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{{#Wiki_filter:/RA/
{{#Wiki_filter:uly 2, 2019


***
==SUBJECT:==
CLINTON POWER STATION, UNIT 1BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000461/2019010


Code of Federal Regulations
==Dear Mr. Hanson:==
On May 24, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution inspection at your Clinton Power Station, Unit 1 and discussed the results of this inspection with Mr. T. Stoner and other members of your staff. The results of this inspection are documented in the enclosed report.


*
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
 
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
 
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
 
Finally the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
 
The NRC inspectors did not identify any finding or violation of more than minor significance. 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
 
Sincerely,
/RA/
Kenneth Riemer, Chief Branch 1 Division of Reactor Projects Docket No.: 05000461 License No.: NPF-62
 
===Enclosure:===
Inspection Report 05000461/2019010
 
==Inspection Report==
Docket Number: 05000461 License Number: NPF-62 Report Number: 05000461/2019010 Enterprise Identifier: I-2019-010-0044 Licensee: Exelon Generation Company, LLC Facility: Clinton Power Station, Unit 1 Location: Clinton, IL Inspection Dates: May 06, 2019 to May 24, 2019 Inspectors: J. Bozga, Senior Reactor Inspector J. Neurauter, Senior Reactor Inspector C. Phillips, Project Engineer D. Sargis, Resident Inspector Approved By: Kenneth Riemer, Chief Branch 1 Division of Reactor Projects Enclosure
 
=SUMMARY=
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at Clinton Power Station, Unit 1 in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
 
List of Findings and Violations No findings were identified.
 
Additional Tracking Items Type      Issue Number              Title                            Report Section    Status URI      05000461/2019010-01      Fuses Subject to Part 21          71152B            Open Potentially Installed in Safety-Related Circuits
 
=INSPECTION SCOPES=
 
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
 
==OTHER ACTIVITIES - BASELINE==
 
===71152B - Problem Identification and Resolution    Biennial Team Inspection (IP Section 02.04) ===
{{IP sample|IP=IP 71152|count=1}}
The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.
* Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems.
* Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments.
* Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
 
==INSPECTION RESULTS==
Assessment                                                                                71152B Corrective Action Program Effectiveness: Based on the samples reviewed, the team determined that the licensees performance in each of these areas adequately supported nuclear safety.
 
Effectiveness of Problem Identification: Overall, the stations effectiveness at identifying issues at a low threshold and properly entering them into the Corrective Action Program (CAP) as required by station procedures was inconsistent. There were several items that were not identified or were not entered into the CAP when identified. For example, non-cited violation (NCV) 2018050-02 described how between May 11 and May 17, 2018, equipment operators repeatedly failed to identify that the isolation valves from the Division 2 emergency diesel generator (EDG) air start receivers to the air start motors were locked closed and failed to identify that this made the Division 2 EDG inoperable.
 
In addition, NCV 2018004-02 described how the station failed to recognize the conditions present for steam voiding in the B residual heat removal (RHR) shutdown cooling return line.
 
After the inspectors brought this to the licensee's attention, the licensee wrote Action Request (AR) 4166749, NRC Question on Potential Voiding of Piping Near 1E12F053B, in response to the inspectors questions. The station evaluated the condition in EC 625392, Evaluation of Potential Voiding of RHR [residual heat removal] B Shutdown Cooling Injection Line, and determined that a void would be present if the body-to-bonnet leak worsened or if the system depressurized as it would during shutdown and cooldown.
 
Also, NCV 2019011-01 described how station procedures Clinton Power Station (CPS) 4402.01 and CPS 4407.01 did not ensure the high pressure core spray system and the suppression pool would remain available for decay heat removal for the duration of a station blackout event. This was identified by an NRC engineering team and was communicated to the licensee who then had to be prompted by the NRC team on more than one occasion before it was finally entered into the CAP.
 
Finally, AR 4172856, NRC Observation, dated September 13, 2018, documented an NRC observation that a ladder was tied off to safety-related service water piping that was under 4 inches in diameter with no evaluation. This was not allowed without an evaluation per CPS 1019.05, Appendix C. The inspectors identified this as a concern and it took additional questions and prompting before the licensee identified this as a problem that needed to addressed through CAP. This issue was not documented in a previous NRC inspection report because it was considered a minor performance deficiency when a further evaluation determined it was acceptable to tie off the ladder to the pipe.
 
Effectiveness of Prioritization and Evaluation of lssues: ln-depth reviews of a risk-informed sampling of ARs, work orders (WOs), and cause evaluations were completed, including a 5-year time period for the Division 1 EDG. The team determined that the issues were generally being appropriately prioritized and evaluated for resolution. There were, however, examples of where the NRC identified flaws in the licensee's methods of evaluation. On September 13, 2018, the licensee performed a water hammer evaluation to determine whether voiding in the RHR shutdown cooling injection line would impact operability. The evaluation was documented in Engineering Change (EC) 625522, Evaluation of Water Hammer Forces From Potential Voiding in RHR Shutdown Cooling Injection Line. Based on the evaluation the licensee concluded the resulting water hammer event would be 10 pound-force (lbf), which was within the capability of the piping and support structures. Therefore, the licensee concluded there was no impact to operability, and operations removed the item from the potential limiting condition for operation list. The inspectors reviewed the calculation and identified multiple deficiencies that significantly impacted the conclusion reached by the licensee. Subsequently the licensee performed a more detailed evaluation that concluded the resulting water hammer event would be approximately 4600 lbf. Though the calculated margin from the initial evaluation was significantly reduced, the conclusion of the second evaluation was still within the capability of the system. The inspectors reviewed the updated calculation and did not identify any additional deficiencies. This performance deficiency was also described in NCV 2018004-02.
 
The inspectors reviewed the licensees evaluation of low pipe wall thickness readings on the A minimum flow line of the RHR system documented in AR 04133436, Low Thickness Readings Discovered On A RHR Minimum Flow Line, dated May 2, 2018. Specifically, the licensee performed EC 624133, Evaluate RHR A Minimum Flow Line Wall Thinning, Revision 1, to demonstrate operability of this piping and concluded that the piping met the design basis and American Society of Mechanical Engineers (ASME) code requirements. However, the inspectors identified that in EC 624133 the licensee calculated an average pipe section modulus around the pipe circumference at the location of low pipe wall thickness readings used to further calculate pipe stress. In addition, the inspectors did not identify specification of an average section modulus to calculate pipe stress in the ASME code. The licensee entered the concern into the CAP as AR 04250898, PI&R Inadequate Methodology in EC 624113, dated May 22, 2019, that indicated using an average section modulus to calculate pipe stress was not a methodology recognized by the ASME code. In addition, AR 04250898 documented reasonable assurance that the A minimum flow line of RHR system was operable by using pipe stress acceptance criteria in Appendix F of Section III of the ASME code in comparison to pipe stress conservatively factored to account for wall thinning. Section C.11 of NRC Inspection Manual Chapter 0326, Operability Determinations & Functionality Assessments for Conditions Adverse to Quality or Safety, issued November 20, 2017, documents the licensee may use criteria in Appendix F for piping and piping support operability determinations. This was considered a minor performance deficiency.
 
The inspectors reviewed the licensees evaluation associated with snubber 1RT01003S failed function test documented in AR 04011410, Mechanical Snubber 1RT01003S Failed Function Test, dated May 16, 2017. Specifically, snubber 1RT01003S failed its drag test and was found locked in the hot setting position. The licensee performed EC 619714 to evaluate the effect of this additional restraint to ensure the piping system was not overstressed. The inspectors noted that EC 619714 did not consider the effect of thermal binding during system cooldown on pipe stress and support loads as the as found snubber did not return to its cold setting. The licensee entered the concern into the CAP as AR 04251430, Failed Snubber Evaluation Inadequate, dated May 23, 2019, that documented immediate corrective action that evaluated the condition and concluded no stress limit was exceeded. Since failed snubber 1RT01003S was replaced, the inspectors also reviewed the licensees associated VT-3 visual examination reports and verified no relevant / recordable indications were identified for the restraint. This was considered a minor performance deficiency.
 
Effectiveness of Corrective Actions: The team concluded that the corrective actions that were implemented were neither consistently robust nor consistently completed. For example, in 2017 and early 2018 the licensee took actions to address a declining trend in human performance errors. The inspectors reviewed those corrective actions and documented the results in NRC inspection report 2018003. In May 2018 at least six separate procedure errors resulted in the Division 2 EDG remaining unavailable when it was being depended upon for plant safety. This was documented in NCV 2018050-01 which became a White finding. Predominately because of this event the inspectors found the licensees previous corrective actions regarding human performance to be ineffective. Since that event the licensee has taken more robust corrective actions in regard to human performance. There have been fewer human performance events since the implementation of these new corrective actions.
 
The inspectors reviewed AR 04073056, Identified USFAR [updated final safety analysis report]
Chapter 10 Discrepancies Still in USAR [updated safety analysis report], dated November 9, 2017. This AR documented that actions to prepare a change package to Chapter 10 of the UFSAR had twice been generated and twice closed out without actually being performed. The change to Chapter 10 of the UFSAR was in the review process but was not implemented as of May 9, 2019. This was considered a minor performance deficiency.
 
The inspectors reviewed AR 04168460, DAC [derived air concentration] Value Discrepancy Discovered in Countroom Software, dated August 30, 2018. The licensee identified that the DAC values in countroom software, used to determine if a potentially airborne work area should be posted or not, did not match the inhalation DAC table values in accordance with Title 10 of the Code of Federal Regulations (CFR), Part 20, for two radio-nuclides. The licensee performed hand calculations to verify that the room was not required to have been posted as an airborne area. A follow-up action was to go and verify that the other values in the software matched 10 CFR Part 20 values. The licensee found about 35 more radio-nuclides whose software value did not match 10 CFR Part 20 but did not go and do hand calculations for previous samples to determine if they had required posting. The licensee has since performed those hand calculations with no issues identified. Questions regarding this issue resulted in finding a similar issue in AR 02620909, 10CFR20 Inhalation DAC Value For KR-85M Found Incorrect, dated February 2, 2016. An action that came from AR 02620909 was to validate the entire library for additional errors. This was marked as complete in March 2016 but was never actually accomplished. This was documented in AR 04247547 and was considered a minor performance deficiency.
 
