-102; Dry Active Waste/Trash; UN3321 Radioactive Material Low Specific Activity (LSA-II)

(2) Radioactive Waste Shipment QC-23-071; Cask with Dewatered Condensate Resin; UN3321 Radioactive Material Low Specific Activity (LSA-II)

(3) Radioactive Waste Shipment QC-23-108; 40' Sealand Dry Active Waste; UN3321 Radioactive Material Low Specific Activity (LSA-II)

(4) Radioactive Material Shipment QC-23-226; Contaminated Laundry; UN3321 Radioactive Material Low Specific Activity (LSA-II)

OTHER ACTIVITIES - BASELINE

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

MS07: High-Pressure Injection Systems (IP Section 02.06)===

(1) Unit 1 (October 1, 2022, through September 30, 2023)

(2) Unit 1 (October 1, 2022, through September 30, 2023)

MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)

(1) Unit 1 (October 1, 2022, through September 30, 2023)

(2) Unit 1 (October 1, 2022, through September 30, 2023)

MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)

(1) Unit 1 (October 1, 2022, through September 30, 2023)

(2) Unit 2 (October 1, 2022, through September 30, 2023)

MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)

(1) Unit 1 (October 1, 2022, through September 30, 2023)

(2) Unit 2 (October 1, 2022, through September 30, 2023)

BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)

(1) Unit 1 (April 1, 2022, through September 30, 2023)

(2) Unit 2 (April 1, 2022, through September 30, 2023)

EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)

(1) April 1, 2022, through June 30, 2023 EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)

(1) April 1, 2022, through June 30, 2023 EP03: Alert And Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)

(1) April 1, 2022, through June 30, 2023

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 4695858, U2 Turbine Trip and SCRAM due to High Moisture Separator Level, on November 15, 2023

(2) AR 4710673, 71111.11 Inspection Results, on October 13, 2023

71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends in issues not being entered into the corrective action program that might be indicative of a more significant safety issue. The inspectors identified several issues that were not entered into the corrective action program as required per other programmatic requirements. Details can be found in the Inspection Results section of this inspection report.

71153 - Follow Up of Events and Notices of Enforcement Discretion Event Follow up (IP Section 03.01)

(1) The inspectors evaluated the Unit 1 emergency diesel generator exciter cabinet arc fault event and licensees response on December 11, 2023.

Event Report (IP Section 03.02) (1 Sample)

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

(1) LERs 05000265/2023-001-00 and 05000265/2023-001-01, Turbine Trip and Automatic Reactor Scram due to High Moisture Separator Level (ADAMS Accession Nos. ML23334A076 and ML23284A284). The inspectors reviewed the original LER submittal and the updated LER submittal. The inspection conclusions associated with this LER are documented in this report under the Inspection Results section. This LER is closed.

INSPECTION RESULTS

Failure to Implement a Preventive Maintenance Strategy for 2A Core Spray Flexible Rubber Cooling Line Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000265/2023004-01 Open/Closed

[H.14] -

Conservative Bias 71111.12 A self-revealed Green finding and associated non-cited violation (NCV) of Technical Specification 5.4.1.a, Procedures, was identified for the licensees failure to establish a preventive maintenance schedule associated with the replacement of the flexible rubber cooling line for the 2A core spray pump upper bearing oil cooler. As a result, on October 20, 2023, the cooling line ruptured during surveillance testing due to age-related degradation of the line.

Description:

On October 20, 2023, while performing quarterly surveillance testing on the 2A core spray pump, the flexible rubber cooling line for the pumps upper bearing oil cooler ruptured. The resulting spray wetted plant equipment in the surrounding area and began accumulating water in the room. The licensee entered procedure QGA 300, Secondary Containment Control, for area water level greater than 1 inch. To stop the leak, operators secured the pump and shut the pump suction valve. Dewatering activities commenced shortly after, and the licensee exited QGA 300 once the water was drained from the room. The licensee documented the event in the corrective action program and performed a causal evaluation under AR 4711200.

The core spray system provides low-pressure core cooling to the reactor pressure vessel during a design-basis accident and is a low-pressure subsystem of the emergency core cooling system. It is a safety-related system and its cooling function during a design-basis accident is considered of high safety significance through the sites maintenance rule program. The flexible cooling line that ruptured, 2-1422A-1-DX, provides cooling to the upper bearing oil cooler by routing water from the discharge of the pump through the oil cooler, and then back to the suction of the pump. The predominant material of the faulted hose was rubber. Subsequent walkdowns performed by the licensee revealed that the degraded cooling line was the only rubber cooling hose installed on any of the other core spray pumps for either unit. All remaining cooling lines installed were made of stainless-steel. The licensee determined that the cooling line had ruptured due to age-related degradation of the rubber in the hose. The hose was subsequently changed out to a stainless-steel flexible hose. The licensee was not able to determine when the flexible rubber cooling line was put into service but estimated the hose had been installed in the mid-1980s. During an extent-of-condition walk down, the licensee identified another flexible rubber cooling line used in a similar application on the 2B residual heat removal (RHR) pump. As this additional line was also identified to have been installed in the mid-1980s, the licensee created a work order to change it out during the next RHR work window. An additional discussion concerning the 2B RHR flexible rubber cooling line can be found in the Inspection Results section of this inspection report.

The inspectors reviewed the licensees causal evaluation and the circumstances surrounding the event. The inspectors noted that licensee procedure ER-AA-200, Preventive Maintenance Program, references performance-centered maintenance (PCM) templates for developing a maintenance strategy for plant equipment. The PCM template for flexible hoses, such as the flexible rubber cooling line that ruptured, includes a task for the time-directed replacement of flexible hoses installed in the plant. In particular, the template states the following regarding flexible hoses used in direct contact with air, oil, or water:

Since flexible hoses have a finite lifetime, there is risk associated with installing flex hoses on critical and non-critical components and leaving the flex hose as a RTF [run to failure]

component with no PMs. Eventual failure of flexible hose due to age-related degradation can have potential negative consequences i.e., valves failing close/open, fluid/water/oil leaks etc.

Therefore, flexible hoses should be replaced as required based upon its application criticality and environmental conditions.

The inspectors reviewed the preventive maintenance strategy for the 2A core spray pump and determined that the licensee had screened the pump in such a way through their preventive maintenance program that the PCM template for flexible hoses was not applicable. Therefore, a replacement frequency for the flexible rubber cooling line was not established. Through discussions with the licensees staff, the inspectors learned that when the rubber hose was originally procured in the mid-1980s it was not purchased as safety-related. Once the hose was received, it was evaluated by the sites commercial grade dedication process at the time, and then reclassified as safety-related after meeting programmatic requirements. However, none of the original paperwork for the dedication of the rubber hose was able to be located by the licensee. Additionally, the licensee was not able to find the original work order that installed the hose. As such, the licensee does not know what the service life of the rubber hose was or how long the rubber hose had been in service prior to the event.

Regulatory Guide 1.33, Quality Assurance Program Requirements, revision 2, dated February 1978, contains requirements for performing maintenance at nuclear power plants and is committed to by the site through the licensees Technical Specifications. Section 9.b of Regulatory Guide 1.33 states that preventive maintenance schedules should be developed to specify the inspection or replacement of parts that have a specific lifetime. As the flexible rubber hose that was installed as a cooling line for the 2A core spray pump was expected to degrade over the course its service life, the inspectors determined that the rubber hose was required to have a replacement frequency as delineated by Regulatory Guide 1.33.

Therefore, the inspectors determined that the lack of any preventive maintenance schedule associated with the 2A core spray flexible cooling line, 2-1422A-1-DX, was a performance deficiency.

Corrective Actions: The licensee replaced the degraded flexible rubber cooling line with a stainless-steel cooling line and restored the 2A core spray system to service.

Corrective Action References: AR 4711200, 2A Core Spray Cooling Line Break During Run

Performance Assessment:

Performance Deficiency: The inspectors determined that the failure to have a preventive maintenance schedule for the replacement of the flexible rubber cooling line on the 2A core spray pump was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the ruptured cooling line prevented cooling to the pumps upper bearing oil cooler, adversely affecting the capability and reliability of the pump.

