IR 05000244/2020013
| ML21047A131 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 02/17/2021 |
| From: | Mel Gray NRC/RGN-I/DRS/EB |
| To: | Rhoades D Exelon Generation Co |
| References | |
| IR 2020013 | |
| Download: ML21047A131 (10) | |
Text
February 17, 2021
SUBJECT:
R. E. GINNA NUCLEAR POWER PLANT, LLC - DESIGN BASIS ASSURANCE INSPECTION (PROGRAMS) INSPECTION REPORT 05000244/2020013
Dear Mr. Rhoades:
On January 15, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at R. E. Ginna Nuclear Power Plant, LLC. On January 22, 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.
No findings or violations of more than minor significance were identified 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: Melvin K. Gray
Mel Gray, Chief Engineering Branch 1 Division of Reactor Safety
Docket No. 05000244 License No. DPR-18
Enclosure:
As stated
Inspection Report
Docket Number:
05000244
License Number:
Report Number:
Enterprise Identifier: I-2020-013-0003
Licensee:
Exelon Generation Company, LLC
Facility:
R. E. Ginna Nuclear Power Plant, LLC
Location:
Ontario, New York
Inspection Dates:
November 02, 2020 to November 20, 2020
Inspectors:
P. Cataldo, Senior Reactor Inspector
D. Kern, Senior Reactor Inspector
E. Miller, Senior Resident Inspector
Approved By:
Mel Gray, Chief
Engineering Branch 1
Division of Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a design basis assurance inspection (programs) 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 URI 05000244/2020013-01 Procedure Adequacy to Verify Supplemental Indications when Performing Inservice Test (IST) Valve Position Indication Verification (valves 3411, 4269)71111.21N.02 Open
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.
REACTOR SAFETY
71111.21N.02 - Design-Basis Capability of Power-Operated Valves Under 10 CFR 50.55a Requirements POV Review (IP Section 03)
The inspectors:
a. Determined whether the sampled power operated valves (POVs) are being tested and maintained in accordance with NRC regulations along with the licensees commitments and/or licensing bases.
b. Determined whether the sampled POVs are capable of performing their design-basis functions.
c. Determined whether testing of the sampled POVs is adequate to demonstrate the capability of the POVs to perform their safety functions under design-basis conditions.
d. Evaluate maintenance activities including a walkdown of the sampled POVs (if accessible).
(1)516, Reactor Coolant Pressurizer - Pressurizer Power Operated Relief Valve (PORV)
Block Valve (2)704B, Residual Heat Removal - RHR Pump B Suction Motor Operated Valve (3)850A, Residual Heat Removal - RHR Pump Motor Operated Suction from Containment Sump A (4)857C, Residual Heat Removal - RHR Pump Motor Operated Discharge to Safety Injection Pump Suction (5)3504A, Main Steam - MOV For Steam Generator B Main Steam Supply to PAF03 (Turbine Driven AFW Pump)
(6)4615, Service Water - Auxiliary Building SW Isolation Valve (7)431C, Reactor Coolant Pressurizer - Pressurizer Power Operated Relief Valve (8)3411, Main Steam - Steam Generator B Atmospheric Relief Valve (ARV)
(9)4269, Main Feedwater - Main FW Control Air Operated valve (AOV) To Steam Generator A (10)4562, Service Water - Air Operated Bypass of Valve 4561 (Containment Fan Coolers SW Outlet Flow Control)
INSPECTION RESULTS
Unresolved Item (Open)
Procedure Adequacy to Verify Supplemental Indications when Performing Inservice Test (IST) Valve Position Indication Verification (valves 3411, 4269)
URI 05000244/2020013-01 71111.21 N.02
Description:
The inspectors identified an unresolved item (URI) while reviewing completed maintenance records to verify the ASME OM-2012 ISTC-3700 Position Verification Testing (VPI) requirements were properly completed for steam generator atmospheric relief valve 3411 and main feedwater control valve 4269. ISTC-3700 states valves with remote position indicators shall be observed locally at least once every 2 years to verify valve operation is accurately indicated. Where practicable, this local observation should be supplemented by other indications such as use of flow meters or other suitable instrumentation to verify obturator position. The observations of local and supplemental plant indications (SPI) need not be concurrent. Title 10 Code of Federal Regulations (CFR) 50.55a(b)(3)(xi) requires that when implementing ASME OM-2012 ISTC-3700, licensees shall (vs "should") verify that valve operation is accurately indicated by supplementing valve position indicating lights with other indications such as flow meters or other suitable instrumentation, to provide assurance of proper obturator (valve disc) position.
