IR 05000244/2014007

Download: ML14273A303

Text

Mr. Joseph E. Pacher, Site Vice President R. E. Ginna Nuclear Power Plant, LLC Exelon Generation Company, LLC 1503 Lake Road Ontario, NY 14519

SUBJECT: R.E. GINNA NUCLEAR POWER PLANT - NRC EVALUATION OF CHANGES, TESTS, OR EXPERIMENTS AND PERMANENT PLANT MODIFICATIONS TEAM INSPECTION REPORT 05000244/2014007

Dear Mr. Pacher:

On August 21, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the R.E. Ginna Nuclear Power Plant. The enclosed inspection report documents the inspection results, which were discussed on August 21, 2014, with Mr. William Carsky, Plant Manager, and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.

In conducting the inspection, the team reviewed selected procedures, calculations and records, observed activities, and interviewed station personnel.

This report documents one NRC-identified finding of very low safety significance (Green). This finding was determined to involve a violation of NRC requirements. However, because of the very low safety significance and because the finding was entered into your corrective action program, the NRC is treating the finding as a non-cited violation (NCV), consistent with Section 2.3.2 of the NRC's Enforcement Policy. If you contest the NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555-0001, with copies to the Regional Administrator, Region I; Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspector at the R.E. Ginna Nuclear Power Plant.

September 29, 2014 In accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/http://www.nrc.gov/reading-rm/adams.html

Sincerely,/RA/ Paul G. Krohn, Chief Engineering Branch 2 Division of Reactor Safety Docket No. 50-244 License No. DPR-18

Enclosure:

Inspection Report 05000244/2014007

w/Attachment:

Supplemental Information cc w/encl: Distribution via ListServ

SUMMARY OF FINDINGS

IR 05000244/2014007; 9/04/2014-9/21/2014; R.E. Ginna Nuclear Power Plant (Ginna); Engineering Specialist Plant Modifications Inspection.

This report covers a two week on-site inspection period of the evaluations of changes, tests, or experiments and permanent plant modifications. The inspection was conducted by three region based engineering inspectors. One finding of very low safety significance (Green) was identified, which was considered to be a non-cited violation. The significance of most findings is indicated by a color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609,

"Significance Determination Process" (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 5, dated February 2014.

Inspector Identified and Self-Revealing Findings

Cornerstone: Mitigating Systems

Green.

The team identified a finding of very low safety significance involving a non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XI, "Test Control," in that Exelon did not assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service were identified and performed in accordance with written test procedures.

Specifically, the team determined that the solenoid-operated valves that actuate the main steam isolation valves were not satisfactorily (independently) tested to demonstrate that the isolation valves would perform satisfactorily in service. In response, Exelon entered the issue into the corrective action program, evaluated current operability, and initiated efforts to develop satisfactory testing methods. The finding was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Using IMC 0609, Appendix A, "The Significance Determination Process for Findings At-Power," Exhibit 2, "Mitigating Systems Screening Questions," the team determined the finding was of very low safety significance (Green) because it was not a design or qualification deficiency, did not represent a loss of system safety function, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. This finding did not have a cross-cutting aspect because the most significant contributor of the performance deficiency was not reflective of current licensee performance.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity 1R17 Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications (IP 71111.17)

.1 Evaluations of Changes, Tests, or Experiments (21 samples)

a. Inspection Scope

The team reviewed three safety evaluations to evaluate whether the changes to the facility or procedures, as described in the Updated Final Safety Analysis Report (UFSAR), had been reviewed and documented in accordance with 10 CFR 50.59 requirements. In addition, the team evaluated whether Exelon had been required to obtain NRC approval prior to implementing the changes. The team interviewed plant staff and reviewed supporting information including calculations, analyses, design change documentation, procedures, the UFSAR, Technical Specifications (TS), and plant drawings to assess the adequacy of the safety evaluations. The team compared the safety evaluations and supporting documents to the guidance and methods provided in Nuclear Energy Institute (NEI) 96-07, "Guidelines for 10 CFR 50.59 Evaluations," as endorsed by NRC Regulatory Guide 1.187, "Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments," to determine the adequacy of the safety evaluations. The team also reviewed a sample of eighteen 10 CFR 50.59 screenings for which Exelon had concluded that no safety evaluation was required. These reviews were performed to assess whether Exelon's threshold for performing safety evaluations was consistent with 10 CFR 50.59. The sample included design changes, calculations, and procedure changes.

The team reviewed the safety evaluations that Exelon had performed and approved during the time period covered by this inspection (i.e., since the last modifications inspection) not previously reviewed by NRC inspectors. The screenings and 10 CFR 50.59 applicability determinations were selected based on the safety significance, risk significance, and complexity of the change to the facility.

