IR 05000244/2022004
| ML23031A024 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 01/31/2023 |
| From: | Erin Carfang Division of Operating Reactors |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2022004 | |
| Download: ML23031A024 (1) | |
Text
January 31, 2023
SUBJECT:
R.E. GINNA NUCLEAR POWER PLANT, LLC - INTEGRATED INSPECTION REPORT 05000244/2022004
Dear David Rhoades:
On December 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at R.E. Ginna Nuclear Power Plant, LLC. On January 30, 2023, the NRC inspectors discussed the results of this inspection with Daren Blankenship, Senior Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this inspection 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, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at R.E. Ginna Nuclear Power Plant, LLC. 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 (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Erin E. Carfang, Chief Projects Branch 1 Division of Operating Reactor Safety
Docket No. 05000244 License No. DPR-18
Enclosure:
As stated
Inspection Report
Docket Number:
05000244
License Number:
Report Number:
Enterprise Identifier: I-2022-004-0033
Licensee:
Constellation Energy Generation, LLC
Facility:
R.E. Ginna Nuclear Power Plant, LLC
Location:
Ontario, New York
Inspection Dates:
October 1, 2022 to December 31, 2022
Inspectors:
J. Schussler, Senior Resident Inspector
C. Swisher, Resident Inspector
T. Fish, Senior Operations Engineer
T. Hedigan, Operations Engineer
S. Veunephachan, Health Physicist
Approved By:
Erin E. Carfang, Chief
Projects Branch 1
Division of Operating Reactor Safety
SUMMARY
The 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
Containment Spray Recirculation Valve 868D Valve Body Porosity Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000244/2022004-01 Open/Closed None 71111.15 The inspectors identified a Green non-cited violation of 10 CFR 50, Appendix B, Criterion XVI,
Corrective Action, when Constellation failed to establish measures to ensure a condition adverse to quality was promptly corrected. Specifically, Constellation failed to properly characterize and correct a borated water leak on containment spray recirculation valve 868D that was monitored from June 2013 to February 2021. In August 2022, the inspectors identified a dry deposit of boric acid on valve 868D, indicative of a borated water leak.
Constellation evaluated the condition and determined the leak to be a result of leakage through porosity in the valve casting, resulting in declaring the valve inoperable and requiring an unplanned entry into Technical Specification condition 3.6.3.A containment isolation boundaries on August 19, 2022.
Additional Tracking Items
None.
PLANT STATUS
Ginna began the inspection period operating at rated thermal power and remained at, or near, rated thermal power for 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 activities described in IMC 2515, Appendix D, Plant Status, conducted routine reviews using IP 71152, Problem Identification and Resolution, observed risk significant activities, and completed on-site portions of IPs. 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
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures of the following systems on December 21, 2022:
- Flex storage 'L' shaped building
- Battery rooms
External Flooding (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures associated with the AquaFence panels, and turbine building installation locations are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding on December 22, 2022
71111.04 - Equipment Alignment
Partial Walkdown (IP Section 03.01) (5 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)
'C' standby auxiliary feedwater train following surveillance testing on October 2, 2022 (2)
'B' residual heat removal train following surveillance testing on October 16, 2022 (3)
'A' loop service water train following maintenance on November 28, 2022 (4)
'A' component cooling water train following surveillance testing on November 30, 2022 (5)
'A' safety injection train following surveillance testing on December 19, 2022
Complete Walkdown (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the
'A' motor driven auxiliary feedwater system following planned maintenance and operational testing on December 2, 2022
71111.05 - Fire Protection
Fire Area Walkdown and Inspection (IP Section 03.01) (8 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) Flex storage 'L' shaped building on October 4, 2022
- (2) Turbine building basement on October 11, 2022
- (3) Auxiliary building intermediate level on October 17, 2022
- (4) Standby auxiliary feedwater building and annex on October 25, 2022 (5)
'A' battery room on October 25, 2022 (6)
'B' battery room on October 25, 2022
- (7) Auxiliary building basement level on December 18, 2022
- (8) Intermediate building controlled side basement on December 18, 2022
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 through November 2022
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 through February 2021.