Additionally, operator action was required to secure the pump and shut the pump suction valve in order to isolate the leak, rendering the pump unavailable.

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, Section A, 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 licensee developed a maintenance strategy that allowed the 2A core spray pump to be classified in such a way that PCM template tasks associated with the replacement of the flexible rubber cooling line of the pump were thought to be not applicable although a maintenance strategy was required through the sites licensing basis.

Enforcement:

Violation: Technical Specification 5.4.1.a, Procedures, states that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, dated February 1978.

Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), Appendix A, Section 9, Procedures for Performing Maintenance, states, in part, that preventive maintenance schedules should be developed to specify replacement of parts that have a specific lifetime.

Licensee procedure ER-AA-200, Preventive Maintenance Program, outlines the method through which the site develops the preventive maintenance strategy for plant structures, systems, and components in order to maintain them at an appropriate state of reliability based on their relative importance to safety, production, and cost. ER-AA-200 is a procedure covered by Regulatory Guide 1.33.

Contrary to the above, on October 20, 2023, the licensee failed to establish, implement, and maintain written procedures covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Specifically, through the implementation of procedure ER-AA-200, the licensee failed to establish a preventive maintenance schedule for the replacement of the 2A core spray pump flexible rubber cooling line. As a result, during surveillance testing of the 2A core spray pump, the line ruptured due to age-related degradation.

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

Loss of Design Control on 2B Residual Heat Removal Pump Associated with a Nonconforming Flexible Rubber Cooling Line Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000265/2023004-02 Open/Closed

[H.6] - Design Margins 71111.12 The inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion III, Design Control, when the licensee failed to maintain the design margins of the Unit 2 residual heat removal system. Specifically, the licensee was not able to provide reasonable assurance that a 2B residual heat removal pump flexible rubber cooling line installed in the mid-1980s continued to meet its design qualification given its time in service and lack of qualification documentation. The line was discovered in service following an extent-of condition walkdown stemming from the failure of a similar flexible rubber cooling line on the 2A core spray pump during surveillance testing on October 20, 2023.

Description:

On October 20, 2023, while performing quarterly surveillance testing on the 2A core spray pump, the flexible rubber cooling line for the pumps upper bearing oil cooler ruptured. The licensee documented the event in the corrective action program and performed a causal evaluation under AR 4711200. The licensee performed an extent-of-condition walk down and identified another rubber cooling line used in a similar application on the 2B residual heat removal (RHR) pump.

The RHR system is a safety-related system that functions during a design-basis accident to provide low-pressure coolant injection to the reactor pressure vessel, drywell and torus spray, and torus cooling. The RHR system is a subsystem of the emergency core cooling system.

Additionally, the aforementioned functions of RHR are considered of high safety significance through the sites maintenance rule program. The flexible rubber cooling line on the 2B RHR pump provides cooling to the upper bearing oil cooler by routing water from the discharge of the pump through the oil cooler and then back to the suction of the pump.

Through discussions with the licensees staff, the inspectors learned that when the rubber hose was originally procured in the mid-1980s it was not purchased as safety-related. Once the hose was received, it was evaluated by the sites commercial grade dedication process at the time and then reclassified as safety-related after meeting programmatic requirements.

However, none of the original paperwork for the dedication of the rubber hose was able to be located by the licensee. Additionally, the licensee was not able to find the original work order that installed the hose. As such, the licensee does not know what the service life of the rubber hose is, how long the rubber hose has been installed, or what the design attributes essential to performing its safety-related function were evaluated against to show suitability of its application.

The inspectors determined that because the line has been installed since the mid-1980s and the rubber material of the flexible cooling line is known to degrade over its service life, the licensee no longer has reasonable assurance that this safety-related component meets the design qualification it was originally qualified to at the time it was procured. The inspectors determined that the failure to maintain reasonable assurance of the design qualifications of the flexible cooling line was a performance deficiency. Given the recent site operating experience with a similar hose rupturing while in service on the 2A core spray pump, the inspectors concluded that the installed flexible rubber cooling line on the 2B RHR pump was nonconforming and the operability of the 2B RHR pump is in question. The licensee performed an operability evaluation of the installed flexible rubber cooling line and determined the line was operable. Additionally, the licensee placed compensatory measures in place to inspect the line before and after any scheduled use of the 2B RHR pump until the line can be replaced during the next available system outage window scheduled for February 2024.

Corrective Actions: The licensee documented the condition in the corrective action program and performed an operability evaluation under Engineering Change (EC) 640529 which included a visual inspection of the flexible rubber cooling line.

Corrective Action References:

AR 4724974, NRC Concern w/2B RHR Motor Cooling Line Not Having Paperwork AR 4716807, Extent of Condition Walkdown Actions RHR, CS, HPCI

Performance Assessment:

Performance Deficiency: The inspectors determined that the failure to provide objective quality evidence that the flexible rubber cooling line continues to meet the qualification requirements it was originally evaluated to in order to perform its safety-related function is a performance deficiency.

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, if the flexible cooling line ruptured during operation of the 2B residual heat removal pump during a design-basis accident, the reliability and capability of the pump would be severely degraded.

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, Section A, and answered Yes to question 1 based on the results of EC 640529. Therefore, the finding screens to very low safety significance (Green).

Cross-Cutting Aspect: H.6 - Design Margins: The organization operates and maintains equipment within design margins. Margins are carefully guarded and changed only through a systematic and rigorous process. Special attention is placed on maintaining fission product barriers, defense-in-depth, and safety-related equipment. Specifically, the licensee failed to account for the age-related degradation aspects of using a flexible rubber hose in this safety-related function and cannot account for the remaining margin, if any, until the degraded condition of the hose exceeds the initial design qualifications.

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that measures be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the structures, systems and components.

Contrary to the above, on December 21, 2023, the licensee failed to review for suitability of application of materials essential to the safety-related functions of the flexible rubber cooling line for the 2B residual heat removal pump upper bearing oil cooler. Specifically, the rubber material of the flexible cooling line is known to degrade over the course of its service life. The licensee does not know the date the line was put into service, what the original service life of the line was evaluated to be, and failed to provide objective quality evidence that the rubber cooling line continues to meet the qualification requirements it was originally evaluated against in order to perform its safety-related function.

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

Failure to Adequately Control Radiological Work Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000254,05000265/2023004-03 Open/Closed

[H.4] -

Teamwork 71124.03 A self-revealed finding of very low safety significance (i.e., Green) and an associated non-cited violation (NCV) of 10 CFR 20.1701 use of process or other engineering controls was reviewed by inspectors when the licensee failed to use, to the extent practical, process or other engineering controls (e.g., containment, decontamination, or ventilation) to control the concentration of radioactive material in air. Specifically, the licensee failed to establish appropriate controls before authorizing high-energy work using a grinder on a pipe with 15 mRad/hour of fixed contamination which resulted in a worker that received or likely received greater than 10 mrem committed effective dose equivalent (CEDE).

Description:

On April 1, 2023, a pipefitter was performing pipe end preparation on an extraction steam piping in the Unit 1 steam tunnel which involved high-energy work using a grinder. The work was performed on RWP QC-01023-00826, Task 4, TB Valve Activities HPHB/STEAM Tunnel Emergent, revision 1. The RWP indicated that alpha level 1 and 2 conditions were expected. The RP coverage requirements included Contact RP Prior to performing tasks that could change the rad conditions to determine RP coverage and contamination control requirements. The ALARA plan for RWP QC-01023-00826 required, Decontaminate the valve internals to <10k dpm.100cm2 or as directed by RP Supervision, and HEPA Unit will be used during breach and inside valve.

The licensee reported a miscommunication between the pipefitter, who possessed limited prior experience working at a nuclear power plant, and a radiation protection technician (RPT). The RPT assumed that grinding would only occur on the outside of the pipe where contamination was very low (<1,000 dpm/100cm2) and did not know the pipe end preparation included grinding on the inside of the pipe. Consequently, a (High Efficiency Particulate)

HEPA unit, a prescribed engineering control, was not utilized for this work activity.

