IR 05000244/2023004

LLC - Integrated Inspection Report 05000244/2023004

ML24032A102
Person / Time
Site:	Ginna
Issue date:	02/05/2024
From:	Erin Carfang NRC/RGN-I/DORS
To:	Rhoades D Constellation Energy Generation, Constellation Nuclear
References
IR 2023004
Download: ML24032A102 (1)

Text

February 5, 2024

SUBJECT:

R.E. GINNA NUCLEAR POWER PLANT, LLC - INTEGRATED INSPECTION REPORT 05000244/2023004

Dear David Rhoades:

On December 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at R.E. Ginna Nuclear Power Plant, LLC. On January 29, 2024, 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.

Two findings of very low safety significance (Green) are documented in this report. One of these findings 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 or a finding not associated with a regulatory requirement 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, 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: DPR-18

Report Number: 05000244/2023004

Enterprise Identifier: I-2023-004- 0038

Licensee: Constellation Energy Generation, LLC

Facility: R.E. Ginna Nuclear Power Plant, LLC

Location: Ontario, New York

Inspection Dates: October 1, 2023 to December 31, 2023

Inspectors: J. Schussler, Senior Resident Inspector J. DeBoer, Sr Emergency Preparedness Inspector S. Mercurio, Emergency Preparedness Inspector P. Ott, Operations Engineer S. Veunephachan, Health Physicist

Approved By: Erin E. Carfang, Chief Projects Branch 1 Division of Operating Reactor Safety

Enclosure

SUMMARY

The U.S. 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

Electro-Hydraulic Circuit Card Failure Leads to Turbine Valve Closure and Over-Temperature Delta Temperature Reactor Trip Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.8] - 71111.12 FIN 05000244/2023004- 01 Procedure Open/Closed Adherence A Green, very low safety significance, self-revealing finding was identified for Constellations failure to follow procedure SM-AA-3019, Parts Quality Initiative, Revision 12 for the replacement of the analog electro-hydraulic control circuit card EHCC1/1A08R during the spring 2023 refueling outage. Specifically, Constellation failed to properly verify that the replacement analog electro-hydraulic control circuit card was tested and inspected prior to accepting it into inventory. This resulted in the card being installed during the spring 2023 refueling outage and subsequently failing in September 2023 which caused a closure of the turbine control valves leading to an over-temperature delta temperature reactor trip from rated thermal power.

A Containment Recirculation Fan Cooler Motor Bearing Failure Due to Greasing Practices Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [H.14] - 71111.12 NCV 05000244/2023004-02 Conservative Open/Closed Bias A Green, very low safety significance, self-revealing finding and associated non-cited violation of Technical Specification 5.4.1.a, Procedures, was identified when Constellation did not establish and implement required written procedures as required by Regulatory Guide 1.33,

Quality Assu rance Program Requirements (Operation), Revision 2, Appendix A, Section 3,

Procedures for Startup, Operation, and Shutdown of Safety-Related PWR Systems.

Specifically, Constellation failed to adequately convey technical requirements of its design analysis document DA-ME-92-119 into preventive maintenance (PM) P301469 and corresponding work order procedures, which resulted in inadequate greasing of the containment recirculation fan cooler (CRFC) motor drive end bearing, eventually contributing to its unexpected failure and inoperability.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000244/2023-002-00 LER 2023-002-00 for R.E. 71153 Closed Ginna Nuclear Power Plant,

Over-Temperature Delta Temperature Reactor Protection System and Auxiliary Feedwater System Actuations on due to 100%

Load Rejection caused by Turbine Overspeed Circuit Card Failure ( Parts Quality Initiative Inspection Bypassed)

PLANT STATUS

Ginna began the inspection period operating at rated thermal power. On October 12, 2023, the reactor was manual tripped due to degrading main condenser vacuum causing an unplanned forced outage. The unit was returned to full power on October 15, 2023 and remained at, or near, rated thermal power for the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/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, 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.

