IR 05000461/2020004

Integrated Inspection Report 05000461/2020004; 07201046/2020001

ML21040A365
Person / Time
Site:	Clinton
Issue date:	02/09/2021
From:	Kenneth Riemer NRC/RGN-III/DRP/B1
To:	Rhoades D Exelon Generation Co, Exelon Nuclear Generation Corp
References
IR 2020001
Download: ML21040A365 (21)

Text

February 9, 2021

SUBJECT:

CLINTON POWER STATION - INTEGRATED INSPECTION REPORT 05000461/2020004; 07201046/2020001

Dear Mr. Rhoades:

On December 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Clinton Power Station. On January 14, 2021, the NRC inspectors discussed the results of this inspection with Mr. T. Chalmers, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding did not involve a violation of NRC requirements.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Clinton Power Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Kenneth R. Riemer, Chief Branch 1 Division of Reactor Projects Docket Nos. 05000461, 07201046 License No. NPF-62

Enclosure:

As stated

Inspection Report

Docket Number: 05000461; 07201046 License Number: NPF-62 Report Number: 05000461/2020004; 07201046/2020001 Enterprise Identifier: I-2020-004-0059 Licensee: Exelon Generation Company, LLC Facility: Clinton Power Station Location: Clinton, IL Inspection Dates: October 1, 2020 to December 31, 2020 Inspectors: J. Beavers, Senior Resident Inspector J. Dalzell, Reactor Inspector N. Fields, Reactor Operations Engineer M. Garza, Emergency Preparedness Inspector G. Hansen, Sr. Emergency Preparedness Inspector C. Mathews, Illinois Emergency Management Agency D. Sargis, Resident Inspector Approved By: Kenneth R. Riemer, Chief Branch 1 Division of Reactor Projects Enclosure

SUMMARY

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

List of Findings and Violations

Failure to Determine Extent of Cause Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.12] - Avoid 71152 Systems FIN 05000461/2020004-01 Complacency Open/Closed The inspectors identified a Green finding when the licensee failed to determine the extent of cause for a root cause in accordance with PI-AA-125-1001, "Root Cause Analysis Manual," Revision 6. Specifically, the licensee failed to identify that lack of technical rigor in the station's FLEX modification caused the FLEX output breaker settings to have been left at factory settings without an analysis.

Additional Tracking Items

None.

PLANT STATUS

Unit 1 operated at or near rated thermal power for the entire inspection period.

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.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the Coronavirus Disease 2019 (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week; conducted plant status activities as described in IMC 2515, Appendix D, Plant Status; observed risk-significant activities; and completed on-site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on-site. The inspections documented below met the objectives and requirements for completion of the IP.

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures for the following systems:

lake/river screen house, fire pump house, and FLEX equipment storage buildings

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (6 Samples)

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

(1) reactor core isolation cooling system on October 8, 2020

(2) Division 3 emergency diesel generator on November 23, 2020

(3) 'B' control room ventilation train on November 23, 2020

(4) 'C' residual heat removal train on November 24, 2020

(5) 'A' feed water train on November 24, 2020

(6) safety direct current power system on December 2, 2020

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Fire Zone A-1b, auxiliary building general access area, elevation 737' on October 6, 2020

(2) Fire Zone A-1a, auxiliary building general access area, elevation 707' on October 6, 2020

(3) Fire Zone D-12, diesel generator building Division 1 diesel generator and day tank room, elevation 712' on November 20, 2020

(4) Fire Zone D-5(a,b), diesel generator building Division 1 diesel fuel tank room, elevation 737' on November 20, 2020

(5) Fire Zone M-1, screen house Division 1 shutdown service water pump room and Fire Zone M-2(a,b), elevation 699'; Divisions 2 & 3 shutdown service water pump room, elevation 699' on November 20, 2020

(6) Fire Zone M-3, screen house 'B' fire pump room and Fire Zone M-4, elevation 699';

screen house 'A' fire pump room, elevation 699' on November 20, 2020

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

(1) The inspectors evaluated the onsite fire brigade training and performance during an unannounced fire drill on November 20, 2020.