The licensee determined the pipefitter had contamination in the nose/mouth area. The pipefitter showered to minimize any external contamination and the licensee used a whole-body counter to assess the level of internal contamination that could be present before allowing the worker to leave site at the end of the work shift. The whole-body count measurements continued twice per shift for next 5 days (until April 6, 2023), when all work was completed, and the pipefitter was released for other employment. No other work was performed by the pipefitter inside the radiologically controlled area after April 1, 2023. The licensee requested the pipefitter to return to the site for a final whole-body count assessment which occurred on April 16, 2023. Based upon the results from the series of measurements by a whole-body counter, the licensee estimated the pipefitter received 12 mrem CEDE from the contamination event. This could not be validated with corresponding air sample data because an air sample was not collected for this evolution. However, this assessment was confirmed, by a third-party health physics firm contracted by the licensee, the worker likely received greater than 10 mrem CEDE.

This health physics contractor also provided an alternate method of estimating the dose using models and assumptions developed after the limits were established 10 CFR 20 Standards for Protection Against Radiation. Specifically, 10 CFR 20 was developed using ICRP 26/30 for lung clearance models that assumed aerosol properties of the airborne radioactive material in particle form were 1 micrometer

(um) in size. The second assessment provided by the health physics contractor to the licensee used a model from ICRP 60/68 and assumed an aerosol of 5 um particles. The results from this calculation estimated 5 mrem of dose.

The inspectors reviewed the alternate method of estimating the dose proposed in the contracted assessment. The impact of changing the particle size from 1 um to 5 um reduced the estimate by a factor of 1.7, a majority of the difference between the two methodologies.

Regulatory Guides 8.9, Acceptable Concepts, Models, Equations, and Assumptions for a Bioassay Program, and 8.25 Air Sampling in the Workplace, provide guidance and equations that can be used to change the particle size and other physical parameters when the particle size is known, and methods for determining these parameters. As previously stated, the size of the particles was not measured or otherwise evaluated.

The licensee became aware of the event when the pipefitter alarmed the personnel contamination monitor after completing the intended work activity. The licensee stopped the work to assess the radiological conditions and determined contamination inside the piping was up to 150,000 dpm/100 cm2 loose and 15 mRad/hour fixed contamination. The process and engineering controls that are required for adequate radiological controls in this scenario meet the description of a radiation protection program barrier and, based upon the description above, this barrier was ineffective. The licensee did not have controls over the scenario to ensure that 10 mrem would not have been exceeded (the minor / more-than-minor threshold in example 6.h in IMC 0612 Appendix E). Calculations performed by the licensee, the licensees contractor and the NRC inspectors using generalized metabolic and biochemical properties assumed in 10 CFR Part 20 demonstrate this conclusion. Even if the parameters assumed in the alternate calculation were valid, it is reasonable to assume the workers could have stayed for additional time, or taken a different work posture, or conducted grinding on the pipe for a little bit longer. Consequently, it is reasonable to conclude the dose to the workers could exceed 10 mrem, with a minor alteration of circumstances, due to inadequate radiological controls.

Corrective Actions: RWP QC-01-23-00826, Task 4 was revised to require use HEPA ventilation and versaflo hoods (a specific type of air-purifying respirator) when performing high-energy work on breached steam piping.

Corrective Action References: AR 4666947, RP Discontinue Work on FAC Piping Replacement and AR 04682942 Internal Dose Assessment

Performance Assessment:

Performance Deficiency: The licensee failed to use, to the extent practical, process or other engineering controls (e.g., containment, decontamination, or ventilation) to control the concentration of radioactive material in air. Specifically, the licensee failed to establish appropriate controls before authorizing high-energy work using a grinder on a pipe with 15 mRad/hour of fixed contamination which resulted in a worker that received or likely received greater than 10 mrem CEDE.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Program & Process attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. The performance deficiency is associated with the program and process attribute of the occupational radiation safety cornerstone and adversely affected the cornerstone objective to ensure adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Specifically, the performance deficiency resulted in inadequately controlled radiological conditions such that the worker received or was likely to receive greater than 10 mrem CEDE.

This is Example 6.h from Inspection Manual Chapter 0612, Appendix E, Examples of Minor Issues.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix C, Occupational Radiation Safety SDP. The inspectors determined that the finding was of very low safety significance (i.e., Green) because:

(1) it did not involve as-low-as reasonably achievable planning or work controls,

(2) there was no overexposure,

(3) there was no substantial potential for an overexposure, and

(4) the ability to assess dose was not compromised.

Cross-Cutting Aspect: H.4 - Teamwork: Individuals and work groups communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety is maintained. Specifically, the communication between the pipefitter performing the work and the radiation protection technician that authorized the work failed to identify high-energy work using a grinder would be performed on a highly contaminated surface.

Enforcement:

Violation: Title 10 of the Code of Federal Regulations, Part 20.1701 states the licensee shall use, to the extent practical, process or other engineering controls (e.g., containment, decontamination, or ventilation) to control the concentration of radioactive material in air.

Contrary to the above, April 1, 2023, the licensee authorized high-energy work using a grinder on a radioactively contaminated system without establishing engineering controls to control the concentration of radioactive material in the air. This resulted in a worker that received or was likely to receive greater than 10 mrem CEDE.

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

Unit 2 Reactor Scram Due to Improperly Tuned Emergency Feedwater Heater Level Control Valve Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000265/2023004-04 Open/Closed

[H.14] -

Conservative Bias 71152A A self-revealed Green finding and an associated non-cited violation (NCV) of Technical Specification 5.4.1. Procedures, was identified for the licensees failure to have general operating procedures, appropriate for the circumstances, to ensure that systems required for startup and power operations were configured as required. Specifically, the feed water heater emergency level control valve for the 2A moisture separator drain tank was improperly tuned for at-power operations following a reactor start up. As a result, on August 11, 2023, following an electrical transient, the emergency level control valve failed to respond as expected, and the Unit 2 main turbine generator tripped on a high-level condition in the 2A moisture separator drain tank. The turbine trip subsequently initiated an automatic scram of the Unit 2 reactor.

Description:

The feedwater heater (FWH) system receives steam from various extraction points on the main turbine along with moisture drains. This steam is used to heat the condensate and feedwater which flows through the tube side of the heaters prior to being returned to the reactor. The moisture separators and moisture separator drain tanks (MSDT) are part of the FWH system. Under normal conditions, solenoid-operated level control valves control water level in the 2A and 2B MSDT. The solenoids are powered by the Unit 2 essential service system (ESS) bus. When water level in the MSDT gets too high, emergency FWH level control valves act as an alternate means of controlling water levels in the 2A and 2B MSDT.

These emergency level control valves are air-operated valves.

Typically, the level controllers for the normal and emergency level control valves are tuned twice during power ascension following a reactor startup. At lower powers, the level controllers are tuned to respond more slowly to level deviations from their given setpoints.

This is desirable to keep the controllers from overshooting the setpoint once the valve changes position, which can lead to excessive valve movement as the controller over and under corrects valve position to achieve the desired water level. At higher powers, the level controllers are tuned to respond more rapidly to deviations from their given setpoints because water level changes happen more rapidly. A slow responding level controller during normal power operations can result in the valve being unable to respond fast enough to maintain water level.

On August 11, 2023, an electrical transient occurred on the Unit 2 ESS bus causing the normal level control valves for the FWH system to go shut. Emergency level control valve 2-3510 did not respond as expected and water level in the 2A MSDT was unable to be controlled during the transient. This condition led to a main turbine generator to trip on high-level in the 2A MSDT. Subsequently, the Unit 2 reactor tripped as designed on a main turbine trip.

The inspectors reviewed the licensees causal evaluation under issue report AR 4695858, and the circumstances surrounding the event. The licensee determined that the voltage perturbation on the ESS bus was from a failed subcomponent internal to the ESS inverter.

