IR 05000244/2020001
| ML20127H676 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 05/06/2020 |
| From: | Erin Carfang Reactor Projects Branch 1 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2020001 | |
| Download: ML20127H676 (14) | |
Text
May 6, 2020
SUBJECT:
R.E. GINNA NUCLEAR POWER PLANT, LLC - INTEGRATED INSPECTION REPORT 05000244/2020001 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION REPORT 07200067/2020001
Dear Mr. Hanson:
On March 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at R.E. Ginna Nuclear Power Plant, LLC. On April 15, 2020, the NRC inspectors discussed the results of this inspection with Mr. Paul Swift, Site Vice President and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspectors did not identify any findings or violation of more than minor significance during this inspection.
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 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, X /RA/
Signed by: Erin E. Carfang
Erin E. Carfang, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket No. 05000244 and 07200067 License No. DPR-18
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000244 and 07200067
License Number:
Report Numbers:
05000244/2020001 and 07200067/2020001
Enterprise Identifiers: I-2020-001-0067
I-2020-001-0021
Licensee:
Exelon Generation Company, LLC
Facility:
R.E. Ginna Nuclear Power Plant, LLC
Location:
Ontario, NY
Inspection Dates:
January 01, 2020 to March 31, 2020
Inspectors:
J. Schussler, Senior Resident Inspector
S. Monarque, Resident Inspector
J. Brand, Reactor Inspector
J. Nicholson, Senior Health Physicist
Approved By:
Erin E. Carfang, Chief
Reactor Projects Branch 1
Division of Reactor Projects
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, 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
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
PLANT STATUS
Ginna began the inspection period at rated thermal power. On March 26, 2020, the unit began gradually lowering power as it entered end-of-cycle coast down operations 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/readingrm/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. From January 1 - March 19, 2020, the inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. 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.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week during which they conducted plant status activities as described in IMC 2515, Appendix D, and observed risk significant activities when warranted. In addition, resident and regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In the cases where it was determined the objectives and requirements could not be performed remotely, management elected to reschedule the inspection to a later date.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
External Flooding Sample (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the 'A' and 'B' battery rooms, the standby auxiliary feedwater rooms and annex door and aqua fence for readiness to cope with external flooding on January 15 and 16, 2020
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)
'A' motor driven auxiliary feedwater following post maintenance operability test on January 13, 2020 (2)
'D' standby motor driven auxiliary feedwater following corresponding system maintenance window on February 3, 2020 (3)
'A' residual heat removal following quarterly surveillance test on March 6, 2020 (4)
'A' safety injection following quarterly surveillance test on March 12, 2020
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (1 Sample)
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)
'B' emergency diesel generator on January 27, 2020
71111.06 - Flood Protection Measures
Cable Degradation (IP Section 03.02) (1 Sample)
The inspectors evaluated cable submergence protection in:
- (1) Manhole/vaults MH-1, MH-1A, and MH-1B on March 4, 2020
71111.07A - Heat Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
- (1) Standby motor driven auxiliary feedwater room cooler AFA01B on March 26, 2020
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the main control room during an announced fire drill on January 29, 2020 and operators' procedure use and adherence to perform a reactor coolant system alternate dilution, nitrogen make-up to 'B' safety injection accumulator and shift turnover on February 24, 2020.
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 March 2, 2020. The training involved a scenario that contained, but was not limited to, a dropped control rod, fuel failure, loss of all offsite power, faulted steam generator, and a failure of containment recirculation fan coolers coincident with a failure of containment spray automatic initiation signal.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Containment isolation, function 21B, (a)(1) determination on March 31, 2020
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)
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) Elevated risk (green), during 'A' motor driven auxiliary feedwater speed reducer coupling planned maintenance on January 13, 2020
- (2) Elevated risk (green), during planned system maintenance window for 'D' standby motor driven auxiliary feedwater pump, motor, and room cooler on January 28, 2020
- (3) Elevated risk (yellow), during a planned system maintenance window of the boric acid storage tank and associated valves on February 11, 2020
- (4) Elevated risk (yellow), during a planned system maintenance window associated with the 'A' emergency diesel generator on February 12, 2020
- (5) Elevated risk (yellow), during planned maintenance on breaker 52/BTA-A, Bus 12A/
Bus 11A tie breaker on March 27, 2020
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Low frequency failure of the motor operated potentiometer a subcomponent of the A' emergency diesel generator Woodward governor on February 7, 2020 (2)4R Kiene valve not fully closed on the 'B' emergency diesel generator on March 7, 2020 (3)
'D' standby motor driven auxiliary feedwater outboard pump bearing failure on March 24, 2020 (4)
'B' motor driven auxiliary feedwater solenoid valve SOV-4326 replacement due to inadequate service water flow on March 26, 2020
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
- (1) Permanent modification of D standby motor driven auxiliary feedwater pump outboard bearing ECP-20-00053 on March 17, 2020
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:
(1)
'A' motor driven auxiliary feedwater pump surveillance test and vibration analysis, following planned maintenance and retorquing of the speed reducer coupling on January 14, 2020 (2)
'C' standby motor driven auxiliary feedwater pump surveillance test following planned pump and motor maintenance on February 12, 2020 (3)
'B' motor driven auxiliary feedwater surveillance test following unplanned service water solenoid valve 4326 replacement on February 25, 2020 (4)
'D' standby motor driven auxiliary feedwater pump surveillance test following planned motor and pump maintenance and unplanned outboard pump bearing replacement on March 2, 2020
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Partial)
(1)
(Partial) The inspectors observed new fuel receipt activities on January 23, 2020 and February 6, 2020.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) STP-O-30.10, 'A' emergency diesel generator pre-startup alignment and STP-O-12.1,
'A' emergency diesel generator on January 16, 2020
- (2) STP-E-10.10, station battery 'A', quarterly on March 10, 2020
- (3) STP-O-2.1-COMP, safety injection pump 'A' comprehensive test on March 11, 2020
- (4) STP-O-2.8Q, component cooling water pump 'B' quarterly test on March 23, 2020
- (5) STP-O-2.1-COMP, safety injection pump 'C', on March 27, 2020
Inservice Testing (IP Section 03.01) (1 Sample)
- (1) STP-O-2.2QA, 'A' residual heat removal pump quarterly, on March 2,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below on March 30, 2020.