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather (IP Section 03.01) (1 Sample)

(1) On December 21, 2023, the inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures for the following systems:

• Flex 'L' shape building

• 'A' emergency diesel room

• 'B' battery room

• Ailiyllr

- Equitlignment

Ptikdow(IPecti) (2 Sple

The ipectors evted systonfirions duritikdow ofling emtrains:

( 'B'mery dior onctober 19, 20

( Turne driviliy pump on Nember 2023

71111.05 - Fire Protection

Fire Area Walkdown and Inspection (IP Section 03.01) (5 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) 'A' emergency diesel room cable vault on October 18, 2023

(2) 'A' emergency diesel generator room on October 19, 2023

(3) Screen house operating floor on November 30, 2023

(4) 'B' battery room on December 8, 2023

(5) Flex 'L' shaped flex storage building on December 15, 2023

71111.07A - Heat Exchanger/Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) 'C' containment recirculation fan cooling coil on December 1, 2023

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 biennial written exams completed February 16, 2023, and the annual operating exams completed December 15, 2023

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 the following licensed operator performance in the main control room:

• Reactor operators and senior reactor operators commencing a plant startup following a reactor trip and unplanned forced outage on October 13 and 14, 2023

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 examination on November 14, 2023. The examination involved a scenario that contained, but was not limited to, a feedwater line rupture inside containment, safety injection, auxiliary feedwater failures, and adverse containment conditions.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (4 Samples)

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

(1) Fire protection backflow preventing check valves CV-2024 and CV-2025 inspection and maintenance frequencies on October 12, 2023

(2) 'A' containment recirculation fan cooler motor maintenance on November 20, 2023

(3) Turbine driven auxiliary feedwater trip throttle valve 3652 on November 21, 2023

(4) Electro-hydraulic control card replacement and installation on December 15, 2023

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management (IP Section 03.01) (1 Sample)

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 (green) and associated technical specification risk informed completion time actions during planned 'A' emergency diesel generator and motor control center H maintenance.

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)

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

(1) Operability determination of seat leakage on pressurizer power operated relief valves 430 and 431C and the subsequent closure of one pressurizer block motor-operated valve 515 on October 10, 2023

(2) Operability determination of the 'D' standby auxiliary feedwater pump following elevated vibration data during a surveillance test on October 12, 2023

(3) Operability determination of the as found testing results for safety-related main steam and turbine driven auxiliary feedwater steam piping system snubbers on October 24, 2023

(4) Operability determination of the deficiencies found on containment insulation panels which overlay the containment carbon steel liner on October 26, 2023

(5) Operability determination of the failed 'B' emergency diesel generator power factor meter on November 1, 2023

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) ECP-22-000166, Main control room toxic gas monitor removal on November 6, 2023

(2) ESR-23-0134, Temporary change to mechanically gag open the intake and discharge dampers of the NFPA805 diesel generator on November 9, 2023

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:

Post-Maintenance Testing (IP Section 03.01) (1 Sample)

(1) Operational testing of the 'A' emergency diesel generator following planned system preventive maintenance on October 20, 2023

Reactor Coolant System Leakage Detection Testing (IP Section 03.01) (1 Sample)

(1) S-12.2, "Operator Action In The Event Of Indication Of Significant Increase In Leakage" on November 1, 2023

71114.02 - Alert and Notification System Testing

Inspection Review (IP Section 02.01 - 02.04) (1 Sample)

(1) As a result of the 2020 COVID-19 Public Health Emergency, the licensee requested and received an exemption to reschedule their biennial emergency preparedness exercise from 2020 to 2021. The inspectors performed the emergency preparedness program inspection scheduled for 2021 in its place, then performed emergency preparedness exercise inspections in 2021 and 2022.

The inspectors evaluated the licensee's maintenance and testing of the Ginna Nuclear Power Plant Alert and N otification System on October 10 through October 12, 2023, for the period of July 2020 through September 2023.

71114.03 - Emergency Response Organization Staffing and Augmentation System

Inspection Review (IP Section 02.01 - 02.02) (1 Sample)

(1) The inspectors evaluated the readiness of the licensee's Emergency Preparedness Organization on October 10 through October 12, 2023.

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01 - 02.03) (1 Sample)

(1) The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes:

• 22-23, EP-AA-120- 1006, EP Reportability, Loss of Emergency Preparedness Capabilities, Revision 7

• 22-34, EP-AA-122-100, Drill and Exercise Planning and Scheduling, Revision 12

• 22-50, R.E. Ginna Nuclear Power Plant Alert and Notification System Design Report, Revision 5

• 22-56, EP-AA-120-F- 01, EP Document Processing Checklist, Revision P

• 22-68, EP-AA-120-F- 06, Evacuation Time Estimate Review Checklist, Revision C

This evaluation does not constitute NRC approval.