The inspectors reviewed AR 4017613, Welding Cables Through Both RT [reactor water clean up] Pump Room B Doors, dated June 2, 2017, which documented that welding cables were running through both secondary containment doors while in mode 2 ( NCV 2017003-05). The corrective actions were assignments -34 and -35 which were to complete a read and sign for all schedulers and planners on the plant barrier impairments (PBI) procedure and its interaction with the work process. The effectiveness was measured with action -42. The corrective actions (CAs) failed the first effectiveness review (EFR) as documented in AR 4062608, EFR for CAPE [corrective action program evaluation] 4017613, dated October 13, 2017. This AR documents that the EFR was done in the same month the corrective action was closed.
 
Therefore, the licensee should have given it more run time, and the licensee re-performed the EFR two months after the CA was closed. Action request 4073308, Effectiveness Review Results For AR 4062608, dated November 10, 2017, documented that the second EFR determined that the CA was ineffective. This time the licensee created a new CA that evaluated the PBI process and implemented actions to resolve the need for emergent PBI requests. The EFR was completed SAT for this CA. The original actions (-34 and -35) were not robust and only addressed the work planners. The later CAs took a larger view of the PBI process and addressed the issue at the shop level and maintenance planner level.
 
Operating Experience (OpE) and Self-Assessments and Audits: The team concluded that the licensee was generally effective in the use of OpE in the CAP, self-assessments and audits.
 
The team determined that when performing causal analysis and determining CAs that OpE was routinely utilized. ln addition, the team sampled OpE from NRC, industry, vendors, and third party groups and determined that for the samples selected that appropriate assessments for applicability to the licensee were performed.
 
Safety Conscious Work Environment: The team found evidence that the licensee's safety conscious work environment (SCWE) was appropriate. The licensee's employees appeared willing to raise nuclear safety concerns through at least one of several means available. The team observed various station meetings, including those in which new CAP items were reviewed, and interviewed a representative cross-section of station personnel, both individually and small groups. Additionally, the team assessed the overall health of the Employee Concerns Program. Specifically, the team interviewed the Employee Concerns Coordinator, reviewed recent case logs and case files and considered statement received during interviews with station personnel.
 
Unresolved Item        Fuses Subject to Part 21 Potentially Installed in Safety-          71152B (Open)                Related Circuits 05000461/2019010-01
 
=====Description:=====
On August 23, 2018, the NRC received a 10 CFR Part 21 notification (Part 21) under LER 05000440/2018-002-00 (ML18236A294). The Part 21 report described a manufacturing defect of Gould Shawmut TR30R fuses. The Part 21 described that the fuse internals had separated from one another indicating that they were under tension. The tension was likely placed on the fuse during manufacturing when the ferrule ends of the fuse were crimped onto the fuse barrel. The Part 21 identified that the fuse had failed even though it was never exposed to an electrical current large enough to have failed the fuse.
 
The licensee initiated an action under AR 04061497-77, 10 CFR Part 21 Applicability Determination, dated September 25, 2018, to perform a Part 21 applicability determination for Clinton Power Station because Clinton was not specifically named in the Part 21. The licensee identified that they had purchased Gould Shawmut TR30R fuses, commercially dedicated them, and installed them in the plant. The licensee believed that the Part 21 would not affect the plant because the fuses purchased were commercially dedicated, checked for ferrule tightness, and checked for resistance. The licensee failed to generate a site specific AR with actions for supply and engineering to evaluate the impact to the station. As a result, the licensee failed to evaluate fuses installed during initial construction, failed to evaluate the impact on operability, and failed to determine if the commercial grade dedication process was adequate to identify this failure mechanism. The above failures were self-imposed standards, not regulatory requirements, and were of minor significance.
 
The inspectors questioned the adequacy of the licensee's determination that the Part 21 does not affect the site and identified that the licensee did not generate a site specific AR as required by their operating experience procedure. The licensee placed the issue in the corrective action program and evaluated the impact of the fuses. The licensee determined that the fuses identified in the Part 21 were from Lot number E-64. The fuses the licensee has installed in the plant were not from this lot, but the licensee did not know if the fuses originally installed in the plant were from lot E-64. The licensee identified that there were five locations in which a failure of the fuse would result in a partial loss of safety function.
 
This is an unresolved item. In order to resolve this issue, the inspectors need to know whether fuses from lot E-64 were installed in safety-related circuits.
 
Planned Closure Actions: The inspectors need to know if any of the fuses from lot E-64 are installed in safety-related circuits. The licensee plans to visually inspect each circuit that could contain the affected fuses. The inspectors will evaluate the results of the inspection and determine if a violation existed.
 
Licensee Actions: The licensee plans to determine if the affected lot of fuses were installed in the plant. The licensee plans to visually inspect each location that this type of fuse is installed.
 
If any fuses from the affected lot are identified, the licensee plans to replace those with fuses that were not from the affected lot.
 
Corrective Action References: AR 04250520, NRC Question: P21 Fuse, dated May 5, 2019 AR 04251536, Part 21 Assessment Results for TR30R Fuses, dated May 24,
 
==EXIT MEETINGS AND DEBRIEFS==
The inspectors verified no proprietary information was retained or documented in this report.
* On May 24, 2019, the inspectors presented the biennial problem identification and resolution inspection results to Mr. T. Stoner and other members of the licensee staff.
 
