IR 05000244/2020001

LLC: Integrated Inspection Report 05000244/2020001 and Independent Spent Fuel Storage Installation Report 07200067/2020001

ML20127H676
Person / Time
Site:	Ginna
Issue date:	05/06/2020
From:	Erin Carfang Reactor Projects Branch 1
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
References
IR 2020001
Download: ML20127H676 (14)

Text

May 6, 2020

SUBJECT:

R.E. GINNA NUCLEAR POWER PLANT, LLC - INTEGRATED INSPECTION REPORT 05000244/2020001 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION REPORT 07200067/2020001

Dear Mr. Hanson:

On March 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at R.E. Ginna Nuclear Power Plant, LLC. On April 15, 2020, the NRC inspectors discussed the results of this inspection with Mr. Paul Swift, 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 findings or violation of more than minor significance during this inspection.

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, X /RA/

Signed by: Erin E. Carfang Erin E. Carfang, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket No. 05000244 and 07200067 License No. DPR-18

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000244 and 07200067 License Number: DPR-18 Report Numbers: 05000244/2020001 and 07200067/2020001 Enterprise Identifiers: I-2020-001-0067 I-2020-001-0021 Licensee: Exelon Generation Company, LLC Facility: R.E. Ginna Nuclear Power Plant, LLC Location: Ontario, NY Inspection Dates: January 01, 2020 to March 31, 2020 Inspectors: J. Schussler, Senior Resident Inspector S. Monarque, Resident Inspector J. Brand, Reactor Inspector J. Nicholson, Senior Health Physicist 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 an 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

None.

PLANT STATUS

Ginna began the inspection period at rated thermal power. On March 26, 2020, the unit began gradually lowering power as it entered end-of-cycle coast down operations 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/readingrm/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. From January 1 - March 19, 2020, 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.

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 (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 during which they conducted plant status activities as described in IMC 2515, Appendix D, and observed risk significant activities when warranted. 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 the cases where it was determined the objectives and requirements could not be performed remotely, management elected to reschedule the inspection to a later date.

71111.01 - Adverse Weather Protection

External Flooding Sample (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the 'A' and 'B' battery rooms, the standby auxiliary feedwater rooms and annex door and aqua fence for readiness to cope with external flooding on January 15 and 16, 2020

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (4 Samples)

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

(1) 'A' motor driven auxiliary feedwater following post maintenance operability test on January 13, 2020

(2) 'D' standby motor driven auxiliary feedwater following corresponding system maintenance window on February 3, 2020

(3) 'A' residual heat removal following quarterly surveillance test on March 6, 2020

(4) 'A' safety injection following quarterly surveillance test on March 12, 2020

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (1 Sample)

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) 'B' emergency diesel generator on January 27, 2020

71111.06 - Flood Protection Measures

Cable Degradation (IP Section 03.02) (1 Sample)

The inspectors evaluated cable submergence protection in:

(1) Manhole/vaults MH-1, MH-1A, and MH-1B on March 4, 2020

71111.07A - Heat Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) Standby motor driven auxiliary feedwater room cooler AFA01B on March 26, 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 main control room during an announced fire drill on January 29, 2020 and operators' procedure use and adherence to perform a reactor coolant system alternate dilution, nitrogen make-up to 'B' safety injection accumulator and shift turnover on February 24, 2020.

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 March 2, 2020. The training involved a scenario that contained, but was not limited to, a dropped control rod, fuel failure, loss of all offsite power, faulted steam generator, and a failure of containment recirculation fan coolers coincident with a failure of containment spray automatic initiation signal.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

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

(1) Containment isolation, function 21B, (a)(1) determination on March 31, 2020

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)

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) Elevated risk (green), during 'A' motor driven auxiliary feedwater speed reducer coupling planned maintenance on January 13, 2020

(2) Elevated risk (green), during planned system maintenance window for 'D' standby motor driven auxiliary feedwater pump, motor, and room cooler on January 28, 2020

(3) Elevated risk (yellow), during a planned system maintenance window of the boric acid storage tank and associated valves on February 11, 2020

(4) Elevated risk (yellow), during a planned system maintenance window associated with the 'A' emergency diesel generator on February 12, 2020

(5) Elevated risk (yellow), during planned maintenance on breaker 52/BTA-A, Bus 12A/

Bus 11A tie breaker on March 27, 2020

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)

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

(1) Low frequency failure of the motor operated potentiometer a subcomponent of the A' emergency diesel generator Woodward governor on February 7, 2020

(2) 4R Kiene valve not fully closed on the 'B' emergency diesel generator on March 7, 2020

(3) 'D' standby motor driven auxiliary feedwater outboard pump bearing failure on March 24, 2020

(4) 'B' motor driven auxiliary feedwater solenoid valve SOV-4326 replacement due to inadequate service water flow on March 26, 2020

71111.18 - Plant Modifications

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

(1 Sample)

(1) Permanent modification of D standby motor driven auxiliary feedwater pump outboard bearing ECP-20-00053 on March 17, 2020

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (4 Samples)