71114.05 - Maintenance of Emergency Preparedness

Inspection Review (IP Section 02.01 - 02.11) (1 Sample)

(1) The inspectors evaluated the maintenance of the emergency preparedness program on October 10 through October 12, 2023, for the period of July 1, 2020 through September 30,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15)===

(1) October 1, 2022 through September 30, 2023

PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences (IP Section 02.16) (1 Sample)

(1) October 1, 2022 through September 30, 2023

EP01: Drill/Exercise Performance (IP Section 02.12) (1 Sample)

(1) July 1, 2022 through June 30, 2023

EP02: Emergency Response Organization Drill Participation (IP Section 02.13) (1 Sample)

(1) July 1, 2022 through June 30, 2023

EP03: Alert And Notification System Reliability (IP Section 02.14) (1 Sample)

(1) July 1, 2022 through June 30, 2023

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (IP Section 03.03)

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

(1) Corrective action program evaluation for 'A' containment recirculation fan cooler motor failure (AR 04677897) on October 11, 2023

(2) Work group evaluation regarding 'B' emergency diesel generator high lube oil filter pressure difference (AR 04514680) on October 19, 2023

71152S - Semi-Annual Trend Problem Identification and Resolution Semi-A nnual Trend Review (IP Section 03.02)

(1) The inspectors reviewed the licensees corrective action program for potential emerging or adverse trends that might be indicative of a more significant safety issue on December 21, 2023

71153 - Follow-up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000244/2023-002-00, Over-Temperature Delta Temperature Reactor Protection System and Auxiliary Feedwater System Actuations on due to 100% Load Rejection caused by Turbine Overspeed Circuit Card Failure (Parts Quality Initiative Inspection Bypassed), ADAMS Accession No. ML23312A176. The inspection conclusions associated with this LER are documented in this report under Inspection Results. This LER is closed.

INSPECTION RESULTS

Electro-Hydraulic Circuit Card Failure Leads to Turbine Valve Closure and Over-Temperature Delta Temperature Reactor Trip Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.8] - 71111.12 FIN 05000244/2023004- 01 Procedure Open/Closed Adherence A Green, very low safety significance, s elf-revealing finding was identified for Constellations failure to follow procedure SM-AA-3019, Parts Quality Initiative, Revision 12 for the replacement of the analog electro-hydraulic control circuit card EHCC1/1A08R during the spring 2023 refueling outage. Specifically, Constellation failed to properly verify that the replacement analog electro-hydraulic control circuit card was tested and inspected prior to accepting it into inventory. This resulted in the card being installed during the spring 2023 refueling outage and subsequently failing in September 2023 which caused a closure of the turbine control valves leading to an over-temperature delta temperature reactor trip from rated thermal power.

Description:

Ginna has four main turbine control valves which are controlled by an analog electro-hydraulic control cabinet. The valves are designed to close rapidly in a reactor trip condition to prevent damage to the main turbine. The analog electro-hydraulic syste m has an overspeed protection circuit to protect from turbine overspeed events. The central location in the overspeed protection circuit for all input and output signals is the analog comparator 8 (AC8) card 1A08R.

Following the September 9, 2023 automatic reactor trip, Constellation troubleshooting efforts identified that a failure of the EHCC1/1A08R card and the R2C resistor led to an improper signal from the overspeed protection circuitry.

Card EHCC1/1A08R is classified as a critical C operational critical component and single point vulnerability in Constellations database. Work packages created to perform maintenance on operational critical components require screening in accordance with procedures ER-AA-2004 System & Component Vulnerability Identification and Mitigation, Revision 13 and MA -AA-716- 010- 1015 Operational Critical Component Work (OPCCW)

Process, Revision 11. The inspectors noted that this screening determines if barriers need to be added to the work order to prevent latent failures of the component.

Constellation issue report 04518980, dated November 2022, captured that analog electro-hydraulic circuit cards were due for replacement, and work order C93867832 was generated.