71111.07A - Heat Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) Division 4 inverter room cooler 1VX014AA

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

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

(1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam administered between October 22 and November 20, 2020.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the control room during power restoration from 90 percent to full power, completion of 24-hour Division 1 emergency diesel generator run, and subsequent fast start of Division 1 emergency diesel generator on November 20, 2020.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated annual dynamic simulator testing on November 18, 2020.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples)

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

(1) condensate polishing system

(2) nuclear system protection system self-testing

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (1 Sample)

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

(1) planned Yellow risk while switching Division 2 battery to swing battery charger, Work Order 4801239

71111.15 - Operability Determinations and Functionality Assessments

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

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Action Request 4373461, "RCIC [reactor core isolation cooling] Pump Oil Cooler Issue"

(2) Action Request 4376204, "ERAT [emergency reserve auxiliary transformer] Static Var Compensator Thyristor Monitor"

(3) Action Request 4375036, "Received Unexpected Annunciator 5006-2L, LPRM [local power range monitor] Upscale Alarm"

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

(1 Sample)

The inspectors evaluated the following temporary or permanent modifications:

(1) revision to secondary containment tornado design criteria

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)

The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:

(1) Work Order 1849500, "Stroke of 1SX041A and 1SX041B after Replacement of Instrument Air Regulator"

(2) Work Order 4776173, "High Pressure Core Spray Pump Run after System Outage Window"

(3) Work Order 5058517, "Reactor Core Isolation Cooling Comprehensive Test after System Outage Window"

(4) Work Order 5088240, "1VF07Y Failed to Open During VG [standby gas treatment]

'A' Shutdown and VF [fuel building ventilation] Startup"

(5) Work Order 5099146, "Signs of Component Failure 0AP25E-4B (0VC24YB Damper Bucket) after Rebuild"

(6) Work Order 5099742, "'B' Reactor Recirculating Pump Flow Control Valve"

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) Work Order 4918018, "Reactor Core Isolation Cooling Remote Shutdown Operability Checks"

(2) Work Order 4820186, "9080.13 Emergency Diesel Generator 1A 24-Hour Run and Hot Restart"

(3) Work Order 5093459, "9071.01 Fire Pump 'B' Operability Run"

(4) Work Order 5048393, "9030.01C06 1B21-N692ABEF Reactor Water Low Level 2 Channel Functional"

71114.02 - Alert and Notification System Testing

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

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

• annual siren inspection and maintenance records for the period from September 2018 to September 2020

• monthly alert notification system (siren) tests for the period from September 2018 to September 2020

71114.03 - Emergency Response Organization Staffing and Augmentation System

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

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

71114.04 - Emergency Action Level and Emergency Plan Changes

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

(1) The inspectors completed an evaluation of submitted emergency action level and emergency plan changes on December 2, 2020. This evaluation does not constitute NRC approval.

71114.05 - Maintenance of Emergency Preparedness

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

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

OTHER ACTIVITIES - BASELINE

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

EP01: Drill/Exercise Performance (IP Section 02.12) ===

(1) 01/01/2019 - 06/30/2020

EP02: ERO Drill Participation (IP Section 02.13) (1 Sample)

(1) 01/01/2019 - 06/30/2020

EP03: Alert & Notification System Reliability (IP Section 02.14) (1 Sample)

(1) 01/01/2019 - 06/30/2020

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) FLEX diesel generator breaker set to factory settings

(2) unplanned reactivity events during

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

60855.1 - Operation of an Independent Spent Fuel Storage Installation at Operating Plants Operation of an Independent Spent Fuel Storage Installation at Operating Plants

(1) The inspectors evaluated the licensees activities related to the long-term operation and monitoring of its independent spent fuel storage installation (ISFSI). The inspectors reviewed relevant documentation and interviewed personnel remotely during the week of November 16, 2020. The inspector performed an onsite walkdown of the ISFSI pad and haul path and evaluated the material condition of the ISFSI pad and HI-STORM FW casks on November 16, 2020. The inspector utilized licensee personnel and radiological instrumentation to verify that radiological conditions on the ISFSI pad were as expected during the walkdown.

The inspectors evaluated the following change reviews:

• changes to the licensee's 10 CFR 72.212 report performed since October 1, 2018

• 10 CFR 72.48 screenings and a 10 CFR 72.48 evaluation performed since October 1, 2018

• procedural changes primarily stemming from lessons learned or operating experience since the licensee's previous loading campaign

INSPECTION RESULTS

Failure to Determine Extent of Cause Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.12] - Avoid 71152 Systems FIN 05000461/2020004-01 Complacency Open/Closed The inspectors identified a Green finding when the licensee failed to determine the extent of cause for a root cause in accordance with PI-AA-125-1001, "Root Cause Analysis Manual,"

Revision 6. Specifically, the licensee failed to identify that lack of technical rigor in the station's FLEX modification caused the FLEX output breaker settings to have been left at factory settings without an analysis.