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

(1) 'A' motor driven auxiliary feedwater pump surveillance test and vibration analysis, following planned maintenance and retorquing of the speed reducer coupling on January 14, 2020

(2) 'C' standby motor driven auxiliary feedwater pump surveillance test following planned pump and motor maintenance on February 12, 2020

(3) 'B' motor driven auxiliary feedwater surveillance test following unplanned service water solenoid valve 4326 replacement on February 25, 2020

(4) 'D' standby motor driven auxiliary feedwater pump surveillance test following planned motor and pump maintenance and unplanned outboard pump bearing replacement on March 2, 2020

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Partial)

(1) (Partial)

The inspectors observed new fuel receipt activities on January 23, 2020 and February 6, 2020.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) STP-O-30.10, 'A' emergency diesel generator pre-startup alignment and STP-O-12.1,

'A' emergency diesel generator on January 16, 2020

(2) STP-E-10.10, station battery 'A', quarterly on March 10, 2020

(3) STP-O-2.1-COMP, safety injection pump 'A' comprehensive test on March 11, 2020

(4) STP-O-2.8Q, component cooling water pump 'B' quarterly test on March 23, 2020

(5) STP-O-2.1-COMP, safety injection pump 'C', on March 27, 2020

Inservice Testing (IP Section 03.01) (1 Sample)

(1) STP-O-2.2QA, 'A' residual heat removal pump quarterly, on March 2,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below on March 30, 2020.

IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) ===

(1) Submitted data from January 1, 2019 - December 31, 2019 IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02)

(1 Sample)

(1) Submitted data from January 1, 2019 - December 31, 2019

IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (1 Sample)

(1) Submitted data from January 1, 2019 - December 31, 2019

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)

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

(1) Review of Exelon's evaluation and corrective actions associated with safety related pumps and machinery oil sampling process. AR 04278159 and AR

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

60854.1 - Preoperational Testing of Independent Spent Fuel Storage Facility Installation at Operating Plants Preoperational Testing of Independent Spent Fuel Storage Facility Installation at Operating Plants

(1) The inspectors evaluated Exelons performance during NRC observed preoperational dry run activities that were performed in order to fulfill requirements in the Certificate of Compliance (CoC) No. 1014, Condition 10. The inspectors observed dry run activities on March 16-17, 2020. Specifically, the inspectors observed or reviewed the following activities;

• Closure welding of an MPC mockup including lid to shell, port covers, and closure ring

• Non-destructive weld evaluations including visual and penetrant testing

• Simulated radiological field surveys and RP coverage of welding activities

• Reviewed a recording of PCI welding personnel cutting open a welded canister mock-up removing the port covers and lid that was witnessed by NRC personnel

INSPECTION RESULTS

Observation: PI&R Sample Inspection Regarding Pump Bearing Oil Sampling 71152 Process The inspectors reviewed Exelons evaluation, extent of condition reviews, and corrective actions associated with two problems involving safety related pump oil sampling and analysis. The first problem was documented in AR 04278159 and involved a safety injection pump lubricating oil sample that was not submitted for analysis as required by Ginna procedures. The second problem was documented in AR 04259000 and involved a low viscosity result from a turbine driven auxiliary feedwater pump inboard bearing lubrication oil sample. Exelon determined the oil sample for the 'A' safety injection pump was not submitted for sampling due to a human performance error and was an isolated event. Additionally, Exelon determined the low viscosity reading on the turbine driven auxiliary feedwater pump was likely a sampling error in that the oil sample was likely taken from the turbine bearing instead of the pump bearing. The readings obtained were consistent with normal readings for the turbine lubricating oil. Exelon's corrective actions included revisions to the labeling process for lubricating oil samples and training to applicable personnel. Exelon determined operability of the safety injection pump and the turbine driven auxiliary feedwater pump was not impacted since the pumps oil reservoirs are small such that a full oil replacement is done every time an oil sample is taken. The inspectors performed visual inspections of all the safety injection and turbine driven auxiliary feedwater pumps, interviewed Exelon's system engineer, the component maintenance optimization engineer, and reviewed applicable safety injection and turbine driven auxiliary feedwater pump vibration and lubricating oil data. In addition, the inspectors verified the safety injection and turbine driven auxiliary feedwater pump surveillance test results were satisfactory and vibration data and bearing temperatures remained normal to date. The inspectors concluded the problem evaluations identified the likely causes and the corrective actions addressed the causes. Additionally, the inspectors affirmed the extent of condition by independently reviewing associated corrective actions issues involving Exelons lubricating oil process at Ginna for the last three years. The inspectors did not identify a negative trend in human performance issues.

EXIT MEETINGS AND DEBRIEFS

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

• On January 17, 2020, the inspectors presented the PI&R Sample Safety Related Pumps and Machinery Oil Sampling Process inspection results to George Wrobel, Regulatory Assurance Manager and other members of the licensee staff.

• On March 17, 2020, the inspectors presented the Preoperational Testing of an Independent Spent Fuel Storage Installation inspection results to Michael Cazzolli, Senior Manager Dry Cask Storage, and other members of the licensee staff.