The decision was made that selectable resistors on the AC8 cards would need to be swapped from the installed cards to spare cards. Constellation assembled a full spare set of cards, which required capacitor replacement, and completed the activity on work order C93805279. The circuit boards, which were utilized to assemble a spare set of boards, were taken from non-stock. These boards were not reserved to the work order and parts quality initiative was not completed. The AC8 circuit boards selected under pre-outage work order C93805279 were visually inspected by the naked eye and tested. During the spring 2023 outage, work order C93867832 replaced the circuit card at location EHCC1/1A08R with a non-stock card. Following replacement, Constellation tested the controller circuits in the analog electro-hydraulic rack for proper operation. The inspectors noted that because the replacement circuit cards were used in an operational critical component location, the requirements of SM-AA-3019 (Parts Quality Initiative) were applicable.

Procedure SM-AA-3019, identifies that through the parts quality initiative process all circuit cards received are to be inspected in accordance with Attachment 5, Circuit Card Inspection Checklist. Attachment 5 includes various inspection requirements, specifically checking the module for workmanship under magnifier work light, examination for discoloration or disfigurement due to heating and using a magnifying glass, microscope, and ultraviolet light are some of the inspection attributes. These inspections are performed offsite at Constellation Power Labs. Constellations evaluation of the automatic trip event noted the failed circuit card would have been identified in the parts quality initiative inspections and likely would have led to a rejection of the subject circuit board.

Based on the above, the inspectors determined that Constellation did not follow their procedure SM-AA-3019, Parts Quality Initiative. Specifically, Constellation failed to properly implement Attachment 5 of SM-AA-3019 to inspect, test and accept EHCC1/1A08R circuit card into inventory, which subsequently failed, resulting in the closure of the turbine control valves leading to a reactor trip from rated thermal power. Specifically, the plant transient originated from the actuation of the turbine overspeed protection circuity on the turbine electro-hydraulic control system demanding the turbine control and intercept valves to close resulting in an over-temperature delta temperature reactor trip and an actuation of the anticipated transient without scram mitigation system actuation circuitry.

Corrective Actions: Constellations corrective actions include the replacement of the failed circuit card, completing parts quality initiative inspections on in-stock EH cards, future inspections/repairs on EHC single point vulnerability cards, and update planning processes for preventive maintenance work orders.

Corrective Action References: IR 04701420

Performance Assessment:

Performance Deficiency: Constellations failure to follow procedure SM-AA-3019, Parts Quality Initiative, Attachment 5 to inspect, test and inventory non-stock material to be used in the electro-hydraulic circuit card replacement was reasonably within their ability to foresee and prevent.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, Constellation failed to properly verify that the non-stock electro-hydraulic circuit card was inspected, tested, and properly inventoried prior to installation. This failure caused an actuation of the overspeed protection circuity on the turbine electro-hydraulic control system demanding the turbine control valves to close resulting in an over-temperature delta temperature reactor trip. The inspectors also noted that the closure of the turbine control valves and subsequent increase in turbine first-stage pressure resulted in meeting the logic for the anticipated transient without scram mitigation system actuation circuitry.

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 IMC 0609 Appendix A, Exhibit 1, Initiating Events Screening Questions. The inspectors determined the finding was of very low safety significance (Green) because the finding did not cause a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition.

Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions. Constellation failed to follow portions of maintenance, engineering, work planning and parts quality initiative procedures, resulting in a component from non-stock being installed in the electro-hydraulic control system.

Enforcement:

Inspectors did not identify a violation of regulatory requirements associated with this finding.

A Containment Recirculation Fan Cooler Motor Bearing Failure Due to Greasing Practices Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [H.14] - 71111.12 NCV 05000244/2023004 -02 Conservative Open/Closed Bias A Green, very low safety significance, self -revealing finding and associated non-cited violation of Technical Specification 5.4.1.a, Procedures, was identified when Constellation did not establish and implement required written procedures as required by Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), Revision 2, Appendix A, Section 3, Procedures for Startup, Operation, and Shutdown of Safety -Related PWR Systems. Specifically, Constellation failed to adequately convey technical requirements of its design analysis document DA-ME-92 -119 into preventive maintenance (PM) P301469 and corresponding work order procedures, which resulted in inadequate greasing of the CRFC motor drive end bearing, eventually contributing to its unexpected failure and inoperability.

