IR 05000244/2020004

R. E. Ginna Nuclear Power Plant, LLC: Integrated Inspection Report 05000244/2020004

ML21033A859
Person / Time
Site:	Ginna
Issue date:	02/08/2021
From:	Ed Miller Division Reactor Projects I
To:	Rhoades D Exelon Generation Co, Exelon Nuclear
References
IR 2020004
Download: ML21033A859 (14)

Text

February 8, 2021

SUBJECT:

R. E. GINNA NUCLEAR POWER PLANT, LLC - INTEGRATED INSPECTION REPORT 05000244/2020004

Dear Mr. Rhoades:

On December 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at R. E. Ginna Nuclear Power Plant, LLC. On January 19, 2021, 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 violations 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: Eric D. Miller Eric D. Miller, Acting 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: 05000244/2020004 Enterprise Identifier: I-2020-004-0034 Licensee: Exelon Generation Company, LLC Facility: R. E. Ginna Nuclear Power Plant, LLC Location: Ontario, New York Inspection Dates: October 01, 2020 to December 31, 2020 Inspectors: J. Schussler, Senior Resident Inspector S. Monarque, Resident Inspector T. Fish, Senior Operations Engineer P. Ott, Operations Engineer S. Shaffer, Senior Health Physicist Approved By: Eric D. Miller, Acting Chief Reactor Projects Branch1 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 100 percent power. The unit remained at, or near, 100 percent 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 (COVID-19), resident and regional inspectors were directed to begin tele-work and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week, increasing the amount of time on site as local COVID-19 conditions permitted. As part of their onsite activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D; 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 portion 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 on December 28, 2020:

• A and B emergency diesel generator space

• Beyond design basis equipment storage trailers

• Auxiliary feedwater pump and water supply tanks

• A and B station batteries

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (1 Sample)

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

(1) 'A' emergency diesel generator pre-startup alignment following a scheduled surveillance test on October 23, 2020

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the wet fire protection piping and components located in all levels of the turbine and auxiliary buildings after system failures and associated maintenance on November 17 and 18, 2020

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 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) Turbine Building oil storage room on October 9, 2020

(2) Canister Preparation Building on October 20, 2020

(3) 'B' emergency diesel generator cable vault on October 27, 2020

(4) Turbine Building basement on November 19, 2020

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 exams administered October -

November, 2020.

71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)

(1) Biennial Requalification Written Examinations The inspectors evaluated the quality of the licensed operator biennial requalification written examinations administered January - February, 2020.

Annual Requalification Operating Tests The inspectors evaluated the adequacy of the facility licensees annual requalification operating test.

Administration of an Annual Requalification Operating Test The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.

Requalification Examination Security The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.

Remedial Training and Re-examinations The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.

Operator License Conditions The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.

Control Room Simulator The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.

Problem Identification and Resolution The inspectors evaluated the licensees ability to identify and resolve problems associated with licensed operator performance.

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 and procedure use and adherence in the main control room during a turbine driven auxiliary feedwater pump operation test and associated power reduction on December 8, 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 examinations on November 12, 2020. The examination involved a scenario that contained, but was not limited to, a loss of all offsite power, turbine vibrations, rapid load reduction, reactor coolant leak, and main steam safety valves failing open.

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 (SSCs) remain capable of performing their intended function:

(1) Service air compressor system 12 on December 2, 2020

(2) Engineered safety features actuation relays system 42C on December 15, 2020

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (4 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, (action green), during planned replacement of station 13A switchyard offsite power 767 circuit transformer 6 on October 13, 2020

(2) Elevated risk, (action green), during planned major maintenance of 'B' emergency diesel generator on October 28, 2020

(3) Elevated risk, (green), during application of a freeze seal in the service water system to facilitate unplanned replacement of service water valve 4687 on October 30, 2020

(4) Elevated risk, (action green), during planned maintenance of hydrogen supply and vent to the chemical volume control system following an action by chemistry to release volume control tank gases on December 17, 2020

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) Turbine building eight inch fire piping elbow failure analysis on November 16, 2020

(2) 'A' emergency diesel primary fuel filter elevated differential pressure and filter selector valve seal failure on December 11, 2020

(3) Safety injection relief valve 1817 raised face flange over torque bolting and flange analysis on December 14, 2020

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (3 Samples)