The inspectors determined Exelon staff at the Ginna plant last completed Procedure STP-O-2.6.1, Main Steam Atmospheric Relief Valve Exercise, Revision 3 on 4/13/20 to meet the biennial ISTC-3700 VPI test requirements for valve 3411. The inspectors also determined Exelon staff last completed Procedure STP-O-R-1.5, Valve Interlock Verification - Feedwater Isolation, Revision 3, on 4/26/20 to meet the same requirements for valve 4269. The inspectors determined Procedures STP-O-2.6.1 and STP-O-R-1.5 required operators to observe the valves locally and verify agreement between local and remote valve position indicators. However, the procedures did not include instructions or acceptance criteria to address observation of supplemental plant indications.
The inspectors determined the last performance of IST-3700 test requirements for valves 3411 and 4269, prior to Ginna implementing the ASME OM-2012 code, was on10/29/18 and 11/05/18 respectively. Therefore, the inspectors concluded the requirement to observe SPI when implementing IST-3700 valve position verification testing, was due on 10/29/20 and 11/05/20 respectively. The inspectors expressed concern that the requirements of 10CFR50.55a(b)(3)(xi) to observe SPI when implementing ISTC-3700 may not be met.
Exelon staff stated the requirements to implement SPI during valve position verification tests became effective on 1/1/20, when Ginna plant staff implemented the 6th 10-year IST Plan which also implemented the ASME OM-2012 code. Accordingly, the start date for the 2-year surveillance interval would be 1/1/20. Exelon staff stated they believe the SPI requirements of 10CFR50.55a(b)(3)(xi) were not required to be completed on any of the Ginna IST program valves until 1/1/22. Ginna plant engineers consulted with their Exelon Fleet Motor Operated Valve program owner and confirmed their position was consistent with guidance he previously provided to the other Exelon plants. Engineers informed the inspectors that Exelon had established a plan to implement SPI and test all required valves by 1/1/22.
The inspectors discussed the issue with Exelon staff and determined the issue is unresolved, awaiting inspector review of further guidance from the NRC Office of Nuclear Reactor Regulation to determine whether a performance deficiency exists regarding the SPI requirements imposed by 10CFR50.55a(b)(3)(xi). Specifically, the inspectors noted the timing of when SPI requirements, imposed by 10CFR50.55a(b)(3)(xi), were to be implemented was a topic discussed in a recent Reactor Oversight Process (ROP) monthly public meeting with stakeholders on December 8, 2021, and was planned to be concluded in future near term monthly public ROP meetings with stakeholders.
Planned Closure Actions: The inspectors plan to request further guidance from the NRC Office of Nuclear Reactor Regulation (NRR) regarding the due date for the Ginna plant to implement SPI requirements to assure proper obturator position when performing ISTC-3700 Position Verification Testing. Following receipt of the requested guidance from NRR, the inspectors plan to determine whether a performance deficiency exists.
Licensee Actions: Engineers reviewed historical SPI data (e.g., steam generator pressure, main steam isolation valve position, feedwater flow, feedwater control valve demand)recorded by the plant process computer during the plant shutdown immediately prior to the most recent refueling outage (4/5/20) and the subsequent plant restart (5/5/20). Engineers determined the data provided evidence that the valve stem and obturator for both the 3411 and 4269 valves were connected when each valve was repositioned to support the plant shutdown and/or startup evolution. Based on review of the SPI data, the inspectors determined the issue did not represent an immediate safety concern.
Corrective Action References: Not applicable.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On January 22, 2021, the inspectors presented the design basis assurance inspection (programs) inspection results to Mr. Paul Swift, Site Vice President and other members of the licensee staff.