Description:

The CRFC systems provide containment atmosphere cooling to limit post-accident pressure and temperature in containment to less than the design values. The CRFC system is an engineered safety feature which is designed to ensure that heat removal capability required during post-accident period can be attained and reduce the potential release of radioactive material, principally iodine, from the containment to the outside environment. R.E. Ginna Technical Specifications Section 3.6.6 defines the CRFC system consisting of four fan units, (A, B, C, and D), and two trains. Specifically, Technical Specification 3.6.6 action statement D requires that one or two inoperable CRFC are to be restored to OPERABLE within 7 days or in accordance with the Risk Informed Completion Time Program. In post-accident operation the CRFC system fans are designed to start automatically following a safety injection, if not already running.

On May 13, 2023, Constellation operators received an alarm for CRFC motor fan vibrations, which was coincident with the A CRFC fan high vibration white light on the front of the main control board. After a reset attempt Constellation secured the fan from operation and using the sound monitor identified an abnormal noise. Operators subsequently declared the A CRFC inoperable, resulting in only one of the two required A train CRFCs being operable and available to reduce containment pressure and temperature during a design basis accident. Constellation entered Technical Specification 3.6.6. condition D and repairs were completed to replace the motor within the Technical Specification action statement of 7 days.

Through the corrective action program evaluation process, Constellation identified that sub-optimal greasing practices contributed to an accelerated aging rate of the motor bearing.

Constellation noted that a change in the method of greasing the motor bearing was implemented in the preventive maintenance job plan in 2008. This change resulted in the grease not being removed from the bearing housing and adding a small amount of new grease, 4 to 10 shots. The design analysis document, DA-ME-92-119 Life Evaluation of the Containment Recirculation Fan Motors Mechanical Components (ACF08A, B, C & D),

Revision 0, specifies injecting three cubic inches, which Constellation calculated to be about 65 shots of grease with the drain plug open. Then running the motor for about 10 minutes to allow excessive grease to drain. Based on the design analysis document, and work order reviews Constellation determined that work order steps for the CRFC motors have been inadequate since 2008. In the timeframe from 2008 to 2023 ten work orders were implemented and one canceled to accomplish the greasing requirements of preventive maintenance document PM-P301469.

Constellation obtained a motor failure analysis from a third-party motor vendor to determined possible causes of the A CRFC motor bearing issue. It was identified that three potential contributions to the bearing failure were evident,

(1) the initial fit could have been on the loose end of the tolerance range, although this cannot be confirmed through documentation, (2)poor greasing practices and

(3) long, slow process forces acting on the bearing fit during startup, operation, and shutdown of the motor. An example of the long, slow process acting on the bearing could be the shaft torque from routine motor start and stops.

The inspectors noted that in the spring of 2023, as part of the refueling outage Constellation had approved a preventive maintenance extension document PMA-23-139626. This change implemented a one-time extension of PM-P301469, the lubrication of the CRFC motors from 18 months to 36 months. The CRFC motors were to be lubricated in the 2023 refueling outage but the work order was canceled, and the activity was scoped deleted, citing preventive maintenance extension as justification. Condition report 04679012 captures this information.

Lastly, Constellation completed an extent of condition review on the B, C, and D CRFC motors. Greasing actions were completed in May of 2023 on the other three motors following the A motor failure, in accordance with work order C93910390.

In this work order grease was added to the bearings with the drain plug open, allowing older and excess grease to evacuate the bearing. Additionally, Constellation has developed a maintenance plan to be completed during the next refueling outage.

Corrective Actions: Constellation performed corrective maintenance to replace the A containment recirculation fan cooler motor including the failed bearing, as well as greased the other three containment recirculation fan cooler motor bearings.

Corrective Action References: 04677897, 04679012

Performance Assessment:

Performance Deficiency: The inspectors determined that Constellation did not establish adequate instructions or procedures to grease the CRFC motors. The design analysis document DA-ME-92-119 contained this information, therefore this performance deficiency was reasonably within Constellations ability to foresee and prevent.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality 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, Constellations preventive maintenance procedures did not have adequate instructions from design analysis document DA-ME-92-119 to properly grease the A CRFC motor bearings, resulting in a failure of the bearings and the component being inoperable.