=DOCUMENTS REVIEWED=
 
Inspection Type              Designation    Description or Title                                            Revision or
Procedure                                                                                                  Date
71152B    Calculations      IP-M-0513      Division I, II and III SX Pipe Wall Thinning Analysis Including 0W
RHR Piping
Corrective Action 04034973      Oil Leak From 1SX01PA                                          07/24/2017
Documents        AR 02385999    1DG005A Relief Valve Lifting Repeatedly                        09/25/2014
AR 02490408    Reactor SCRAM from Trip of 1AP07EJ                              12/09/2017
AR 02592592    1DG005A: Relief Valve Lifting Repeatedly                        11/25/2015
AR 02595942    NCV 2015003-03, Failure to Obtain Lic Amend on Sec Cnmt        12/04/2015
Mod
AR 02596437    Upper Bearing Oil Cooler Leak                                  12/06/2015
AR 02598117    1WS01PB, WS 'B' Lower Bearing Oil Level Sightglass Full        12/09/2015
AR 02620909    10CFR20 Inhalation DAV Value for KR-85M Found Incorrect        02/02/2016
AR 02644384    OPEX Evaluation: IER L3-16-6, Control Rod Drive Vent Plug      03/23/2016
Leakage Concern
AR 02649780    RAT 4538 Failure: Numerous Unexpected Alarms 5010-1A,          04/02/2016
1C, 8A
AR 02654953    1FW01PB (TDRFP B) Vibration has Continued to Degrade          04/13/2016
AR 02667822    Unexpected Alarms 5050-1F/2F and 1VH01CA Trip                  05/10/2016
AR 02675486    1WS01PB, WS Pump B Leaking from Upper Bearing                  05/30/2016
AR 02704548-04 NRC Information Notice 2016-11: Potential for Material          11/14/2016
Handling Events to Cause Internal Flooding
AR 02742442    CDBI: Inappropriate Calculation Method for CR Habitability      11/17/2016
AR 03950913    WS Requires Maintenance Rule (A)(1) Evaluation                  01/09/2017
AR 03962443-97 10 CFR Part 21 Applicability Determination                      10/12/2017
AR 03978324    Lost 138KV Feed Causing ERAT Transient                          02/24/2017
AR 04006988    OPEX Evaluation: NRC IN 2017-01, Reactor Coolant System        05/05/2017
Leakage from a Control Rod Drive Threaded Connection
AR 04007861    Entered 4008.01 and 4002.01 Due to FCV Runback                  05/07/2017
AR 04009845    PSU: C1R17 MSIV LLRT [local leak rate test] Tech Spec          05/12/2017
3.6.1.3 Limit Exceeded
AR 04011410    Mechanical Snubber 1RT01003S Failed Function Test              05/16/2017
AR 04015342    NRC Identified Two Issues Regarding Snubber Testing            05/26/2017
Inspection Type Designation    Description or Title                                          Revision or
Procedure                                                                                    Date
AR 04016563    Automatic Reactor Scram                                      05/30/2017
AR 04017613    Welding Cables Through Both RT Pump Room 'B' Doors            06/02/2017
AR 04022757-02 NRC Information Notice 2017-03 Anchor Darling Double Disc    08/19/2017
Gate Valve Wedge Pin and Stem-Disc Separation Failures
AR 04044082    OPEX Review: NRC IN 2017-04, High Energy Arcing Faults in    08/21/2017
Electrical Equipment Containing Aluminum Components
AR 04049063    OPEX Evaluation: IN 2-17-05, Potential Binding of Schneider  09/05/2017
Electic/Square-D Master Pact 480-VAC Circuit Breaker Anti-
Pump Feature
AR 04052455    10 CFR Part 21 Update Regarding Grayboot Socket Contacts      09/15/2017
AR 04052639    Gothic V8.1 and V8.2 Computer Code Errors Potential Part 21  08/22/2017
AR 04054180    Follow Up on Overall Strategy for 1CC103 Leak                09/20/2017
AR 04055133    Valve 1IA128B Failed Seat Leakage Test                        09/23/2017
AR 04056394    2017PIR 4410.00C001 Needs 50.59 Screening                    09/27/2017
AR 04061340    Part 21 For HMA Relay Potentially Applicable                  10/10/2017
AR 04061497-77 10 CFR Part 21 Applicability Determination                    09/25/2018
AR 04062608    EFR for CAPE 4017613                                          10/13/2017
AR 04066250    OPEX Level 3 Review - NRC IN 2017-06, Battery and Battery    10/24/2017
Charger Short-Circuit Current Contributions to a Fault on the
Direct Current Distribution System
AR 04069750    BRE [bullet resistant enclosure] Energized Power Plug        11/01/2017
AR 04069935    MCR [main control room] Unexpected Alarm 5067-3F MS          11/02/2017
                              [main steam] Line Radiation High
AR 04071277    ERAT SVC [static variable compensator] Tripped Due to        11/05/2017
Substation Breaker Cycling
AR 04072627    Shephard Calibrator Interlocks not Functioning as Designed    11/08/2017
AR 04073308    Effectiveness Review Results for AR 4062608                  11/10/2017
AR 04075431    NCV 2017007-01 Fail to Eval Defeating RCIC Interlocks/Trips  11/16/2017
AR 04075432    NCV 2017003-05 Entered Mode 2 While Secondary                11/16/2017
Containment Inop
AR 04075433    NCV 2017003-01 Condition Based Maint Approach On MSIV        11/16/2017
                              [main steam isolation valve] Leakage
AR 04075433    NCV 2017003-01 Condition Based Maint Approach on MSIV        11/07/2017
Leakage
Inspection Type Designation    Description or Title                                        Revision or
Procedure                                                                                  Date
AR 04075435    NCV 2017-003-03, Fail to Perform Engineering Evaluation for  11/16/2017
Snubber Failure
AR 04075436    NCV 2017003-04 RR Pump Runback Due to FCVs not Locked        11/16/2017
Out
AR 04075581    IP 92723 - Inadequate Extent of Condition on NCV 2016002-    11/16/2017
AR 04075779    RHR A & B Min Flow Piping Removed From C1R18 Scope          11/17/2017
AR 04080756    SEC ID-Camera 37 Loss of Coverage                            12/04/2017
AR 04081583    Potential NRC SL IV Violation for Time to Boil 72.48 Screen  12/06/2017
AR 04084004    SEC ID: EVD#2 Failed Testing                                12/14/2017
AR 04089480    Failure to Implement CAPR [corrective action to prevent      01/02/2018
recurrence] At First Available Opportunity
AR 04096509    RCIC PCIV 1E51-F064 Isolated During 9030.01 Surveillance    01/24/2018
AR 04099250    NRC FIN 2017012-02 Fail to Prop Classify NSR Aux            01/30/2018
Transformer
AR 04102073    10 CFR Part 21 - NRC Log 2017-55 - SOR                      02/08/2018
AR 04105979    NRC NCV 2017004-02 Failure to Assess and Manage Risk        02/20/2018
AR 04105980    NRC NCV 2017004-003, Failure to Perform an Extent of        02/20/2018
Condition
AR 04105981    NRC SL IV NCV 2017004-04, URI 72.48 Time-to-Boil            02/20/2018
Calculation Closed
AR 04107258    NRC Information Notice: IN 2018-01, ISFSI Noble Gas          02/23/2018
Releases
AR 04108860-02 NRC 2018-002 Target Rock 3-Stage SRV Model 0867F            07/13/2018
Degredation
AR 04111775-05 Information Notice (IN) 2018-04: Operating Regarding Failure 06/27/2018
of Operators to Trip the Plant when Experiencing Unstable
Conditions
AR 04125651    Part 21 - Potential Failure of Reverse Power Relays          04/11/2018
AR 04128705    1VT02A Cooling Coil has Cracked Tube                        04/19/2018
AR 04130828    NRC Question on Last Performance of 9861.09D006              04/25/2018
AR 04131749    NRC NCV 2018001-01 Failure to Follow Procedure Isolates      04/27/2018
RCIC
AR 04133436    Low Thickness Readings Discovered on A RHR Minimum        05/02/2018
Inspection Type Designation Description or Title                                      Revision or
Procedure                                                                              Date
Flow Line
AR 04134393 1VH01CA SX Pump Room A Area Cooler Tripped              05/04/2018
AR 04134785 Low Thickness Readings Discovered on B RHR Minimum      05/05/2018
Flow Piping
AR 04137003 Rejected Weld Indication During Radiography B RHR Piping 05/12/2018
AR 04137330 9861.02D017, Leakage Needs Evaluated, RCIC Steam Supply    05/14/2018
AR 04139396 9861.09 and Data Sheets - SX Boundary Leak Test Procedure  05/20/2018
Changes
AR 04140601 Steam Leak in 6 Pipe Elbow on 1GS15B                      05/23/2018
AR 04143037 Piping Upstream of 1CC103 Still Leaking after Maintenance  05/31/2018
AR 04151429 L3 OPEX Evaluation Results - Battery Charger Fault        06/28/2018
Contribution
AR 04156632 NRC IN 2018-07: Pump/Turbine Bearing Oil Sightglass        07/18/2018
Problems
AR 04160873 RPID: TSP 2017-67 Needs to Remain in Place Permanently    08/01/2018
AR 04161074 RPID: Increased Dose Rates On WZ Piping                    08/02/2108
AR 04162483 NRC NCV 2018002-02, Fail to Establish Adequate Leak Test  08/07/2018
Procedure
AR 04163523 NRC IN 2018-09: Electric Arc Flash Caused by Foreign      08/11/2018
Material Damages Fire Door
AR 04164644 UT Pipe Wall Thinning at 4 Elbow of Pipe of 1SX21AB      08/15/2018
AR 04164975 UT Indicates Pipe Wall Tinning at 24 Pipe of 1WS14A      08/16/2018
AR 04166724 Leak Identified on 1DG155 Flanged Joint                    08/23/2018
AR 04166725 Leak Identified on 1DG04TA Threaded Joint                  08/23/2018
AR 04166730 Packing Leak on 1DG011A                                    08/23/2018
AR 04166731 Two Threaded Joint Leaks Found on 1DG169                  08/23/2018
AR 04168460 DAC Value Discrepancy Discovered in Countroom Software    08/30/2018
AR 04172921 UT Pipe Wall Thinning at 4 Elbow of Pipe 1SX21AA          09/13/2018
AR 04173375 UT Pipe Wall Thinning on 2-1/2 Pipe 1WSB9W                09/14/2018
AR 04177094 NRC Information Notice: IN 2018-11, Kobe Steel Quality    09/26/2018
Assurance Falsification
AR 04177203 Interruption In 138 KV Line Service to CPS ERAT [emergency 09/26/2018
reserve auxiliary transformer]
Inspection Type Designation Description or Title                                        Revision or
Procedure                                                                              Date
AR 04179395 NRC NCV 2018412-01 Fail to Search All Areas of a Vehicle    10/02/2018
AR 04180603 NRC IN 2018-03 - Failure to Meet TSs for Changing Plant    10/05/2018
Conditions
AR 04188313 Evaluate RHR A SDC Temperature Transient                    10/27/2018
AR 04188538 Reactor Scram on High IRM Flux                              10/28/2018
AR 04194966 Part 21 - Notification of Dry Type Transformer S/N 24-26458 11/14/2018
AR 04199126 NRC NCV 2018041-02, Fail to Establish Acceptance Criteria  11/30/2018
for Component Performance Monitoring
AR 04202559 Division 2 Diesel Generator 1DG01KC Oil Cooler Leak (Oil)  12/12/2018
AR 04203045 Improve Rounds Point for Division 3 EDG                    12/14/2018
AR 04206548 Small Oil Leak on Division 3 DG AC Circ LO Pump 1DG616PA    12/29/2018
AR 04208699 Division 2 DG Governor Oil Leak                            01/07/2019
AR 04208701 Division 2 DG 26 Cyl AC Circ Oil Pump Leak                  01/07/2019
AR 04208708 Oil Leak from Casing of 1DG16A                              01/07/2019
AR 04208712 1DG628PA Oil Leak from Fitting                              01/07/2019
AR 04208720 Oil Leaking from Fitting on 1DG605PA                        01/07/2019
AR 04209422 Division 1 DG 12 Cyl LO Filter Leak                        01/09/2019
AR 04209427 Division 1 DG 16 Cyl Crankcase Seal Leak                    01/09/2019
AR 04211426 Oil Leaking from Division 1 DG Oil Cooler Flanges          01/16/2019
AR 04212873 SEC ID: Contingency Weapon Left Unattended in the OCA      01/22/2019
                            [owner controlled area]
AR 04216769 1DG622PA Has Small Oil Leak                                02/03/2019
AR 04218343 SEC ID: Security Fencing Needs Repair                      02/08/2019
AR 04220198 NRC NCV 2018004-04 Fail Follow Proc. Resulting CRD Pump    02/14/2019
Trip
AR 04220199 NRC NCV 2018004-03, Fail to Include Acceptance Criteria for 02/14/2019
Division 3 EDG
AR 04220200 NRC NCV 2018004-02-Fail to ID a Degraded Cond. in RHR B    02/14/2019
AR 04220201 NRC NCV 2018004-01 Fail to Prevent Instal of Non-Conf.      02/14/2019
Parts
AR 04220251 NOS ID: Combustible Material Less than 3 Feet from a SWGR  02/14/2019
AR 04220260 NOS ID: Wrong PIDS Methodologies Used for Testing          02/14/2019
AR 04221273 Several Throughwall Pinhole Leaks Downstream of 1SX013D    02/18/2019
Inspection Type              Designation    Description or Title                                      Revision or