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

(1) Operational testing of the 'B' emergency diesel generator, following planned maintenance on November 5, 2020

(2) Pressure testing of turbine driven auxiliary feedwater steam supply piping following planned maintenance to replace check valve 3504B inspection port plug and gasket on December 8, 2020

(3) Operational testing of the 'B' emergency diesel generator fuel oil transfer pump following planned replacement of the pre-lube pump on December 16, 2020

71114.06 - Drill Evaluation

Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated a simulator training evolution involving an Alert declaration based on any loss or any potential loss of fuel cladding or reactor coolant system barrier due to loss of a reactor coolant system barrier. This clarification was identified by a safety injection actuation due to reactor coolant system leakage on October 20,

71124.04 - Occupational Dose Assessment

Source Term Characterization (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.

External Dosimetry (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to external dosimetry that is used to assign occupational dose.

Internal Dosimetry (IP Section 03.03) (1 Sample)

The inspectors evaluated the following internal dose assessments for actual internal exposures:

(1) The inspectors reviewed air sample results for work on the installation of the cavity seal. The highest air sample activity was

.022 DAC for air sample 201103. No

internal dose was assigned.

Special Dosimetric Situations (IP Section 03.04) (1 Sample)

The inspectors evaluated the following special dosimetric situations:

(1) The dose assessment for two declared pregnant workers.

71152 - Problem Identification and Resolution

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

(1) The inspectors reviewed Exelons corrective action program for potential adverse trends that might be indicative of a more significant safety issue on December 22, 2020

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

(1) 'B' standby auxiliary feedwater pump outboard bearing failure, AR 04313757, on December 7,

INSPECTION RESULTS

Minor Violation 71152 Minor Violation: Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basisare correctly translated into specifications, drawings, procedures, and instructions. These measures shall include provisions to assure that appropriate quality standards are specified and included in design documents. Contrary to the above, from 1977 to 2020, Exelon did not correctly translate a vendor design document related to the D standby auxiliary feedwater pump design basis into specifications, drawings, procedures, and instructions. Specifically, Vendor Technical Manual VTD-I0075-4003, Instructions for Auxiliary Feed Water Pumps, specified the installation of an oil ring on the thrust end bearing, and an oil level of 1-3/4 from the centerline of the oil level bubbler. However, in 1977, during pump acceptance testing, the license holder at the time removed, and did not reinstall the oil ring, or adjust oil level. Consequently, on January 29, 2020, following planned D standby auxiliary feedwater pump maintenance, the thrust end bearing failed during post maintenance testing.

Screening: The inspectors determined the performance deficiency was minor. The inspectors independently evaluated the deficiency for significance in accordance with the guidance in IMC 0612, Appendix B, Additional Issue Screening Guidance, issued December 12, 2019 and Appendix E, Examples of Minor Issues, issued December 23, 2019. The inspectors determined that the vendor design document related to the design basis of the pump not correctly translating into specifications, drawings, procedures, and instructions did not adversely affect the mitigating systems cornerstone objectives since maintenance was on the pump bearing and the failure was during post maintenance testing prior to returning the component to service.

Enforcement:

This failure to comply with Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III, Design Control, constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Observation: 'D' Standby Auxiliary Feedwater Pump outboard bearing failure 71152 The inspectors reviewed Exelons corrective action program evaluation, work orders, extent of condition reviews and corrective actions associated with the failure of the D standby auxiliary feedwater pump outboard thrust bearing. Exelon entered this issue into their corrective action program as IR 04313757. The inspectors assessed Exelons problem identification threshold, causal analysis, prioritization, and timeliness of corrective actions to determine whether Exelon had taken timely and appropriate corrective actions.

The inspectors observed that Exelon performed a thorough review of the issue and determined the cause of the bearing failure was overheating from a lack of lubrication due to low oil level. Exelons immediate corrective actions were to declare a failure of the post maintenance test which kept the pump inoperable, replace the bearing, and revise the bearing oil level to account for not having an oil ring installed. Additionally, the inspectors noted Exelon has verified the oil level for the C standby auxiliary feedwater pump outboard bearing, which also does not have an oil ring. Lastly, the inspectors noted that Exelon issued a design equivalent change package to reconcile the actual configuration, including oil level, with the design, and maintenance documents.