Description:

On June 26, 2020, the licensee wrote Action Request 4352937 documenting that the FLEX diesel generator output breakers did not have an engineering analysis to determine the correct breaker settings. Both FLEX diesel generator output breakers were still set to the factory default settings. Upon discovery of the condition, it was uncertain if the FLEX diesel generators would have been able to supply power without tripping the output breaker. The licensee evaluated the condition and determined that the breaker would not trip if it were supplying power and that there was less margin in the calculation than would normally be acceptable. The licensee adjusted the breaker settings to provide a more acceptable margin.

The licensee performed a corrective action program evaluation for the condition and identified that the breaker settings were not discussed in Engineering Change 392335, which installed the breakers. The licensee determined that the cause was less than adequate technical rigor by the engineer responsible for the FLEX modification. The inspectors noted that this cause was nearly identical to the cause identified in Root Cause Report 4297570 for the FLEX diesel generator 1FX01KA being wired with its phase rotation out of phase from the plant equipment phase rotation. The phase rotation issue was previously identified as a Green finding identified in NRC integrated inspection report 05000461/2020001 as FIN 05000461/2020001-01 "FLEX Diesel Generator Phase Rotation Incorrect."

The inspectors reviewed Root Cause Report 4297570 to determine the similarities between the FLEX diesel generator phase rotation issue and the output breaker settings issue. The root cause identified was that engineers did not apply technical human performance fundamentals during selection of post-modification testing for the FLEX modification. The licensee conducted an extent-of-cause review for the root cause in accordance with PI-AA-125-1001, "Root Cause Analysis Manual," Revision 6. The extent-of-cause review evaluated all modifications that were completed by the responsible engineers to verify that post-modification testing was correct. The extent-of-cause did not review the modifications to verify overall adequacy or that the appropriate engineering rigor was applied to areas outside of post-modification testing.

Exelon procedure PI-AA-125-1006, "Investigation Techniques Manual," Revision 5, includes considerations for performing an extent-of-cause review. The manual stresses the importance of identifying how a cause could affect programs or processes other than the one that was already identified. When the licensee focused their extent-of-cause review on the adequacy of post-modification testing, they did not consider how the cause could affect other processes or programs that could have been affected by lack of technical rigor in implementing the FLEX modification. Specifically, the review did not identify that Engineering Change 392335 did not provide any analysis of the FLEX breakers; therefore, the breakers did not have any discussion for post-modification testing.

Corrective Actions: The licensee determined correct breaker settings and performed the change to support breaker functionality.

Corrective Action References: Action Request 4352937, "FLEX Diesel Generator Breaker Settings"

Performance Assessment:

Performance Deficiency: The licensee failed to determine the extent of cause for a root cause as required by PI-AA-125-1001. This led to the licensee failing to identify that the FLEX diesel generator output breaker settings were not evaluated and were set to factory default settings instead of site-specific settings.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, there was reasonable doubt as to the functionality of the FLEX generator output breakers until a detailed analysis was performed, and following the analysis, the licensee determined that the settings should be revised. This was similar to example 3.a in Inspection Manual Chapter 0612, Appendix E, "Examples of Minor Issues."

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors used Exhibit 2, "Mitigating Systems Screening Questions," Section E "Flexible Coping Strategies (FLEX)," and answered "No" to all questions. Therefore, the finding screens to Green or very low safety significance.

Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Specifically, when the licensee attempted to identify the extent of cause for the FLEX diesel generator phase rotation issue; they only focused on post-modification testing and did not attempt to identify other areas where lack of technical rigor could have impacted the FLEX implementation.

Enforcement:

Inspectors did not identify a violation of regulatory requirements associated with this finding.