Annual Requalification Operating Tests
The inspectors evaluated the adequacy of the facility licensees annual requalification operating test administered October 24 through 28, 2022.
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 in the main control room during:
'A' emergency diesel generator monthly testing and reactivity management on October 19, 2022
'A' motor driven auxiliary feedwater flowing to the steam generator on October 21, 2022
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 1, 2022 and November 16, 2022. The examination involved a scenario that contained, but was not limited to, a loss of pressurizer instrumentation channel, pressurizer relief valve failing open, offsite power disturbance, and a faulted steam generator
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 remain capable of performing their intended function:
- (1) Standby auxiliary feedwater diesel engine preventative maintenance plan on December 1, 2022
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following structures, systems and components remains capable of performing its intended function:
- (1) Commercial grade dedication of flow switch (purchase order 01332817) used in the standby auxiliary feedwater system and actuator diaphragm (purchase order
===01351064) used in the reactor coolant sampling system on November 23, 2022
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management (IP Section 03.01)===
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) Evaluation of plant risk (action green) during planned 'A' motor driven auxiliary feedwater pump maintenance and instrumentation calibration on October 20, 2022
- (2) Evaluation of plant risk (green) during planned 'B' emergency diesel generator engine, fuel system, and cable vault maintenance on November 2, 2022
- (3) Evaluation of plant risk (green) during unplanned 'C' instrument air compressor motor overcurrent trip and maintenance activities on November 21, 2022
- (4) Evaluation of plant risk (green) during planned 'B' containment spray system maintenance activities on November 29, 2022
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (1 Sample)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Operability of containment penetrations' 105 and 109 closed loop outside containment isolation boundaries and containment spray flow path following an identified boric acid leak on valve 868D on December 5, 2022
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (3 Samples)
The inspectors evaluated the following temporary or permanent modifications:
- (1) ECP-20-000364, Revise 1815A and 1815B, safety injection pump 'C' suction motor operated valves from breaker locked closed to breaker locked open on October 28, 2022
- (2) ECP-20-000476, Install gearbox on valve 9083 flex alternate reactor coolant system injection on December 12, 2022
- (3) ECP-20-000274, Reconfigure MOV-4663 to use torque/limit control on December 14, 2022
71111.19 - Post-Maintenance Testing
Post-Maintenance Test (IP Section 03.01) (5 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:
- (1) Operational pump comprehensive test of the 'A' motor driven auxiliary feedwater pump following planned maintenance and instrument calibration on October 20, 2022
- (2) Operational test of the 'A' service water motor and pump following planned breaker maintenance on October 26, 2022
- (3) Operational test of the 'B' emergency diesel generator following planned maintenance on November 4, 2022
- (4) Functional test of the permanently mounted alternate reactor coolant system injection pump following planned maintenance on November 8, 2022
- (5) Functional test of the 'A' instrument air compressor following unplanned maintenance November 23, 2022
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:
Surveillance Tests (other) (IP Section 03.01) (3 Samples)
- (1) STP-O-2.1.QB, "Safety Injection Pump B Quarterly Test" on November 9, 2022
- (2) STP-O-16QT, "Auxiliary Feedwater Turbine Pump - Quarterly Test" on November 15, 2022
- (3) STP-O-2.8Q, "Component Cooling Water Pump Quarterly Test" on November 27,
RADIATION SAFETY
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Permanent Ventilation Systems (IP Section 03.01) (1 Sample)
The inspectors evaluated the configuration of the following permanently installed ventilation systems:
- (1) Control room emergency air treatment system
Temporary Ventilation Systems (IP Section 03.02) (1 Sample)
The inspectors evaluated the configuration of the following temporary ventilation systems:
- (1) Portable high energy particulate air filter in intermediate building sub-basement
Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees use of respiratory protection devices
Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)
- (1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses
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 how the licensee processes, stores, and uses external dosimetry
Internal Dosimetry (IP Section 03.03) (2 Samples)
The inspectors evaluated the following internal dose assessments:
- (1) Dose assessment through whole body count monitoring of a worker due to loss of powered air purifying hood
- (2) Dose assessment of worker who received facial contamination from floor drain work
Special Dosimetric Situations (IP Section 03.04) (2 Samples)
The inspectors evaluated the following special dosimetric situations:
- (1) Declared pregnant worker program
