IR 05000244/2024003
| ML24312A214 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 11/08/2024 |
| From: | Erin Carfang Division of Operating Reactors |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2024003 | |
| Download: ML24312A214 (1) | |
Text
November 8, 2024
SUBJECT:
R.E. GINNA NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000244/2024003
Dear David Rhoades:
On September 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at R.E. Ginna Nuclear Power Plant. On October 31, 2024, the NRC inspectors discussed the results of this inspection with Daren Blakenship, 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.
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. 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 (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-2024-003-0033
Licensee:
Constellation Energy Generation, LLC
Facility:
R.E. Ginna Nuclear Power Plant
Location:
Ontario, New York
Inspection Dates:
July 1, 2024 to September 30, 2024
Inspectors:
C. Swisher, Senior Resident Inspector
K. Poolman, Resident Inspector
B. Dyke, Operations Engineer
N. Floyd, Senior Reactor Inspector
J. Fuller, Senior Resident Inspector
K. Smetana, Reactor Engineer
Approved By:
Erin E. Carfang, Chief
Projects Branch 1
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at R.E. Ginna Nuclear Power Plant, 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 an Alternative Compensatory Measure for an Inoperable Fire Barrier Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000244/2024003-01 Open/Closed
[H.8] -
Procedure Adherence 71111.05 The inspectors identified a Green finding and associated non-cited violation of the Ginna Operating License Condition 2.C.(3), Fire Protection, where Constellation failed to evaluate the acceptability of an alternative method for performing a fire watch. Specifically,
Constellation utilized a camera as a means of performing a fire watch without adequate justification while a fire barrier was inoperable.
Additional Tracking Items
None.
PLANT STATUS
Ginna began the inspection period operating at 100 percent rated thermal power. On September 14, 2024, Ginna commenced reactor plant coast-down. On September 30, 2024, the unit was taken offline for planned refueling outage 1GR45 and remained offline 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.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)
'C' standby auxiliary feedwater on July 2, 2024 (2)
'A' safety injection on July 9, 2024 (3)
'B' emergency diesel generator on July 17, 2024
- (4) Turbine driven auxiliary feedwater pump on July 30, 2024 (5)
'B' charging pump on August 15, 2024
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 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) Air handling room on July 1, 2024
- (2) Intermediate building sub-basement on July 1, 2024
- (3) Relay room on July 1, 2024
- (4) L-shaped building on July 8, 2024
- (5) Technical support center on July 12, 2024
- (6) Auxiliary building basement on August 15, 2024
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the on-site fire brigade training and performance during an unannounced fire drill on September 12, 2024
71111.06 - Flood Protection Measures
Flooding Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated internal flooding mitigation protections in the screenhouse, concerning the dike that separates safety-related service water pumps and 480 volt buses from the circulating water system
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 control room during a response to a tornado warning on July 10, 2024
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 requalification training on August 15, 2024
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (3 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components remain capable of performing their intended function:
- (1) Service air compressor preventative maintenance on August 29, 2024
- (2) Pressure control valve 135 preventative maintenance on August 29, 2024
- (3) Service water valves preventative maintenance on September 11, 2024
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (1 Sample)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activity to ensure configuration changes and appropriate work controls were addressed:
- (1) Evaluation of plant risk (Green) during unplanned alternate reactor coolant system injection diesel driven flex pump relief valve testing on August 16, 2024
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Operability assessment of the 'B' residual heat removal pump after noted elevated motor vibrations and temperatures on September 12, 2024
- (2) Operability assessment of the 'B' emergency diesel generator after the failure of the lubrication oil temperature switch on September 17, 2024
- (3) Functionality assessment of the motor driven fire water pump following degraded performance during the annual fire water system surveillance test on September 25, 2024
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
- (1) PCR-24-02240, Procedure change package to utilize intermediate range detectors in lieu of power range detectors during initial criticality and low-power physics testing on September 23, 2024