Observation: Unplanned Reactivity Events in 2020 71152 The inspectors observations and assessments of trends related to several unplanned power changes over 2020 indicated an inconsistent range of response in assessment as well as communication with the support organizations and management. The inspectors determined that the lack of an off normal procedure to address unplanned power changes impacted the consistent application of process in both response and communication. All minor issues with each event were individually addressed in the quarter in which they occurred during the quarterly exits. The station did take note of the inspectors observations regarding the response to these events and is developing an off normal response procedure for unplanned power changes. The procedure is slated for completion by the first half of

EXIT MEETINGS AND DEBRIEFS

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

• On January 14, 2021, the inspectors presented the integrated inspection results to Mr. T. Chalmers, Site Vice President, and other members of the licensee staff.

• On October 15, 2020, the inspectors presented the emergency preparedness baseline inspection results to Mr. J. Kowalski, Plant Manager, and other members of the licensee staff.

• On November 20, 2020, the inspectors presented the independent spent fuel storage installation (ISFSI) program review inspection results to Mr. T. Chalmers, Site Vice President, and other members of the licensee staff.

• On December 2, 2020, the inspectors presented the IP 71114.04 exit meeting inspection results to Mr. D. Moore, Senior Manager - Emergency Preparedness, and other members of the licensee staff.

• On December 14, 2020, the inspectors presented the annual licensed operator requalification examination inspection results to Mr. R. Tyler, Licensed Operator Lead Instructor, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

