IR 05000456/2018010
| ML18257A024 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 09/13/2018 |
| From: | Eric Duncan Region 3 Branch 3 |
| To: | Bryan Hanson Exelon Generation Co |
| References | |
| IR 2018010 | |
| Download: ML18257A024 (12) | |
Text
UNITED STATES ber 13, 2018
SUBJECT:
BRAIDWOOD STATION, UNITS 1 AND 2NRC BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000456/2018010 AND 05000457/2018010
Dear Mr. Hanson:
On August 3, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Braidwood Station, Units 1 and 2. On that date, the NRC team discussed the results of this inspection with Ms. A. Ferko, Plant Manager, 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. However the team identified a weakness in the effectiveness of corrective actions taken to resolve problems. Specifically, several issue reports (IRs) that the team reviewed were coded as complete in the corrective action process, but remained open in other processes, or were closed to actions with informal accountability requirements.
The team also evaluated the stations processes for the 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 to be willing to raise nuclear safety concerns through at least one of the several means available.
The NRC team 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/
Eric R. Duncan, Chief Branch 3 Division of Reactor Projects Docket Nos. 50-456; 50-457 License Nos. NPF-72; NPF-77 Enclosure:
IR 05000456/2018010; 05000457/2018010 cc: Distribution via ListServ
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring licensees performance by conducting a problem identification and resolution inspection at Braidwood Station, Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors.
Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations No findings or violations were identified.
Additional Tracking Items Type Issue Number Title Report Status Section PD 05000456/2018010-001 Minor Performance Deficiency 71152 - Discussed and (PD)Operability Evaluation Corrective 05000457/2018010-001 Closed Before Completion of Actions Corrective Actions
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedure (IP) 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 team reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71152Problem Identification and Resolution
The team performed a biennial assessment of the licensees corrective action program (CAP),use of operating experience, self-assessments and audits, and safety conscious work environment. The assessment is documented below.
- (1) Corrective Action Program Effectiveness: Problem Identification, Problem Prioritization and Evaluation, and Corrective Actions (CAs) - The inspection team reviewed the stations CAP and the stations implementation of the CAP 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.
- (2) Operating Experience and Self-Assessments and Audits - The team evaluated the stations processes for the use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
- (3) Safety Conscious Work Environment - 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.
INSPECTION RESULTS
71152Problem Identification and Resolution ObservationCorrective Action Program Effectiveness 71152 Corrective Action Program: Based on the samples reviewed, the team determined that the staffs performance in each of these areas adequately supported nuclear safety. The team identified a weakness in the effectiveness of corrective actions taken to resolve problems.
Specifically, several issue reports (IRs) that the team reviewed were coded as Complete in the corrective action process, but remained open in other processes, or were closed to actions with informal accountability requirements. For example, several IRs were considered complete because a work request (WR) was generated to address the problem identified, but upon reviewing the WR the team identified that either a work order (WO) had not yet been created, or that a WO was created, but had been subsequently canceled. Although these discrepancies did not impact any safety-related equipment or adversely affect the plant, the team could not readily determine the reason for canceling these WOs absent additional inquiry. As an example of this issue, the team reviewed a number of IRs generated and addressed by the licensees Training Department. Two of these IRs were closed to actions that were not clearly explained in the corrective action closure report in the CAP. The Training Department CAP Coordinator subsequently responded to the teams questions regarding these IRs and provided an adequate basis for the actions that were taken to close the issues.
Effectiveness of Problem Identification: Overall, the station was effective at identifying issues at a low threshold and was properly entering them into the CAP as required by station procedures. The team determined that the station was generally effective at identifying negative trends that could potentially impact nuclear safety. The team walked down portions of the auxiliary feedwater system, the component cooling water system, the emergency diesel generators, the essential service water system, and the 4 kilovolt (kV) and 480 volt (V)electrical switchgear. For the areas reviewed, the team did not identify any issues in the area of problem identification.