- (2) Neutron dosimetry program
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
OR01: Occupational Exposure Control Effectiveness (IP Section 02.15)===
- (1) October 1, 2021 through September 30, 2022
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) October 1, 2021 through September 30, 2022
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Diesel driven fire pump starting pressure recorded below acceptance criteria (AR
===04465564) on October 27, 2022
- (2) Procedure revision inadvertently removed B battery low charging rate alarm (AR 04406482) on December 22, 2022
71152S - Semi-annual Trend Problem Identification and Resolution
Semi-annual Trend Review (Section 03.02)===
- (1) The inspectors reviewed Constellation's corrective action program for potential adverse trends that might be indicative of a more significant safety issue on December 22,
INSPECTION RESULTS
Containment Spray Recirculation Valve 868D Valve Body Porosity Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity
Green NCV 05000244/2022004-01 Open/Closed
None 71111.15 The inspectors identified a Green non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, when Constellation failed to establish measures to ensure a condition adverse to quality was promptly corrected. Specifically, Constellation failed to properly characterize and correct a borated water leak on containment spray recirculation valve 868D that was monitored from June 2013 to February 2021. In August 2022, the inspectors identified a dry deposit of boric acid on valve 868D, indicative of a borated water leak. Constellation evaluated the condition and determined the leak to be a result of leakage through porosity in the valve casting, resulting in declaring the valve inoperable and requiring an unplanned entry into Technical Specification condition 3.6.3.A containment isolation boundaries on August 19, 2022.
Description:
Containment spray recirculation valve 868D was added to the system in a 2009 engineering change package as part of a full flow recirculation test modification. The valve has two functions, first the valve seat ensures fluid flow to the containment spray ring. The second function is fulfilled by the valve body and seat which provide a containment isolation boundary. Specifically, the valve is part of the B containment spray pump discharge pressure boundary and is a containment boundary valve for penetrations 105 and 109.
In 2013, valve 868D was observed to have a borated water leak. The condition was entered into the corrective action program and the valve was added to the boric acid corrosion control program. Valve 868D was monitored as part of the boric acid corrosion control program from June 17, 2013 to February 2021. During that monitoring period, two corrective maintenance work orders were performed to reapply torque at the bonnet to body mechanical joint. Both instances were ineffective at correcting the leak long term.
In June 2022, the inspectors identified a residual heat removal valve 712A that had deposits of boric acid on the valve body from a previous borated water leak. This issue was documented in inspection report as05000244/2022003-01, Constellation documented it as AR 04506193. During completion of corrective action assignments for AR 04506193, Constellation prepared for performing a thorough inspection of A and B train boric acid systems. During boric acid walkdowns in August 2022, the inspectors identified that valve 868D had dry boric acid deposits on the valve body. Constellation entered this condition into their corrective action program as AR 04517790 and evaluated the leak in accordance with their boric acid corrosion control program. Additionally, Constellation is committed to an edition of The American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI which defines valve 868D as in scope. As a result, the applicable articles of the code further state requirements for examination, inspection, repair, and corrective actions.
Constellation determined the borated water leak was likely due to original casting porosity and likely an original manufacture flaw. It is noted that the flaw was on the downstream side of the recirculation flow path, and above the pressure boundary function of the valve seating surface. As a result, the valve seat would still maintain flow to the spray ring, but containment penetration 109 was reduced from two valves providing isolation to one. Additionally, valve 868D is the second containment isolation boundary for penetration 105 because of this deficiency, that penetration was also reduced from having two valves provide isolation, to one. These conditions required Constellation to enter technical specification action statement 3.6.3.A for penetrations 105 and 109. Constellation completed actions to verify the affected penetration flow path is isolated by at least one closed valve within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and once per 31 days thereafter. Lastly, Constellation completed corrective maintenance to replace the leaking valve on December 1, 2022.
Corrective Actions: Containment penetration 105 and 109 were declared inoperable, technical specification requirements were entered. An operability evaluation was completed for valve 868D and the containment penetrations. Corrective maintenance to remove and replace the valve and post-maintenance testing was completed December 1, 2022.