- On November 20, 2020, the inspectors presented the Interim Status of NRC 2020 R. E. Ginna Design Basis Assurance Inspection (Power Operated Valve Programs)inspection results to Mr. Paul Swift, Site Vice President and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71111.21N.02 Calculations
CALC-2011-0017
Design Analysis of the Main Steam Atmospheric Relief
Valve 3410 & 3411 Replacement (ECP-11-000562, ECP-
11-000564)
Revision 0
DA-ME-2003-037
Valve 3411 AOV Program Basis Review Calculation
Revision 0
Corrective Action
Documents
04340259
CR-2008-003928
Corrective Action
Documents
Resulting from
Inspection
04381935
Oil Streak on 4269 Actuator
04382005
Oil Leak on 3504A Actuator
04382430
857C Packing Leakoff Line Conditions
04382562
Flange for 1817 Condition
04382734
IR Not initiated for Grade 3 Grease - MOV 850A
04382785
MOV-704B Documented Gasket Compression Below
Accept
04385385
Missed Peer Check
04385400
MOV-4615 Post Diagnostic Data Review Not Completed
04385488
Evaluate Potential Trend in Maintenance Procedure Use &
Adherence
04385624
IST Program Plan Deficiencies
04391510
MOV-3504A Differential Pressure Dynamic Test Delayed
from 2011 to 2012
04396703
Test Method for AOV 4562 is Inadequate
Engineering
Changes
109682-ME-339
Main Feedwater Regulating Valve Replacement - PCR
2004-0060
Revision 0
Engineering
Evaluations
ECP-17-000240
Anchor/Darling Double Disc Gate Valve Wedge Pin
Evaluation
Revision 2
EEQ-Package
01D
Main Feedwater Isolation Solenoid Operated Valves
Environmental Qualification Package
Revision 8
Miscellaneous
10-Year Interval (1/1/2020 - 12/31/2029)
Revision 0
R. E. Ginna Nuclear Power Plant Technical Specifications
Revision 95
ASME OM-2012
Operation and Maintenance of Nuclear Power Plants
Revision 0
NRC Memo
Integrated Plan Safety Assessment Report (IPSAR)
04/21/1983
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Section 4.14, Pipe Break Outside Containment R.E. Ginna
Nuclear Power Plant
Commitments for Resolution of Anchor Darling Double
Disc Gate Valve Part 21 Issues
2/19/2017
Procedures
AR-C-10
Containment Recirculation Coolers Water Outlet Low Flow
1050 gpm
Revision 1
MOV Rising Stem Motor Operated Valve Thrust and
Torque Sizing and Set-Up Window Determination
Methodology
Revision 11
Administrative Requirements for Inservice Testing
Revision 13
Inservice Testing of Motor Operated Valves
Revision 4
IP-IIT-2
Inservice Testing Program for Pumps and Valves
Revision 16
Periodic Inspection of Limitorque Model SMB/SB/SBD-000
Through 5 Motor Operated Valves, Revision 12
MA-GI-723-300
Diagnostic Testing of Motor Operated Valves
Revision 0
Daily Surveillance Log
05/01/2020
STP-O-2.3
Safeguard Power Operated Valve Operation
Revision 7
STP-O-2.5.5
Air Operated Valves and Manual Valve Quarterly
Surveillance - Clean Intermediate Building
Revision 12
STP-O-2.6.5
RCS Overpressure Protection System PORV Operability
Verification
Revision 4
Work Orders
C19221494
1993 - 4615 Stem Machining
C19601967
MOV-857C Lantern Leak Off Line Weld Repair
11/12/2011
C93264433
March 2017 Maintenance on 850A
C93302641
Limitorque Operator/Valve 4615 - Diagnostic Testing
Perform Static Testing per M-64.1.2
05/01/2020
C93624508
Calibrate Pressurizer Power Operated Relief Valve
(PORV) 431C
10/18/2018
C93625530
October 2018 Maintenance on 850A
C93687589
PMOT-431C
04/17/2020
C93690088
431C Diagnostic
04/17/2020
C93690691
Main Steam Atmospheric Relief Valve Exercise
04/13/2020
C93690798
STP-O-R-1.5, Feedwater Isolation - Valve 4269 PMOT
04/26/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
C93695313
516 PORV Block Valve Diagnostic Testing
C93696207
MOV-857C Exercise Test