The voltage perturbation resulted in a temporary loss of power to the solenoids of all 15 Unit 2 FWH normal level control valves. Consequently, the normal control valves failed shut as expected. Level controller LIC 2-3541-16A sent an open signal to emergency FWH level control valve 2-3510 to control water level in the 2A MSDT, however, the stroke time of the valve was slower than expected because the level controller was incorrectly left tuned for low-power operations following a previous Unit 2 startup. As a result, neither the normal nor emergency level control valves were available to control water levels in the 2A MSDT. This led to water level rising in the 2A MSDT until the high-level set point was reached initiating a trip of the main turbine generator.

The inspectors determined that the licensees general operating procedures for reactor startup and power operations failed to provide direction to the operators to ensure that systems required for reactor startup and normal power operations were configured as required. Specifically, licensee procedure QCGP 1-2, Unit 2 Normal Startup, contains a note, but not a procedural step, that states, Direct IMs to backfill instrument lines and tune MSDT normal and emergency controllers as needed for satisfactory operation. Level should be maintained within the normal and emergency level control bands. Additionally, step F.9.j.(2) states, If controller problems were encountered, then direct IMs to backfill and tune normal emergency level controller as needed. Licensee procedure, QCGP 3-1, Reactor Power Operations, step F.3.e(4), sub step f.(7).(a) states, If level swings are >20% in the MSDTs AND/OR >5 in the D heaters, THEN notify IMs to make controller tuning adjustments as needed.

Both QCGP 1-2 and 3-1 provide direction to operators to have instrument maintenance technicians perform actions to tune the FWH level controllers as needed to achieve satisfactory operation. Neither procedure contains instructions, appropriate for the circumstances, to ensure that the activity is done correctly. Once the activity is completed, the as-left configuration of the level controllers cannot be verified by the operators in the control room. Ultimately, if water level in the MSDT stays within the desired control band, and no problems with the controller occur, the operators have no way of knowing if the level controller has been incorrectly tuned until the problem reveals itself during a transient in which the controller does not respond as desired. As such, the inspectors concluded that both QCGP 1-2 and QCGP 3-1 were written non-conservatively such that operators could follow procedural direction (direct instrument maintenance technicians to tune the level controllers),obtain the procedurally desired response (water level maintained in the control band and no problem with the controller), and still fail to ensure systems are configured as required for normal power operations (a level controller is inadvertently left tuned for low-power operations).

In addition, the licensee determined in their causal evaluation that the tuning of level controller LIC 2-3541-16A had been occurring without work instructions for several years prior to the event. Technicians and first line supervisors assumed that if they were directed by operators to perform the task, work instructions were not required despite several site procedures that indicated otherwise. Additionally, one particular technician had performed the tuning activity so many times over multiple years that the individual assumed that work instructions were not required due to the individuals proficiency at performing the activity. As such, when QCGP1-2 or QCGP 3-1 directed operators to have technicians to tune the FWH level controllers, no work instructions or procedural steps were being followed to tune level controller LIC 2-3541-16A or track the completion of the activity.

The inspectors determined that level controller LIC 2-3541-16A being inadvertently tuned to low-power operations, a degraded condition, ultimately led to a Unit 2 reactor trip.

The proximate cause of the degraded condition was the lack of procedural guidance on how to accomplish the tuning activities contained in QCGP 1-2 and QCGP 3-1 to ensure that level controller LIC 2-3541-16A was configured as required, and therefore, a performance deficiency.

Corrective Actions: The licensee performed a root cause evaluation under issue report AR 4695858.

Corrective Action References: AR 4695858, U2 Turbine Trip and SCRAM due to High Moisture Separator Level

Performance Assessment:

Performance Deficiency: The inspectors determined that the failure to have general operating procedures, appropriate for the circumstances, to ensure that systems required for startup and power operations were configured as required was a performance deficiency.

Specifically, the FWH emergency level control valve for the 2A moisture separator drain tank was incorrectly tuned for low-power operation and not discovered until the valve failed to respond as expected during a water level transient in the FWH system.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Configuration Control attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the high-level condition in the 2A MSDT was due to improper tuning of an emergency FWH level control valve. As a result, the emergency level control valve failed to respond as expected resulting in a Unit 2 reactor trip.

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 1, Section B, and answered No to the screening question. 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, technicians assumed that work instructions were not required for tuning of the FWH level controllers. As a result, no formal work instruction was used to tune level controller 2-3541-16A or track the completion of the activity. This assumption was not in alignment with site procedures but was repeatedly rationalized for the sake of completing the activity over the past several years.

Enforcement:

Violation: Technical Specification 5.4.1, Procedures, states that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Quality Assurance Program Requirements, Appendix A, Section 2 requires instructions for general plant operating procedures. Licensee procedures QCGP 1-2, Normal Unit 2 Startup and GCGP 3-1, Reactor Power Operations, have been established by the licensee to provide instructions to meet the requirements of Regulatory Guide 1.33.

Contrary to the above, from approximately April 23, 2022, to August 11, 2023, the licensee failed to establish and maintain written procedures covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.

Specifically, both procedures QCGP 1-2 and QCGP 3-1 did not contain instructions to ensure that level controller 2-3541-16A was tuned as required for the applicable operating conditions.

As a result, on August 11, 2023, following an electrical transient, emergency level control valve 2-3510 failed to respond as expected, resulting in the automatic trip of the Unit 2 reactor.

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

Observation: Licensed Operator Requalification Training Observations 71152A In accordance with Inspection Procedure (IP) 71152, Problem Identification and Resolution, Section 03.03, the inspectors selected an annual problem identification and resolution sample concerning issues that challenge operator performance. Specifically, the inspectors provided several observations to the licensee following an evaluation of the adequacy of the licensees annual requalification operating test under section 71111.11B of this report. Those observations included:

• During post-scenario follow-up questioning, a lack of sequestration occurred on multiple scenarios when operators were not separated from each other that resulted in operators hearing questions being asked to other operators.

• During one evaluated scenario, the booth instructor provided information that was not requested by the crew which resulted in cueing the crew to the applicable Technical Specification.

• During an evaluated scenario as well as a Job Performance Measure, the guide was missing content for the booth instructor. This resulted in the licensees reliance on the booth instructors knowledge of the events to provide the appropriate indications vice being contained within the guide.

• One licensee re-activation form was missing a signature denoting completion of a plant tour. Later the licensee provided evidence that the tour was completed via card reader data.

• During post-scenario follow-up questioning, the evaluator and operator interaction was excessively collegial and lacked formality.

Additionally, the inspectors noted a lack of training resources during the inspection, resulting in the training department relying on other departments to conduct core training business.

The lack of overall training resources has the potential to adversely impact the successful development and execution of the NRC initial licensing exam scheduled for the second quarter of 2024.

Overall, the inspectors determined that the observed decline in operator and evaluator performance standards, coupled with a lack of training resources, could increase the likelihood of operations department performance issues, and an increase in plant risk due to human performance errors, if not corrected. The licensee documented this observation in the corrective action program under AR 4710673.

No findings or violations were identified during this inspection sample.

Failure to Maintain Unit 1 Station Blackout Diesel in a Standby Lineup During Chemistry Sampling Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000254/2023004-05 Open/Closed

[H.14] -

Conservative Bias 71152S The inspectors identified a Green finding and associated non-cited violation (NCV) of Technical Specification 5.4.1.a, Procedures, for the licensees failure to implement the station annunciator response procedure for low lubricating oil temperature on the Unit 1 station blackout diesel. As a result, lubricating oil temperature reached 75 degrees Fahrenheit, below that which the station blackout diesel could be considered functional and available for operation.

Description:

On November 7, 2023, at approximately 5:35 p.m. C.S.T., the licensee placed the Unit 1 station blackout (SBO) diesel generator jacket water cooling system on recirculation to obtain a chemistry sample. Subsequently, on operator rounds the next morning at 1:03 a.m., an equipment operator discovered that the Unit 1 SBO diesel lubricating oil temperature was at 75 degrees Fahrenheit. The minimum required oil temperature to consider the SBO diesel available in a standby condition, as established by the vendor owners group, is 85 degrees, and is documented in licensee evaluation ECR 431051. Upon identifying the degraded condition, the licensee logged the Unit 1 SBO diesel unavailable in the control room logs and updated the unit online risk per station procedures. The licensee failed to enter the condition into the station corrective action program.

