IR 05000244/2022012
| ML23012A127 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 01/12/2023 |
| From: | Mel Gray NRC/RGN-I/DORS |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2022012 | |
| Preceding documents: |
|
| Download: ML23012A127 (1) | |
Text
January 12, 2023
SUBJECT:
R.E. GINNA NUCLEAR POWER PLANT, LLC - DESIGN BASIS ASSURANCE INSPECTION (TEAMS) INSPECTION REPORT 05000244/2022012
Dear David Rhoades:
On December 1, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at R.E. Ginna Nuclear Power Plant, LLC. On January 6, 2023, the NRC inspectors discussed the results of this inspection with Daren Blankenship, Site 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 (NCV) 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.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; 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, Mel Gray, Chief Engineering 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-2022-012-0009
Licensee:
Constellation Energy Generation, LLC
Facility:
R.E. Ginna Nuclear Power Plant, LLC
Location:
Ontario, New York
Inspection Dates:
November 14, 2022 to December 1, 2022
Inspectors:
N. Floyd, Senior Reactor Inspector
D. Kern, Senior Reactor Inspector
J. Kulp, Senior Reactor Inspector
N. Mentzer, Resident Inspector
J. Schoppy, Senior Reactor Inspector
D. Tifft, Regional State Liaison Officer
Approved By:
Mel Gray, Chief
Engineering Branch 1
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a design basis assurance inspection (teams) 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
Failure to Evaluate Water Leakage during Modification of Circulating Water Pump Automatic Trip Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000244/2022012-01 Open/Closed
[H.6] - Design Margins 71111.21M The NRC inspectors identified a Green finding and associated Non-cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion III, Design Control when the licensee performed a plant modification to remove the automatic trip of the circulating water pumps after a flood is detected in the turbine building. Specifically, the licensee did not evaluate the impact of water leakage into the emergency diesel generator (EDG) and battery rooms during the analyzed internal flooding event.
Additional Tracking Items
None.
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
===71111.21M - Design Bases Assurance Inspection
The inspectors evaluated the following components and listed applicable attributes, permanent modifications, and operating experience:
Design Review - Risk-Significant/Low Design Margin Components (IP Section 02.02)
=
The inspectors used the event scenario-based approach described in IP Section 03.01.c to select components for the design review. The high-risk event scenarios utilized by the team included initiating events from
- (i) a house heating steam leak in the screen house and
- (ii) a 200 gallon per minute flood in the relay room.
- (1) 'C' Standby Auxiliary Feedwater Pump
- Material condition and installed configuration (e.g., visual inspection/walkdown)
- Normal, abnormal, and emergency operating procedures
- Consistency among design and licensing bases and other documents/procedures
- System health report, maintenance effectiveness and records, and corrective action history
- Design calculations
- Surveillance testing and recent test results
- System and component level performance monitoring
- Equipment protection from fire, flood, and water intrusion or spray
- Operator actions
- Heat removal cooling water and ventilation
The team used Appendix B guidance for Valves, Pumps, Instrumentation, and As-Built System.
(2)480V Bus 14
- Material condition and installed configuration (e.g., visual inspection/walkdown)
- Consistency among design and licensing bases and other documents/procedures
- Maintenance records and corrective action history
- Adequacy of design (calculations and modifications)
- Surveillance testing and recent test results
- System and component level performance monitoring
- Control logic
- Component adequacy for minimum voltage
- Protection coordination (load in-rush and full load current)
- Energy source availability (electricity)
- Equipment qualification suitable for the environment expected under all conditions
The team used Appendix B guidance for Instrumentation, Circuit Breakers and Fuses, Cables, Electric Loads, and As-Built System.
