IR 05000244/2023010

LLC - Age-Related Degradation Inspection Report 05000244/2023010

ML23352A278
Person / Time
Site:	Ginna
Issue date:	12/19/2023
From:	Mel Gray Division of Operating Reactors
To:	Rhoades D Constellation Energy Generation, Constellation Nuclear
References
IR 2023010
Download: ML23352A278 (1)

Text

December 19, 2023

SUBJECT:

R.E. GINNA NUCLEAR POWER PLANT, LLC - AGE-RELATED DEGRADATION INSPECTION REPORT 05000244/2023010

Dear David Rhoades:

On November 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at R.E. Ginna Nuclear Power Plant, LLC and discussed the results of this inspection with James D. 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:

DPR-18

Report Number:

05000244/2023010

Licensee:

Constellation Energy Generation, LLC

Facility:

R.E. Ginna Nuclear Power Plant, LLC

Location:

Ontario, New York

Inspection Dates:

November 13, 2023, to November 30, 2023

Inspectors:

P. Cataldo, Senior Reactor Inspector

E. Miller, Reactor Inspector

J. Schoppy, Senior Reactor Inspector

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 an age-related degradation 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

Less Than Adequate Corrective Actions in Response to Service Water Manual Valve Stem-to-Disc Separation Failures Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000244/2023010-01 Open/Closed

[P.2] -

Evaluation 71111.21N.

The team identified a Green finding and associated non-cited violation (NCV) of 10 CFR 50,

Appendix B, Criterion XVI, Corrective Action, because Constellation did not correct a condition adverse to quality associated with service water (SW) manual valve stem-to-disc separation failures discovered in March 1993.

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

71111.21N.04 - Age-Related Degradation Age-Related Focused Engineering Inspection (section 03.01)

The inspectors selected a sample of components and structures to verify that engineering performance and maintenance activities addressed age-related degradation and that problems were appropriately identified, addressed, and corrected.

Samples were selected considering risk insights and the potential for degradation. Specifically, the inspectors selected samples that were risk-significant and either had indications of age-related degradation or were exposed to environments that could cause age-related degradation.

The inspectors considered site-specific and industry-wide operating experience to identify samples and included both active and passive sub-components within each component or structure.

For each selected sample listed below, the inspectors reviewed the licensees engineering and maintenance activities credited to address age-related degradation to assess whether they were being performed using applicable standards and procedures, evaluated against appropriate acceptance criteria, and that maintenance and condition monitoring was completed at an appropriate interval. The inspectors also assessed whether issues identified during licensee activities were being entered into and addressed by the applicable station processes including the corrective action program, and whether periodic assessments of maintenance effectiveness and operating experience were being completed, including feedback and process adjustments.

(1) Fire Water Piping Degradation

(2) MOV-738A A200 Relay Failure

(3) DB-50 Bus 17 Breaker Failure

(4) Component Cooling Water Piping in Auxiliary Building

(5) Relay Room Drains Blocked

(6) B Emergency Diesel Generator Leaks and Performance Problems

(7) B Fuel Oil Storage Tank Coating Failure

(8) B Residual Heat Removal Flow Transmitter Deficiencies

(9) Component Cooling Water to B Heat Exchanger Coating Failure

(10) V4667 Service Water Supply to Emergency Diesel Generator Disc Degradation

(11) Instrument Air Compressor C Service Water Inlet Isolation Valve Solenoid 8242 Degradation

(12) Safety Injection Accumulator Transmitter 937 and Relay Chatter

INSPECTION RESULTS

Less Than Adequate Corrective Actions in Response to Service Water Manual Valve Stem-to-Disc Separation Failures Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems

Green NCV 05000244/2023010-01 Open/Closed

[P.2] -

Evaluation 71111.21N.

The team identified a Green finding and associated non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, because Constellation did not correct a condition adverse to quality associated with SW manual valve stem-to-disc separation failures discovered in March 1993.

Description:

On July 20, 1993, the licensee (Rochester Gas & Electric Corporation) submitted License Event Report (LER) 93-03 for two safety-related SW manual valves found with stem-to-disc separation. The two valves were normally locked-open manual valves found in the closed position (stem fully retracted to the open position but the disc disconnected and in the valve seat). The stem-to-disc separation conditions were identified on March 28, 1993, during examination of the valve internals; however, the licensee was unable to determine with certainty when the stems separated from their respective discs. LER 93-03 documented that the underlying cause was due to the use of dissimilar metals in the manufacture of the stem and disc, combined with prolonged exposure to raw SW, and differential aeration cell (concentration cell) corrosion due to stagnant conditions surrounding the T-slot area in the valve bonnet. The licensees corrective actions included replacing the two affected Crane Model 101XU SW valves with valves of a different design and material composition (stainless steel disc and stem). In addition, the licensee replaced or refurbished the majority of other susceptible normally locked-open manual SW valves during refueling outages in 1993 and 1994. In their LER, the Ginna staff committed to establish a preventative maintenance frequency for valves in the service water system. The team noted that this commitment was repeated in the licensees docketed response to the NRC, dated August 23, 1993, for the associated Notice of Violation following the NRC Enforcement Conference.