In response to the SBO rule outlined in 10 CFR 50.63, Loss of All Alternating Current Power, the licensee installed two non-safety-related SBO diesel generators capable of providing power to safety-related buses and safe shutdown loads in the event of a total or partial loss of offsite power concurrent with the unavailability of the stations onsite emergency diesel generators. Each SBO diesel has a jacket water cooling system that functions to maintain lubricating oil temperature between 125 to 155 degrees Fahrenheit while the engine is shutdown via an immersion heater. When the jacket water system is put on recirculation to obtain a chemistry sample, water is drawn from a tank external to the SBO building and recirculated through the jacket water system, to include the lubricating oil cooler, to obtain a representative sample.

At the time of the event, external outside temperature was approximately 45 degrees. The colder water being recirculated through the lubricating oil cooler was more than the immersion heater could compensate for over the course of the approximately 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> the jacket water system was placed on recirculation. Station annunciator response procedure QCAN 2201(2)-105 D-1, SBO DG 1(2) Engine B(A) Lube Oil Temperature Lo Alarm, alarmed locally on Panel 2201-106 in the SBO building and on the distributed control system (DCS) console in the control room at a lubricating oil temperature of 95 degrees. The inspectors determined that operators in the control room failed to respond to the alarming condition until the low lubricating oil temperature was reported by the equipment operator performing midnight rounds in the SBO building, after the Unit 1 SBO diesel was already rendered unavailable. Therefore, the inspectors determined that the licensees failure to implement QCAN 2201(2)-105 D-1 was a performance deficiency. Additionally, the inspectors determined that the failure to enter the condition adverse to quality into the corrective action program represented a minor performance deficiency, which is evaluated under the Inspection Results section of this report.

Per Inspection Manual Chapter 0612, licensee-identified findings and violations are

(1) identified as a result of deliberate observation by licensee personnel; and

(2) entered into the licensee corrective action program. Although the degraded condition was identified by an equipment operator as part of a deliberate observation (i.e., during the performance of rounds) it was not entered into the corrective action program. Therefore, this issue is not considered licensee-identified.

NRC-identified findings or violations are defined, in part, as issues initially identified by the licensee to which the inspector has identified inadequacies in the licensees characterization or evaluation of the issue of concern. The degraded condition was discovered by an equipment operator after lubricating oil temperature had dropped below 85 degrees, indicating a missed opportunity for the licensee to intervene prior to lubricating oil temperatures dropping below that which support system availability, and was not entered into the corrective action program. Subsequently, the inspectors identified inadequacies in the licensees characterization and evaluation of the issue; therefore, the inspectors consider this issue NRC-identified and not self-revealed.

Corrective Actions: After discussions with the inspectors, the licensee captured this issue in the corrective action program under AR 4716213.

Corrective Action References: AR 4716213, U1 SBO Unavailable Due to Low Lube Oil Temp

Performance Assessment:

Performance Deficiency: The inspectors determined that the failure to implement annunciator response procedure QCAN 2201(2)-105 D-1 prior to the Unit 1 SBO diesel lubricating oil temperature dropping below a level that supported availability of the SBO diesel was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the degraded condition resulted in the Unit 1 SBO diesel being inadvertently rendered unavailable for standby operation.

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, Section A, and answered No to all of the 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, although procedurally allowed to place the jacket water system on recirculation to obtain a chemistry sample, operators failed to account for external factors such as outside air temperature that could adversely affect other SBO diesel system parameters if the jacket water system was to be recirculated for an extended period of time.

Enforcement:

Violation: Technical Specification 5.4.1.a, Procedures, states that written procedures shall be established, implemented, and maintained, covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, dated February 1978.

Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), Appendix A, includes section 5, Procedures for Abnormal, Offnormal, or Alarm Conditions.

Station annunciator response procedure QCAN 2201(2)-105 D-1, SBO DG 1(2) Engine B(A)

Lube Oil Temperature Lo Alarm, is applicable to Regulatory Guide 1.33, Revision 2, Appendix A.

Contrary to the above, on November, 7, 2023, the licensee failed to implement QCAN 2201(2)-105 D-1 in response to the Unit 1 SBO diesel lubricating oil temperature falling to 95 degrees. As a result, lubricating oil temperature continued to fall to 75 degrees, below which the Unit 1 SBO diesel could be considered available for operation.

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

Minor Performance Deficiency 71152S Failure to Initiate an Issue Report for a Condition Adverse to Quality Associated with the Station Blackout Diesel Minor Performance Deficiency: Licensee document, NO-AA-10, Quality Assurance Topical Report, states that the licensee is committed to appendices A and B of RG 1.155, Station Blackout. RG 1.155, appendix A, Section 8, Corrective Action, states that measures should be established to ensure that failures, malfunctions, deficiencies, deviations, defective components, and nonconformances are promptly identified, reported, and corrected.

NO-AA-10, Section A.2, Requirements, states deficiencies are address in accordance with the corrective action program.

Contrary to the above, on November 8, 2023, while recirculating the jacket water system on the Unit 1 station blackout diesel, the licensee inadvertently lowered lube oil temperature below that which was required for the diesel to be considered available for operation. Upon discovery, the licensee documented the condition in the control room logs and updated the Unit 1 risk profile but failed to document the condition in the corrective action program as required. The inspectors identified that the issue was not documented in the corrective action program during performance of plant status activities the following morning.

Screening: The inspectors determined the performance deficiency was minor. Specifically, the failure to initiate an issue report was not viewed as a precursor to a significant event, did not have the potential to lead to a more significant safety issue, and did not adversely affect a cornerstone objective.

Minor Violation 71152S Failure to Initiate an Issue Report as Directed During Motor-Operated Valve Testing Minor Violation: Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

Site procedure MA-AA-732-300, Diagnostic Testing of Motor Operated Valves, Revision 14, is a licensee procedure used for the acquisition of motor-operated valve diagnostic test data, an activity affecting quality. Step 4.4 of the procedure states, Any UNSAT criteria documented in this section of the procedure shall be documented in an issue report.

Contrary to this, on March 17, 2021, while performing diagnostic testing under Work Order (WO) 4892430 associated with safety-related valve 1-1001-23A, the as-found closed valve condition load value was higher than acceptance criteria and the as-left run load closed value was higher than acceptance criteria. The licensee failed to initiate an issue report to document non-conforming conditions. The inspectors determined the performance deficiency was minor because although an issue report was not generated as directed, the licensee completed the additional actions that were procedurally required. Specifically, the licensee performed an evaluation demonstrating the higher running loads were acceptable and there was still positive margin available for the valve to perform its design-basis safety function.

Screening: The inspectors determined the performance deficiency was minor. Specifically, the failure to initiate an issue report was not viewed as a precursor to a significant event, did not have the potential to lead to a more significant safety issue, and did not adversely affect a cornerstone objective.

Enforcement:

This failure to comply with 10 CFR Part 50, Appendix B, Criterion V, constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Minor Violation 71152S Failure to Initiate an Issue Report as Directed per Lubricating Oil Analysis Procedure Minor Violation: Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances, and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

Site procedure MA-AA-716-230-1001, Oil Analysis Interpretation Guideline, is credited by the licensee for providing the acceptance criteria for reviewing lubricating oil sample analysis results, an activity affecting quality. MA-AA-716-230-1001, Section 3 outlines the data interpretation and reporting guidelines following a lubricating oil sample analysis and states conditions in the alert range indicate an adverse trend or deviation from normal operating conditions. Additional monitoring or analyses may be required, and corrective action should be scheduled. Additionally, a parameter in the alert range should have an issue report generated for trending purposes.

Contrary to the above, on September 7, 2023, the lubricating oil sample for the Unit 2 emergency diesel generator crankcase, a safety-related component, had parameters in the alert range for lead, tin, and silicon, but no issue report was generated. Based on a historical review of lubricating oil samples, no parameter had entered the fault range indicating a serious deviation from normal operating conditions exists, which may cause an equipment failure.

Screening: The inspectors determined the performance deficiency was minor. Specifically, the failure to initiate an issue report was not viewed as a precursor to a significant event, did not have the potential to lead to a more significant safety issue, and did not adversely affect a cornerstone objective.