- (3) Standby Auxiliary Feedwater Diesel Generator - KDG08
- Material condition and installed configuration (e.g., visual inspection/walkdown)
- Normal, abnormal, and emergency operating procedures
- Consistency among design and licensing bases and other documents/procedures
- System health report, maintenance effectiveness and records, and corrective action history
- Design calculations
- Surveillance testing and recent test results
- System and component level performance monitoring
- Equipment protection from fire, flood, and water intrusion or spray
- Operator actions
- Heat removal cooling water and ventilation
The team used Appendix B guidance for Valves, Pumps, Instrumentation, and As-Built System.
- (4) A Emergency Diesel Generator - KDG01
- Material condition and configuration (e.g., visual inspection/walkdown)
- Normal, abnormal, and emergency operating procedures
- Consistency among design and licensing bases and other documents/procedures
- System health report, maintenance effectiveness and records, and corrective action history
- Adequacy of design (calculations and modifications)
- Surveillance testing procedures and recent test results
The team used Appendix B guidance for Valves, Instrumentation, Circuit Breakers, Electrical Loads, and As-built System.
Design Review - Large Early Release Frequency (LERFs) (IP Section 02.02) (1 Sample)
- (1) Atmospheric Relief Valve 3410
- Material condition and installed configuration (e.g., visual inspection/walkdown)
- Normal, abnormal, and emergency operating procedures
- Consistency among design and licensing bases and other documents/procedures
- Maintenance records and corrective action history
- Equipment/environmental controls and qualification
- Adequacy of design (calculations and modifications)
- Surveillance testing and recent test results
- Component degradation and performance monitoring
- Operator actions
The team used Appendix B guidance for Valves, Pumps, Instrumentation, and As-Built System.
Modification Review - Permanent Mods (IP Section 02.03) (6 Samples)
- (1) ECP-18-000455: ESR-18-0152 - 'B' Battery Room Cable Vault Level Alarm
- (2) ECP-19-000306: ESR-19-0067 - Modify MOV-700 to Prevent Pressure Locking
- (3) ECP-19-000482: Install Spring-Loaded Check Valve in Emergency Diesel Generator Lube Oil Supply Line to Turbo
- (4) ECP-21-000008: Reduce Fouling Upstream of Service Water Strainers for A & B Auxiliary Feedwater Pumps by Increasing Size of Tubing, Valves, and Strainers
- (5) ECP-21-000049: Eliminate Circulating Water Pump Flood Switch Trip in Screenhouse and Turbine Building
Review of Operating Experience Issues (IP Section 02.06) (3 Samples)
- (1) NRC Information Notice 2019-01: Inadequate Evaluation of Temporary Alterations, dated March 12, 2019
- (2) NRC Information Notice 2020-02: Flex Diesel Generator Operational Challenges, dated September 15, 2020
- (3) NRC Operating Experience Smart Sample OpESS 2007/02: Analysis of Flooding Vulnerabilities, dated September 11,
INSPECTION RESULTS
Failure to Evaluate Water Leakage during Modification of Circulating Water Pump Automatic Trip Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000244/2022012-01 Open/Closed
[H.6] - Design Margins 71111.21M The NRC inspectors identified a Green finding and associated Non-cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion III, Design Control when the licensee performed a plant modification to remove the automatic trip of the circulating water pumps after a flood is detected in the turbine building. Specifically, the licensee did not evaluate the impact of water leakage into the emergency diesel generator (EDG) and battery rooms during the analyzed internal flooding event.
Description:
In April 2021, licensee staff performed a plant modification under ECP-21-000049 to disable the automatic trip function of the circulating water pumps when a flood is detected in the screenhouse or the turbine building lower elevation (pit beneath the turbine condenser). The flood switches were left in-place to provide alarm functions in the control room, but the automatic pump trip function was removed. The primary scenario affected was postulated internal flooding due to ruptured rubber expansion boots between the circulating water inlet piping to the turbine condenser inlet head. The licensee determined that by removing the automatic trip of the circulating water pumps, that the final steady-state flood water height inside the turbine building basement increased to 4.8 feet from the previous height of 9 inches and was limited to 4.8 feet by the failure of the rollup door TB-10 due to pressure effects of the flood water. The two EDG rooms and two vital battery rooms are both located in the turbine basement. While the EDG room doors are at the same elevation as the turbine building basement, the battery room doors are on top of an 18-inch wall which is a physical barrier between the battery room floor and the turbine basement floor. These rooms need to be protected from the effects of flooding as they house safety-related equipment that provides electrical power for various safety related components and instruments that mitigate the effects of design basis accidents.