Procedure                                                                                              Date
AR 04225272    Request for Decon of the Spent Resin Pump Room            03/01/2019
AR 04227872    UT Pipe Wall Thinning of 3 Pipe of 1SX29BB                03/08/2019
AR 04229909    UT Indicates Pipe Wall Thinning at 8 Pipe of 1SX04AC      03/15/2019
AR 04231145    SX Piping Mitigation Strategy Review                      03/20/2019
CAPE 04012075  Workers Enter Incorrect Elevation of the Drywell Bioshield 06/22/2017
CAPE 04181437  October Trip of Reserve Auxiliary Transformer (RAT) Static 12/05/2018
VAR Compensator (SVC)
CAPE 4017613  Secondary Containment ITS Violation                        06/28/2017
CAPE 4096509  RCIC PCIV 1E51-F064 Isolated During 9030.01 Surveillance  02/28/2018
CAPR 03982792- Modify VC Load Shedding Wiring 0AP06E (EC 625821)          12/13/2018
CAPR 03982792- Modify VC Load Shedding Wiring 0AP05E (EC 625820)          02/26/2019
ECAP 02667822  Unexpected Alarms 5050-1F/2F and 1VH01CA Trip              06/01/2016
ECAPE 04148838 High Pressure Core Spray (HPCS) 1E22-F004 Valve Found      09/21/2018
Open
RCR 04016563  Automatic Reactor Scram                                    07/20/2017
RCR 04082490  Transformer Failure Results in Trip of 4160V 1A1 Breaker  10/04/2018
1AP07EJ and Loss of Power to 480V Unit Substation A
                                            (0AP05E) and 480V Unit Substation 1A (1AP11E)
RCR 4188538    IRM Scram                                                  12/14/2018
Corrective Action AR 04247254    NRC ID: Gaps Associated with Actions Under 4073308        05/08/2019
Documents        AR 04247547    NRC ID: Ineffective Action Closure                        05/08/2019
Resulting from    AR 04247831    NRC PI&R RHR Area Walkdown Issues                          05/09/2019
Inspection        AR 04248044    PI&R Identified Min Wall Reading on 1SX21AB Below          05/10/2019
Allowable
AR 04248056    PI&R WO Acceptance Criteria Not Per Calc                  05/10/2019
AR 04248079    PI&R 1SX21AB-4 Replacement Not Scheduled                  05/10/2019
AR 04249310    NRC ID: Root Cause Report 401653 Process Weakness          05/15/2019
AR 04249310    NRC ID: Root Cause Report 4016563 Process Weakness        05/15/2019
AR 04249610    NRC ID: IR 4180203 Should be Sig Level 3D                  05/16/2019
AR 04250520    NRC Question: P21 Fuse                                    05/20/2019
AR 04250898    PI&R Inadequate Methodology in EC 624113                  05/22/2019
Inspection Type          Designation    Description or Title                                        Revision or
Procedure                                                                                          Date
AR 04251096    Tracability of Fuses Issued to Ops and IMD                  05/22/2019
AR 04251113    PI&R Identified Violation Actions Inadequate                05/22/2019
AR 04251114    NRC ID: Min Wall Calcs Extent of Condition                  05/22/2019
AR 04251430    Failed Snubber Evaluation Inadequate                        05/23/2019
AR 04251536    Part 21 Assessment Results for TR30R Fuses                  05/24/2019
Engineering  EC 350224      Evaluation of Proposed Heatup/Startup of RHR in Shutdown    Revision 1
Changes                      Cooling
EC 438722      1SX01PC Pump Acceptance Criteria, Motors Amps and          02/05/2019
Coastdown Time
EC 619936      Endorsement and Application of GE Analysis for OPRM        03/07/2018
Setpoint Change
EC 621828      Replace Springs with Temporary Struts on RT Lines in the    0
Drywell (1RT01004C and 1RT01014C)
EC 625392      Evaluation Of Potential Voiding In RHR B Shutdown Cooling  Revision 0
Injection Line
Engineering  EC 619714      Snubber (1RT01003S) Failure Evaluation of Snubber          0
Evaluations                  Inspection Program
EC 624113      Evaluate RHR A Minimum Flow Line Wall Thinning            1
Miscellaneous AR 04005206-02 RP OE: Loss of Radiation Monitoring Equipment Due to Loss  06/21/2017
of 23kV Station Service
AR 04009125-02 #407927 OE - Equipment Misoperation - Event Final Complete  06/26/2017
Last Updated: 2017-05-05 Sequoyah
AR 04111775-05 Information Notice 2018-04: Operating Regarding Failure of  06/27/2018
Operators to Trip the Plant When Experiencing Unstable
Conditions
AR 04138790    Root Cause Report for Division 2 Emergency Diesel Generator 06/26/2018
Air Receivers Found Isolated During Rounds
AR 4008122-02  Exelon Nuclear Event Report (NER) AC-17-001, Reactor        06/21/2017
Protection System B Half SCRAM (Blown Fuse Investigation)
AR 4053493-35  ICES # 431701 Indian Point Unit 3 Automatic Trip Due to A  06/13/2019
Loss of Main Generator Excitation
AR 4117076    #432283 Loss of Instrument Air Due to Dryer Valve Failure  07/16/2018
C1R17-419      VT-3 NDE Report, Component 1RT01003S                        05/11/2017
C1R17-529      VT-3 NDE Report, Component 1RT01003S                        05/15/2017
Inspection Type        Designation    Description or Title                                              Revision or
Procedure                                                                                              Date
Event Number:  Part 21 - Interim Notification of a Potential Defect on a Printed 06/23/2017
2736          Circuit Board
LER            Part 21 - Failed Fuse Leads to Loss of Safety Function            08/23/2018
05000440/2018-
2-00
LER            Trip of Emergency Reserve Auxiliary Transformer Static VAR        01/04/2018
05000461/2017- Compensator Causes Positive Secondary Containment
009-00        Pressure Following Voltage Transient on 138kV Offsite Source
LER            Degraded Personnel Airlock Interlock Results in Loss of          05/29/2018
05000461/2018- Primary Containment
001-00
LER            Load Driver Card Failure Resulting in High Pressure Core          06/20/2018
05000461/2018- Spray Inoperability
003-01
LER            Unplanned Reactor Scram During Maintenance Outage Due to          04/24/2019
05000461/2018- High Intermediate Range Monitor Flux
005-02
M-1RT01003S    Support/Hanger Drawing                                            F
N/A            10 CFR Part 21 Curtiss-Wright Grayboot Socket Contacts            06/21/2017
NSED Review    Commercial Grade Dedication Summary                              Revision 1
95012
Operability EC 620644      Oil Leak From Div 1 SX Motor                                      Revision 2
Evaluations
Procedures  CPS 9431.26    OPRM Channel Calibrations                                        Revision 39c
CPS 9861.09    Shutdown Service Water Boundary Valve Leak Testing                08/29/2018
ER-AA-335-016  VT-3 Visual Examination of Component Supports,                    10
Attachments, and Interiors of Reactor Vessels
ER-CL-300      Clinton Power Station Snubber Program                            2
LS-AA-107      UFSAR/FPR [fire protection report] Update Procedure              Revision 12
MA-CL-0001    Fuse Program Guidance                                            Revision 3
NES-MS-03.1    Piping Minimum Wall Thickness Calculation                        5
NES-MS-03.2    Evaluation of Discrepant Piping and Support Systems              7
NO-AA-10      Quality Assurance Topical Report (QATR)                          Revision 94
OP-AA-108-115  Operability Determinations                                        21
Inspection Type            Designation    Description or Title                                        Revision or
Procedure                                                                                              Date
PI-AA-115-1003 Processing of Level 3 OPEX Evaluations                      Revision 5
PI-AA-120      Issue Identification and Screening Process                  Revision 8
PI-AA-125      Corrective Action Program (CAP) Procedure                  Revision 6
PI-AA-125-1001 Root Cause Analysis Manual                                  Revision 3
PI-AA-125-1003 Corrective Action Program Evaluation Manual                4
PI-AA-125-1006 Investigation Techniques Manual                            Revision 4
Self-Assessments AR 04047344    Perform Self-Assessment Operational Decision Making        12/07/2017
                                          (ODMs) Closed Prior Year (Last 12 Months)
AR 3950645-02  Maintenance Role In Work Management                        01/26/2017
AR 4014949    Nuclear Oversight Audit Report - Engineering Design Control 08/01/2017
AR 4030936    FIN Team Process Compliance Self-Assessment                10/12/2017
AR 4099631    Control of Quality Parts                                    02/28/2019
AR 4103467    MP Use of Work Package Quality Verification Checklist      09/12/2018
AR 4106025    2018 Clinton Clearance and Tagging Self-Assessment          01/18/2018
AR 4108988    Clinton Reactivity Management                              08/31/2018
AR 4114268    Nuclear Oversight Audit Report - Engineering Programs and  04/11/2018
Station Blackout
AR 4209487    Nuclear Oversight Audit Report - Materials Management and  02/06/2019
Procurement Engineering
NOSA-CPS-17-06 Radiation Protection Audit Report                          07/18/2017
                            (AR 4014520)
NOSA-CPS-17-08 Clinton Operations Audit                                    08/07/2017
                            (AR 04039870)
NOSA-CPS-19-02 Security Programs Audit Report                              02/20/2019
                            (AR 4209506)
Work Orders      WO 01136842-02 Replace 1SX29BB-3 Piping                                    04/14/2009
WO 01136842-07 Coat Inside of Pipe 1SX29BB                                04/13/2009
WO 01230598-02 1E12D001A, Fabricate New Orifice Plate                      09/17/2013
WO 01230598-13 1RH198BA, Coat Prefabricated Piping Spools                  04/16/2015
WO 01230598-30 1E12D001A, Fabricate New Orifice Plate                      04/20/2015
WO 01865591-01 NDE Ultrasonic Examination, 1SX29BA-3 Piping Downstream    03/24/2017
of 1SX23M Division 1 Orifice
WO 01872658-19 Install New Upper Motor Oil Cooler                          04/06/2016
Inspection Type Designation    Description or Title                                      Revision or
Procedure                                                                                Date
WO 01898016    Model Work Order, Measure Motor Amps and Coastdown        0
Time
WO 01923407-02 Replace Overload Relays                                  05/03/2016
WO 01923407-03 Operations Post Modification Test Run 1VH01CA IAW 3405.01 05/11/2016
WO 04646520    Update OPRM Setpoints Per EC 619936                      10/19/2017
WO 04680029-89 T-MOD, Install Rigid Strut on 1RT01004C                  05/01/2018
WO 04680029-90 Remove Temporary Rigid Strut / Restore Support 1RT01004C  05/12/2018
WO 04680029-97 T-MOD, Install Rigid Strut on 1RT01014C                  05/01/2018
WO 04680029-98 Remove Temporary Rigid Strut / Restore Support 1RT01014C  05/12/2018
WO 04766924    Containment 828 Personnel Airlock Interlock Failure      03/30/2018
WO 04772358    1PL12JA GGP Relay Holding Coil Potential Deficiency      05/24/2018
WO 04798571-11 Replace High Pressure Core Spray Load Driver 1H13-P663-  06/21/2018
A16-A123
WO 04798571-16 Replace High Pressure Core Spray Driver 1H13-P663-A16-    06/22/2018
A121
WO 04838315-01 Modify VC Load Shedding Wiring, 0AP05E (EC625820)        02/22/2019
WO 04838315-02 Post Modification Testing, DC Control Circuit Ground      02/23/2019
Verification, 0AP05E (EC 625820)
WO 04838315-03 Post Modification Testing, Test of 480V Bus A Sequencing, 02/23/2019
0AP05E (EC 625820)
WO 04838315-06 Operations Post Modification Testing, 0AP05E (EC 625820)  02/23/2019
WO 04846440    1WSB9A: Trend in UT Results Indicate Pipe Replacement    05/19/2019
Needed
WO 04847239-01 Modify VC Load Shedding Wiring, 0AP06E (EC 625821)        12/07/2018
WO 04847239-02 Post Modification Testing, DC Control Circuit Ground      12/08/2018
Verification, 0AP06E (EC 625821)
WO 04847239-03 Post Modification Testing, Test of 480V Bus A Sequencing, 12/08/2018
0AP06E (EC 625821)
WO 04847239-06 Operations Post Modification Testing, 0AP06E (EC 625821)  12/10/2018
WO 04864828-01 0AP117E, Inspect/Clean ERAT SVC Fans and Filter          03/26/2019
WO 04866066-01 Measure Motors Amps and Coastdown Time                    03/16/2019
18
}}
}}