Effectiveness of Prioritization and Evaluation of Issues: In-depth reviews of IRs, WOs, and cause evaluations were completed for a 5-year time period for the safety-related emergency diesel generators and 4 kV safety-related switchgear. The team determined that the licensee had established a low threshold for entering deficiencies into the CAP for these systems, that the issues were generally being appropriately prioritized and evaluated for resolution, and that CAs were implemented to mitigate the future risk of issues occurring that could affect overall system operability and/or reliability.
As part of the walk down and review of the essential service water system, the team reviewed CAs associated with piping degradation that was self-revealed through numerous through-wall piping leaks. The licensee had developed an essential service water piping health plan that included a prioritized list of planned inspections and piping replacements. The team concluded that the essential service water piping issues were being adequately monitored and prioritized.
Effectiveness of Corrective Actions: The team concluded that the licensee was generally effective in developing CAs that were appropriately focused to correct the identified problem and to address the root and contributing causes for significant conditions adverse to quality to preclude repetition. The licensee generally completed CAs in a timely manner and in accordance with procedural requirements commensurate with the safety significance of the issue. For NRC-identified issues, the team determined that the licensee generally assigned CAs that were effective and timely.
In one instance, however, the team identified that the procedurally required review of completed corrective actions had not been performed for a 2011 NRC-identified violation.
Specifically, as documented in AR 1254636, NRC Green Finding - Failure to Analyze Design of the AF [Auxiliary Feedwater] System, the assigned corrective action was completed in 2012; however, the effectiveness review of those actions had been extended 18 times and was still open at the end of this inspection. The team concluded that although the corrective action appeared to correct the cause of the violation, the failure to perform a timely review adversely impacted the basis for performing the effectiveness review.
The team also reviewed corrective actions associated with a non-cited violation (NCV)associated with the failure to correctly design and prevent high energy line break (HELB)secondary missiles and for the errors contained in the analysis of record for a main steam line HELB. Following that review, the team identified a performance deficiency related to the closure of the associated operability evaluation as described below.
Minor Performance DeficiencyOperability Evaluation Closed Before 71152 Completion of Corrective Actions Minor Performance Deficiency: Issues involving the Failure to Design/Prevent Secondary HELB Missiles, and Errors in Analysis of Record for MS [Main Steam] Line HELB, were documented as NCVs in NRC inspection report 05000456/2017008; 05000457/2017008. The licensee entered these issues into their CAP as AR 04075641, AR 04086419, and AR 04086455.
Operability Evaluation 17-002, Unanalyzed Consequence from a MSLB [Main Steam Line Break] Outside Containment, documented the operability of the affected components and CA 04086455-05 was created to restore compliance with the design basis as described in Section 3.6.1.2 of the Braidwood Updated Final Safety Analysis Report (UFSAR). This CA required the development of a new main steam line pressurization analysis to evaluate the pressure response assuming the removable roof slabs in the main steam line valve isolation rooms did not lift and to determine the need for physical restraints for these removable slabs.
Operability Evaluation 17-002 used engineering judgment in some cases and the licensee subsequently performed a technical evaluation to support this engineering judgment. Based on the results of this technical evaluation, the licensee closed the operability evaluation. The team determined that the licensees closure of the operability evaluation was not in accordance with Exelon procedural requirements.
Section 4.1.18 of Exelon procedure OP-AA-108-115, Operability Determinations, Revision 21, stated, in part:
When the nonconforming and/or degraded condition has been resolved by corrective action or accepted as is with a completed 10 CFR 50.59 review or operability of the SSC [structure, system, or component] is no longer supported or required, then:
APPROVE closure of the OpEval Operability Evaluation 17-002 was closed without meeting the above requirements.
Specifically, the CA for performing a main steam line pressurization re-analysis was still open, and therefore the CA had not been completed; the technical evaluation used as a basis for the closure of the operability evaluation did not include a 10 CFR 50.59 review; and the components potentially impacted by a main steam line break were still required to be operable.
Screening: Using the IMC 0612, Appendix B, More-than-Minor screening questions, the team determined that the issue was of only minor safety significance because the existing technical evaluations demonstrated operability. Additionally, CA 04086455-05 to perform a re-analysis to restore conformance with the design basis remained open. The licensee subsequently entered this issue into their CAP as AR 04161329 - PI&R Procedure Adherence With Op Eval 17-002 Closure.