In addition, the team compared Exelon's administrative procedures used to control the screening, preparation, review, and approval of safety evaluations to the guidance in NEI 96-07 to evaluate whether those procedures adequately implemented the requirements of 10 CFR 50.59. The safety evaluations and screenings reviewed by the team are listed in the Attachment.

b. Findings

No findings were identified.

.2.1 Instrument Air Intermediate Building Piping Reclassification

a. Inspection Scope

The team reviewed modification ECP-14-000658 that reclassified the instrument air piping located near the main steam isolation valves (MSIVs), including the piping between the MSIVs and the actuating solenoid-operated valves (SOVs). The piping section classification was changed from ASME Class 3 to non-ASME Q-Class piping.

The modification stated that the change had no operational impact as all the safety functions of associated components were maintained. Changing the piping classification would allow greater flexibility in performing piping repairs, if necessary. The team reviewed the modification to determine if the design basis, licensing basis, or performance capability of the instrument air system or MSIVs had been degraded by the modification. The team interviewed engineers and reviewed the modification package to determine if the change met design requirements. A walkdown of the associated piping section was performed to assess the overall material condition of the piping and associated equipment. The team also reviewed the design, configuration, and testing of the MSIVs, which remained supported by the instrument air system to evaluate whether the modification could result in an adverse effect to safety components. A review of condition reports was performed to evaluate whether there were any reliability or performance issues associated with the post-modification configuration. The 10 CFR 50.59 screening determination associated with this modification was also reviewed as described in Section 1R17.1 of this report. Documents reviewed are listed in the

.

b. Findings

Introduction:

The team identified a finding of very low safety significance (Green) involving a non-cited violation of 10 CFR 50, Appendix B, Criterion XI, "Test Control,"

in that Exelon did not assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service were identified and performed in accordance with written test procedures. Specifically, the team determined that the solenoid-operated valves that actuate the main steam isolation valves (MSIVs) were not satisfactorily (independently) tested to demonstrate that the isolation valves would perform satisfactorily in service.

Description:

While reviewing a modification associated with reclassifying a portion of the instrument air system, the team questioned the function and testing of SOVs that provide instrument air to the MSIVs. The MSIVs are supplied with instrument air via two, in-series SOVs that function to hold the MSIV disc in the 'up' position (i.e., MSIV open).

The instrument air supply to the MSIVs is also connected with two, parallel SOVs that open to vent air from the MSIV to allow the spring-assisted valve disk to close. When the MSIV receives a signal to close, the supply series SOVs close and the parallel vent SOVs simultaneously open. The design is such that only one of the SOVs in each set is required to actuate (single failure design) to reposition the MSIV to its safety-related position (i.e., closed). The supply and vent SOVs are normally de-energized and are energized to actuate. Each set of supply and vent SOVs is associated with one train of actuation (i.e., 'A' and 'B' train SOVs). There are two MSIVs.

Exelon stated that the MSIVs are stroke-time tested (closed) during each refueling outage. However, both SOVs in each SOV set are given an actuation signal (to both actuating trains) simultaneously. That is, the SOVs in each train are not independently tested. Using this methodology, if one of the two in-series, supply SOVs and/or one of the two parallel, vent SOVs fail to actuate, the MSIV would still close, and a SOV failure could be masked.

In response to this concern, Exelon initiated Condition Report 2014-004750. In addition, Exelon indicated that all of the SOVs were independently tested during the refueling outage in 2003. Specifically, Exelon performed a Safety Injection Functional Test (procedure RSSP-2.1) during 2003 that tested the two independent actuating trains, 'A' and 'B'. During a refueling outage, only the actuating relays are tested (not the SOVs or the MSIVs) since the MSIVs are not typically fully assembled and available for closing. During the 2003 refueling outage, however, the MSIVs were in place and closed by each of the two SOV trains. During that test, both MSIVs closed successfully, indicating that all four SOVs on each MSIV functioned properly.

Exelon indicated that there was a reasonable assurance of operability based on several factors, including the successful and repeatable results of the MSIV timed-closure tests (conducted each refueling outage) and the results of the 2003 test, which conducted an independent SOV actuation test. Furthermore, a 10-year SOV preventive maintenance activity to replace the external SOV O-rings had been satisfactorily completed. The team reviewed Exelon's bases for interim operability, and determined that their assessment was adequate. Exelon planned to develop or modify existing testing methodologies to incorporate independent SOV testing.

Analysis:

The team determined that the failure to fully periodically and independently test the SOVs that actuate to operate (close) the MSIVs was a performance deficiency that was reasonably within Exelon's ability to foresee and prevent. The finding was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, a postulated and undetected failure of two, untested SOVs, in conjunction with a single failure of another SOV, could affect the intended MSIV safety function to close during a design basis event. Traditional enforcement does not apply because the issue did not have any actual safety consequences or potential for impacting the NRC's regulatory function, and was not the result of any willful violation of NRC requirements.