Latest revision as of 11:59, 18 December 2019

Biennial Problem Identification and Resolution Inspection Report 05000461/2019010
ML19184A105
Person / Time
Site: Clinton Constellation icon.png
Issue date: 07/02/2019
From: Kenneth Riemer
Reactor Projects Branch 1
To: Bryan Hanson
Exelon Generation Co, Exelon Nuclear
References
IR 2019010
Download: ML19184A105 (21)


Text

uly 2, 2019

SUBJECT:

CLINTON POWER STATION, UNIT 1BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000461/2019010

Dear Mr. Hanson:

On May 24, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution inspection at your Clinton Power Station, Unit 1 and discussed the results of this inspection with Mr. T. Stoner and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

Finally the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

The NRC inspectors did not identify any finding or violation of more than minor significance. 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Kenneth Riemer, Chief Branch 1 Division of Reactor Projects Docket No.: 05000461 License No.: NPF-62

Enclosure:

Inspection Report 05000461/2019010

Inspection Report

Docket Number: 05000461 License Number: NPF-62 Report Number: 05000461/2019010 Enterprise Identifier: I-2019-010-0044 Licensee: Exelon Generation Company, LLC Facility: Clinton Power Station, Unit 1 Location: Clinton, IL Inspection Dates: May 06, 2019 to May 24, 2019 Inspectors: J. Bozga, Senior Reactor Inspector J. Neurauter, Senior Reactor Inspector C. Phillips, Project Engineer D. Sargis, Resident Inspector Approved By: Kenneth Riemer, Chief Branch 1 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at Clinton Power Station, Unit 1 in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations No findings were identified.

Additional Tracking Items Type Issue Number Title Report Section Status URI 05000461/2019010-01 Fuses Subject to Part 21 71152B Open Potentially Installed in Safety-Related Circuits

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

OTHER ACTIVITIES - BASELINE

71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)

The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.

  • Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems.
  • Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments.
  • Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.

INSPECTION RESULTS

Assessment 71152B Corrective Action Program Effectiveness: Based on the samples reviewed, the team determined that the licensees performance in each of these areas adequately supported nuclear safety.

Effectiveness of Problem Identification: Overall, the stations effectiveness at identifying issues at a low threshold and properly entering them into the Corrective Action Program (CAP) as required by station procedures was inconsistent. There were several items that were not identified or were not entered into the CAP when identified. For example, non-cited violation (NCV) 2018050-02 described how between May 11 and May 17, 2018, equipment operators repeatedly failed to identify that the isolation valves from the Division 2 emergency diesel generator (EDG) air start receivers to the air start motors were locked closed and failed to identify that this made the Division 2 EDG inoperable.

In addition, NCV 2018004-02 described how the station failed to recognize the conditions present for steam voiding in the B residual heat removal (RHR) shutdown cooling return line.

After the inspectors brought this to the licensee's attention, the licensee wrote Action Request (AR) 4166749, NRC Question on Potential Voiding of Piping Near 1E12F053B, in response to the inspectors questions. The station evaluated the condition in EC 625392, Evaluation of Potential Voiding of RHR [residual heat removal] B Shutdown Cooling Injection Line, and determined that a void would be present if the body-to-bonnet leak worsened or if the system depressurized as it would during shutdown and cooldown.

Also, NCV 2019011-01 described how station procedures Clinton Power Station (CPS) 4402.01 and CPS 4407.01 did not ensure the high pressure core spray system and the suppression pool would remain available for decay heat removal for the duration of a station blackout event. This was identified by an NRC engineering team and was communicated to the licensee who then had to be prompted by the NRC team on more than one occasion before it was finally entered into the CAP.

Finally, AR 4172856, NRC Observation, dated September 13, 2018, documented an NRC observation that a ladder was tied off to safety-related service water piping that was under 4 inches in diameter with no evaluation. This was not allowed without an evaluation per CPS 1019.05, Appendix C. The inspectors identified this as a concern and it took additional questions and prompting before the licensee identified this as a problem that needed to addressed through CAP. This issue was not documented in a previous NRC inspection report because it was considered a minor performance deficiency when a further evaluation determined it was acceptable to tie off the ladder to the pipe.

Effectiveness of Prioritization and Evaluation of lssues: ln-depth reviews of a risk-informed sampling of ARs, work orders (WOs), and cause evaluations were completed, including a 5-year time period for the Division 1 EDG. The team determined that the issues were generally being appropriately prioritized and evaluated for resolution. There were, however, examples of where the NRC identified flaws in the licensee's methods of evaluation. On September 13, 2018, the licensee performed a water hammer evaluation to determine whether voiding in the RHR shutdown cooling injection line would impact operability. The evaluation was documented in Engineering Change (EC) 625522, Evaluation of Water Hammer Forces From Potential Voiding in RHR Shutdown Cooling Injection Line. Based on the evaluation the licensee concluded the resulting water hammer event would be 10 pound-force (lbf), which was within the capability of the piping and support structures. Therefore, the licensee concluded there was no impact to operability, and operations removed the item from the potential limiting condition for operation list. The inspectors reviewed the calculation and identified multiple deficiencies that significantly impacted the conclusion reached by the licensee. Subsequently the licensee performed a more detailed evaluation that concluded the resulting water hammer event would be approximately 4600 lbf. Though the calculated margin from the initial evaluation was significantly reduced, the conclusion of the second evaluation was still within the capability of the system. The inspectors reviewed the updated calculation and did not identify any additional deficiencies. This performance deficiency was also described in NCV 2018004-02.

The inspectors reviewed the licensees evaluation of low pipe wall thickness readings on the A minimum flow line of the RHR system documented in AR 04133436, Low Thickness Readings Discovered On A RHR Minimum Flow Line, dated May 2, 2018. Specifically, the licensee performed EC 624133, Evaluate RHR A Minimum Flow Line Wall Thinning, Revision 1, to demonstrate operability of this piping and concluded that the piping met the design basis and American Society of Mechanical Engineers (ASME) code requirements. However, the inspectors identified that in EC 624133 the licensee calculated an average pipe section modulus around the pipe circumference at the location of low pipe wall thickness readings used to further calculate pipe stress. In addition, the inspectors did not identify specification of an average section modulus to calculate pipe stress in the ASME code. The licensee entered the concern into the CAP as AR 04250898, PI&R Inadequate Methodology in EC 624113, dated May 22, 2019, that indicated using an average section modulus to calculate pipe stress was not a methodology recognized by the ASME code. In addition, AR 04250898 documented reasonable assurance that the A minimum flow line of RHR system was operable by using pipe stress acceptance criteria in Appendix F of Section III of the ASME code in comparison to pipe stress conservatively factored to account for wall thinning. Section C.11 of NRC Inspection Manual Chapter 0326, Operability Determinations & Functionality Assessments for Conditions Adverse to Quality or Safety, issued November 20, 2017, documents the licensee may use criteria in Appendix F for piping and piping support operability determinations. This was considered a minor performance deficiency.

The inspectors reviewed the licensees evaluation associated with snubber 1RT01003S failed function test documented in AR 04011410, Mechanical Snubber 1RT01003S Failed Function Test, dated May 16, 2017. Specifically, snubber 1RT01003S failed its drag test and was found locked in the hot setting position. The licensee performed EC 619714 to evaluate the effect of this additional restraint to ensure the piping system was not overstressed. The inspectors noted that EC 619714 did not consider the effect of thermal binding during system cooldown on pipe stress and support loads as the as found snubber did not return to its cold setting. The licensee entered the concern into the CAP as AR 04251430, Failed Snubber Evaluation Inadequate, dated May 23, 2019, that documented immediate corrective action that evaluated the condition and concluded no stress limit was exceeded. Since failed snubber 1RT01003S was replaced, the inspectors also reviewed the licensees associated VT-3 visual examination reports and verified no relevant / recordable indications were identified for the restraint. This was considered a minor performance deficiency.

Effectiveness of Corrective Actions: The team concluded that the corrective actions that were implemented were neither consistently robust nor consistently completed. For example, in 2017 and early 2018 the licensee took actions to address a declining trend in human performance errors. The inspectors reviewed those corrective actions and documented the results in NRC inspection report 2018003. In May 2018 at least six separate procedure errors resulted in the Division 2 EDG remaining unavailable when it was being depended upon for plant safety. This was documented in NCV 2018050-01 which became a White finding. Predominately because of this event the inspectors found the licensees previous corrective actions regarding human performance to be ineffective. Since that event the licensee has taken more robust corrective actions in regard to human performance. There have been fewer human performance events since the implementation of these new corrective actions.

The inspectors reviewed AR 04073056, Identified USFAR [updated final safety analysis report]

Chapter 10 Discrepancies Still in USAR [updated safety analysis report], dated November 9, 2017. This AR documented that actions to prepare a change package to Chapter 10 of the UFSAR had twice been generated and twice closed out without actually being performed. The change to Chapter 10 of the UFSAR was in the review process but was not implemented as of May 9, 2019. This was considered a minor performance deficiency.

The inspectors reviewed AR 04168460, DAC [derived air concentration] Value Discrepancy Discovered in Countroom Software, dated August 30, 2018. The licensee identified that the DAC values in countroom software, used to determine if a potentially airborne work area should be posted or not, did not match the inhalation DAC table values in accordance with Title 10 of the Code of Federal Regulations (CFR), Part 20, for two radio-nuclides. The licensee performed hand calculations to verify that the room was not required to have been posted as an airborne area. A follow-up action was to go and verify that the other values in the software matched 10 CFR Part 20 values. The licensee found about 35 more radio-nuclides whose software value did not match 10 CFR Part 20 but did not go and do hand calculations for previous samples to determine if they had required posting. The licensee has since performed those hand calculations with no issues identified. Questions regarding this issue resulted in finding a similar issue in AR 02620909, 10CFR20 Inhalation DAC Value For KR-85M Found Incorrect, dated February 2, 2016. An action that came from AR 02620909 was to validate the entire library for additional errors. This was marked as complete in March 2016 but was never actually accomplished. This was documented in AR 04247547 and was considered a minor performance deficiency.