Corrective Action References: AR 04517790
Performance Assessment:
Performance Deficiency: Constellation failed to properly characterize and correct an identified borated water leak on containment spray valve 868D which resulted in adversely affecting two containment penetration isolation boundaries.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Structure, System and Component and Barrier Performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events. Specifically, containment spray valve 868D through valve body porosity leakage resulted in two containment isolation boundaries, 105 and 109, to be isolated with a single valve.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process for Findings At-Power, dated January 1, 2021. The inspectors performed a review of this finding using the guidance provided in Inspection Manual Chapter 0609, Appendix A, Exhibit 3, Barrier Integrity Screening Questions, and determined this finding is of very low safety significance (Green) because the questions in Exhibit 3, Section C Reactor Containment were answered No. Specifically, the finding did not represent an actual open pathway in the physical integrity of reactor containment.
Cross-Cutting Aspect: None. In accordance with Inspection Manual Chapter 0612, the performance deficiency occurred within the last three years, but the performance characteristic has been corrected because of previous enforcement actions detailed in in inspection report as05000244/2022003-01, documented by Constellation as AR 04506193.
Therefore, a cross-cutting aspect is not reflective of present performance.
Enforcement:
Violation: 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected. Contrary to the above, from June 17, 2013 to August 19, 2022, Constellation failed to ensure measures were established to assure a condition adverse to quality was promptly identified and corrected on containment spray valve 868D.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Observation: Diesel Driven Fire Pump Starting Pressure Recorded Below Acceptance Criteria 71152A The inspectors reviewed Constellations functionality assessment, procedure changes, and corrective actions regarding an issue with the diesel driven fire pump. This issue was documented in their corrective action program as AR 04466905.
Constellation identified that on December 15, 2021, during the performance of STP-O-13, Fire Pump Operation and System Alignment, Revision 028, the recorded value for starting pressure of the diesel driven fire pump was 76 psig, and required starting pressure is 85 psig (plus or minus 5 psig). Constellation documented the condition adverse to quality in their corrective action program as AR 04466905.
Constellation performed a functionality assessment (ESR-21-0251) and determined that the diesel driven fire pump remained functional and capable of fulfilling its purpose as described in UFSAR Section 9.5.1.2.3.2, namely, If the pressure drops below the nominal 85 psig (plus or minus 5 psig), the diesel driven fire pump starts. The functionality assessment determined that the pressure sample rate of the diesel fire pump control panel impacted when the fire pump started. A note exists in STP-O-13 that precedes the step to depressurize the sensing line that states, Diesel Fire Pump sensing line pressure should be lowered at a rate of approximately less than one PSIG per second when pressure is below 100 PSIG. On December 15, 2021, the control panel recorded a pressure drop of 25 psig in half a second, and at that time started the diesel driven fire pump when it sensed a pressure below its setpoint. The system was depressurized faster than the control panel could sense, therefore by the time the control panel sensed a pressure below 85 psig (plus or minus 5 psig) the acceptance criteria had already been exceeded.
Constellation determined that the acceptance criteria in STP-O-13 was unnecessary, as preventative maintenance (P105994) was already in use to validate the starting pressure setpoint of the diesel driven fire pump. As part of their corrective actions, procedure change PCR-21-03838 was implemented to remove the acceptance criteria of 85 psig (plus or minus 5 psig) from STP-O-13. Instead, the starting pressure would be recorded for trending purposes to determine a decline in system performance. In future performances of STP-O-13, if the starting pressure were to be exceeded again, no further operator action would be required because of the removal of the acceptance criteria
Observation: Procedure Revision Inadvertently Removed B Battery Low Charging Rate Alarm 71152A The inspectors reviewed Constellations work group evaluation, procedure changes, and corrective actions regarding an issue with the B battery low charging rate alarm setpoint and alarm initiation (J-31 vital battery monitoring system) function. This issue was documented in their corrective action program as AR 04406482.