Operating Experience and Self-Assessments and Audits Observation 71152 Operating Experience and Self-Assessments and Audits: Based on the samples reviewed, the team determined that the stations performance in each of these areas adequately supported nuclear safety. In particular, the team concluded, overall, that operating experience was adequately evaluated for applicability and that appropriate actions were implemented to address lessons learned, as needed. In general, the team determined that the licensee was effective at performing self-assessments and audits to identify issues at a low level, properly evaluated those issues, and resolved them commensurate with their safety significance. The team also noted that in some cases the self-assessments performed focused on procedural compliance rather than the overall effectiveness of the program; however, this did not result in any actual equipment or operational issues.
Safety Conscious Work Environment Observation 71152 Safety Conscious Work Environment: The team found no evidence of challenges to the organizations safety conscious work environment. Employees appeared willing to raise nuclear safety concerns through at least one of the several means available. The team observed various morning planning meetings, meetings to review new IRs, and interviewed station personnel both individually and in focus groups. Additionally, the team interviewed the Employee Concerns Coordinator and reviewed recent case logs and case files.
EXIT MEETINGS AND DEBRIEFS
The team confirmed that proprietary information was controlled to protect it from public disclosure. No proprietary information is documented in this report.
On August 3, 2018, the team presented the biennial problem identification and resolution inspection results to Ms. A. Ferko, Braidwood Plant Manager, and other members of the licensee staff.
DOCUMENTS REVIEWED
71152Problem Identification and Resolution
Action Request (AR) 4010851; Trend in Processing of PM Changes; 05/15/2017
AR 2615400; Inadequate Test Methodology for AF PP Suction Press Loops; 01/21/2016
AR 2705092; NES-MS-04.1; Inadequate Change Management Resulted in Scaffolds Built
Without the Required Engineering Evaluation; 09/22/2016
AR 2686762; OPEX Review NRC IN 2016-08; 09/15/2016
AR 4063858; Radwaste Self-Assessment; 10/17/2017
AR 4077797; SA NRC 71124.01 Occupational ALARA Planning and Controls; 11/28/2017
AR 2612914; Unexpected Indication During 2PSL-AF051 Functionality; 01/15/2016
AR 2703967; Scaffold Build Deficiencies; 08/13/2016
AR 2705092; CB&I NCS MS-04.1 Rev. 1 Knowledge Gap ID; 08/16/2016
AR 2734948; Maintenance Response to NRC IN 2016-08 Gap; 10/31/2016
WC-AA-106; Work Screening and Processing; Revision 18
MA-AA-796-024; Scaffold Installation, Inspection, and Removal; Revision 11
NOSA-BRW-18-01, Maintenance Functional Area Audit Report; 03/08/2018
NOSA-BRW-17-06; Radiation Protection Audit Report; 08/02/2017
NOSA-BRW-17-04; CAP Audit Report; 03/29/2017
NOVA-17-002; Fleet Evaluation of Exelon Midwest; June 5-9, 2017
AR 02722783; Root Cause Investigation-Level 2 Clearance and Tagging Event; 10/01/2016
AR 04132973; CAPE Report; Adverse Trend in Clearance and Tagging Event; 05/01/2018