The inspectors reviewed AR 4017613, Welding Cables Through Both RT [reactor water clean up] Pump Room B Doors, dated June 2, 2017, which documented that welding cables were running through both secondary containment doors while in mode 2 ( NCV 2017003-05). The corrective actions were assignments -34 and -35 which were to complete a read and sign for all schedulers and planners on the plant barrier impairments (PBI) procedure and its interaction with the work process. The effectiveness was measured with action -42. The corrective actions (CAs) failed the first effectiveness review (EFR) as documented in AR 4062608, EFR for CAPE [corrective action program evaluation] 4017613, dated October 13, 2017. This AR documents that the EFR was done in the same month the corrective action was closed.

Therefore, the licensee should have given it more run time, and the licensee re-performed the EFR two months after the CA was closed. Action request 4073308, Effectiveness Review Results For AR 4062608, dated November 10, 2017, documented that the second EFR determined that the CA was ineffective. This time the licensee created a new CA that evaluated the PBI process and implemented actions to resolve the need for emergent PBI requests. The EFR was completed SAT for this CA. The original actions (-34 and -35) were not robust and only addressed the work planners. The later CAs took a larger view of the PBI process and addressed the issue at the shop level and maintenance planner level.

Operating Experience (OpE) and Self-Assessments and Audits: The team concluded that the licensee was generally effective in the use of OpE in the CAP, self-assessments and audits.

The team determined that when performing causal analysis and determining CAs that OpE was routinely utilized. ln addition, the team sampled OpE from NRC, industry, vendors, and third party groups and determined that for the samples selected that appropriate assessments for applicability to the licensee were performed.

Safety Conscious Work Environment: The team found evidence that the licensee's safety conscious work environment (SCWE) was appropriate. The licensee's employees appeared willing to raise nuclear safety concerns through at least one of several means available. The team observed various station meetings, including those in which new CAP items were reviewed, and interviewed a representative cross-section of station personnel, both individually and small groups. Additionally, the team assessed the overall health of the Employee Concerns Program. Specifically, the team interviewed the Employee Concerns Coordinator, reviewed recent case logs and case files and considered statement received during interviews with station personnel.

Unresolved Item Fuses Subject to Part 21 Potentially Installed in Safety- 71152B (Open) Related Circuits05000461/2019010-01

Description:

On August 23, 2018, the NRC received a 10 CFR Part 21 notification (Part 21) under LER 05000440/2018-002-00 (ML18236A294). The Part 21 report described a manufacturing defect of Gould Shawmut TR30R fuses. The Part 21 described that the fuse internals had separated from one another indicating that they were under tension. The tension was likely placed on the fuse during manufacturing when the ferrule ends of the fuse were crimped onto the fuse barrel. The Part 21 identified that the fuse had failed even though it was never exposed to an electrical current large enough to have failed the fuse.

The licensee initiated an action under AR 04061497-77, 10 CFR Part 21 Applicability Determination, dated September 25, 2018, to perform a Part 21 applicability determination for Clinton Power Station because Clinton was not specifically named in the Part 21. The licensee identified that they had purchased Gould Shawmut TR30R fuses, commercially dedicated them, and installed them in the plant. The licensee believed that the Part 21 would not affect the plant because the fuses purchased were commercially dedicated, checked for ferrule tightness, and checked for resistance. The licensee failed to generate a site specific AR with actions for supply and engineering to evaluate the impact to the station. As a result, the licensee failed to evaluate fuses installed during initial construction, failed to evaluate the impact on operability, and failed to determine if the commercial grade dedication process was adequate to identify this failure mechanism. The above failures were self-imposed standards, not regulatory requirements, and were of minor significance.

The inspectors questioned the adequacy of the licensee's determination that the Part 21 does not affect the site and identified that the licensee did not generate a site specific AR as required by their operating experience procedure. The licensee placed the issue in the corrective action program and evaluated the impact of the fuses. The licensee determined that the fuses identified in the Part 21 were from Lot number E-64. The fuses the licensee has installed in the plant were not from this lot, but the licensee did not know if the fuses originally installed in the plant were from lot E-64. The licensee identified that there were five locations in which a failure of the fuse would result in a partial loss of safety function.

This is an unresolved item. In order to resolve this issue, the inspectors need to know whether fuses from lot E-64 were installed in safety-related circuits.

Planned Closure Actions: The inspectors need to know if any of the fuses from lot E-64 are installed in safety-related circuits. The licensee plans to visually inspect each circuit that could contain the affected fuses. The inspectors will evaluate the results of the inspection and determine if a violation existed.

Licensee Actions: The licensee plans to determine if the affected lot of fuses were installed in the plant. The licensee plans to visually inspect each location that this type of fuse is installed.

If any fuses from the affected lot are identified, the licensee plans to replace those with fuses that were not from the affected lot.

Corrective Action References: AR 04250520, NRC Question: P21 Fuse, dated May 5, 2019 AR 04251536, Part 21 Assessment Results for TR30R Fuses, dated May 24,

EXIT MEETINGS AND DEBRIEFS

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

  • On May 24, 2019, the inspectors presented the biennial problem identification and resolution inspection results to Mr. T. Stoner and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71152B Calculations IP-M-0513 Division I, II and III SX Pipe Wall Thinning Analysis Including 0W

RHR Piping

Corrective Action 04034973 Oil Leak From 1SX01PA 07/24/2017

Documents AR 02385999 1DG005A Relief Valve Lifting Repeatedly 09/25/2014

AR 02490408 Reactor SCRAM from Trip of 1AP07EJ 12/09/2017

AR 02592592 1DG005A: Relief Valve Lifting Repeatedly 11/25/2015

AR 02595942 NCV 2015003-03, Failure to Obtain Lic Amend on Sec Cnmt 12/04/2015

Mod

AR 02596437 Upper Bearing Oil Cooler Leak 12/06/2015

AR 02598117 1WS01PB, WS 'B' Lower Bearing Oil Level Sightglass Full 12/09/2015

AR 02620909 10CFR20 Inhalation DAV Value for KR-85M Found Incorrect 02/02/2016

AR 02644384 OPEX Evaluation: IER L3-16-6, Control Rod Drive Vent Plug 03/23/2016

Leakage Concern

AR 02649780 RAT 4538 Failure: Numerous Unexpected Alarms 5010-1A, 04/02/2016

1C, 8A

AR 02654953 1FW01PB (TDRFP B) Vibration has Continued to Degrade 04/13/2016

AR 02667822 Unexpected Alarms 5050-1F/2F and 1VH01CA Trip 05/10/2016

AR 02675486 1WS01PB, WS Pump B Leaking from Upper Bearing 05/30/2016

AR 02704548-04 NRC Information Notice 2016-11: Potential for Material 11/14/2016

Handling Events to Cause Internal Flooding

AR 02742442 CDBI: Inappropriate Calculation Method for CR Habitability 11/17/2016

AR 03950913 WS Requires Maintenance Rule (A)(1) Evaluation 01/09/2017

AR 03962443-97 10 CFR Part 21 Applicability Determination 10/12/2017

AR 03978324 Lost 138KV Feed Causing ERAT Transient 02/24/2017

AR 04006988 OPEX Evaluation: NRC IN 2017-01, Reactor Coolant System 05/05/2017

Leakage from a Control Rod Drive Threaded Connection

AR 04007861 Entered 4008.01 and 4002.01 Due to FCV Runback 05/07/2017

AR 04009845 PSU: C1R17 MSIV LLRT [local leak rate test] Tech Spec 05/12/2017

3.6.1.3 Limit Exceeded

AR 04011410 Mechanical Snubber 1RT01003S Failed Function Test 05/16/2017

AR 04015342 NRC Identified Two Issues Regarding Snubber Testing 05/26/2017

Inspection Type Designation Description or Title Revision or

Procedure Date

AR 04016563 Automatic Reactor Scram 05/30/2017

AR 04017613 Welding Cables Through Both RT Pump Room 'B' Doors 06/02/2017

AR 04022757-02 NRC Information Notice 2017-03 Anchor Darling Double Disc 08/19/2017

Gate Valve Wedge Pin and Stem-Disc Separation Failures

AR 04044082 OPEX Review: NRC IN 2017-04, High Energy Arcing Faults in 08/21/2017

Electrical Equipment Containing Aluminum Components

AR 04049063 OPEX Evaluation: IN 2-17-05, Potential Binding of Schneider 09/05/2017

Electic/Square-D Master Pact 480-VAC Circuit Breaker Anti-

Pump Feature

AR 04052455 10 CFR Part 21 Update Regarding Grayboot Socket Contacts 09/15/2017

AR 04052639 Gothic V8.1 and V8.2 Computer Code Errors Potential Part 21 08/22/2017

AR 04054180 Follow Up on Overall Strategy for 1CC103 Leak 09/20/2017

AR 04055133 Valve 1IA128B Failed Seat Leakage Test 09/23/2017

AR 04056394 2017PIR 4410.00C001 Needs 50.59 Screening 09/27/2017

AR 04061340 Part 21 For HMA Relay Potentially Applicable 10/10/2017

AR 04061497-77 10 CFR Part 21 Applicability Determination 09/25/2018

AR 04062608 EFR for CAPE 4017613 10/13/2017

AR 04066250 OPEX Level 3 Review - NRC IN 2017-06, Battery and Battery 10/24/2017

Charger Short-Circuit Current Contributions to a Fault on the

Direct Current Distribution System

AR 04069750 BRE [bullet resistant enclosure] Energized Power Plug 11/01/2017

AR 04069935 MCR [main control room] Unexpected Alarm 5067-3F MS 11/02/2017

[main steam] Line Radiation High

AR 04071277 ERAT SVC [static variable compensator] Tripped Due to 11/05/2017

Substation Breaker Cycling

AR 04072627 Shephard Calibrator Interlocks not Functioning as Designed 11/08/2017