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 IMC 0609 Appendix A, Exhibit 3, Barrier Integrity Screening Questions, Section C for Reactor Containment. The inspectors determined that there was no actual open pathway in the physical integrity of the reactor containment, no failure of the containment isolation system, no failure of containment heat removal components, or no failure of the plants severe accident mitigation features. Additionally, there was no actual reduction in function of the hydrogen igniters in the reactor containment. Therefore, the finding is of very low safety significance, Green.

Cross-Cutting Aspect: H.14 - Conservative Bias: Individuals use decision making-practices that emphasize prudent choices over those that are simply allowable. A proposed action is determined to be safe in order to proceed, rather than unsafe in order to stop. In this instance during the spring 2023 refueling outage Constellation approved a one-time extension to the CRFC preventive maintenance greasing job plan without sufficiently reviewing and understanding the technical design analysis basis for the maintenance plan, resulting in a less conservative decision.

Enforcement:

Violation: R.E. Ginna Nuclear Power Plant Technical Specification 5.4.1.a, Procedures, requires in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Revision 2, Appendix A, Section 3.f.(4), includes containment cooling system as structure, system or component requiring such procedures.

Specifically, Constellation initiated 10 work order procedures and preventive maintenance document PM-P301469 perform 18 month containment lube and inspection procedures, to implement this requirement.

Contrary to the above, from 2008 until 2023, Constellation did not establish procedures to properly lubricate the containment recirculation fan cooler motor bearings. Specifically, 10 work orders and preventive maintenance document PM-P301469 did not establish the correct lubricating steps for the motor bearings. As a result, the bearing failed while operating.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Observation: B Emergency Diesel Generator High Lube Oil Filter Differential 71152A Pressure The inspectors independently reviewed Constellations corrective action documents, work group evaluation, work orders, maintenance calibration and testing procedures, and associated actions regarding an issue where the B emergency diesel generator lubricating oil filter observed a high differential pressure. Constellation performed a failure mode causal tree analysis and determined that the most likely cause of the high lube oil filter differential pressure was air in the lube oil filter pressure switch sensing line. Constellation was able to refute other possible failure modes.

Constellation entered the issue into the corrective action program as AR 04514680 and subsequently completed a work group evaluation on the issue. As required by Ginnas Technical Specifications Section 3.8.1, Constellation completed a common cause failure evaluation, action 04514680- 17, to determine if the issue was applicable to the identical system on the A emergency diesel generator. Constellation determined the A emergency diesel generator did not exhibit similar issues. As part of the corrective maintenance following the issue Constellation vented air from the sensing lines and replaced the filters. Subsequently, the maintenance instrumentation calibration and testing procedures were updated to ensure air was vented from the sensing lines following maintenance and calibrations.

The inspectors independently reviewed the maintenance procedure changes to ensure they were incorporated prior to future use, as well as the effectiveness of sensing line venting instructions. Additionally, the inspectors conducted field inspections when Constellation performed maintenance activities to replace the lube oil filter, vent air from the system and calibrate the differential pressure sensing instrumentation. Also, the inspectors reviewed and inspected the common cause failure applicability to the identical system on the A emergency diesel generator. Lastly the inspectors interviewed Constellations engineering and maintenance staff. The inspectors interview topics consisted of the lube oil deficiency, corrective actions, common cause failure and operating experience.

The inspectors independently evaluated the lube oil differential pressure issue 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.

Observation: A Containment Recirculation Fan High Vibration and Motor 71152A Bearing Failure The inspectors independently reviewed Constellations corrective action documents, corrective action program evaluation, preventive maintenance documents, work orders, testing procedures and associated actions regarding an issue where the A containment recirculation fan motor bearing failed.

Constellation completed a corrective action program evaluation, IR 04677897- 04, which in conjunction with a third-party vendor completed motor and bearing failure analysis.

Constellation determined that there were three potential causes to the bearing failure. The cause contributors were initial bearing fit, greasing bearing practices, and long, slow process of the forces acting on the bearing during startup, operation, and shutdown of the motor. An example of the long, slow process acting on the bearing could be the shaft torque from routine motor start and stops. Of these contributors the initial bearing fit was unable to be determined specifically, and Constellation determined the most likely cause was the sub-optimal greasing practices which contributed to an accelerated aging rate. A preventive maintenance change in 2008 led to aged grease not being removed from the bearing housing, and small amounts of new grease being added.