The inspectors reviewed the design change package for the modification and performed a walk down of the turbine building focusing on the configuration of the EDG and battery room doors. The inspectors noted that the licensee assumed the flood doors were essentially watertight in their analysis and did not account for any flood water leakage into the rooms. The doors were procured and installed as airtight to mitigate a high-energy line break in the turbine building. Rubber flap seals were installed between the door and the door jambs to cover the gap between the two components. They were subsequently dedicated as "flood doors" with a modification to the flap seals which increased the width of the seal from 1.5 inches to 2 inches, adding an additional half inch of seal to cover the gap. The inspectors observed that the doors are not the traditional watertight door which use a knife edge, elastomer seal and door latches to provide a compression seal. The inspectors questioned the assumption of watertightness for the existing doors based on the air leakage allowance in the door procurement specification as well as design documentation submitted to the NRC in 2014 for external flooding hazard re-analysis that calculated a leak rate (i.e., water-resistant)to qualify the doors. The inspectors also questioned the qualification of the flood doors since the licensee did not consider differences between the design drawings and as-found configuration of the doors (i.e., gap between the flap seals and doors) and because there was no analyses or calculations of water leakage at the qualified flood heights described in the plant design basis documents.
The inspectors observed that the licensee did not determine the change in leakage rate due to the increase flood height nor evaluate the effects of the additional leakage over the undefined timeline for the safety related equipment in the EDG or the battery rooms. While the licensee had an alarm response procedure for when the turbine building high-level flood detectors indicated in the control room, they did not credit or evaluate any operator actions in the analysis for the modification to mitigate the effects of this internal flood.
Corrective Actions: The licensee staff entered the issue into their corrective action program and performed a calculation of water leakage in the EDG and battery rooms at the new flood height. The licensee plans to update their design basis documentation, including the door drawings and seal inspection criteria.
Corrective Action References: IR 04541356 and IR 04546969
Performance Assessment:
Performance Deficiency: The licensee did not evaluate the impact of increased flood water leakage into the EDG and battery rooms when they made a plant modification to disable the automatic circulating water pump trip. Specifically, the modification increased the flood height in the turbine building from 9 inches to 4.8 feet, and the licensee did not evaluate the water leakage at this new height.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, plant modification ECP-21-000049 affected the availability and reliability of the safety-related components in the EDG and battery rooms due to increased water leakage during a postulated internal flooding event. The inspectors considered this is similar to IMC 0612, Appendix E, example 3.a because there was a reasonable doubt about the amount of flood water that would leak into the rooms for a flood occurring over an indefinite period of time.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using IMC 0609, Appendix A, Exhibit 2, Mitigating System Screening Questions, the inspectors determined the finding to be of very low safety significance (Green) because the systems and components in the impacted rooms would maintain their operability during the internal flooding event. This was based on the inspectors independent assessment of design-specification door seal performance and reasonable operator actions for the postulated internal flooding event of concern at the revised flood height of 4.8 feet. Specifically, the inspectors determined, based upon licensee staff calculations completed in response to this issue, operators would receive an alarm in the control room, follow the steps in the alarm response procedure to investigate the source of the flood, and would have sufficient time to trip the circulating water pumps and mitigate the event before the affected safety systems of concern were rendered inoperable or non-functional.