Enforcement:

This failure to comply with 10 CFR Part 50, Appendix B, Criterion V constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Observation: Failure to Document Issues in the Corrective Action Program 71152S The final NRC Safety Culture Policy Statement (SCPS) that was published on June 14, 2011, provides the NRCs expectation that individuals and organizations performing regulated activities establish and maintain a healthy safety culture that recognizes the safety and security significance of their activities and the nature and complexity of their organizations and functions. Because safety and security are the primary pillars of the NRCs regulatory mission, consideration of both safety and security issues, commensurate with their significance, is an underlying principle of the SCPS. NUREG-2165, Safety Culture Common Language, lists the traits, attributes, and examples of a healthy nuclear safety culture.

In accordance with Inspection Procedure (IP) 71152, Problem Identification and Resolution, Section 03.02, the inspectors performed a semiannual trend analysis of the licensees corrective action program to identify any potential trends that might indicate the existence of a more significant safety issue. During their review, inspectors determined that there was a negative trend in the area of PI.1, Identification, of NUREG-2165, where the organization implements a corrective action program with a low threshold for identifying issues. Specific examples reviewed by the inspectors are provided below:

AR 4714913, NRC CETI ID: Lube Oil Analysis AMP Not Followed During an NRC Comprehensive Engineering Team Inspection (CETI), inspectors identified lubricating oil sample results in the alert range for the Unit 2 emergency diesel generator crankcase that were not documented in the corrective action program as directed by the applicable site procedures. This issue resulted in a minor non-cited violation documented in the Inspection Results section of this report.

AR 4714916, NRC CETI: IR Not Initiated for WO 04892430 As-left Results During an NRC CETI, inspectors identified that as-found running load in the closed direction on a safety-related residual heat removal motor-operated valve were higher than the acceptance criteria in the work package and was not documented in the corrective action program as directed by the applicable site procedures. This issue resulted in a minor non-cited violation documented in the Inspection Results section of this report.

AR 4716213, U1 SBO Unavailable Due to Low Lube Oil Temp While recirculating the jacket water system on the Unit 1 station blackout diesel, the licensee inadvertently lowered lube oil temperature below that which was required for the diesel to be considered available for operation. The inspectors identified that the issue was a condition adverse to quality, and not documented in the corrective action program. This issue resulted in a non-cited violation and a minor performance deficiency documented in the Inspection Results section of this report.

Overall, the inspectors noted that the site continues to see negative performance in entering issues into the corrective action program either upon identifying a condition adverse to quality, or as directed by other site programmatic requirements. This behavior will be a focus area for the resident office heading into the next inspection year.

EXIT MEETINGS AND DEBRIEFS

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

• On January 9, 2024, the inspectors presented the integrated inspection results to Brian Wake, Site Vice President, and other members of the licensee staff.

• On October 10, 2023, the inspectors presented the licensed operator biennial requalification program inspection results to Adnan Ali, Operations Director, and other members of the licensee staff.

• On October 13, 2023, the inspectors presented the licensed operator biennial requalification program inspection results to Adnan Ali, Operations Director, and other members of the licensee staff.

• On October 26, 2023, the inspectors presented the emergency preparedness inspection results to Valentine Ezugha, Director of Organizational Performance and Regulatory, and other members of the licensee staff.

• On December 18, 2023, the inspectors presented the emergency action level and emergency plan change review inspection results to Fred Muhly, Emergency Preparedness Manager, and other members of the licensee staff.

• On January 18, 2024, the inspectors presented the radiation protection inspection results to W. K. Akre, Sr. Manager Site Radiation Protection, and other members of the licensee staff.

THIRD PARTY REVIEWS As discussed in IMC 0611, Section 13.01, inspectors reviewed World Association of Nuclear Operators reports that were issued during the inspection period.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

m-36

Diagram of Core Spray Piping

05/28/1998

Drawings

M-87

Diagram of High-Pressure Coolant Injection - HPCI Piping

05/11/1998

QCAP 0400-17

Station Lube and Fuel Oil Sampling Points and Schedule

Procedures

QCOS 2300-10

HPCI Monthly Valve Position Verification

009

WO 4689324

Mechanical Inspection and Stem Lube

04/24/2023

WO 5374911

Sample HPCI Turbine Main Pump Gear Set Resvr Oil

08/29/2023

WO 5379122

1A CS Operability Verification

09/22/2023

WO 5400331

1A CS Valve Lineup Verification

10/13/2023

WO 5406738

Safety System Manual Valve Position Verification

11/04/2023

71111.04

Work Orders

WO 5406738

Safety System Manual Valve Position Verification

11/06/2023

AR 4709303

Quarterly Fire Brigade Drill Tracking / Trending Crew E

10/13/2023

AR 4712836

Pressure Tag Needs Removal

10/26/2023

Corrective Action

Documents

AR 4716563

Blocked Floor Drains on U-1 666 Elevation

11/09/2023

FZ 1.1.1.5

Unit 1 RB 666'-6" Elev Stand-By Liquid Control 4th Floor

West

08/2022

FZ 5.0

Safe Shutdown Pump Room

FZ 8.1

Clean and Dirty Oil Tank Room

FZ 8.2.3.A

Unit 1 TB 572'-6" Elev. CRD Pumps

08/2022

FZ 8.2.6.E

Unit 2 TB 595' Elev. 4kV Switchgear & Trackway Area,

Unit 2 TB 595' Elevation Storage Expansion Building

11/2022

FZ 8.2.7.A

Unit 1 TB 615'-6" Elev Hydrogen Seal Oil Area and MCCs

09/2022

FZ 9.1

UNIT 1 TB 595 Elev Diesel Generator

08/2022

Pre Fire Plan 9.1

Unit 1 Diesel Generator Room

Fire Plans

QCMMS 4100-97

Turbine Radwaste and LTD Building Fire Inspection Check

Sheet (Fire Hose Inspection)

FDS 2023 4th Qtr

1. 1

Fire Drill Scenario Number 2023 4th Qtr#1

FL-15045

Standby Diesel Room Cardox Calculations

10/02/1968

71111.05

Miscellaneous

SER July 21,

1988

Safety Evaluation Report for Exemption Requests from the

Regulatory Requirements of 10 CFR 50, Appendix R,

Specifically Relating to FZ 8.2.3.A Firewalls, Among Others

07/21/1988

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Operability

Evaluations

PBI 3175

Plant Barrier Impairment Relating to Fire Damper Inspection

Causing a Control Room Emergency Ventilation Breach

While Open (Related to Work Order 5228200)

Procedures

QCMMS 4100-97

Hose Reel Fire Inspection

QC-PSA-012

QC PRA Internal Flood Evaluation and Summary Notebook

WO 5008277

Fire Damper Visual Inspection

08/20/2021

WO 5163373

Standby DG Cardox Fire Protection Functional Test

11/28/2022

WO 5163728

Special NEIL Fire Hose Reel Inspection

06/10/2022

WO 5164932

NEIL R Area Fire Hose Reel Inspection

04/14/2023

WO 5229483

NEIL Reactor Building Fire Hose Reel Inspection

01/06/2023

WO 5268312

NEIL Special Hose Reel Fire Inspection

05/08/2023

Work Orders

WO 5268312

Special Hose Reel Fire Inspection

05/08/2023

AR 4509196

2A FRV Failed Closed - U2 Manual SCRAM on Low Level

07/04/2022

AR 4539936

3B ERV Missed Technical Specification

08/23/2023

Corrective Action

Documents

AR 4563432

Unanalyzed Loads on 4kV System in Cribhouse

03/20/2023

AEM-127704

Post Training Effectiveness for FRV Failure

10/10/2022

Job Performance

Measure (JPM)

LP-6500-01

Job Performance

Measure (JPM)

LS-0300-03

Job Performance

Measure (JPM)

LS-6500-01-A

Job Performance

Measure (JPM)

LS-5750-02

Job Performance

Measure (JPM)

LP-6800-01

Job Performance

Measure (JPM)

LP-2900-01

Job Performance

Measure (JPM)