The team performed a risk screening, in accordance with IMC 0609, Appendix A, "Significance Determination Process for Findings At-Power," using Exhibit 2, "Mitigating Systems Screening Questions." The team determined the finding was of very low safety significance (Green) because it was not a design or qualification deficiency, did not represent a loss of system safety function, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. This finding did not have a cross-cutting aspect because the most significant contributor of the performance deficiency was not reflective of current licensee performance.

Enforcement:

10 CFR 50, Appendix B, Criterion XI, "Test Control," requires, in part, that a test program be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is performed in accordance with written test procedures. Contrary to the above, prior to August 21, 2014, Exelon did not perform adequate periodic and independent testing to demonstrate that SOVs that actuate to operate (close) the MSIVs would perform satisfactorily in the event of a postulated single failure during a design basis event. Exelon performed an operability assessment, planned to modify existing testing methodologies, and entered the issue into the corrective action program. Because this violation was of very low safety significance (Green) and has been entered into Exelon's corrective action program (CR-2014-004750), this violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000244/2014007-01, Inadequate Test Control for MSIV Solenoid-Operated Valves)

.2.2 Safety Injection Accumulator Back-Leakage Mitigation

a. Inspection Scope

The team reviewed modification ECP-12-000220 that was implemented to collect and monitor any potential off-gassing in the safety injection (SI) pump and adjacent piping due to SI accumulator back-leakage through the SI pump discharge check valves. Due to the lower pressure at the upstream side of the SI pump discharge valves, the dissolved nitrogen can come out of solution and can result in off-gassing of the nitrogen in the water. This modification connected a collection tank via 3/4 inch pipe upstream of each of the three SI pump discharge check valves. Operators monitor and record level in the collection tanks so that action can be taken in the event gas accumulates in the tank. Further, the collection point is designed and oriented such that the potential accumulation does not adversely impact the SI system.

The team reviewed the modification to determine if the design basis, licensing basis, or performance capability of the SI system had been degraded by the modification. The team interviewed engineers and reviewed the gas collection tank design and configuration to determine if the changes met design requirements. Additionally, the team reviewed post-modification testing results and associated maintenance to determine if the changes were appropriately implemented. The team also performed a walkdown of the SI pump areas to determine if the modification was in accordance with the design, and to assess the overall material condition of the components following the modification work. A review of condition reports was performed to evaluate whether there were any reliability or performance issues associated with the post-modification configuration. The 10 CFR 50.59 screening determination associated with this modification was also reviewed as described in Section 1R17.1 of this report. Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.2.3 Standby Auxiliary Feedwater Room Coolers

a. Inspection Scope

The team reviewed modification ECP-13-000186 that was implemented to prevent a column closure waterhammer associated with the standby auxiliary feedwater (SAFW) room coolers during postulated design basis events. In particular, engineers changed the orientation of a service water (SW) system supply check valve to one of the coolers to vertical (from horizontal) to prevent SW back-leakage. In addition, two check valves were added to the instrument air system supply for each of the two room cooler SW outlet valves to keep the air-operated valves from opening (preventing a void path) if instrument air pressure was lost during a postulated loss-of-offsite power event. The team reviewed the modification to determine if the design basis, licensing basis, or performance capability of the SAFW room coolers had been degraded by the modification. The team interviewed engineers and reviewed the room cooler design and configuration to determine if the changes met design requirements. Additionally, the team reviewed post-modification testing results and associated maintenance to determine if the changes were appropriately implemented. The team also performed a walkdown of the SAFW pump room and related areas to determine if the modification was in accordance with the design, and to assess the overall material condition of the components following the modification work. A review of condition reports was performed to evaluate whether there were any reliability or performance issues associated with the post-modification configuration. The 10 CFR 50.59 screening determination associated with this modification was also reviewed as described in Section 1R17.1 of this report.

Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.2.4 Air Start Regulators

a. Inspection Scope

The team reviewed modification ECP-12-000774, which was an equivalency evaluation associated with the emergency diesel generator (EDG) starting air regulators. The air start motors are commercial grade safety-related as per procurement requirement evaluation form 11631. The regulators are non-environmentally qualified and are seismic.

The team reviewed the modification to determine if the design basis, licensing basis, or performance capability of the air start regulators had been degraded by the modification. The team interviewed engineers and reviewed the air start regulator design and configuration to determine if the changes met design requirements. Additionally, the team reviewed post-modification testing requirements and results to determine if the changes were appropriately implemented. The team also performed a walkdown of the installed regulators and associated components in the EDG rooms to determine if the modification was in accordance with the design and to assess the overall material condition of the components. A review of condition reports was performed to evaluate whether there were any reliability or performance issues associated with the post-modification configuration. The 10 CFR 50.59 screening determination associated with this modification was also reviewed as described in Section 1R17.1 of this report.

Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.2.5 Turbine Driven Auxiliary Feedwater Pump Modifications

a. Inspection Scope

The team reviewed modification ECP-11-000547 which installed several instrumentation monitoring components for the turbine driven auxiliary feedwater (TDAFW) pump. The Auxiliary Feedwater (AFW) system is designed to maintain the steam generator water inventory when the normal feedwater system is not available. The AFW system is an engineered safety feature because it provides a secondary heat sink for residual heat removal and therefore provides core protection and prevention of reactor coolant release through the pressurizer safety valves. The TDAFW pump modification included the addition of pressure indicators for the lubricating oil system and accumulators; level indicators for inboard and outboard bearing oil levels; temperature indicators for lubricating oil system and inboard and outboard bearings; a differential pressure indicator for outboard cooling flow rate; installation of a tachometer for pump speed; and replacement of valve V-4089A.

The team reviewed the modification to verify the design basis, licensing basis, and performance capability of the TDAFW pump and supported safety-related components had not been degraded by the modification. The team interviewed plant engineers and reviewed drawings to determine if the changes met design and licensing requirements.

Additionally, the team reviewed evaluations, and the post maintenance test (PMT) results to evaluate whether Exelon had properly implemented the TDAFW pump modification. The team also reviewed condition reports to evaluate whether the instrument indicators performed reliably since installation and whether any new performance issues had resulted from the modification. The team also walked down the TDAFW pump room to assess its material condition and standby configuration. The 10 CFR 50.59 screening determination associated with this modification was also reviewed as described in Section 1R17.1 of this report. The documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.2.6 Replacement of Charging Pump Motor and Speed Control Mechanism (2 Samples)

a. Inspection Scope

The team reviewed modifications ECP-09-000467, ECP-11-000788, and ECP-11-000789 which replaced the obsolete mechanical speed control mechanism for the 1A, 1B, and 1C charging pumps. The charging pumps are variable speed positive displacement pumps. The pumps are designed to inject coolant into the RCS in order to maintain RCS inventory, provide reactor coolant pump seal injection, control reactivity, and control primary chemistry. The charging pump modification included replacement of the obsolete pump speed control mechanism, which consisted of a constant speed motor and a belt-driven continuously variable transmission, with a direct coupled motor controlled by a variable frequency drive (VFD).

The team reviewed the modification to verify the design basis, licensing basis, and performance capability of the replacement motor, speed control system, and supported safety-related components had not been degraded by the modification. The team verified that the design specifications of the replacement motor and VFD were at least equivalent to the original model. The team interviewed plant engineers, and reviewed evaluations, and the PMT results to evaluate whether Exelon had properly implemented the modification. The team also reviewed condition reports to evaluate whether the new motor and VFD performed reliably since installation and whether any new performance issues had resulted from the modification. The team also walked down the charging pumps to assess the material condition and operating and standby configurations. The 10 CFR 50.59 screening determination associated with this modification was also reviewed as described in Section 1R17.1 of this report. The documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.2.7 MOV 3150 and MOV 3151 DC Control Circuits

a. Inspection Scope

The team reviewed modification ECP-14-000316 which installed protective fusing to the control circuits for the circulating water pump (CWP) motor operated valves (MOV) 3150 and 3151. The function of the circulating water system is to provide a reliable supply of water to condense the steam exhausted from the low-pressure turbines. The functions of the CWP discharge butterfly valves 3150 and 3151 are to isolate the circulating water intake in the event of a break in the intake tunnel between the valves and the downstream condenser inlet valves and to stop the flow of circulating water after the pumps are tripped. The MOV modification included addition of protective fusing to the MOV control circuitry and was performed to provide protection from potential high-impedance shorts identified during an NFPA 805 / Appendix R analysis. The high-impedance shorts have the potential to overheat and cause a fire in the indication/control circuitry cables, which run parallel to safety-related and Appendix R cabling located in the turbine building, diesel generator rooms, screenhouse, control room, and other vital areas.

The team reviewed the modification to verify the design basis, licensing basis, and performance capability of the CWP had not been degraded by the modification. The team verified that the fuse addition was within the guidance provided in the National Electric Code. The team interviewed plant engineers, and reviewed cable and fuse breakdown curves, vendor information, and drawings to evaluate whether Exelon had properly implemented the modification. The team also reviewed condition reports to evaluate whether the CWP had performed reliably or experienced any failures after the modification. The 10 CFR 50.59 screening determination associated with this modification was also reviewed as described in Section 1R17.1 of this report. The documents reviewed are listed in the Attachment

b. Findings

No findings were identified.