60855.1 Corrective Action Selected Corrective Action Documents Created Since

Documents October 2018

AR 4236199 60-Day Reporting Period for ISFSI ARERR Not Met 04/04/2019

AR 4355273 Unexpected Water Flowing Out of the MPC Drain Port 07/07/2020

AR 4364058 Forced Helium Drying Skid Issue: Braidwood 09/18/2020

Corrective Action AR 4385229 Errors in Survey Calculations 11/18/2020

Documents AR 4385391 Spalling on South West Edge of ISFSI Pad 11/19/2020

Resulting from

Inspection

Engineering ECO 5018-65 Holtec Engineering Change Order 0

Changes ISFSI 72.212-CR- 72.212 Evaluation Report Change Requests 0

2018-001, ISFSI

2.212-CR-2018-

2, ISFSI 72.212-

CR-2018-003, ISFSI

2.212-CR-2018-

004, ISFSI 72.212-

CR-2019-001

Miscellaneous Clinton Power Station Unit 1 10 CFR 72.212 Evaluation 2

Report for the HI-STORM FW MPC Storage System

Docket 72-1046

2018 Annual Radiological Environmental Operating 04/25/2019

Report Clinton Power Station - Docket Number 50-461

2019 Annual Radiological Environmental Operating 04/28/2020

Report Clinton Power Station - Docket Number 50-461

2.48 Holtec 10 CFR 72.48 Screening/Evaluation for ECO 0, 1

Screening/Evaluation 5018-65

209

2.48-CL-2018-S- 10 CFR 72.48 Screenings and Evaluations October

2, 72.48-CL-2018- 2018 to

S-023, 72.48-CL- October

2018-S-024, 72.48- 2020

Inspection Type Designation Description or Title Revision or

Procedure Date

CL-2018-E-024,

2.48-CL-2018-S-

25, 72.48-CL-2018-

S-026, 72.48-CL-

2019-S-001, 72.48-

CL-2020-S-001

EP-AA-1003, Emergency Action Levels for Clinton Station 5

Addendum 3

NO-AA-10 Quality Assurance Topical Report 95

U-604484 Clinton Power Station, October 1, 2016 to September 30, 04/24/2019

2017, Independent Spent Fuel Storage Installation Annual

Radioactive Effluent Release Report

U-604485 Clinton Power Station, October 1, 2017 to 04/25/2019

September 30, 2018, Independent Spent Fuel Storage

Installation Annual Radioactive Effluent Release Report

U-604577 Clinton Power Station, October 01, 2018 to September 11/13/2020

30, 2019, Independent Spent Fuel Storage Installation

Annual Radioactive Effluent Release Report

U-604578 Clinton Power Station, October 01, 2019 to September 11/13/2020

30, 2020, Independent Spent Fuel Storage Installation

Annual Radioactive Effluent Release Report

Procedures CPS 1019.05 Transient Equipment/Materials 25

CPS 1860.01C001 Operations Department Cold Weather Preparations 9b

Checklist

CPS 1893.04M913 Independent Spent Fuel Storage Facility Installation 0a

(ISFSFI) Prefire Plan

CPS 9000.01D001 Control Room Surveillance Log - Mode 1, 2, 3 Data Sheet 58d

CPS 9000.01D002 Control Room Surveillance Log - Mode 4, 5 Data Sheet 39

CY-AA-170-1001 Environmental Dosimetry - Performance Specifications, 1

Testing, and Data Analysis

ER-AA-450 Structures Monitoring 9

HPP-2226-200 MPC Loading at Clinton 10

HPP-2226-400 MPC Transfer at Clinton 8

HPP-2226-500 HI-STORM Movements 8

Inspection Type Designation Description or Title Revision or

Procedure Date

HPP-2226-600 MPC Unloading at Clinton 1

HPP-2226-700 Responding to Abnormal Conditions 4

OP-AA-108-111- Severe Weather and Natural Disaster Guidelines 22

1001

OU-AA-3005 Conduct of Outage Services Manual T&RM 19

OU-AA-630-1000 Spent Fuel Loading Campaign Management 10

OU-AA-630-101 Dry Cask Storage/ISFSI Inspection Surveillance Program 2

OU-CL-800-81 DCS Campaign Preparations and Restoration 3

OU-CL-800-83 Spent Fuel Cask Contingency Actions 2

RP-AA-305 Holtec HI-TRAC Radiation Survey 5

RP-AA-306 Holtec HI-STORM Radiation Survey 2

RP-AA-307 Holtec Independent Spent Fuel Storage Installation 2

(ISFSI) Radiation Survey

RP-AA-401-1006 Controls for Independent Spent Fuel Storage (ISFSI) 2

Associated Activities

Radiation 2019-046314 Outside Areas - ISFSI Pad Grid Survey 06/15/2019

Surveys (per RP-CL-300-1004 - Sections 5.1-5.3)

2019-046316 Outside Areas - ISFSI Pad Protected Area Fence Survey 06/15/2019

(per RP-CL-300-1004 - Section 5.4)

20-072193 Outside Areas - ISFSI Pad 05/04/2020

20-080757 Outside Areas - ISFSI Pad Grid Survey 09/26/2020

(per RP-CL-300-1004 - Sections 5.1-5.3)

20-080759 Outside Areas - ISFSI Pad Protected Area Fence Survey 09/26/2020

(per RP-CL-300-1004 - Section 5.4)

Self- AR 429608-02 Clinton Spent Fuel Loading Readiness Assessment 07/29/2020

Assessments NOSA-CPS-18-10 Independent Spent Fuel Storage Installation Audit Report: 11/14/2018

(AR 4177215) Clinton Power Station

NOSA-CPS-20-10 Independent Spent Fuel Storage Installation Audit Report 10/02/2020

Work Orders WO 4817969-01 ISFSI - DCS Eng Perform Annual Insp of ISFSI per 08/14/2019

OU-CL-630-100

WO 4978935-01 OP 9000.01 Control Room Surv Log for Mode 1/2/3, 11/17/2019

D001-Weekly

WO 5013563-01 OP 9000.01 Control Room Surv Log for Mode 1/2/3, 03/08/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

D001-Weekly

WO 5033760-01 ISFSI - DCS Eng Perform Annual Insp of ISFSI per 08/12/2020

OU-CL-630-100

71111.01 Procedures WC-AA-107 Seasonal Readiness 22

71111.04 Drawings M05-1004, Sheet 1 P&ID Reactor Feedwater (FW) AH

Procedures CPS 3310.01V001 Reactor Core Isolation Cooling Valve Lineup 13

CPS 3312.01V001 Residual Heat Removal Valve Lineup 17c

CPS 3402.01E001 Control Room HVAC Electrical Lineup 10e

CPS 3506.01C003 Diesel Generator 1C Pre-Start Checklist 6e

71111.05 Fire Plans CPS 1893.04M100 707 Auxiliary Building General Access Area Prefire Plan 5a

CPS 1893.04M110 737 Auxiliary Building General Access Area Prefire Plan 6b

Procedures CPS 1893.04M511 737 Diesel Generator Building Div 1 Diesel Generator & 6c

Day Tank Room

CPS 1893.04M800 699 Screen House Div 1 SX Pump Room Prefire Plan 5a

CPS 1893.04M801 699 Screen House Div 2&3 SX Pump Rooms and Tunnel 6a

Prefire Plan

CPS 1893.04M802 699 Screen House 'B' Fire Pump Room Prefire Plan 6a

CPS 1893.04M803 699 Screen House 'A' Fire Pump Room Prefire Plan 6a

71111.07A Work Orders WO 4789401 Inspect, Boroscope, Clean, Eddy Current, and Hydrolase 05/12/2020

as Required

71111.11A Procedures TQ-AA-150-F25 Clinton 2020 LORT Annual Exam Status Report 12/07/2020