SRO-33

Job Performance

Measure (JPM)

LS-0500-01-A

71111.11B

Miscellaneous

Job Performance

Measure (JPM)

LS-5750-01

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Job Performance

Measure (JPM)

LS-4400-01-A

NF-QC-770

Manual Heat Balance 100% Power Simulator

NF230044

Quad Cities 1 Cycle 28 Simulator Core Model Update

PI-AA-125-1001

Performance Analysis of FRV closure

07/25/2022

PI-AA-125-1006

Performance Analysis of Cribhouse Htrs

06/16/2023

Scenario 00-07

Scenario-Based Testing Report LOR Cycle 23-06

09/06/2023

Scenario-Based

Testing Report

Maximum Size Reactor Coolant System Rupture Combined

with Loss of Off-Site Power - TR-08

04/24/2023

Scenario-Based

Testing Report

Simultaneous Trip of All Reactor Recirculation

Pumps - TR-04

04/24/2023

Scenario-Based

Testing Report

Simultaneous Trip of All Main Feedwater Pumps - TR-02

04/24/2023

Scenario-Based

Testing Report

Simulator Steady State Test

04/24/2023

Scenario-Based

Testing Report

Simulator Real Time Test

04/21/2023

Simulator

Exercise Guide

(SEG)

00-19

Simulator

Exercise Guide

(SEG)

00-28

Simulator

Exercise Guide

(SEG)

00-05

Simulator

Exercise Guide

(SEG)

00-20

Simulator

Paperwork

Simulator Work Request List (2021-2023)

Simulator

Paperwork

List of Open/Deferred Simulator Work List

SWR 137676

Install PPC Point Changes Made per Plant IR 4458613

04/15/2022

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

SWR 138161

HPCI Turbine Trip Pushbutton Latch

2/07/2023

SWR 138518

SBO QCOS 6620-01 SBO DG Quarterly Test

07/06/2023

TR-220720-007

Training Request for Failed FRV

07/20/2022

TR-230606-005

Training Request for Cribhouse Heaters

06/06/2023

Written Exam

23 LORT NRC Crew F RO

09/20/2023

Written Exam

23 LORT NRC Crew F SRO

09/20/2023

NF-QC-770

Manual Heat Balance 50% Power Simulator

NF-QC-770

Manual Heat Balance 75% Power Simulator

OP-AA-105-101

Administrative Process for NRC License and Medical

Requirements

OP-AA-105-102

NRC Active License Maintenance

QDC-0000-N-

2446

Quad Cities Unit 1 Cycle 28 Cycle Management Report

TQ-AA-150

Operator Training Programs

TQ-AA-201

Examination Security and Administration

TQ-AA-306

Simulator Management

TQ-AA-306-F-06

BWR Critical Conditions for Cold Startup

04/24/2023

TQ-AA-306-F-07

BWR Power Coefficient of Reactivity and Control Rod Worth

04/24/2023

TQ-AA-306-F-08

BWR Xenon Worth

04/24/2023

Procedures

TQ-AA-306-F-09

BWR Site Specific Shutdown Margin and Reactivity Anomaly

Tests

04/24/2023

Self-Assessments PI-AA-126-1001-

F01

LOR Training Program Focused Self-Assessment

08/14/2023

AR 4711200

2A Core Spray Cooling Line Break During Run

10/20/2023

71111.12

Corrective Action

Documents

AR 4716807

Extent of Condition Walkdown on RHR, CS, and HPCI

11/10/2023

AR 4707503

Control Room Envelope DP Less than Expected on B HVAC

10/06/2023

Corrective Action

Documents

AR 4708729

UFSAR Section 6.4 Inconsistencies

10/10/2023

4E-6870AB,

Sheet 16

Schematic Diagram Station Blackout DG Annunciator

2/21/1997

4E-6871N, Sheet

Wiring Diagram Station Blackout ECP-B PNL 2201-105,

PLC RK 2

2/21/1997

71111.15

Drawings

4E-6871N, Sheet

Wiring Diagram Station Blackout Engine Control Panel B

Panel 2201-105

11/26/2007

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

4E-6871N, Sheet

Wiring Diagram Station Blackout Engine Control Panel B

Panel 2201-105

06/06/2019

4E-6871N, Sheet

Wiring Diagram Station Blackout Engine Control Panel B

Panel 2201-105

06/06/2019

4E-6871N, Sheet

Wiring Diagram Station Blackout Engine Control Panel B

Panel 2201-105

06/06/2019

17-R15-024

Removal of the Reference to 0.125" Water Gauge

Differential Pressure Above Adjacent Areas During Accident

Conditions

08/01/2019

Engineering

Changes

EC 368462

Show Control Room Envelope Boundary on P&ID Dut and

Gen. Layout Dwgs

2/18/2008

QCOS 5750-03

Manual Isolation of Control Room Ventilation

QCOS 5750-04

Quarterly Testing of Control Room HVAC System Valves

and Dampers

QCOS 5750-11

Control Room Emergency Ventilation Air Conditioning

System Test

Procedures

QCOS 5750-15

Containment and Control Room Ventilation Boundary Smoke

Test

WO 5196034

Control Room Emergency AC System Test

10/03/2023

WO 5196035

Periodic DO Test of Control Room Envelope

10/10/2023

Work Orders

WO 5382934

Control Room HVAC System Check VLV Test

10/03/2023

Calculations

QDC-1300-M-

0800

Pressure Drop Through RCIC Discharge Piping to Reactor

Vessel

03/11/1999

AR 4724312

U1 EDG did not Meet Performance Acceptance Criteria

2/18/2023

Corrective Action

Documents

AR 4724312

U-1 EDG did not Meet Performance Acceptance Criteria

2/18/2023

Miscellaneous

IN 87-42

Information Notice 87-42 - Diesel Generator Fuse Contacts

09/04/1987

QCOS 1100-07

SBLC Pump Flow Rate Test

QCOS 6620-01

SBO DG 1(2) Quarterly Load Test

QCOS 6620-11

SBO DG 1(2) Semi-Annual Remote/Local/PLC Bypass

Emergency Start Test

QCOS 7500-05

SBGTS Operability Test

QOA 7000-01

20 VAC Reactor Protection Bus Failure

71111.24

Procedures

TIC 3761

Unit 1 Diesel Generator Endurance and Margin/Full Load

Reject/ Hot Restart Test

17A

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

WO 5306695

B SBLC Pump Flow Rate (IST)

01/27/2023

WO 5360821

B SBLC Pump Flow Rate Test

08/11/2023

WO 5368110

SBGT Operability (A Train)

06/19/2023

WO 5376373

SBGT Operability (A Train)

07/20/2023

WO 5393548

SBGT Operability (A Train)

09/20/2023

WO 5400314

RCIC Pump Operability

2/08/2023

Work Orders

WO 5401997

SBGT Operability (A Train)

10/18/2023

Monthly Siren Test Results

10/01/2022-

09/30/2023

Emergency Preparedness for the

Quad Cities Area - 2020/2021 (Information Handbook)

06/17/2020

Emergency Preparedness for the

Quad Cities Area - 2022/2023 (Information Handbook)

09/02/2022

Miscellaneous

Siren Annual Preventative Maintenance Records

10/01/2021-

09/30/2023

Off-Site Emergency Plan Prompt and Alert and Notification

System Addendum for the Quad Cities Nuclear Power

Station

71114.02

Procedures

EP-AA-1006

Radiological Emergency Plan Annex for Quad Cities

AR 4552919

ERO Database Files Degraded Impacting Fleet Everbridge

System

2/06/2023

AR 4673349

Route 84 Closed Due to Flooding, ERO Response Impact

04/27/2023

Corrective Action

Documents

AR 4696502

Potential Adverse Trend - Missed ERO Training

08/15/2023

Quad Cities ERO Team Roster

08/31/2023

ERO Quarterly Augmentation Drill Records

10/01/2021-

09/30/2023

Miscellaneous

ERO Team Training and Qualification Records

(Sample - 15)

