IR 05000244/2019002

LLC: Integrated Inspection Report 05000244/2019002

ML19224A245
Person / Time
Site:	Ginna
Issue date:	08/12/2019
From:	Erin Carfang Division Reactor Projects I
To:	Bryan Hanson Exelon Generation Co
References
IR 2019002
Download: ML19224A245 (13)

Text

ust 12, 2019

SUBJECT:

R.E. GINNA NUCLEAR POWER PLANT, LLC - INTEGRATED INSPECTION REPORT 05000244/2019002

Dear Mr. Hanson:

On June 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at R.E. Ginna Nuclear Power Plant, LLC. On July 16, 2019, the NRC inspectors discussed the results of this inspection with Mr. William Carsky, Site Vice President and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspectors did not identify any finding or violation of more than minor significance.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Erin E. Carfang, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket No. 05000244 License No. DPR-18

Enclosure:

As stated

Inspection Report

Docket Number: 05000244 License Number: DPR-18 Report Number: 05000244/2019002 Enterprise Identifier: I-2019-002-0034 Licensee: Exelon Generation Company, LLC Facility: R.E. Ginna Nuclear Power Plant, LLC Location: Ontario, New York 14519 Inspection Dates: April 01, 2019 to June 30, 2019 Inspectors: N. Perry, Senior Resident Inspector J. Schussler, Resident Inspector L. Dumont, Reactor Inspector S. McCarver, Physical Security Inspector Approved By: Erin E. Carfang, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a quarterly integrated inspection at R.E. Ginna Nuclear Power Plant,

LLC 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 of more than minor significance were identified.

Additional Tracking Items Type Issue Number Title Report Section Status LER 05000244/2019-001- Air Leakage From Turbine 71153 Closed 00 Driven Auxiliary Feed Pump Lube Oil Accumulator Results in Unexpected Pump Inoperability.

PLANT STATUS

Ginna began the inspection period at 100 percent power. On June 14, operators began shutting down the unit to perform maintenance on the generator step-up transformer. Operators halted the shutdown at about 30 percent power to troubleshoot a single rod out of sequence; the shutdown was completed on June 16. Once maintenance activities were completed, the reactor was restarted and 100 percent power achieved on June 18. The unit remained at, or near, 100 percent power for the remainder of the 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 performed plant status activities described in IMC 2515 Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

71111.01 - Adverse Weather Protection Summer Readiness Sample (IP Section 03.01)

(1) The inspectors evaluated summer readiness of offsite and alternate AC power systems on June 6, 2019.

71111.04 - Equipment Alignment Partial Walkdown Sample (IP Section 03.01)

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

(1) 'A' emergency diesel generator (EDG) on April 19, 2019

(2) 'A' safety injection on June 21, 2019

(3) Turbine driven auxiliary feedwater on June 30, 2019

71111.04S - Equipment Alignment Complete Walkdown Sample (IP Section 03.02)

(1) The inspectors evaluated system configurations during a complete walkdown of 'D' standby auxiliary feedwater on June 30, 2019.

71111.05A - Fire Protection (Annual) Annual Inspection (IP Section 03.02)

(1) The inspectors evaluated fire brigade performance on June 6, 2019

71111.05Q - Fire Protection Quarterly Inspection (IP Section 03.01)

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Intermediate building controlled sub-basement on April 17, 2019

(2) 13 transformer yard on May 14, 2019

(3) Intermediate building clean top floor on May 24, 2019

(4) Auxiliary building west basement and residual heat removal sub-basement on June 3, 2019

(5) Intermediate building clean basement on June 20, 2019

71111.06 - Flood Protection Measures Inspection Activities - Internal Flooding (IP Section 02.02a.)

(1) The inspectors evaluated internal flooding mitigation protections in the screenhouse (dikes and curbs) and the turbine building (elevated doorways and penetrations) on June 26, 2019.

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) The inspectors observed and evaluated licensed operator performance in the main control room during shift turnover on May 15, 2019, during forced outage plant shutdown on June 14, 2019, and startup on June 18, 2019.

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

(1) The inspectors observed and evaluated licensed operator performance in the simulator during licensed operator requalification training on May 21, 2019. The training involved a scenario that contained, but was not limited to, a nuclear instrument detector failure, a loss of an offsite power circuit, a reactor coolant pump seal failure, and a loss of coolant accident with a reactor coolant pump seal failure.