Constellation completed an extent of condition on the remaining three containment recirculation fan cooler motors: B, C and D. The bearing life, greasing practices and maintenance history were reviewed by Constellation and repair plan corrective actions are being planned. Additionally, fan motors for B, C, and D were greased per work order C93910390 in May of 2023 following the failure of the A motor bearing.

The inspectors independently evaluated Constellations corrective actions and repair plans. Upon the initial motor bearing failure in May 2023 the inspectors independently conducted field inspections of the removed component and maintenance activities.

Additionally, the inspectors reviewed preventive maintenance changes to the frequencies and procedure steps. The conclusions associated with this focused problem identification and resolution inspection sample are documented in this report under the Inspection Results.

Assessment 71152S Corrective Action Program Semi-Annual Tend Review

The inspectors reviewed Constellations corrective action program and evaluated a sample of issues and events that occurred from July 2023 through December 2023 at Ginna. The inspectors then verified whether the issues were appropriately evaluated by Const ellation 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, and entered them into the corrective action program for resolution. The inspectors noted low level or precursor trends identified by Constellation relating to training and qualifications, equipment performance trends and human performance precursors.

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 October 12, 2023, the inspectors presented the emergency preparedness program inspection results to Daren Blankenship, Site Vice President, and other members of the licensee staff.

• On January 29, 2024, the inspectors presented the integrated inspection results to Daren Blankenship, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.05 Corrective Action 04721341 1 of 2 Fire Extinguishers at SH40P Sent for Hydro 12/04/2023

Documents 04723879 Housekeeping Issues Identified in L-shape Building 12/15/2023

Resulting from

Inspection

71111.12 Corrective Action 04701420 Rx Trip on OTDT 09/09/2023

Documents

Procedures MA-AA-716-010 Maintenance Planning Revision 33

MA-AA-716-010- Maintenance Planning, Work Package Enhancement (MMC) Revision 12

1010 Maintenance Modification Contractor

MA-AA-7165-010- Operational Critical Component Work (OPCCW) Process Revision 11

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SM-AA-3019 Parts Quality Initiative Revision 12

SM-AA-3019 Parts Quality Initiative Revision 13

71111.13 Corrective Action 04711062 Door 10 Found Closed Further than Expected 10/19/2023

Documents

Resulting from

Inspection

71114.02 Corrective Action AR 04709130 ANS Siren Design Report for Siren Updates 10/12/2023

Documents

Resulting from

Inspection

Procedures

R.E. Ginna Nuclear Power Plant, Alert and Notification Revision 5

System Design Report

EP-MA-121-1002 Alert and Notification System Program Revision 15

71114.04 Procedures EP-AA-120-1001 10CFR50.54(q) Change Evaluation Revision 11

71114.05 Corrective Action AR 04709127 Drill Report Didn't Credit Assembly and Accountability Drill 10/12/2023

Documents AR 04710014 ERO Depth to Fully Staff 10/16/2023

Resulting from

Inspection

Miscellaneous KLD TR - 1261, Robert E. Ginna Nuclear Power Plant 08/22/2022

Development of Evacuation Time Estimates

Procedures EP-AA-1000 Exelon Nuclear Standardized Radiological Emergency Plan Revision 33

Inspection Type Designation Description or Title Revision or

Procedure Date

EP-AA-1012 Exelon Nuclear Radiological Emergency Plan Annex for Revision 8

Ginna Station

71152A Corrective Action 04514680 EDG 'B' High Lube Oil Filter DP After Start 08/03/2022

Documents 04677897 'A' Containment Recirc Fan High Vibration 05/13/2023

Engineering DA-ME-92-119 Life Evaluation of the Containment Recirculation Fan Motors Revision 0

Evaluations Mechanical Components (ACF08A, B, C &D)

Miscellaneous 04677897-04 Corrective Action Program Evaluation, 'A' Containment 07/3/2023

Recirc Fan High Vibration

PMA-23-139626 One-time Extension to Numerous 18 Month Lubrication and

Inspects of Containment HVAC Components

Procedures CPI-INSTR-64A Calibration of Emergency Diesel Generator A Revision 31

Instrumentation

CPI-INSTR-64B Calibration of Emergency Diesel Generator B Revision 29

Instrumentation

Work Orders C93910390 Perform Greasing of Motors MO/CF1B, MO/CF1C, and

MO/CF1D after MO/CF1A Swapout is Complete

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