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) (4 Samples)
- (1) Functional testing of the containment hydrogen monitor 'A' cell after analyzer cell failure and completed repairs on July 3, 2024
- (2) Functional testing of the 'C' charging pump following valve packing replacement and plunger repairs on July 5, 2024
- (3) Calibration and testing of nuclear instrumentation system intermediate range N36 following cable repair on July 25, 2024
- (4) Functional testing with load bank of standby auxiliary feedwater diesel generator following maintenance on August 13, 2024
Surveillance Testing (IP Section 03.01) (2 Samples)
- (1) STP-O-16QT-RECIRC, "Auxiliary Feedwater Turbine Pump - Quarterly (Recirculation Alignment)" on September 9, 2024
- (2) STP-O-2.1QC, "Safety Injection Pump C Quarterly Test" on September 10, 2024
Diverse and Flexible Coping Strategies Testing (IP Section 03.02) (1 Sample)
- (1) Functional test of the 'A' diesel driven flexible coping strategies pump following annual preventative maintenance on August 12,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS06: Emergency AC Power Systems (IP Section 02.05)===
- (1) For the period July 1, 2023 through June 30, 2024
MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)
- (1) For the period July 1, 2023 through June 30, 2024
MS08: Heat Removal Systems (IP Section 02.07) (1 Sample)
- (1) For the period July 1, 2023 through June 30, 2024
MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)
- (1) For the period July 1, 2023 through June 30, 2024
MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)
- (1) For the period July 1, 2023 through June 30, 2024
===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 issue:
- (1) Work group evaluation and corrective actions regarding the reactor pressure vessel flange O-ring leak (AR04674097) on August 15,
INSPECTION RESULTS
Failure to Evaluate an Alternative Compensatory Measure for an Inoperable Fire Barrier Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000244/2024003-01 Open/Closed
[H.8] -
Procedure Adherence 71111.05 The inspectors identified a Green finding and associated non-cited violation of the Ginna Operating License Condition 2.C.(3), Fire Protection, where Constellation failed to evaluate the acceptability of an alternative method for performing a fire watch. Specifically, Constellation utilized a camera as a means of performing a fire watch without adequate justification while a fire barrier was inoperable.
Description:
The purpose of a fire barrier is to delay the spread of fire between two separate fire zones. When a fire barrier cannot perform its function, additional measures must be taken to account for the increase in fire risk. On August 8, 2024, the licensee opened and uncapped a two-inch drain valve, floor drain isolation valve 2653A, which opened a pathway in the three-hour concrete fire barrier between fire zone ABM in the chemical volume control system holdup tank room, and fire zone ABO in the new fuel storage room. The valve is required to be open while new fuel is being stored in the new fuel building prior to a refueling outage. The fire zones contain separate trains of 480 volt safety-related switchgear. The fire barrier impairment was tracked using procedure A-52.12-F-03, Revision 4, Control of LCO for Fire Suppression, Detection, Fire Barriers, NFPA 805 and High Safety Significant Components (HSSC), and an hourly fire watch was indicated as required.
Technical Requirement 3.7.5 requires that fire barrier rated assemblies and components in Table TR 3.7.5-1 shall be operable. If one or more required fire barrier rated assemblies or components is inoperable, the licensee is required to establish a continuous fire watch on one side of the affected assembly or component within one hour, or perform a fire watch inspection of the affected fire zones once within one hour and every hour thereafter and verify detectors on at least one side of the affected assembly or component are operable within one hour, and restore affected assembly or component to operable status within seven days. The licensee verified detection on both sides of the drain valve operable and elected to use a remotely operated camera to perform the fire watch inspection once per hour of the chemical volume control system holdup tank room side of the drain valve.
OP-AA-201-007, "Fire Protection System Impairment Control," Revision 2, allows the use of a camera for fire watches in high radiation areas. The inspectors questioned the licensee about the use of the camera as the area in which the camera was utilized was not posted as a high radiation area. The inspectors also asked the licensee if the impact of the change to the Ginna fire protection program to allow the use of cameras for fire watch tours was evaluated as required by Ginna Operating License Condition 2.C.(3), "Fire Protection." The evaluation had not been performed as required.
Corrective Actions: The licensee stopped use of the camera and began hourly fire watch inspections of both sides of the inoperable fire barrier while the drain valve was open.