AR 04038298; Trend in Latent Issues Due to Gap in Historical Reviews; 08/02/2017
AR 03953846; Self-Assessment - SX Piping Health Plan Check-In; 04/14/2017
AR 03963996; Self-Assessment - Configuration Control; 09/17/2017
AR 02589930; Heavy General Corrosion on 0SXH2AA 6 in 0SX165A Pit; 11/19/2015
AR 04001297; OSP-A 2B AF Pump SX Return Piping Leak; 04/22/2017
AR 02689352; Trending - Operations IR Generation and Documentation; 07/05/2016
AR 02688291; Trend - Engineering 2Q2016 Performance; 07/01/2016
NOSA-BRW-18-05, Engineering Programs and Station Blackout Audit Report; 05/16/2018
NOSA-BRW-17-08, Operations Functional Area Audit Report; 09/15/2017
Engineering Change (EC) 622424; Impact of a Main Steam Line Break on the Removable
Roof Slab on the MSIV Rooms; Revision 0
EC 623380; Impact of Removable Slabs Falling on the MSSV Roof; Revision 0
EC 619274; Operability Evaluation 17-001 - Pin Hole Leak in 2SXA9A-6; 04/25/2017
SX Piping Health Plan Update; 07/31/2017
Issue Report (IR) 989516; Potential Non-Conservative DO Tech Spec 3.8.3; 11/05/2009
IR 1120846; 4.0 Crew Critique Unit 1 Reactor Trip; 10/01/2010
IR 1169814; Hand Calorimetric Procedure 1/2 BwOSR 3.3.1.2-2 Enhancement; 02/01/2011
IR 1192980; NER 11-009 - Deficiency/Enhancement; 1/2SX169A/B Direction; 03/27/2011
IR 1295320; Rod Drive Surveillance Enhancement; 11/29/2011
IR 1318823; Create Procedural Guidance for TRM 3.3.E Required Action; 01/27/2012
IR 1399005; Possible Condenser Vacuum Leak Issue; 09/09/2012
IR 1532547; 8-Fold Predicted Criticality Outside of Administrative Band; 07/04/2013
IR 1559075; A1R17LL Need WO Scope Enhanced for MSR RV Drain Lines; 09/16/2013
IR 2438001; Action Plan to Extend Main Turbine RV/IV Test Frequency; 01/15/2015
IR 2437854; Remove Valve Actuator Box Cover for Inspection - 1MS5004A; 01/15/2015
IR 2437856; Remove Valve Actuator Box Cover for Inspection - 2MS5004C; 01/15/2015
IR 2501820; Through Wall Leak Downstream of 1SX007; 05/17/2015
IR 2512997; EOC Examination from Leak on 1SX03A of 2SX03A; 06/10/2015
IR 2512999; EOC Examination from Leak on 1SX03A of 0SX03A; 06/10/2015
IR 3949609; (A)(1) Determination Required for AP-04 (AP4); 12/05/2016
IR 4042901; Abnormalities Observed with Unit 1 Main Generator; 08/17/2017
IR 4141635; RW-11 Piping Separation; 05/27/2018
Work Order (WO) 1847075; EOC Examination from Leak on 1SX03A of 2SX03A; 02/24/2017
WO 1847077; EOC Examination from Leak on 1SX03A of 0SX03A; 02/01/2018
WO 1891809; EOC Examination from Leak on 1SX03A of 0SX03A; 03/16/2018
IR 4068617; 2017 Equipment Reliability Evaluation; 10/30/2017
IR 4087455; UAT 141-2 Low Oil Level Alarm Received; 12/27/2017
IR 4103318; Braidwood EP Pre-Exercise - Failed Facility Objective B.6; 02/12/2018
IR 4116653; Issues Identified During VS/VC Crosstie Walkdown; 03/19/2018
IR 4125225; Oil Viscosity Low on 0DG01K; 04/10/2018
IR 2712545; EP - Early Siren Activation; 09/06/2016
IR 3999431; Conditional Release of Tube Bundle for 2TO01AB; 04/18/2017
IR 4120720; CO2 Injection Fails One Pump Mod Test; 03/29/2018
IR 4134012; Excavation Required for U1 and U2 CO2 Injection at LSH; 05/03/2018
IR 2672653; Trng: Trend Identified with ILT SRO-I Losses; 05/23/2016
IR 2691920; Trng: Performance EP Failure (DEP); 07/12/2016