.2.8 Disable Amptector Discriminator Circuit and Test on MCCC and MCCD

a. Inspection Scope

The team reviewed modifications ECP-11-000785 which disabled the breaker discriminator circuit from motor control center (MCC) '1C' and '1D.' The breakers that supply power to MCCC and MCCD have an Amptector model with a Long Delay, a Short Delay, and a Ground Trip function. The function of the discriminator circuit is to provide protection to prevent closing an energized bus into a fault. The discriminator circuit was not reflected in the 480 volt coordination analysis and a preliminary short circuit study indicated the breakers supplying MCCC and MCCD could trip if a non-safety load faulted at the same time the motor control centers were reenergized following a loss of offsite power. The modification to disable the discriminator circuit added a jumper at the amptector device of the MCC feeder circuit breakers. The jumper installation is a design option for the amptector device. The modification was performed to provide adequate protection coordination as described in NRC Information Notice (IN) 92-29, "Potential Breaker Miscoordination Caused by Instantaneous Trip Circuitry," and NRC inspection finding NCV 05000244/2010009-01, "Inadequate Evaluation of Breaker Coordination Amptector Type LSG Trip Unit Discriminator Feature." The IN provided information to address potential breaker miscoordination involving the breaker manufacturer-installed instantaneous trip circuitry and short time delay. The team reviewed the modification to verify the design basis, licensing basis, and performance capability of the breakers and to verify that supported safety-related components had not been degraded by the modification. The team interviewed plant engineers, and reviewed electrical design calculations changes and coordination studies, evaluations, and a sample of surveillance tests that demonstrated that the downstream breakers were tested for instantaneous protection. The team also reviewed condition reports to evaluate whether the modification performed reliably. The 10 CFR 50.59 screening determination associated with this modification was also reviewed as described in Section 1R17.1 of this report. The documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.2.9 Control Switches in Power Circuit to EDG Service Water AOVs

a. Inspection Scope

The team reviewed modification ECP-09-000481 which added individual control switches to the power circuits of the solenoid valves associated with the air-operated valves (AOV)of the EDG service water lines. Each EDG is supplied with cooling water from the service water system to cool the EDG lubricating oil and jacket water systems. Two AOVs are installed in each service water line and are normally closed when the EDG is not running. Power is required to the solenoid valves associated with each AOV to allow instrument air pressure on the diaphragm to maintain the AOV in the closed position. A spring in the actuator opposes the air pressure on the diaphragm allowing the AOV to fail open upon loss of instrument air or control power. Upon an EDG start signal, the logic circuit de-energizes the solenoid valves to isolate instrument air and vent the diaphragm, allowing the actuator spring to open the valve. The addition of the control switches in the power circuit for each solenoid valve allows for the independent isolation of power to each solenoid to facilitate IST quarterly stroke time testing requirements of the four service water AOVs.

The team reviewed the modification to determine if the design basis, licensing basis, or performance capability of the EDGs had been degraded by the modification. The team interviewed engineers and reviewed the design and configuration to determine if the changes met design requirements. The team reviewed surveillance and post-modification test results to verify that the AOVs continued to function as required. The team verified the appropriate changes were made to surveillance test procedures and system drawings. The 10 CFR 50.59 safety evaluation associated with this modification was reviewed as described in section 1R17.1 of this report. Finally, the team walked down both EDG rooms and the accessible portions of the modification to ensure the system configuration was in accordance with design and to assess the overall material condition. The documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.2.10 AFW Check Valve CV-4000C Replacement and Relocation

a. Inspection Scope

The team reviewed modification ECP-12-000042 that replaced auxiliary feedwater (AFW) system check valve CV-4000C with a like-for-like valve and relocated it from a horizontal to a vertical section of piping upstream of its original location. The modification was implemented to minimize factors that led to degradation of the valve internals. In particular, engineers had determined that: system vibration matching the natural frequency of the valve internals; flow characteristics during outages; and the location directly downstream of an elbow, were all mechanisms leading to that degradation. The new location centered CV-4000C in piping between two seismic supports and in the vicinity of a rigid anchor support, minimizing valve vibration during normal operation. The new location also allows for better system flow development and valve performance when subjected to low flow. The relocation additionally moved the Safety Class (SC) boundary, necessitating replacement and relocation of valve V-4099N to allow draining of the downstream piping. As a result, a new valve, V-4099R, was installed upstream of CV-4000C to allow venting and draining of the upstream piping.

The team reviewed the modification to determine if the design basis, licensing basis, or performance capability of the AFW had been degraded by the modification. The team interviewed engineers and reviewed the configuration to determine if the changes met design requirements. Additionally, the team reviewed post-modification test results and associated work orders to verify that the installation was appropriately implemented and would function in accordance with design assumptions. The team performed a walkdown of the related areas to determine if the modification was in accordance with the design and to assess material condition. A review of condition reports was performed to evaluate whether there were any reliability or performance issues associated with the post-modification configuration. The 10 CFR 50.59 screening determination associated with this modification was also reviewed as described in Section 1R17.1 of this report.

Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems (IP 71152)

a. Inspection Scope

The team reviewed a sample of condition reports associated with 10 CFR 50.59 and plant modification issues to evaluate whether Exelon was appropriately identifying, characterizing, and correcting problems associated with these areas, and whether the planned and/or completed corrective actions were appropriate. In addition, the team reviewed condition reports written on issues identified during the inspection to verify adequate problem identification and incorporation of the problem into the corrective action system. The condition reports reviewed are listed in the Attachment.

b. Findings

No findings were identified.

4OA6 Meetings, including Exit

The team presented the inspection results to Mr. W. Carsky, Plant Manager, Mr. T. Mogren, Director of Engineering, and other members of Exelon's staff at an exit meeting on August 21, 2014. The team returned the proprietary information reviewed during the inspection and verified that this report does not contain proprietary information.

ATTACHMENT

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Exelon Personnel

W. Carsky, Plant Manager

J. Cieri, Battery System Engineer

K. Connor, Fuels Engineer

C. Downs, Electrical Design Supervisor

E. Durkish, Mechanical Design Supervisor

R. Fellows, Shift Manager

S. Gardner, Fuels Engineer

D. Garofoli, IST and App J Program Owner

M. Harriman, Project Engineer

J. Metzger, Design Engineer

T. Mogren, Director of Engineering

L. Oldfield, Design Engineer

D. Peters, Design Engineer

C. Siverd, Regulatory Engineer

J. Wells, Sr. Manager Design Engineering

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

Opened and Closed

05000244/2014007-01 NCV Inadequate Test Control for MSIV Solenoid Operated Valves (Section 1R17.2.1)

LIST OF DOCUMENTS REVIEWED

10

CFR 50.59 Evaluations

EVAL-2012-0001, Change to methodology for calculating degraded voltage relay uncertainty in

DA-EE-93-006-08, dated 6/20/12

EVAL-2012-0002, Evaluation of Using Drill or Handwheel in Place of Trolley Motor on Fuel Manipulator Crane, dated 11/03/12

EVAL-2013-0001, Revise the SGTR safety analysis as described in the UFSAR, 7/12/13

CFR 50.59 Screened-out Evaluations

ECP-10-000105,

GL 2008-01 Vent Line Additions, 5/17/10

ECP-11-000119, Remote Vibration Capability Provided for Containment Recirculation Fans and Motors, 10/17/11

Attachment

ECP-11-000539, Charging Pump Room Cooler Upgrade to Stainless Steel, 11/28/11

ECP-11-000562, Replacement of Main Steam Atmospheric Relief Valves and Installation of Discharge Stack Blowback Preventers, 11/14/11

ECP-11-000564, Main Steam Safety Valve Connector Installation, 5/10/12

ECP-11-000811, Install PIs to Indicate Pressure Drop Across SW Strainers, 4/20/12

ECP-11-000824, SW Piping Replacement and Removal of Valves 4619A and 4619B, 9/27/11

ECP-11-000852, Reactor Cavity Water Level Indication, 10/28/11

ECP-12-000061, Documentation of Cycle 37 Reload Core Design, Revision 0

ECP-12-000764, Design Change Modification to Improve

MOV-3184 Position Indication,

10/15/12

ECP-13-000074, Fire System Valve 8544 Design Change, 2/11/13

ECP-13-000537, Review Open Changes to DC Loading Analysis

DA-EE-99-047 and

Determine the Current Nominal Loading on the Station Batteries and Revise the Station Battery

Sizing Calculations

DA-EE-97-069, 5/29/13

ECP-13-000547, SFP Level Indication Modification for Fukushima Response, 1/19/14

ECP-13-000656, Flux Mapping Software Upgrade, 8/27/13

ECP-13-000762, Incorporate Calculation and Provide Additional Basis for LTC Motor Operating

Voltage Rating in Analysis

DA-EE-96-068-03, 9/04/13

PCR 12-04904, Loss of CCW - Plant Shutdown (AP-CCW.3), 8/21/12

PCR 12-06162, Loss of RHR (AP-RHR.1), 10/19/12

PCR 12-07132, Reactor Trip or Safety Injection (E-0), 11/4/13

Modification Packages

ECP-09-000467, Chemical Volume Control System Varidrive Replacement Project, Revision 0

ECP-09-000481, EDG SW AOV Control Switches for 4598G, 4598H, 4599G, and 4599H, dated 12/16/09