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness Inspection (IP Section 02.01)

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Turbine driven auxiliary feedwater on June 24, 2019

(2) Service water on June 27, 2019

71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01)

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Elevated risk, hand control valve 110A planned maintenance on April 9, 2019

(2) Elevated risk, under voltage surveillance testing of busses 14 and 18 planned on April 18, 2019

(3) Elevated risk for hand control valve 110A, service air compressor, and 'B' spent fuel pool cooling, planned out of service on May 28, 2019

(4) Elevated risk, forced outage on June 17, 2019

(5) Elevated risk, turbine driven auxiliary feedwater planned out of service on June 20, 2019

71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessments (IP Section 02.02)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) 'B' service water pump rotor bar defect on April 12, 2019

(2) Flow element 910 safety injection recirculation line fitting leak impact on safety injection and containment spray flow on June 12, 2019

(3) 'B' phase generator step-up transformer connection elevated temperature June 19, 2019

71111.18 - Plant Modifications Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

The inspectors evaluated the following temporary or permanent modification:

(1) Turbine driven auxiliary feedwater lubricating oil valve permanent modification ECP-19-000203 on June 26, 2019

71111.19 - Post-Maintenance Testing Post-Maintenance Test Sample (IP Section 03.01)

The inspectors evaluated the post-maintenance tests for the following maintenance activities:

(1) Diesel air compressor planned maintenance on April 11, 2019

(2) 'A' motor driven auxiliary feedwater planned maintenance on April 24, 2019

(3) Motor driven fire pump planned maintenance on May 3, 2019

(4) Diesel driven flex air compressor B planned maintenance on May 22, 2019

(5) Control rod K07 emergent maintenance on June 17, 2019

(6) 'A' main steam isolation valve emergent maintenance on June 18, 2019

71111.20 - Refueling and Other Outage Activities Refueling/Other Outage Sample (IP Section 03.01)

(1) The inspectors evaluated a plant forced outage to repair a main generator step-up transformer bolted connection, including observations of shutdown and startup activities from June 14 through June 18, 2019.

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Inservice Testing (IP Section 03.01)

(1) STP-O-2.2QA, 'A' residual heat removal quarterly on June 4, 2019

Surveillance Tests (other) (IP Section 03.01) (4 Samples)

(1) STP-O-30.11, 'B' emergency diesel generator on May 1, 2019

(2) STP-O-2.71C, 'C' service water pump test on May 15, 2019

(3) STP-O-R-2.3B, 'B' emergency diesel generator trip testing on May 29, 2019

(4) CH-PRI-SAMP-ROOM on June 7,

OTHER ACTIVITIES - BASELINE

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

BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) ===

(1) April 1, 2018 - March 31, 2019

BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)

(1) April 1, 2018 - March 31, 2019 MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (1 Sample)

(1) April 1, 2018 - March 31, 2019

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues (IP Section 02.03)

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

(1) A and B Emergency Diesel Generator lube oil heaters and A EDG fuel oil heat trace deficiencies, on April 1, 2019.

Semiannual Trend Review (IP Section 02.02) (1 Sample)

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends that might be indicative of a more significant safety issue on June 30, 2019.

71153 - Followup of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

The inspectors evaluated the following licensee event report (LER):

(1) LER 05000244/2019-001-00, Air Leakage From Turbine Driven Auxiliary Feed Pump Lube Oil Accumulator Results in Unexpected Pump Inoperability, ADAMS accession:

MLML19127A149. The circumstances surrounding this LER were previously documented in Inspection Report 05000244/2019001, NCV 05000244/2019001-01.

The inspectors concluded that no additional performance deficiencies or violations of NRC requirements were identified.

INSPECTION RESULTS

Observation: Semi-Annual Trend Review 71152 The inspectors reviewed Exelons corrective action program (CAP) for trends that might be indicative of a more significant safety issue on June 30, 2019. The inspectors evaluated a sample of issues and events that occurred over the course of the first and second quarters of 2019 to determine whether issues were appropriately considered as emerging or adverse trends. The inspectors verified that these issues were addressed within the scope of the CAP or through department review.

The evaluation did not reveal any new trends that could indicate a more significant safety issue. The inspectors determined that Exelon personnel were identifying trend issues at a low threshold, entered them into the CAP for resolution and had appropriately prioritized investigation reviews. The inspectors noted minor adverse trends identified by Exelon staff in the areas of flex equipment battery failures, maintenance rework, EDG vault humidity, foreign material exclusion events (outage), and unplanned entries into loss of Sodus line circuit. The inspectors raised an observation to plant management concerning a potential trend in communication of pant issues to management.

There were no adverse safety consequences as a result of these low-level trend issues. Based on the overall results of the semi-annual trend review, the inspectors determined that Exelon had properly identified adverse trends at Ginna before they became more significant safety problems. The inspectors independently evaluated the deficiencies noted above for significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues. The inspectors determined that none of the conditions were deficiencies of greater than minor significance and, therefore, are not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Minor Violation 71152 10 CFR, Part 50, Appendix B, Criterion XVI, Corrective Action, states in part, that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. Between November 11, 2018, and January 10, 2019, Exelons corrective action program did not assure that a condition adverse to quality associated with heat trace on the A emergency diesel generator fuel oil line was promptly corrected.