10/31/2023

EP-AA-1006

Radiological Emergency Plan Annex for Quad Cities

EP-AA-1006,

Addendum 1

Quad Cities Station On-shift Staffing Technical Basis

71114.03

Procedures

EP-AA-112

Emergency Response Organization (ERO) / Emergency

Response Facility (ERF) Activation and Operation

71114.04

Miscellaneous

CFR 50.54(Q) Reviewer Qualification Records

06/01/2023

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

(Spreadsheet)

EP-AA-1000

Exelon Nuclear Radiological Emergency Plan

EP-AA-1006

Exelon Nuclear Radiological Emergency Plan for Quad

Cities Station

EP-AA-1006,

Addendum 3

Emergency Action Levels for Quad Cities Station

Procedures

EP-AA-120-1001

CFR 50.54(Q) Change Evaluation

AR 4448428

Quarterly Inventory for Genesis-Silvis Expiring Supplies

09/24/2021

AR 4482176

EP 1Q22 PI Drill CR/SIM Demonstration Criteria Failure

03/03/2022

AR 4482190

EP 1Q22 PI Drill TSC Demonstration Criteria Failure

03/03/2022

AR 4482239

EP 1Q22 PI Drill TSC Performance Issues

03/03/2022

AR 4482256

EP 1Q22 PI Drill Facility and Equipment Issues

03/03/2022

AR 4505702

22 EP Pre Exercise Critique and Learnings

06/15/2022

AR 4505731

22 EP Pre Exercise Drill Issues

06/15/2022

AR 4512943

TSC ENS Phone Not Functional

07/26/2022

AR 4556071

EP 2-7-23 PI Drill TSC Demonstration Criteria Failure

2/21/2023

Corrective Action

Documents

AR 4556072

EP 2-7-23 PI Drill OSC Demonstration Criteria Failure

2/21/2023

ERO Newsletter

03/20/2023

Emergency Preparedness Letters of Agreements with

Off-Site Response and Support Organizations

10/01/2021-

10/01/2023

Select Exercise and Drill Evaluation Reports

10/01/2021-

10/01/2023

Quarterly Control Room and Emergency Response Facilities

Testing and Maintenance Records

10/01/2021-

10/01/2023

Miscellaneous

NOSA-QDC-22-

Quad Cities Generating Station Emergency Preparedness

Audit Report

05/11/2022

EP-AA-1000

Exelon Nuclear Standardized Radiological Emergency Plan

EP-AA-1006

Radiological Emergency Plan Annex for Quad Cities

EP-AA-1006,

Addendum 3

Emergency Action Levels for Quad Cities Station

71114.05

Procedures

KLD TR - 1255

Evacuation Time Estimates for Quad Cities

08/02/2022

71124.03

Miscellaneous

EID CHAPP1407

Intake Investigation RWP QC-01-23-00826

07/13/2023

71124.04

Miscellaneous

EID CHAPP1407

Intake Investigation RWP QC-01-23-00826

07/13/2023

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

AR 4547681

Condensate Resin Liners >1000 mR/hr at 3 meters

2/21/2023

Corrective Action

Documents

AR 4701267

Unable to Locate Material That Contains Rad Source

11/10/2023

Corrective Action

Documents

Resulting from

Inspection

AR 4720737

White Stains at Floor-to-Wall Joints in IRSF

11/30/2023

RP-AA-800,

Source Leak Test Record

05/13/2022

11/19/2021

10/13/2023

SRRS:2B.127

Source Inventory Page

11/19/2021

10/10/2023

5/13/2022

TBE Sample ID

L92357-4

21 DAW - 10CFR61 Database Analysis 2021 DAW

08/04/2021

TBE Sample ID

L97074-2

21 Condensate Resin - 10CFR61 Database Analysis

21 Condensate Resin

10/04/2022

TBE Sample ID

L97074-3

22 Condensate Resin - 10CFR61 Database Analysis

22 Condensate Resin

10/04/2022

Miscellaneous

TBE Sample ID

L97074-4

22 DAW - 10CFR61 Database Analysis 2022 DAW

08/25/2022

RP-AA-605

CFR 61 Program

Procedures

RP-AA-800

Control, Inventory, and Leak Testing of Radioactive Sources

AR 4481844

Radwaste

11/03/2022

71124.08

Self-Assessments

AR 4535851

Radioactive Solid Waste Processing and Radioactive

Material Handling, Storage, and Transportation

09/18/2023

Alert and Notification System Reliability Records

04/01/2022-

06/30/2023

Emergency Response Organization Drill Participation

Records

04/01/2022-

06/30/2023

71151

Miscellaneous

Drill and Exercise Performance Records

04/01/2022-

06/30/2023

71152A

Corrective Action

AR 4695858

U2 Turbine Trip and SCRAM due to High Moisture Separator 08/11/2023

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Documents

Level

QCGP 1-2

Normal Reactor Startup

Procedures

QCGP 3-1

Reactor Power Operations

Work Orders

WO 5032928

Troubleshoot & Tune All FW HTR LVL IND Controllers

03/15/2022

AR 4714008

NRC CETI ID: U2 EDG 9-7-2023 Oil Sample In Alert

10/31/2023

AR 4714913

NRC CETI ID: Lube Oil Analysis AMP Not Followed

11/02/2023

AR 4714916

NRC CETI: IR Not Initiated for WO 04892430 As-left Results

11/02/2023

Corrective Action

Documents

AR 4716213

U1 SBO Unavailable Due to Low Lube Oil Temp

11/08/2023

Corrective Action

Documents

Resulting from

Inspection

AR 4710673

71111.11 Inspection Results

10/18/2023

Engineering

Changes

ECR 431051

Minimum Lubricating Oil Temperature for Station Blackout

Diesel Standby Operation

MA-AA-716-230-

1001

Oil Analysis Interpretation Guideline

Procedures

QCAN 2201(2)-

105 D-1

SBO DG 1(2) Engine B(A) Lube Oil Temperature LO Alarm

71152S

Work Orders

WO 4892430

Install Close Torque Switch Bypass and Change Gearing

EC404721

03/16/2021

AR 2453092

U2 EDG Excitation Fuse Contacts Found Degraded

(Dresden)

2/15/2015

AR 4714930

U2 EDG Failure During MMD Overspeed Test

11/02/2023

AR 4722813

U1 EDG Failed During Performance of QCOS 6600-41

2/11/2023

AR 4724312

U-1 EDG Did Not Meet Performance Acceptance Criteria

2/18/2023

Corrective Action

Documents

AR 675966675966Fuse Found Not Fully Seated in 2251-12 Panel

09/26/2007

4E-1336

Relay Meter and Excitation Diagram Standby Diesel

Generator 1

11/26/2001

4E-1645B

Wiring Diagram Standby Diesel Generator 1 Excitation

Cabinet 2251-12

10/31/1994

Drawings

Figure 6800-01

Essential Service Power Supplies

Engineering

Changes

EC 403598

Drawing Updates for Equipment Tag Numbers for Exciter

Panel Circuit Breakers for the Standby Diesel Generators

71153

Engineering

311398

Receipt Inspection and Commercial Grade Dedication

2/14/2023

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Evaluations

Package for the Fuse Holder

C0002

EDG Technical Vendor Manual

03/24/1969

Miscellaneous

IN 87-42

Information Notice No. 87-42: Diesel Generator Fuse

Contacts

09/04/1987

MA-QC-773-401

Quad Cities NOAD RPS and EPA Relay Calibration

QOA 7000-01

20 VAC Reactor Protection Bus Failure (One or Both

Buses)

Procedures

TIC 3761

Temporary Instruction Change of QCOS 6600-56, Unit 1

Diesel Generator Endurance and Margin/Full Load

Reject/Hot Restart Test

17a

Q63734

Inspect and Clean PT Compartment and Fuse Contacts

07/14/1988

Q63735

Inspect and Clean PT Compartment and Fuse Contacts

06/10/1988

Q63736

Inspect and Clean PT Compartment and Fuse Contacts

05/08/1988

WO 4768693

EM Perform U1 DG 12-year Electrical Inspections

09/21/2021

Work Orders

WO 5416561

Unit 1 Diesel Generator Monthly Load Test

2/07/2023