ECP-11-000547, TDAFW Instrumentation Upgrade, Revision 0

ECP-11-000785, Disable Amptector Discriminator and Test on MCCC and MCCD Feeder

Circuit Breakers, Revision 0

ECP-11-000788, Chemical Volume Control System Varidrive Replacement Project, Revision 0

ECP-11-000789, Chemical Volume Control System Varidrive Replacement Project, Revision 1

ECP-12-000042, Relocation of

CV-4000C, Revision 0

ECP-12-000220, SI Accumulator Back-Leakage Mitigation, Revision 0

ECP-12-000774, Air Start Regulators, Revision 0

ECP-13-000186, Modification to the SAFW Room Coolers, Revision 0

ECP-14-000316, Add Fusing to

MOV 3150 and 3151 DC Control Circuits, Revision 0

ECP-14-000658, Instrument Air Intermediate Building Piping Reclassification, Revision 0

Calculations, Analysis, and Evaluations

DA-EE-93-006-08, Instrument Performance Evaluation and Setpoint Verifcation:

Undervoltage Relays and Voltmeters on 480V Safeguards Busses, Revision 5

DA-EE-93-006-08, Instrument Performance Evaluation and Setpoint Verifcation:

Undervoltage Relays and Voltmeters on 480V Safeguards Busses, Revision 6

DA-EE-93-104-07, 480 Volt Coordination and Circuit Protection Study, Revision 7

ECP-10-000371, Documentation of Cycle 36 Reload Core Design, Revision 0

Attachment Completed Surveillance and Modification Acceptance Tests M-51.13EQ, Maintenance and/or Replacement of EQ Valcor Solenoid Valves, performed 10/27/12

RSSP-2.1, Safety Injection Functional Test, performed 10/06/03

STP-O-COMP-A, AFW Pump A - Comprehensive Test, performed 7/23/12, 7/18/13

and 7/19/13

Condition Reports

CR-2007-004536

CR-2007-006081

CR-2008-000780

CR-2008-008345

CR-2009-002859

CR-2010-007062

CR-2010-007105

CR-2010-007927

CR-2011-005291

CR-2011-007485

CR-2012-007681

CR-2012-007683

CR-2012-008688

CR-2012-008701

CR-2013-004920

CR-2013-006695

CR-2014-001137

CR-2014-001443

CR-2014-001995

CR-2014-001996

CR-2014-002054

CR-2014-002061

CR-2014-002062

CR-2014-002897

CR-2014-003069

CR-2014-003069

CR-2014-003929

CR-2014-004104

CR-2014-004518*

CR-2014-004730*

CR-2014-004750*

(* denotes NRC identified during this inspection)

Drawings

10904-0164, 480 Volt Motor Control Center C Schedule, Revision 28 10904-0165, 480 Volt Motor Control Center C Schedule, Revision 33

10904-0166, 480 Volt Motor Control Center C Schedule, Revision 22

10905-0639, Circulating Water Pump A Discharge Butterfly

MOV-3150, Elementary Wiring Diagram, Sheet 1, Revision 5

10905-0640, Circulating Water Pump B Discharge Butterfly

MOV-3150,

Elementary Wiring Diagram, Sheet 1, Revision 5 10905-0731, Main Steam Isolation Valve B, Revision 1

21946-0639, Circulating Water Pump A Discharge Butterfly

MOV-3150, Control Schematic, Sheet 1, Revision 2

21946-0640, Circulating Water Pump B Discharge Butterfly

MOV-3151,

Control Schematic, Sheet 1, Revision 3 33013-0652, 480 Volt One Line Wiring Drawing, Revision 29

33013-1231, Sht. 1, Main Steam, Revision 2

33013-1237, Auxiliary Feedwater (FW) P&ID, Revision 58

33013-1237, Sht. 1, Auxiliary Feedwater P&ID, Revision 68 33013-1250, Sht. 2, Station Service Cooling Water, Revision 49 33013-1736, Sht. 1, Diesel Generator A Control Schematic, Revision 16

33013-1736, Sht. 9, Diesel Generator A Control Panel Auxiliary Schematics, Revision 4

33013-1737, Sht. 1A, Diesel Generator B Control Schematic, Revision 7

33013-1892, Instrument Air, Auxiliary Building, Revision 9

33013-1893, Instrument Air, Intermediate Building, Revision 25 33013-2285, Motor Driven and Turbine Driven Auxiliary Feedwater Pumps Lubricating Oil

Skid P&ID, Revision 18

33013-2941, TDAFW Lubricating Oil Piping Isometric, Revision 0

A-07444295-D, Sht. 1, Assembly, Ginna Pool Layout, Revision 4

Attachment C381-0351, Sht. 2, Feed Water Pump Suction and Discharge Intermediate Building, Revision 4 C381-0351, Sht. 4, Feed Water Pump Suction and Discharge Intermediate Building, Revision 3 C381-0352, Sht. 2, Auxiliary Feedwater Pump Discharge Intermediate Building, Revision 9