The inspectors independently reviewed the engineering change package which adjusted bearing oil level, the bearing failure analysis report, and operability determination. At the time of Exelons immediate corrective actions, the inspectors observed the in-field maintenance activities to replace the bearing and adjust oil level. Additionally, the inspectors reviewed work orders from 1994 in order to evaluate past maintenance practices, previous and current problem identification and associated corrective actions. The inspectors determined that Exelons actions in identifying and resolving the issue was appropriate, timely, and commensurate with the safety significance.

Observation: Corrective Action Semiannual Trend Review 71152 The inspectors reviewed Exelons corrective action program for trends that might be indicative of a more significant safety issue on December 22, 2020. The inspectors evaluated a sample of issues and events that occurred over the course of the third and fourth quarters of 2020 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 corrective action program 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 low level or precursor trends identified by Exelon staff in the areas of human performance tools and techniques.

There were no adverse safety consequences as a result of these low level trend issues.

Based on the overall results of the semiannual 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.

EXIT MEETINGS AND DEBRIEFS

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

• On January 19, 2021, 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

71111.01 Corrective Action 04391123 NRC Identified - Low Temperature in FLEX Robust Storage 12/28/2020

Documents Buildings

Resulting from

Inspection

Procedures O-22 Cold Weather Walkdown Procedure Revision 028

71111.04 Corrective Action 04385165 Cracked Gaskets on V-9225 flanges 11/18/2020

Documents 04385398 NRC Fire Problem Identification and Resolution: Skewed 11/19/2020

Resulting from Pipe hanger near Fire Water Storage Tank

Inspection

71111.15 Corrective Action 04376953 'B' battery room water intrusion 10/15/2020

Documents 04376964 'B' battery room conduit bolts loose 10/15/2020

Resulting from 04385202 Dried boric acid on drainpipe downstream of V-2826A 11/08/2020

Inspection 04387299 Flow indicator 2012 became noisy after auxiliary feedwater 12/01/2020

test

04390110 Condition of flange for valve 861 12/14/2020

Engineering GIN-66275 Failure analysis of 8" fire protection piping 10/16/2020

Evaluations

Engineering OpEVAL-20-005 Relief Valve 1817 raised face flange for safety injection relief 11/10/2020

Evaluations valve over torqued

71111.19 Corrective Action 04379899 Failed White Light Testing for Bus 17 EDG supply Breaker 10/27/2020

Documents 04379962 PS-2886 found out of service 10/27/2020

04379973 Wires too short on FAL-2047/Fall-2048 10/27/2020

04380060 TS-2091 was found out of service 10/28/2020

04380094 Sluggish contactor for EDG B jacket water Heaters 10/28/2020

04380129 PI-2859 found out of service 10/28/2020

04380679 EDG Pre lube pump out of acceptance Criteria 10/29/2020

04380695 Union found loose upstream of SOV 5943A during EDG start 10/29/2020

Work Orders C93693174 Replace all Hoses on Jacket Water and Fuel Oil and Lube 10/27/2020

Systems Flush all new Fuel Oil Systems Hoses

C93723464 Inspect/Clean Fuel Oil Transfer System Strainers- 10/26/2020

NDG03/NDG08

C93723473 Diesel Generator B Starting Air Motor - Changeout Motor 10/27/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

with Spare from Stock

C93723474 Diesel Generator B - Mechanical Preventive Maintenance 10/26/2020

Inspection

71152 Corrective Action 04376395 KDG09 NFPA 805 DG Alarms 10/13/2020

Documents 04376629 Oil residue on MOV-9703A 10/13/2020

Resulting from 04376631 Oil residue on MOV-9703B 10/13/2020

Inspection 04383212 Small packing leak from S03 isolation V-9240 11/09/2020

04385165 Cracked gaskets on V-9225 flanges 11/18/2020

04387859 Typographical error in TRM 12/03/2020

04385202 Dry Boric Acid on Drain Piping Downstream of V-2826A 11/18/2020

Corrective Action PSF01B Standby Auxiliary Feed Water Pump Outboard

Program Bearing Loud Noise

Engineering ECP-20-000053 Standby Auxiliary Feedwater Pump Outboard Bearing Oil 0.1

Evaluations Level and Housing Conditions

Procedures Vendor Technical Instructions for Auxiliary Feed Water Pumps

Manual VTD-

I0075-4003

2