AR 04073308 Effectiveness Review Results for AR 4062608 11/10/2017

AR 04075431 NCV 2017007-01 Fail to Eval Defeating RCIC Interlocks/Trips 11/16/2017

AR 04075432 NCV 2017003-05 Entered Mode 2 While Secondary 11/16/2017

Containment Inop

AR 04075433 NCV 2017003-01 Condition Based Maint Approach On MSIV 11/16/2017

[main steam isolation valve] Leakage

AR 04075433 NCV 2017003-01 Condition Based Maint Approach on MSIV 11/07/2017

Leakage

Inspection Type Designation Description or Title Revision or

Procedure Date

AR 04075435 NCV 2017-003-03, Fail to Perform Engineering Evaluation for 11/16/2017

Snubber Failure

AR 04075436 NCV 2017003-04 RR Pump Runback Due to FCVs not Locked 11/16/2017

Out

AR 04075581 IP 92723 - Inadequate Extent of Condition on NCV 2016002- 11/16/2017

AR 04075779 RHR A & B Min Flow Piping Removed From C1R18 Scope 11/17/2017

AR 04080756 SEC ID-Camera 37 Loss of Coverage 12/04/2017

AR 04081583 Potential NRC SL IV Violation for Time to Boil 72.48 Screen 12/06/2017

AR 04084004 SEC ID: EVD#2 Failed Testing 12/14/2017

AR 04089480 Failure to Implement CAPR [corrective action to prevent 01/02/2018

recurrence] At First Available Opportunity

AR 04096509 RCIC PCIV 1E51-F064 Isolated During 9030.01 Surveillance 01/24/2018

AR 04099250 NRC FIN 2017012-02 Fail to Prop Classify NSR Aux 01/30/2018

Transformer

AR 04102073 10 CFR Part 21 - NRC Log 2017-55 - SOR 02/08/2018

AR 04105979 NRC NCV 2017004-02 Failure to Assess and Manage Risk 02/20/2018

AR 04105980 NRC NCV 2017004-003, Failure to Perform an Extent of 02/20/2018

Condition

AR 04105981 NRC SL IV NCV 2017004-04, URI 72.48 Time-to-Boil 02/20/2018

Calculation Closed

AR 04107258 NRC Information Notice: IN 2018-01, ISFSI Noble Gas 02/23/2018

Releases

AR 04108860-02 NRC 2018-002 Target Rock 3-Stage SRV Model 0867F 07/13/2018

Degredation

AR 04111775-05 Information Notice (IN) 2018-04: Operating Regarding Failure 06/27/2018

of Operators to Trip the Plant when Experiencing Unstable

Conditions

AR 04125651 Part 21 - Potential Failure of Reverse Power Relays 04/11/2018

AR 04128705 1VT02A Cooling Coil has Cracked Tube 04/19/2018

AR 04130828 NRC Question on Last Performance of 9861.09D006 04/25/2018

AR 04131749 NRC NCV 2018001-01 Failure to Follow Procedure Isolates 04/27/2018

RCIC

AR 04133436 Low Thickness Readings Discovered on A RHR Minimum 05/02/2018

Inspection Type Designation Description or Title Revision or

Procedure Date

Flow Line

AR 04134393 1VH01CA SX Pump Room A Area Cooler Tripped 05/04/2018

AR 04134785 Low Thickness Readings Discovered on B RHR Minimum 05/05/2018

Flow Piping

AR 04137003 Rejected Weld Indication During Radiography B RHR Piping 05/12/2018

AR 04137330 9861.02D017, Leakage Needs Evaluated, RCIC Steam Supply 05/14/2018

AR 04139396 9861.09 and Data Sheets - SX Boundary Leak Test Procedure 05/20/2018

Changes

AR 04140601 Steam Leak in 6 Pipe Elbow on 1GS15B 05/23/2018

AR 04143037 Piping Upstream of 1CC103 Still Leaking after Maintenance 05/31/2018

AR 04151429 L3 OPEX Evaluation Results - Battery Charger Fault 06/28/2018

Contribution

AR 04156632 NRC IN 2018-07: Pump/Turbine Bearing Oil Sightglass 07/18/2018

Problems

AR 04160873 RPID: TSP 2017-67 Needs to Remain in Place Permanently 08/01/2018

AR 04161074 RPID: Increased Dose Rates On WZ Piping 08/02/2108

AR 04162483 NRC NCV 2018002-02, Fail to Establish Adequate Leak Test 08/07/2018

Procedure

AR 04163523 NRC IN 2018-09: Electric Arc Flash Caused by Foreign 08/11/2018

Material Damages Fire Door

AR 04164644 UT Pipe Wall Thinning at 4 Elbow of Pipe of 1SX21AB 08/15/2018

AR 04164975 UT Indicates Pipe Wall Tinning at 24 Pipe of 1WS14A 08/16/2018

AR 04166724 Leak Identified on 1DG155 Flanged Joint 08/23/2018

AR 04166725 Leak Identified on 1DG04TA Threaded Joint 08/23/2018

AR 04166730 Packing Leak on 1DG011A 08/23/2018

AR 04166731 Two Threaded Joint Leaks Found on 1DG169 08/23/2018

AR 04168460 DAC Value Discrepancy Discovered in Countroom Software 08/30/2018

AR 04172921 UT Pipe Wall Thinning at 4 Elbow of Pipe 1SX21AA 09/13/2018

AR 04173375 UT Pipe Wall Thinning on 2-1/2 Pipe 1WSB9W 09/14/2018

AR 04177094 NRC Information Notice: IN 2018-11, Kobe Steel Quality 09/26/2018

Assurance Falsification

AR 04177203 Interruption In 138 KV Line Service to CPS ERAT [emergency 09/26/2018

reserve auxiliary transformer]

Inspection Type Designation Description or Title Revision or

Procedure Date

AR 04179395 NRC NCV 2018412-01 Fail to Search All Areas of a Vehicle 10/02/2018

AR 04180603 NRC IN 2018-03 - Failure to Meet TSs for Changing Plant 10/05/2018

Conditions

AR 04188313 Evaluate RHR A SDC Temperature Transient 10/27/2018

AR 04188538 Reactor Scram on High IRM Flux 10/28/2018

AR 04194966 Part 21 - Notification of Dry Type Transformer S/N 24-26458 11/14/2018

AR 04199126 NRC NCV 2018041-02, Fail to Establish Acceptance Criteria 11/30/2018

for Component Performance Monitoring

AR 04202559 Division 2 Diesel Generator 1DG01KC Oil Cooler Leak (Oil) 12/12/2018

AR 04203045 Improve Rounds Point for Division 3 EDG 12/14/2018

AR 04206548 Small Oil Leak on Division 3 DG AC Circ LO Pump 1DG616PA 12/29/2018

AR 04208699 Division 2 DG Governor Oil Leak 01/07/2019

AR 04208701 Division 2 DG 26 Cyl AC Circ Oil Pump Leak 01/07/2019

AR 04208708 Oil Leak from Casing of 1DG16A 01/07/2019

AR 04208712 1DG628PA Oil Leak from Fitting 01/07/2019

AR 04208720 Oil Leaking from Fitting on 1DG605PA 01/07/2019

AR 04209422 Division 1 DG 12 Cyl LO Filter Leak 01/09/2019

AR 04209427 Division 1 DG 16 Cyl Crankcase Seal Leak 01/09/2019

AR 04211426 Oil Leaking from Division 1 DG Oil Cooler Flanges 01/16/2019

AR 04212873 SEC ID: Contingency Weapon Left Unattended in the OCA 01/22/2019

[owner controlled area]

AR 04216769 1DG622PA Has Small Oil Leak 02/03/2019

AR 04218343 SEC ID: Security Fencing Needs Repair 02/08/2019

AR 04220198 NRC NCV 2018004-04 Fail Follow Proc. Resulting CRD Pump 02/14/2019

Trip

AR 04220199 NRC NCV 2018004-03, Fail to Include Acceptance Criteria for 02/14/2019

Division 3 EDG

AR 04220200 NRC NCV 2018004-02-Fail to ID a Degraded Cond. in RHR B 02/14/2019

AR 04220201 NRC NCV 2018004-01 Fail to Prevent Instal of Non-Conf. 02/14/2019

Parts

AR 04220251 NOS ID: Combustible Material Less than 3 Feet from a SWGR 02/14/2019

AR 04220260 NOS ID: Wrong PIDS Methodologies Used for Testing 02/14/2019

AR 04221273 Several Throughwall Pinhole Leaks Downstream of 1SX013D 02/18/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

AR 04225272 Request for Decon of the Spent Resin Pump Room 03/01/2019

AR 04227872 UT Pipe Wall Thinning of 3 Pipe of 1SX29BB 03/08/2019

AR 04229909 UT Indicates Pipe Wall Thinning at 8 Pipe of 1SX04AC 03/15/2019

AR 04231145 SX Piping Mitigation Strategy Review 03/20/2019

CAPE 04012075 Workers Enter Incorrect Elevation of the Drywell Bioshield 06/22/2017

CAPE 04181437 October Trip of Reserve Auxiliary Transformer (RAT) Static 12/05/2018

VAR Compensator (SVC)

CAPE 4017613 Secondary Containment ITS Violation 06/28/2017

CAPE 4096509 RCIC PCIV 1E51-F064 Isolated During 9030.01 Surveillance 02/28/2018

CAPR 03982792- Modify VC Load Shedding Wiring 0AP06E (EC 625821) 12/13/2018

CAPR 03982792- Modify VC Load Shedding Wiring 0AP05E (EC 625820) 02/26/2019

ECAP 02667822 Unexpected Alarms 5050-1F/2F and 1VH01CA Trip 06/01/2016

ECAPE 04148838 High Pressure Core Spray (HPCS) 1E22-F004 Valve Found 09/21/2018

Open

RCR 04016563 Automatic Reactor Scram 07/20/2017

RCR 04082490 Transformer Failure Results in Trip of 4160V 1A1 Breaker 10/04/2018

1AP07EJ and Loss of Power to 480V Unit Substation A

(0AP05E) and 480V Unit Substation 1A (1AP11E)

RCR 4188538 IRM Scram 12/14/2018

Corrective Action AR 04247254 NRC ID: Gaps Associated with Actions Under 4073308 05/08/2019