C381-0352, Sht. 4, Auxiliary Feedwater Pump Discharge Intermediate Building, Revision 7

Licensing Documents Technical Requirements Manual, Revision 55 Technical Specifications, Amendment 115 Updated Final Safety Analysis Report, Revision 24

Miscellaneous

FIRE-2012-0003,

ECP-09-000467 Appendix R/Fire Protection Conformance Verification

Checklist and Combustible Loading Worksheets, Attachments 2 and 8, Revision 0 Information Notice 92-19, Potential Breaker Miscoordination Caused by Instantaneous Trip Circuitry

IST Basis Document for 3516S1-S4 and 3517S1-S4

IST Database for EDG JW and LO Cooler SW Isolation Valves

AOV-4598G/H and

AOV4599G/H for the period 9/22/09 - 7/16/14 MSIV 3516 stroke time results for the period 10/12/00 - 5/17/14

MSIV 3517 stroke time results for the period 10/12/00 - 5/17/14

NSAL-07-11, Westinghouse Nuclear Safety Advisory Letter, 11/15/07

QR2600-515, Qualification Test Report for IEEE Class 1E Solenoid Valve P/N V52600-515,

11/21/77

WCAP-9272-P-A, Westinghouse Reload Safety Evaluation Methodology, dated July 1985

Procedures

A-503.1, Emergency and Abnormal Operating Procedures Users Guide, Revision 04409

A-601.10, Time Critical Action Management Program, Revision 00301 A-601.15, Review and Control of Local Operator Actions in EOPs, Revision 00000

CME-44-02-MCCC, Westinghouse, Type W Motor Control Center Motor Control Center C

Maintenance for MCCC, Revision 01300

CME-44-02-MCCC/B, Westinghouse, Motor Control Center C Unit Molded Case Circuit Breaker Maintenance for MCCC/B, Revision 05

CME-44-02-MCCD, Westinghouse, Type W Motor Control Center Motor Control Center D

Maintenance for MCCD, Revision 01000

CNG-CM-1.01-1003, Design and Engineering Configuration Control, Revision 00601

CNG-CM-1.01-1006, Design Verification, Revision 00001

E-3, Steam Generator Tube Rupture, Revision 04800

GME-50-02-DB50, Westinghouse, 480V Air Circuit Breaker, TYPE

DB-50 Maintenance for

Type

DB-50 breakers, Revision 02400

GME-50-2-DBSETUP, Westinghouse, DB Breaker Setup, Revision 00702

IP-CON-3, Setpoint Instrument Uncertainty Control and Verification Process, Revision 00600

M-51.13EQ, Maintenance and/or Replacement of EQ Valcor Solenoid Valves, Revision 01300

RE-100, Preparation, Review, and Approval of Fuel Movement Sequence Sheets and

Document Closeout, Revision 01302

RE-103, Control of Reload Core Design, Revision 00303

Attachment

STP-O-2.5.7, EDG Air Operated Valves, Quarterly Surveillance, Revision 00300

STP-O-30.10, EDG A Pre-Startup Alignment, Revision 00501

STP-O-R-25, Service Water System Flow Test, Revision 00600

Work OrdersC19101975

C91465051

C91498819

C91498820

C91640022

C91640026

C92170493

Vendor Documents

CAVMC-0509, Cash Valve, B Series, Pressure Regulators, January 1999

OMM-6180, Operation and Maintenance Manual for Pilot Assisted, Latching 2 Way Valve (Valcor Engineering), Revision G

Attachment

LIST OF ACRONYMS

ADAMS Agencywide Documents Access and Management System

AFW Auxiliary Feedwater

AOV Air Operated Valve

CFR Code of Federal Regulations

CST Condensate Storage Tank

CWP Circulating Water Pump DRS Division of Reactor Safety

ECP Engineering Change Package

EDG Emergency Diesel Generator

IN Information Notice

IP Inspection Procedure IST In-Service Testing

JW Jacket Water

LO Lubricating Oil

MCC Motor Control Center

MOV Motor-Operated Valve

MS [[]]

IV Main Steam Isolation Valves

NEI Nuclear Energy Institute

NF [[]]

PA National Fire Protection Association

NRC Nuclear Regulatory Commission

PARS Publicly Available Records

PCR Procedure Change Request PMT Post-Modification Test

SA [[]]

FW Standby Auxiliary Feedwater

SFP Spent Fuel Pool

SI Safety Injection Pump

SW Service Water

TDA [[]]

FW Turbine-Driven Auxiliary Feedwater

TS Technical Specifications

UFS [[]]

AR Updated Final Safety Analysis Report

VFD Variable Frequency Drive