Corrective Action References: AR04793889
Performance Assessment:
Performance Deficiency: The inspectors determined that the failure to implement an appropriate fire watch for an inoperable fire barrier was a performance deficiency. The use of a camera to perform hourly fire watch tours of the affected zone was not evaluated per Technical Requirement Manual basis 3.7.5.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors 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. (i.e., core damage). Specifically, by not performing an adequate fire watch of the zones impacted by the inoperable fire barrier, the licensee may have been unable to detect and respond to a fire affecting multiple trains of equipment important to safe shutdown.
Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP.
The inspectors assessed the significance of the finding using IMC 0609, Attachment 4, Initial Characterization of Findings, Table 3, SDP Appendix Router. The inspectors transitioned to Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP," because
- (1) the finding did not involve discrepancies with the fire brigade and
- (2) did involve fixed fire protection systems or the ability to confine a fire.
The inspectors determined this finding to be under the Fire Prevention and Administrative Controls category, in accordance with Table 1.2.1, Finding Categories of IMC 0609, Appendix F. A low degradation rating could not be assigned in accordance with step 1.3.1.
This issue screened to very low safety significance (Green) in Phase 1, step 1.4.1 because (A) the fire finding could delay detection of a fire such that the credited safe shutdown strategy could be adversely impacted but (B) the finding adversely affected an area with adequate automatic detection and suppression.
Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions. Specifically, Constellation did not follow station procedures when they used an alternative compensatory measure for an inoperable fire barrier without an evaluation.
Enforcement:
Violation: Ginna Operating License Condition 2.C.(3), Fire Protection, states, in part, that Constellation Energy Generation, LLC shall implement and maintain in effect all provisions of the fire protection program. Ginna Fire Protection Program Report Section 5.0, Definitions, Revision 20, dated April 14, 2023, states, in part, A fire watch is a compensatory action used when fire protection systems or features are inoperable or impaired as required by the Technical Requirements Manual. Technical Requirement 3.7.5 states, in part, that "fire barrier rated assemblies and components in Table TR 3.7.5-1 shall be OPERABLE," and if one or more required fire barrier rated assemblies or components are inoperable then the required action is to perform a fire watch inspection of the affected fire zones once within one hour and every hour thereafter until the barrier is operable.
Contrary to the above, between August 8, 2024, and August 12, 2024, Constellation established and performed an inadequate fire watch without completing an appropriate evaluation to support the deviation from Technical Requirement 3.7.5. Specifically, the licensee used a camera to remotely perform the hourly fire watch which was not an evaluated method for performing a fire watch.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Observation: Review of Reactor Pressure Vessel Flange O-ring Leak 71152A The inspectors reviewed the licensees evaluation and corrective actions associated with the reactor vessel flange inner O-ring leak that was identified on April 30, 2023, and documented under AR04674097. Licensee staff performed immediate actions to align the seal leak-off to the outer O-ring and determined the likely potential cause(s) of the leak to be foreign material intrusion or a defect on the reactor vessel/head flange mating surface. The inspectors determined that licensee staff plan to perform detailed visual examinations and collect measurement data (surface finish, flatness, and dimensional) of the mating surfaces during the fall 2024 refueling outage to inform the cause(s) of the leak. In addition, the licensee revised their procedure RF-501, "Reactor Vessel Head O-ring Replacement," with additional guidance for handling and inspections, and the licensee approved a design change to use an O-ring with a thicker cladding to improve sealing performance during future replacement activities. The inspectors did not identify any findings or violations.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 31, 2024, the inspectors presented the integrated inspection results to Daren Blakenship, Site Vice President, and other members of the licensee staff.
THIRD PARTY REVIEWS
Inspectors reviewed Institute of Nuclear Power Operations reports that were issued during an inspection period.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
08/14/2024
Procedures
2.12-F-03
Control of LCO for Fire Suppression, Detection, Fire Barriers,
NFPA 805 and High Safety Significant Components (HSSC)
Revision 4
Fire Protection System Impairment Control
Revision 2
Corrective Action
Documents
04/30/2023
Procedures
RF-501
Reactor Vessel Head O-ring Replacement
Revision 007