71111.11Q Miscellaneous ESG-LOR-10 Clinton Power Station Licensed Operator Training 01

Simulator Exercise Guide

71111.13 Work Orders WO 4801239 OP Cross-Tie Div II DC MCC 1B / Swing Charger 10/26/2020

1DC11E

71111.19 Work Orders WO 5058517 OP 9054.01C002 RCIC 1E51-C001 High Pressure 09/24/2020

Operability Check

WO 5088240 1VF07Y Failed to Open During VG 'A' Shutdown and VF 10/27/2020

Startup

WO 5099146 0AP25E-4B (0VC24YB Damper Bucket) Rebuild 0

WO 5099742 Leakcheck RR Subloop B1 0

71111.22 Corrective Action AR 4371952 ATM B21N692B and F Gross Fail High Didn't Come in As 09/25/2020

Documents Expected

Inspection Type Designation Description or Title Revision or

Procedure Date

Work Orders WO 4918018 OP 9054.05 RCIC Remote Shutdown Panel Operability 09/24/2020

Checks

WO 5048393 9030.01C06 Channel Functional RCIC Reactor Low Level 09/25/2020

B21-N692ABEF

WO 5093459 9071.01B21 Fire Pump Operability Run 11/23/2020

71114.02 Corrective Action AR 4257968 EP- Siren Failures (CL06 & CL21) 06/19/2019

Documents AR 4262593 EP ID: Trend IR; Multiple CPS Siren Failures 07/08/2019

AR 4336468 EP - Dewitt County Siren Controller Inoperable 04/17/2020

Miscellaneous Exelon Nuclear Manager, Midwest Emergency 10/01/2018

Preparedness Letter to Program Enhancement Manager,

Illinois Emergency Management Agency; Submission of

Clinton Power Station Public Alert and Notification System

(ANS) Design Report, Revision 3

Clinton Station Monthly Siren Availability Reports 09/01/2018 -

09/30/2020

Clinton Primary Notification System (PNS) Maintenance 09/01/2018 -

Reports 09/30/2018

Semi-Annual Clinton Power Siren Reports 09/01/2018 -

09/30/2020

2019/2020 Emergency Planning for the Clinton Area 07/19/2019

(Community Information Booklet)

20/2021 Emergency Planning for the Clinton Area 06/17/2020

(Community Information Booklet)

U.S. Department of Homeland Security, FEMA Letter, 12/10/2012

Subj: Backup Alert and Notification System

KLD-TR-987 Clinton Power Station Alert and Notification System (ANS) 09/19/2018

Design Report

Procedures EP-AA-120-F-02 EP Staff Initial Developmental Checklist H

EP-AA-112-200 TSC Activation and Operation 14

EP-AA-112-300 OSC Activation and Operation 14

EP-AA-112-400 EOF Activation and Operation 15

71114.03 Corrective Action AR 4173268 EP ID: 1 Hour Responder Failed to Call During 09/14/2018

Documents Augmentation Drill

AR 4249806 EP ID: 2nd Quarter ERO Augmentation Drill 05/17/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

Miscellaneous Quarterly Unannounced Off-Hours Call-In Augmentation 09/01/2018 -

Drill Results 09/30/2020

Emergency Response Organization Duty Roster 09/22/2020

Procedures EP-AA-1003, On-Shift Staffing Technical Basis 2

Addendum 1

EP-AA-112 Emergency Response Organization (ERO)/Emergency 22

Response Facility (ERF) Activation and Operation

EP-AA-112-100-F-06 ERO Notification or Augmentation X

TQ-AA-113 ERO Training and Qualification 39

71114.04 Corrective Action AR 4325295 Perform Impact Review of EAL Revisions from 03/10/2020

Documents EOP/SAMG, Rev. 4

AR 4329864 NOS ID: Revise Standardized Emergency Plan 03/26/2020

AR 4334253 EPlan: CDAM 50.54(q) Potential Deficiencies 04/09/2020

Miscellaneous Eval No. 19-29 Exelon Nuclear Standardized Radiological Emergency 09/04/2020