Cross-Cutting Aspect: H.6 - Design Margins: The organization operates and maintains equipment within design margins. Margins are carefully guarded and changed only through a systematic and rigorous process. Special attention is placed on maintaining fission product barriers, defense-in-depth, and safety related equipment. Specifically, the licensee made a design change that significantly increased the flood height during a postulated internal flood event and did not carefully evaluate the impact of that change to guard the design margin.
Enforcement:
Violation: 10 CFR 50, Appendix B, Criterion III, Design Control, states in part that measures shall be established to assure that applicable regulatory requirements and the design basis for those structures, systems, and components are correctly translated into specifications, drawings, procedures, and instructions, and that design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program.
Contrary to the above, from April 2021 to present, the licensee failed to verify the adequacy the of the design for an analyzed internal flooding event. Specifically, the licensee performed a plant modification to remove the automatic trip of the circulating water pumps when a flood is detected in the turbine building and did not evaluate the impact of increased water leakage into the EDG and battery rooms.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On December 1, 2022, the inspectors presented the preliminary inspection results to Doug Hild, Plant Manager, and other members of the licensee staff.
- On January 6, 2023, the inspectors presented the design basis assurance inspection (teams) inspection results to Daren Blankenship, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71111.21M Calculations
9001-05050056.0
Alternate Test Media Correlation for Pressure Relief Valves
5959 & 5960
71111.21M Calculations
CALC-2010-0018
Time to Locally Open ARV 3410/3411
71111.21M Calculations
DA-EE-92-098-01 Diesel Generator A Steady-State Loading Analysis
71111.21M Calculations
DA-EE-92-111-01 Diesel Generator A Dynamic Loading Analysis
71111.21M Calculations
DA-EE-93-006-08 Instrument Performance Evaluation and Setpoint Verification
Undervoltage Relays and Voltmeters on 480V Safeguards
Busses
71111.21M Calculations
DA-EE-93-104-07 480V Coordination and Circuit Protection Study
71111.21M Calculations
DA-EE-95-146
Evaluate Concurrent Routing of Cable
71111.21M Calculations
DA-EE-98-089
Emergency Diesel Generator Overcurrent Protection
71111.21M Calculations
DA-ME-12-005
SAFW Hydraulic Model
71111.21M Calculations
DA-ME-13-012
Seismic Design of SAFW Diesel Generator and Associated
Electrical Equipment
71111.21M Calculations
DA-ME-2001-053
Minimum Engineering Limit for Differential Pressure for
Preferred and Standby Auxiliary Feedwater Pumps During
Periodic Testing
71111.21M Calculations
GC-20226
RG&E Ginna Superwall Check for Water Pressure due to
Flooding
03/23/1983
71111.21M Corrective Action
Documents
CR-2010-006914
2568045
03995521
04004226
04036374
04149657
04169669
04171248
04194833
230952
271817
278201
04321584
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
04333162
04342146
04363839
04364457
04364913
04368000
04383941
04383962
04402989
04424057
04428133
04446627
04449563
04450886
04453318
04459583
04461152
04471260
04476764
04492882
04494013
04510333
04510507
04516938
04533848
04535292
04535442
04535937
04538765
71111.21M Corrective Action
Documents
Resulting from
Inspection
04529821
04535218
04536858
04536930
04536954
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
04537064
04537165
04537450
04537613
04537638
04537846
04537935
04539568
04539589
04539598
04539610
04539641
04539667
04539682
04539821