IR 2710825; 7300 N-1 Mod Radio Interference Potential; 08/31/2016
IR 4078828; Ovations Upgrade Adverse Results in Simulator ANSI Test; 11/29/2017
IR 4149494; NOS ID Invalid Authentication of Training Record; 06/22/2018
EC 622424; Technical Evaluation for MSSV House Removable Roof
Slab Lift; 04/20/2018
IR 4075641; Green NCV - Potential Green NCVs from the NRC 2.206 Petition Inspection;
11/16/2017
IR 4086452; Green NCV - Untimely Corrective Action for Secondary Missiles; 12/21/2017
IR 2506005; Documentation of EDG Exhaust Pipe Minimum Wall; 05/27/2015
IR 2519208; 2A DOST Tank Valve 2DO001A Leakage Impacts 2B EDG; 06/24/2015
IR 2635537; Need WO for Additional UT of DG Exhaust Stack; 03/03/2016
IR 3982772; Documentation of 2A EDG Exhaust Stack UT; 03/07/2017
IR 4128714; OSP-A Loss of ESF Bus 141 During 1A EDG Sequencer Testing; 04/19/2018
IR 4129712; OSP-A 1A DG Secured During 1BwOSR 3.8.1.19-1; 04/22/2018
BwHS 4002-072; Cleaning and Inspection of Electrical Equipment, Revision 11
BwMP 3100-02; Diesel Generator 2 Year Inspection, Revision 36
MA-BR-773-300; Diesel Generators Relay Routine, Revision 7
MA-BR-EM-4-09070; Diesel Generator Electrical Inspection, Revision 16
AR 04052607; 0LI-CF071 Screen Display Is Black; 09/15/2017
AR 02674553; 2016 REMP Broad Leaf Vegetation Open Issue; 05/26/2016
AR 04072014; LEVEL 3 OPEX Review Required; 11/07/2017
AR 02614924; Missed REMP Samples 3rd and 4th Quarter 2015; 01/20/2016
RCR 4020644; Water Containing Tritium Pumped to Ground; Revision 5
CAPE 4010851; Trend in Processing of PM Changes; 06/12/2017
NOSA-BRW-16-02; Security Programs Audit Report; 02/03/2016
NOSA-BRW-16-04; Chemistry, Radwaste, Effluent and Environmental Monitoring Audit
Report; 07/13/2016
NOSA-BRW-17-02; Security Programs Audit Report; 02/01/2017
AR 4074980; Chemical Control Program Assessment; 04/02/2018
AR 3985485; Pre-NRC Self-Assessment: Protective Strategy Evaluation; 06/16/2017
AR 2727290; Pre-NRC Inspection 71130.02, 71130.08, & 71151; 01/04/2017
EFR 04013337-40; Elevated Steam Generator Blowdown Impurities; 07/05/2018
AR 04002540; NRC ID: Broadleaf Vegetation Not Sampled in 2015; 04/25/2017
AR 03968800; Perform Formal Level 3 OPEX Review Per PI-AA-115-1003; 01/31/2017
AR 02707258; Request Level 3 OPEX Review of ICES 323780; 08/22/2016
AR 04104083; ENV-ID CHEM Control Blitz Results for Cabinet MS-003; 02/14/2018
AR 04028449; Trend on Unit 1 SGBD Sodium and Chloride; 06/30/2017
AR 02702875; Security - Turnover Trend; 08/10/2016
AR 03962969; Chemistry HU/THU OBE Results; 01/13/2017
AR 04022573; Security: Equipment Trend on SD 504 (S&L 434); 06/16/2017
AR 04010851; Trend in Processing of PM Changes; 05/15/2017
AR 04020644; H3 Water Being Pumped onto Surrounding Ground; 06/08/2017
AR 04025024; NER NC-17-015-R, Water Containing Tritium Pumped to Ground; 06/23/2017
BwOP WX-902; Use of Portable Sump Pumps for Non-Installed Sump Pump Application;
Revision 1
BwOP WX-900; Use Of Portable Sump Pumps Within Station Sumps; Revision 12
Logs; ECP; 2016; 12/31/2016
Logs, ECP; 2017; 12/31/2017
Logs; ECP; 2018; 08/01/2018
ECP File; Case File 2017-001; 2017
ECP File; Case File 2017 C-13; 2017
Survey; Organization Effectiveness Survey; 08/31/2017
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