Constellation identified that on March 4, 2021, in preparation of modification ECP-19-000629 to replace the A and B vital battery monitors with digital recorders, the B battery low charging rate alarm setpoint had been adjusted which resulted in a loss of alarm initiation (J-31 vital battery monitoring system). Constellation determined that in 2018, procedure change PCR-18-00339 for procedure EMP-PM052-00002, Vital Battery B Local Monitor Testing and Maintenance, changed the setpoint for the low charging rate alarm from an accuracy of hundredths to tenths. Specifically, the setpoint adjustment from hundredths to tenths resulted in an alarm not initiating if there was a complete loss of charging current to the battery. Since this issue, Constellation has also implemented change ECP-19-000629 to remove the low charging rate alarm for both vital batteries in an effort to reduce nuisance alarms, as there is no licensing basis or regulatory commitment for the alarm.
Constellation performed a work group evaluation and determined that the Maintenance department falsely believed at the time that the changes incorporated with procedure change request PCR-18-00339, were editorial in nature and did not require cross discipline review.
After determining the cause, Constellation performed corrective actions including briefing applicable parties on the importance of cross functional reviews and requiring documented engineering review if changes are made to set points, acceptance criteria, or other values.
Constellation also sampled ten maintenance procedures across all disciplines to ensure the necessary reviews were performed.
Assessment: Corrective Action Program Semi-Annual Trend Review 71152S The inspectors reviewed Constellations corrective action program and evaluated a sample of issues and events that occurred from July 2022 through December 2022 at Ginna. The inspectors then verified whether the issues were appropriately evaluated by Constellation for emerging or adverse trends and addressed within the scope of the corrective action program or through department review.
The inspection did not reveal any new trends that could indicate a more significant safety issue. The inspectors determined that Constellation personnel were identifying trend issues at a low threshold, entered them into the corrective action program for resolution. The inspectors noted low level or precursor trends identified by Constellation relating to some of the following items: human performance precursors, work preparation, identification of plant deficiencies by operations, service water leaks relating to instrument air compressors, and flux mapping computer issues.
Based on the overall results of the semi-annual trend review, the inspectors determined that Constellation 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 NRC's Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On November 3, 2022, the inspectors presented the 71124.03 and 71124.04 inspection results to Doug Hild, Plant Manager, and other members of the licensee staff.
- On January 30, 2023, the inspectors presented the integrated inspection results to Daren Blankenship, Senior Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
01955554
868D
06/17/2013
04148821
868D
06/20/2018
Corrective Action
Documents
Resulting from
Inspection
04517790
Dry Boric Acid on 868D
08/19/2022
Drawings
33013-1261
Revision 48
Miscellaneous
Rep Task P32039 Repetitive Task associated with boric acid inspection
Operability
Evaluations
OPEVAL-22-003
868D, IR 04517790
Revision 000
Procedures
A-3.3
Containment Integrity Program
Revision 28
STP-O-23.18B
Local Leak Rate Test of Containment Spray Header B Pen
109
Revision 005
Work Orders
C92316645
C93671161
Corrective Maintenance for 868D
10/13/2016
2/19/2018
C92813256
Perform Boric Acid and Leakage Inspection of 'B' Train Int &
Aux Bldg Equipment SSC
07/27/2015
C93774553
C93754787
C93731942
Boric Acid Corrosion Control Program Inspections Relating to
868D
3/7/2022
8/11/2021
2/9/2021
Corrective Action
Documents
J-31 Alarm Setpoint Inadvertently Impacted by Procedure
Rev.
03/04/2021
DFP Event Log Recorded Start at 76 psig During Testing
2/15/2021
Engineering
Changes
ECP-19-000629
Replace the Vital battery monitor
03/30/2021
PCR-18-00339
Delete Unnecessary Steps, Fix Typos, and Add Necessary
Steps for Procedure Completeness.
05/16/2018
PCR-21-03838
Revise DDFP Start Criteria in Accordance with ESR-21-
251. Provide Enhanced Steps for Testing the Auto Start of
the Motor Fire Pump.
2/17/2021
Operability
Evaluations
ESR-21-0251
Functionality Evaluation of the DDFP for IR 04465564
2/17/2021
Procedures
STP-O-13
Fire Pump Operation and System Alignment
Revision 028