Documents AR 04247547 NRC ID: Ineffective Action Closure 05/08/2019

Resulting from AR 04247831 NRC PI&R RHR Area Walkdown Issues 05/09/2019

Inspection AR 04248044 PI&R Identified Min Wall Reading on 1SX21AB Below 05/10/2019

Allowable

AR 04248056 PI&R WO Acceptance Criteria Not Per Calc 05/10/2019

AR 04248079 PI&R 1SX21AB-4 Replacement Not Scheduled 05/10/2019

AR 04249310 NRC ID: Root Cause Report 401653 Process Weakness 05/15/2019

AR 04249310 NRC ID: Root Cause Report 4016563 Process Weakness 05/15/2019

AR 04249610 NRC ID: IR 4180203 Should be Sig Level 3D 05/16/2019

AR 04250520 NRC Question: P21 Fuse 05/20/2019

AR 04250898 PI&R Inadequate Methodology in EC 624113 05/22/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

AR 04251096 Tracability of Fuses Issued to Ops and IMD 05/22/2019

AR 04251113 PI&R Identified Violation Actions Inadequate 05/22/2019

AR 04251114 NRC ID: Min Wall Calcs Extent of Condition 05/22/2019

AR 04251430 Failed Snubber Evaluation Inadequate 05/23/2019

AR 04251536 Part 21 Assessment Results for TR30R Fuses 05/24/2019

Engineering EC 350224 Evaluation of Proposed Heatup/Startup of RHR in Shutdown Revision 1

Changes Cooling

EC 438722 1SX01PC Pump Acceptance Criteria, Motors Amps and 02/05/2019

Coastdown Time

EC 619936 Endorsement and Application of GE Analysis for OPRM 03/07/2018

Setpoint Change

EC 621828 Replace Springs with Temporary Struts on RT Lines in the 0

Drywell (1RT01004C and 1RT01014C)

EC 625392 Evaluation Of Potential Voiding In RHR B Shutdown Cooling Revision 0

Injection Line

Engineering EC 619714 Snubber (1RT01003S) Failure Evaluation of Snubber 0

Evaluations Inspection Program

EC 624113 Evaluate RHR A Minimum Flow Line Wall Thinning 1

Miscellaneous AR 04005206-02 RP OE: Loss of Radiation Monitoring Equipment Due to Loss 06/21/2017

of 23kV Station Service

AR 04009125-02 #407927 OE - Equipment Misoperation - Event Final Complete 06/26/2017

Last Updated: 2017-05-05 Sequoyah

AR 04111775-05 Information Notice 2018-04: Operating Regarding Failure of 06/27/2018

Operators to Trip the Plant When Experiencing Unstable

Conditions

AR 04138790 Root Cause Report for Division 2 Emergency Diesel Generator 06/26/2018

Air Receivers Found Isolated During Rounds

AR 4008122-02 Exelon Nuclear Event Report (NER) AC-17-001, Reactor 06/21/2017

Protection System B Half SCRAM (Blown Fuse Investigation)

AR 4053493-35 ICES # 431701 Indian Point Unit 3 Automatic Trip Due to A 06/13/2019

Loss of Main Generator Excitation

AR 4117076 #432283 Loss of Instrument Air Due to Dryer Valve Failure 07/16/2018

C1R17-419 VT-3 NDE Report, Component 1RT01003S 05/11/2017

C1R17-529 VT-3 NDE Report, Component 1RT01003S 05/15/2017

Inspection Type Designation Description or Title Revision or

Procedure Date

Event Number: Part 21 - Interim Notification of a Potential Defect on a Printed 06/23/2017

2736 Circuit Board

LER Part 21 - Failed Fuse Leads to Loss of Safety Function 08/23/2018

05000440/2018-

2-00

LER Trip of Emergency Reserve Auxiliary Transformer Static VAR 01/04/2018

05000461/2017- Compensator Causes Positive Secondary Containment

009-00 Pressure Following Voltage Transient on 138kV Offsite Source

LER Degraded Personnel Airlock Interlock Results in Loss of 05/29/2018

05000461/2018- Primary Containment

001-00

LER Load Driver Card Failure Resulting in High Pressure Core 06/20/2018

05000461/2018- Spray Inoperability

003-01

LER Unplanned Reactor Scram During Maintenance Outage Due to 04/24/2019

05000461/2018- High Intermediate Range Monitor Flux

005-02

M-1RT01003S Support/Hanger Drawing F

N/A 10 CFR Part 21 Curtiss-Wright Grayboot Socket Contacts 06/21/2017

NSED Review Commercial Grade Dedication Summary Revision 1

95012

Operability EC 620644 Oil Leak From Div 1 SX Motor Revision 2

Evaluations

Procedures CPS 9431.26 OPRM Channel Calibrations Revision 39c

CPS 9861.09 Shutdown Service Water Boundary Valve Leak Testing 08/29/2018

ER-AA-335-016 VT-3 Visual Examination of Component Supports, 10

Attachments, and Interiors of Reactor Vessels

ER-CL-300 Clinton Power Station Snubber Program 2

LS-AA-107 UFSAR/FPR [fire protection report] Update Procedure Revision 12

MA-CL-0001 Fuse Program Guidance Revision 3

NES-MS-03.1 Piping Minimum Wall Thickness Calculation 5

NES-MS-03.2 Evaluation of Discrepant Piping and Support Systems 7

NO-AA-10 Quality Assurance Topical Report (QATR) Revision 94

OP-AA-108-115 Operability Determinations 21

Inspection Type Designation Description or Title Revision or

Procedure Date

PI-AA-115-1003 Processing of Level 3 OPEX Evaluations Revision 5

PI-AA-120 Issue Identification and Screening Process Revision 8

PI-AA-125 Corrective Action Program (CAP) Procedure Revision 6

PI-AA-125-1001 Root Cause Analysis Manual Revision 3

PI-AA-125-1003 Corrective Action Program Evaluation Manual 4

PI-AA-125-1006 Investigation Techniques Manual Revision 4

Self-Assessments AR 04047344 Perform Self-Assessment Operational Decision Making 12/07/2017

(ODMs) Closed Prior Year (Last 12 Months)

AR 3950645-02 Maintenance Role In Work Management 01/26/2017

AR 4014949 Nuclear Oversight Audit Report - Engineering Design Control 08/01/2017

AR 4030936 FIN Team Process Compliance Self-Assessment 10/12/2017

AR 4099631 Control of Quality Parts 02/28/2019

AR 4103467 MP Use of Work Package Quality Verification Checklist 09/12/2018

AR 4106025 2018 Clinton Clearance and Tagging Self-Assessment 01/18/2018

AR 4108988 Clinton Reactivity Management 08/31/2018

AR 4114268 Nuclear Oversight Audit Report - Engineering Programs and 04/11/2018

Station Blackout

AR 4209487 Nuclear Oversight Audit Report - Materials Management and 02/06/2019

Procurement Engineering

NOSA-CPS-17-06 Radiation Protection Audit Report 07/18/2017

(AR 4014520)

NOSA-CPS-17-08 Clinton Operations Audit 08/07/2017

(AR 04039870)

NOSA-CPS-19-02 Security Programs Audit Report 02/20/2019

(AR 4209506)

Work Orders WO 01136842-02 Replace 1SX29BB-3 Piping 04/14/2009

WO 01136842-07 Coat Inside of Pipe 1SX29BB 04/13/2009

WO 01230598-02 1E12D001A, Fabricate New Orifice Plate 09/17/2013

WO 01230598-13 1RH198BA, Coat Prefabricated Piping Spools 04/16/2015

WO 01230598-30 1E12D001A, Fabricate New Orifice Plate 04/20/2015

WO 01865591-01 NDE Ultrasonic Examination, 1SX29BA-3 Piping Downstream 03/24/2017

of 1SX23M Division 1 Orifice

WO 01872658-19 Install New Upper Motor Oil Cooler 04/06/2016

Inspection Type Designation Description or Title Revision or

Procedure Date

WO 01898016 Model Work Order, Measure Motor Amps and Coastdown 0

Time

WO 01923407-02 Replace Overload Relays 05/03/2016

WO 01923407-03 Operations Post Modification Test Run 1VH01CA IAW 3405.01 05/11/2016

WO 04646520 Update OPRM Setpoints Per EC 619936 10/19/2017

WO 04680029-89 T-MOD, Install Rigid Strut on 1RT01004C 05/01/2018

WO 04680029-90 Remove Temporary Rigid Strut / Restore Support 1RT01004C 05/12/2018

WO 04680029-97 T-MOD, Install Rigid Strut on 1RT01014C 05/01/2018

WO 04680029-98 Remove Temporary Rigid Strut / Restore Support 1RT01014C 05/12/2018

WO 04766924 Containment 828 Personnel Airlock Interlock Failure 03/30/2018

WO 04772358 1PL12JA GGP Relay Holding Coil Potential Deficiency 05/24/2018

WO 04798571-11 Replace High Pressure Core Spray Load Driver 1H13-P663- 06/21/2018

A16-A123

WO 04798571-16 Replace High Pressure Core Spray Driver 1H13-P663-A16- 06/22/2018

A121

WO 04838315-01 Modify VC Load Shedding Wiring, 0AP05E (EC625820) 02/22/2019

WO 04838315-02 Post Modification Testing, DC Control Circuit Ground 02/23/2019

Verification, 0AP05E (EC 625820)

WO 04838315-03 Post Modification Testing, Test of 480V Bus A Sequencing, 02/23/2019

0AP05E (EC 625820)

WO 04838315-06 Operations Post Modification Testing, 0AP05E (EC 625820) 02/23/2019

WO 04846440 1WSB9A: Trend in UT Results Indicate Pipe Replacement 05/19/2019

Needed

WO 04847239-01 Modify VC Load Shedding Wiring, 0AP06E (EC 625821) 12/07/2018

WO 04847239-02 Post Modification Testing, DC Control Circuit Ground 12/08/2018

Verification, 0AP06E (EC 625821)

WO 04847239-03 Post Modification Testing, Test of 480V Bus A Sequencing, 12/08/2018

0AP06E (EC 625821)

WO 04847239-06 Operations Post Modification Testing, 0AP06E (EC 625821) 12/10/2018

WO 04864828-01 0AP117E, Inspect/Clean ERAT SVC Fans and Filter 03/26/2019

WO 04866066-01 Measure Motors Amps and Coastdown Time 03/16/2019

18