On November 11, 2018, Exelon discovered that heat trace circuit No. 3 for the fuel line to the A EDG was not drawing current when the thermostat was set to turn it on. The heat tracing is thermostatically controlled to maintain the fuel oil in the line above 40 °F during the winter. This ensures that EDG fuel oil temperature is maintained above its cloud point temperature below which it becomes more resistant to flow, which can adversely impact the operability of the EDG. On January 3, 2019, the inspectors determined that, although the heat trace circuits degraded condition was identified before the winter season started, repairs to the affected heat trace circuit were not scheduled until May 15, 2019, after the winter season ended. The inspectors concluded that Exelons actions did not assure that the degraded heat trace circuit was promptly corrected. In response to the inspectors concern, Exelon repaired the degraded circuit on January 10, 2019.

Screening: The inspectors determined the performance deficiency was minor. The inspectors used the IMC 0612, Appendix B, More-than-Minor screening questions. A review of diesel fuel oil temperatures confirmed that temperatures at the location of the faulty heat trace never reached 5 °F, the current EDG fuel cloud point, and, therefore, EDG operability was not adversely impacted by the degraded heat trace.

Enforcement:

This failure to comply with 10 CFR, Part 50, Appendix B, Criterion XVI, Corrective Action, constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy. To correct the violation, Exelon repaired the degraded heat trace circuit and issued IR

EXIT MEETINGS AND DEBRIEFS

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

• On April 4, 2019, the inspectors presented the failure to promptly correct the heat trace on the A EDG fuel oil line when the malfunction was identified to Clyde Siverd and other members of the licensee staff.

• On July 16, 2019, the inspectors presented the integrated inspection results to Mr. William Carsky, Site Vice President and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Miscellaneous Ginna 2018 Summer Readiness Critique

Procedures O-23, Hot Weather Seasonal Readiness Walkdown 017

WC-AA-107 Seasonal Readiness Critique 021

71111.11Q HU-AA-1211, Pre-Job Briefings 15

OP-AA-101-113-1006, 4.0 Crew Critique Guidelines, 10

Revision

TQ-GI-150-F31 (LORT), Ginna Site Specific License 9

Operator Requalification Training Program

71111.12 ER-AA-310, Implementation of the Maintenance Rule 12

ER-AA-310-1001, Maintenance Rule - Scoping 4

ER-AA-310-1002, Maintenance Rule Functions - Safety 3

Significance Classification

ER-AA-310-1003, Maintenance Rule - Performance Criteria 5

Selection

ER-AA-310-1004, Maintenance Rule - Performance 14

Monitoring

ER-AA-310-1005, Maintenance Rule - Dispositioning 7

Between (A)(1) and (A)(2)

71111.13 OPG-PROTECTED-EQUIPMENT, Operations Protected 21

Equipment Program

71111.15 Corrective Action 04231038

Documents 04255886

255886

255750

Miscellaneous OPEVAL-19-001, FE-910 leakage

OPEVAL-19-002, B Service Water Pump

OPEVAL-19-003, FE-910 leakage

Adverse Condition Monitoring and Contingency Plan, GSU

B-Phase HV Bushing Bolted Connection Elevated

Temperature

71111.18 Engineering ECP-19-000203, Relocation of Valve 5492D 01

Changes

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.19 Miscellaneous MA-AA-716-004 Attachment 1, Troubleshooting log for

Control Rod K07

Procedures MA-AA-716-004, Conduct of Troubleshooting 16

71111.20 OP-AA-108-108, Unit Restart Review 020

71111.22 Miscellaneous CTP-IST-001 Appendix 1, Evaluation of Precondition

Acceptability, Starting Diesel with both SOVs in service prior

to STP-O-12.2

Procedures CH-PRI-SAMP-ROOM, Sampling in the Nuclear Sample 06000

Room

CY-AA-130-3010, Dose Equivalent Iodine Determination 06

ER-AA-321-1007, Inservice Testing (IST) Program 02

Corporate Technical Positions

71152 Corrective Action 04194155

Documents 04231969

228793

214486

04170132

2578700

04091493

Corrective Action 04236387*

Documents

Resulting from

Inspection

Drawings 68-166A Heat tracing Systems - Ginna Station Revision 3

D-304-281 Miscellaneous Piping (Diesel Generator Building) Plan & Revision 8

Section

Engineering ECP-09-000374 Replace Heat Trace Circuit Three with Equivalent Delta- Revision 000

Changes Therm Series (PT) Cable

Procedures CH-190 Diesel Fuel Oil Testing Program Revision

00900

M-1306.1 Station Electrical Maintenance Winterizing Inspection Revision 029

Program

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

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

Inspection Type Designation Description or Title Revision or

Procedure Date

WC-AA-106 Work Screening and Processing Revision 18

Work Orders C90671247

C93687250

71153 Corrective Action 04227333

Documents

Miscellaneous PI-AA-125-1003, Attachment 2 Corrective Action Program

Evaluation Report Template, V-3652 Tripped During

Performance of STP-O-16QT

Procedures PI-AA-125-1003, Corrective Action Program Evaluation

Manual, Revision 004

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