• On April 15, 2020, the inspectors presented the integrated inspection results to Mr. Paul Swift, Site Vice President and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

60854.1 Miscellaneous Certificate of HI-STORM 100 System Amendment

Compliance 13

(CoC) No. 1014

Procedures PI-CNSTR-OP- Closure Welding of Holtec Multi-Purpose Canisters-HI- Revision 4

HLTC-H-01 STORM 100, HI-STAR100, HI-STORM FW & UMAX

Systems

71111.01 Corrective Action 04095305

Documents

Corrective Action 04318485

Documents

Resulting from

Inspection

Miscellaneous ME-91-0022, Analysis of Penetrations in A & B Battery 11/20/92

Rooms NCR 91-410

ECP-14-000571, External Flood Barrier Qualification Revision 1

WO-C91729814, FPS-3, Periodic Inspection of Fire Barrier Completed

Penetration Seals 12/08/12

DA-CE-93-081, Turbine Building Pressure Wall Seals Revision 1

DA-ME-94-118-11, Fire Barrier Penetration Seal 01/08/15

Qualification Analysis for Pipe, Conduit, Sleeve Penetrations

(PENQ-11)

Procedures FSP-3, Fire Barrier Inspection Program Revision 4

FPS-2, Fire Barrier Penetration Seal Program Revision 9

71111.04 Corrective Action 04312620

Documents 04312630

Resulting from

Inspection

Procedures STP-O-30.1 Safety Injection System valve and Breaker Position Revision 002

Verification

STP-O-30.2 RHR System Valve and Breaker Position Verification Revision 001

STP-O-30.3 Containment Spray System Valve and Breaker Position Revision 002

Verification

Inspection Type Designation Description or Title Revision or

Procedure Date

STP-O-30.4 Auxiliary Feedwater System Valve and Breaker Position Revision 006

Verification

STP-O-30.5 Standby Auxiliary Feedwater Pumps Valves and Breakers Revision 006

71111.05 Corrective Action 04312954

Documents

Resulting from

Inspection

71111.06 Work Orders C93694434 Perform manhole Inspections for the Off-Site Power Circuits 01/16/2019

71111.07A Procedures C93681177-130 71 Standby Auxiliary Feedwater Room Cooler B

ER-AA-340-1002 Service Water Heat Exchanger Inspection Guide Revision 9

71111.13 Procedures OPG-Protected- Equipment Operations Protected Revision 22

Equipment Program

71111.15 Corrective Action 04313757 SAFW bearing

Documents

Operability AR 04299839 Kiene Valve

Evaluations AR 04303106 Low frequency 'A' EDG

OPEVAL-20-001 'B' MDAFW pump service water flow, SOV-4326

71111.18 Procedures ECP-20-000053 SAFW Pump Outboard Bearing Oil Level and Housing Revision 001

Conditions

71111.19 Corrective Action AR 04313441 Pitting Discovered During Eddy Current Exam of AFA01B 01/28/2020

Documents room cooler coil, maintains Standby Auxiliary Feedwater

Pump Building less than 120F during accident conditions

Drawings 33013-1238 Standby Auxiliary Feedwater (FW) P&ID 43

Procedures CPI-FLO-4085 Calibration of Standby Auxiliary Feedwater Pump D Flow Revision 019

4085

CPI-TEMP- Calibration of SAFW Pump Room Cooling Unit B Revision

CNTRL-4012 Instrumentation TS-4012, FS-4014, and TS-4015 00700

STP-O-16QA Auxiliary Feedwater Pump A - Quarterly Revision 21

STP-O-36- Standby Auxiliary Feedwater Pump D- Comprehensive Test Revision 018

COMP-D

Work Orders C93699666 Swap Out RV-9709B with a Tested Spare 03/01/2019

71111.20 Work Orders C93683207 2020 New Fuel Receipt 10/09/2018

71111.22 Corrective Action 04313852

Documents 04320096

Inspection Type Designation Description or Title Revision or

Procedure Date

Resulting from 04310143

Inspection 04314976

04310287

Procedures STP-E-10.10 Station Battery A Quarterly Surveillance Revision 002

STP-O-12.1 Emergency Diesel Generator A Revision 32

STP-O-2.1- Safety Injection Pump A Comprehensive Test Revision 017

COMP-A

STP-O-2.1- Safety Injection Pump C Comprehensive Test Revision 012

Comp-C

STP-O-2.2QA Residual Heat Removal Pump A Inservice Test Revision 020

STP-O-2.8Q Component Cooling Water Pump Quarterly Test Revison 017

STP-O-30.10 Emergency Diesel Generator A Pre-Startup Alignment Revision 14

71151 Corrective Action 04331235

Documents 04330853

Resulting from

Inspection

71152 Corrective Action 04092244

Documents 04192168

04192755

214234

259000

259035

260128

278159

04310109* * Initiated in response to this inspection

Corrective Action 04310109

Documents 04313239

Resulting from

Inspection

Work Orders C93262117

11