Plan

Eval No. 19-65 Exelon Nuclear Standardized Radiological Emergency 09/06/2019

Plan

Eval No. 19-79 Various Station Emergency Plan Annexes 11/08/2019

Eval No. 19-80 On-Shift Staffing Assessments 11/08/2019

71114.05 Corrective Action AR 4335802 NOS ID: Increase communication with Warner Hospital 04/15/2020

Documents AR 4335805 Communicate with Maroa FD About Their EP Role 04/15/2020

AR 4335859 NOS ID: Satellite Testing not Conducted by Required 04/15/2020

Disciplines

AR 4335887 Exercise/Drill Evaluated Reports and Communication Test 04/15/2020

Forms Contain Documentation Errors

AR 4336124 Annual Testing not Performed on 47 of 259 Public 04/16/2020

Address (PA) Speakers in 2019

Miscellaneous Full Scale PI Drill Series Report 12/19/2018

Clinton 2020 1st Half Health Physics Drill Report 07/22/2020

Clinton Medical/Health Physics Drill Evaluation Report 11/15/2019

Clinton 2019 NRC Graded Exercise Evaluation Report 04/18/2019

TSC PI Focus Drill Report 03/09/2020

2019 NRC Pre-Exercise WANO Emergency Management 03/11/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

Performance Evaluation

Clinton 2019 1st Half Health Physics Drill Report 05/31/2019

EP-AA-124-F-01 Quarterly Emergency Response Data System (ERDS) 09/01/2018 -

Test Records 09/30/2020

EP-MW-124-1001-F- Control Room/Simulator Inventory Records 09/01/2018 -

09/30/2020

EP-MW-124-1001-F- CR/Simulator/TSC/OSC Equipment Test-TSC Software 09/01/2018 -

and Reference Document Inventory Records 09/30/2020

EP-MW-124-1001-F- Technical Support Center Inventory Records 09/01/2018 -

09/30/2020

EP-MW-124-1001-F- Operations Support Center Inventory Records 09/01/2018 -

09/30/2020

EP-MW-124-1001-F- Field Team Inventory Records 09/01/2018 -

09/30/2020

EP-MW-124-1001-F- Assembly Area Inventory Records 09/01/2018 -

09/30/2020

EP-MW-124-1001-F- Medical Response Kit Inventory Records 09/01/2018 -

09/30/2020

EP-MW-124-1001-F- Monthly NARS Communications Test Records 09/01/2018 -

09/30/2020

EP-MW-124-1001-F- Monthly ENS Communications Test Records 09/01/2018 -

09/30/2019

EP-MW-124-1001-F- Quarterly Directors Hotline Test Records 09/01/2018 -

09/30/2020

EP-MW-24-1001-F- Quarterly Operations Status Line Test Records 09/01/2018 -

09/30/2020

EP-MW-124-1001-F- Quarterly Damage Control Line Test Records 09/01/2018 -

09/30/2020

EP-MW-124-1001-F- Quarterly Technical Support Line Test Records 09/01/2018 -

09/30/2020

KLD-TR-1002 Clinton Power Station 2018 Population Update Analysis 09/08/2018

KLD-TR-1181 Clinton Power Station 2020 Population Update Analysis 09/05/2020

Procedures EP-AA-1000 Exelon Nuclear Standardized Radiological Emergency 33

Plan

Inspection Type Designation Description or Title Revision or

Procedure Date

EP-AA-1003 Exelon Nuclear Radiological Emergency Plan Annex for 29

Clinton Station

EP-AA-1003, Evacuation Time Estimates for Clinton Power Station 1

Addendum 2 Plume Exposure Pathway Emergency Planning Zone

EP-AA-122 EP-AA-122; Drills and Exercise Program 22

EP-AA-124 Inventories and Surveillances 11

Self- NOSA-CPS-19-03 Emergency Preparedness Audit Report 03/15/2019

Assessments NOSA-CPS-20-03 Emergency Preparedness Audit Report 04/22/2020

71151 Miscellaneous NRC Performance Indicator Data; Emergency 01/01/2019 -

PreparednessDrill/Exercise Performance 06/30/2020

NRC Performance Indicator Data; Emergency 01/01/2018 -

PreparednessERO Readiness 06/30/2020

NRC Performance Indicator Data; Emergency 01/01/2018 -

PreparednessAlert and Notification System Reliability 06/30/2020

18