04539861
04539930
04539940
04539943
04539944
04540133
04540175
04540202
71111.21M Drawings
10905-0067
Auxiliary Building Service Water Isolation Valve MOV-4615
Elementary Wiring Diagram
71111.21M Drawings
11310-0199
MOV-4615 Auxiliary Building Service Water Isolation Valve
Connection Diagram
71111.21M Drawings
33013-1238
Standby Auxiliary Feedwater (FW) P&ID
71111.21M Drawings
33013-1239,
Sheet 1
Diesel Generator - A (DG) P&ID
71111.21M Drawings
33013-1239,
Sheet 2
Diesel Generator - B (DG) P&ID
71111.21M Drawings
33013-1250,
Sheet 2
Station Service Cooling Water Safety Related (SW) P&ID
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71111.21M Drawings
33013-1606,
Sheet 1
Miscellaneous Relay Rack M1
71111.21M Drawings
33013-2539
AC System Plant Load Distribution One Line Diagram
71111.21M Drawings
D5 File 7477
Overly Manufacturing Door Design for Robert E. Ginna
Nuclear Station
71111.21M Engineering
Changes
ECN 4136-1
A D.G. ELCP Mod
01/23/1986
71111.21M Engineering
Changes
ECP-14-000571
Flood Barrier Qualification Summary
71111.21M Engineering
Changes
ECP-16-000445
Ginna Design Basis Flood Re-evaluation
71111.21M Engineering
Changes
ESR-11-0362
Evaluate Enhancements for Diesel Generator Margin
71111.21M Engineering
Changes
EWR 3990-CE1
Design Analysis Ginna Station DGB Modifications
71111.21M Engineering
Changes
PMA-21-132507
Revise Frequencies of PMs Not Completed in RFP 2021
03/01/2022
71111.21M Engineering
Changes
PMC-21-131112
Change Frequency of P200123 Perform PM Inspection on
2/PHCG Pressurizer Heater Control to 9 Years
10/13/2021
71111.21M Engineering
Changes
PMC-21-131563
Extend Breaker 52/MCC1C (MCC C Supply Breaker) PM
P200124
10/14/2021
71111.21M Miscellaneous
Exelon Generation Company, LLC Response to March 12,
2012, Request for Information Enclosure 2,
Recommendation 2.1, Flooding, Required Response 3,
Flooding Focused Evaluation Summary Submittal
03/10/2017
71111.21M Miscellaneous
TS-203-044594-
G5
Technical Specifications for Doors and Door Frames Ginna
Station
05/24/1978
71111.21M Procedures
AR-DG-A-3
Primary Fuel Filter Hi DP
71111.21M Procedures
AR-L-12
Condenser Pit or Screen House Hi Level 6.5
71111.21M Procedures
ER-AFW.1
Alternate Water Supply to the AFW Pumps
71111.21M Procedures
ER-D/G.1
Restoring D/Gs
71111.21M Procedures
ER-SH.1
Response to Loss of Screenhouse
71111.21M Procedures
GC-76.8
Installation and Inspection of Tubing and
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Instrumentation/Tubing Supports
71111.21M Procedures
GME-50-02-
DB50
Westinghouse 480V Air Circuit Breaker Type DB-50
Maintenance
71111.21M Procedures
IP-CON-9
Plant Barrier Control Program Implementation
71111.21M Procedures
MMP-GM008-
00003
A or B Diesel Generator Primary and Secondary Fuel Oil
Filter Minor Inspection and Maintenance
71111.21M Procedures
Operator Response Time Program
71111.21M Procedures
OP-GI-102-106
Operator Response Time Program at Ginna Station
71111.21M Procedures
SC-3.17.1
SAFW Annex Flood Barrier Installation/Removal/Inspection
71111.21M Procedures
STP-O-12.1
71111.21M Procedures
STP-O-30.11
Emergency Diesel Generator B Pre-Startup Alignment
71111.21M Procedures
T-44.2
Standby Auxiliary Feedwater (SAFW) System Alignment for
Normal Operation
71111.21M Procedures
Preventive Maintenance Database Revision Requirements
71111.21M Work Orders
C90638092
C90638094
C90638095
C90960720
C91453936
C92100746
C92592215
C93060937
C93612036
C93636558
C93687220
C93692742
C93699259
C93719524
C93723304
C93723305
C93737945
C93757543
C93759291
C93772303
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
C93772719
C93775060
C93775878
C93775879
C93782279
C93790219
C93794156
C93794370
C93794825
C93794825
C93802841
C93804275
C93804679
C93807963