During the inspection, the team reviewed corrective action issue report (IR) 4493977 initiated in April 2022 that described severe corrosion-related degradation in the stem-to-disc connection area on manual SW valve V4667, the A SW loop supply to the A emergency diesel generator (EDG) heat exchangers (HXs). The team noted that the IR documented that a stem-to-disc separation was imminent and that the valve was last examined in 1993. The team also noted that IR 4672224, initiated in April 2023, documented that the stem-to-disc connection was found degraded unsatisfactory during the internal examination of SW manual valve V4668B, the B SW loop inlet isolation valve to the A and B EDG HXs. The team noted that the most recent visual examination of V4668B was completed in September 2003.

The stem and disc parts of these two valves were replaced (with stainless steel stems and carbon steel discs).

The team observed that the licensee had identified 32 valves in the population of concern (normally locked-open manual SW valves) and created repetitive tasks (reptasks P002212, P002213, & P002214) to review the population of valves grouped by SW header outage (valves requiring an A SW header outage, B SW header outage, or no SW header outage, respectively). The team ascertained that the licensee had created a recurring task (every 18 months) to review these SW valves for consideration for a subsequent internal exam. The team reviewed the associated tracking spreadsheet which was organized by reptask, valve number, component description, valve style, internal materials, maintenance history, corrective action history, and prioritization. The team observed that 19 of the 32 SW valves were presently prioritized as more susceptible due to their internal materials (carbon steel disc and stainless steel stem). The team identified that the preventative maintenance (PM)task stated that once an inspection work order was generated it could be rejected by the system engineer or PM analyst. The document further stated the PM shall be reviewed at least every 10 years.

The team ascertained that PM implementation had resulted in many susceptible valves remaining in service 20+ years between visual internal examinations. Specifically, four valves were last examined 20+ years ago, thirteen valves were last inspected 10+ years ago, and PM implementation from December 2012 through March 2022 had resulted in only two valves being examined. The team requested documentation of the most recent 10-year review of the PM program; however, the licensee found no evidence of a 10-year review. The team noted the conditions for corrosion described in LER 93-03 remained for in-service SW valves.

The team ascertained that at the time of the inspection, additional safety-related SW valves in the population of concern remained vulnerable to stem-to-disc separation failures. These SW valves included but were not limited to V4640 (refurbished in 1993 and 2003, but with the original carbon steel disc still installed), V4608 (refurbished in 1995 and 2011, but with the original carbon steel disc still installed), V4665 (carbon steel disc replaced in kind in 1994 and last refurbished in 2009), and V4756 (carbon steel disc replaced in kind in 1993 and last refurbished in 2008).

Based on the teams assessment, independent visual examination of the valve removed from V4667 that showed imminent stem-to-disc separation, and review of photos of the degraded V4668B valve; the team concluded performance to implement this PM as a corrective action did not reliably maintain the valves to perform their intended safety functions.

The team determined that Constellation staff missed opportunities to evaluate their PM effectiveness in review of the degraded conditions of valves V4667 and V4668B found in 2022 and 2023, respectively. Additionally, a Nuclear Oversight (NOS) audit of this area in 2023 (NOSA-GIN-23-04) presented an opportunity to re-consider the PM effectiveness.

Corrective Actions: Constellation staff entered the performance deficiency into the corrective action program in IR 4720652 to evaluate corrective actions necessary.

Corrective Action References: IR 4720652

Performance Assessment:

Performance Deficiency: Constellation did not correct a condition adverse to quality associated with SW manual valve stem-to-disc separation failures discovered in March 1993.

Specifically, Constellation did not establish valve internal examinations or other actions commensurate with the safety significance (potential adverse impact on SW-supplied safety-related structures, systems, or components).

Screening: This issue was more than minor because if left uncorrected, the performance deficiency had the potential to lead to a more significant safety concern. Specifically,

(1) a stem-to-disc separation could preclude timely repositioning of one of the locked-open manual SW valves required to be repositioned in accordance with emergency operating procedures (EOPs) and/or abnormal operating procedures (AOPs),

(2) the unexpected SW manual valve closure due to a stem-to-disc separation could adversely impact the in-service supply to safety-related structures, systems, or components (SSCs), or

(3) a latent failure of one of the normally locked-open SW manual valves could reduce SW system designed redundancy and remain undetected until relied upon to mitigate an abnormal occurrence (e.g. loss of one SW train).

Significance: The team assessed the significance of the finding using IMC 0609 Appendix A, Significance Determination of Reactor Inspection Findings for At - Power, Exhibit 2, Mitigating Systems Screening Questions. The team determined that this finding was a deficiency affecting the design or qualification of mitigating SSCs, where the SSCs maintained their operability or functionality. Specifically, the team did not identify additional stem-to-disc separation failures since March 1993 and found no evidence of a stem-to-disc separation condition currently present in the 32 locked-open manual SW valves of concern.

Therefore, the team determined the finding to be of very low safety significance (Green).

Cross-Cutting Aspect: P.2 - Evaluation: The organization thoroughly evaluates issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. Specifically, Constellation did not thoroughly evaluate the unexpected results of internal SW valve inspections in 2022 and 2023 (including extent-of-condition)commensurate with the potential safety significance. (P.2)

Enforcement:

Violation: 10 CFR 50, Appendix B, Criterion XVl, "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, Constellation did not implement actions to assure that a previously identified condition adverse to quality was corrected. The condition adverse to quality involved locked-open, safety-related, manual SW valves susceptible to corrosion and stem-to-disc separation. Specifically, when examinations in April 2022 showed that the stem and disc connection of an affected valve was severely corroded, Constellation did not review their previous corrective actions for this condition (including PM program) and make adjustments to maintain the reliability and capability of the affected valves.

Enforcement Action: This violation is being treated as an NCV, 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 November 30, 2023, the inspectors presented the design basis assurance inspection (programs) inspection results to James D. Blankenship, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.21N.04 Calculations

DA-EE-92-084-

Instrument Loop Performance Evaluation and Setpoint

Verification

Revision 3

71111.21N.04 Corrective Action

Documents

CR-2009-2306

CR-2009-3214

CR-2012-3641

CR-2014-2114

1903336

2602825

2647356

2730010

4194155

4185107

200666

202260

207936

209419

215597

275196

287990

4366987

4375219

4445472

4466775

4467102

4493977

4507319

4514680

4534489

4560524

4565372

4670255

4670626

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

4672224

4676452

4677255

4678974

4694230

4700792

4701077

71111.21N.04 Corrective Action

Documents

Resulting from

Inspection

4709179

4717636

4717827

4717831

4717924

4717925

4717946

4718195

4718749

4718751

4718847

4718852

4719825

4719957

4719987

20030

20631

20652

20685

71111.21N.04 Engineering

Evaluations

Technical Evaluation ESR-17-0002-309-101-01

dated 5/1/18

71111.21N.04 Engineering

Evaluations

AR 04287990

Exelon Powerlabs Failure Analysis of Buried Fire Water

Pipe

dated

2/26/20

71111.21N.04 Engineering

Evaluations

ECP-22-000223

EDG Piping Change from Sch. 40 to Sch. 80

Revision 0

71111.21N.04 Miscellaneous

PCM Template, Low Voltage Circuit Breaker

Revision 7

71111.21N.04 Miscellaneous

PCM Template, Motor Control Centers

Revision 7

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.21N.04 Miscellaneous

Fire Piping UT Results Database - LR-FWS-PROGPLAN

dated

2/5/22

71111.21N.04 Miscellaneous

BOP-UT-20-145

UT Erosion/Corrosion Examination, Stainless Steel Elbow

Above Valve 4420, B CCW HX

dated

2/16/20

71111.21N.04 Miscellaneous

GME-50-02-

DB50

Westinghouse, 480V Air Circuit Breaker, Type DB-50

Maintenance for Type DB-50 Breakers

Revision 30

71111.21N.04 Miscellaneous

LR-BTNK-

PROGPLAN

Buried Piping and Tanks Program

Revision 5

71111.21N.04 Miscellaneous

M-95

Fire Protection Backflow Prevention and Drains

Inspection, and Sump Pump Operability Check

performed

2/4/22

71111.21N.04 Miscellaneous

STP-0-12.2

Emergency Diesel Generator B

performed

10/4/23 &

11/1/23

71111.21N.04 Miscellaneous

STP-0-12.2-

24HR

Emergency Diesel Generator B 24 Hour Endurance Run

performed

10/30/19

71111.21N.04 Miscellaneous

STP-0-12.68

Diesel Generator Fuel Oil Transfer Pump B Test

performed

11/1/23

71111.21N.04 Procedures

AP-SW.1

Service Water Leak

Revision 23

71111.21N.04 Procedures

AP-SW.2

Loss of Service Water

Revision 8

71111.21N.04 Procedures

ER-AA-200-1001

Equipment Classification

Revision 8

71111.21N.04 Procedures

IP-EQP-1

Control of Environmental Qualifications (EQ) Master List

Revision 12

71111.21N.04 Work Orders

C20104039

C20800104

C20800105

C90694247

C90799382

C90873327

C91323413

C91432247

C91786628

C92568787

C92568799

C92660300

C93308953

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

C93382500

C93605834

C93608941

C93632316

C93663960

C93691405

C93699620

C93701190

C93716157

C93731946

C93747946

C93748656

C93757195

C93757197

C93758656

C93770076

C93773580

C93774459

C93775257

C93787546

C93790767

C93808677

C93808952

C93813296

C93815545

C93816419

C93819631

C93842450

C93847843

C93851056

C93851753

C93892537

C93912586

C93941323