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01)===
- (1) Submitted data from January 1, 2019 - December 31, 2019
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (1 Sample)
- (1) Submitted data from January 1, 2019 - December 31, 2019
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (1 Sample)
- (1) Submitted data from January 1, 2019 - December 31, 2019
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Review of Exelon's evaluation and corrective actions associated with safety related pumps and machinery oil sampling process. AR 04278159 and AR
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
===60854.1 - Preoperational Testing of Independent Spent Fuel Storage Facility Installation at Operating Plants
Preoperational Testing of Independent Spent Fuel Storage Facility Installation at Operating Plants===
- (1) The inspectors evaluated Exelons performance during NRC observed preoperational dry run activities that were performed in order to fulfill requirements in the Certificate of Compliance (CoC) No. 1014, Condition 10. The inspectors observed dry run activities on March 16-17, 2020. Specifically, the inspectors observed or reviewed the following activities;
- Closure welding of an MPC mockup including lid to shell, port covers, and closure ring
- Non-destructive weld evaluations including visual and penetrant testing
- Simulated radiological field surveys and RP coverage of welding activities
- Reviewed a recording of PCI welding personnel cutting open a welded canister mock-up removing the port covers and lid that was witnessed by NRC personnel
INSPECTION RESULTS
Observation: PI&R Sample Inspection Regarding Pump Bearing Oil Sampling Process 71152 The inspectors reviewed Exelons evaluation, extent of condition reviews, and corrective actions associated with two problems involving safety related pump oil sampling and analysis. The first problem was documented in AR 04278159 and involved a safety injection pump lubricating oil sample that was not submitted for analysis as required by Ginna procedures. The second problem was documented in AR 04259000 and involved a low viscosity result from a turbine driven auxiliary feedwater pump inboard bearing lubrication oil sample. Exelon determined the oil sample for the 'A' safety injection pump was not submitted for sampling due to a human performance error and was an isolated event. Additionally, Exelon determined the low viscosity reading on the turbine driven auxiliary feedwater pump was likely a sampling error in that the oil sample was likely taken from the turbine bearing instead of the pump bearing. The readings obtained were consistent with normal readings for the turbine lubricating oil. Exelon's corrective actions included revisions to the labeling process for lubricating oil samples and training to applicable personnel. Exelon determined operability of the safety injection pump and the turbine driven auxiliary feedwater pump was not impacted since the pumps oil reservoirs are small such that a full oil replacement is done every time an oil sample is taken. The inspectors performed visual inspections of all the safety injection and turbine driven auxiliary feedwater pumps, interviewed Exelon's system engineer, the component maintenance optimization engineer, and reviewed applicable safety injection and turbine driven auxiliary feedwater pump vibration and lubricating oil data. In addition, the inspectors verified the safety injection and turbine driven auxiliary feedwater pump surveillance test results were satisfactory and vibration data and bearing temperatures remained normal to date. The inspectors concluded the problem evaluations identified the likely causes and the corrective actions addressed the causes. Additionally, the inspectors affirmed the extent of condition by independently reviewing associated corrective actions issues involving Exelons lubricating oil process at Ginna for the last three years. The inspectors did not identify a negative trend in human performance issues.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On January 17, 2020, the inspectors presented the PI&R Sample Safety Related Pumps and Machinery Oil Sampling Process inspection results to George Wrobel, Regulatory Assurance Manager and other members of the licensee staff.
- On March 17, 2020, the inspectors presented the Preoperational Testing of an Independent Spent Fuel Storage Installation inspection results to Michael Cazzolli, Senior Manager Dry Cask Storage, and other members of the licensee staff.
- On April 15, 2020, the inspectors presented the integrated inspection results to Mr. Paul Swift, Site Vice President and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
60854.1
Miscellaneous
Certificate of
Compliance
(CoC) No. 1014
HI-STORM 100 System
Amendment
Procedures
PI-CNSTR-OP-
HLTC-H-01
Closure Welding of Holtec Multi-Purpose Canisters-HI-
STORM 100, HI-STAR100, HI-STORM FW & UMAX
Systems
Revision 4
Corrective Action
Documents
04095305
Corrective Action
Documents
Resulting from
Inspection
04318485
Miscellaneous
ME-91-0022, Analysis of Penetrations in A & B Battery
Rooms NCR 91-410
11/20/92
ECP-14-000571, External Flood Barrier Qualification
Revision 1
WO-C91729814, FPS-3, Periodic Inspection of Fire Barrier
Penetration Seals
Completed
2/08/12
DA-CE-93-081, Turbine Building Pressure Wall Seals
Revision 1
DA-ME-94-118-11, Fire Barrier Penetration Seal
Qualification Analysis for Pipe, Conduit, Sleeve Penetrations
(PENQ-11)
01/08/15
Procedures
FSP-3, Fire Barrier Inspection Program
Revision 4
FPS-2, Fire Barrier Penetration Seal Program
Revision 9
Corrective Action
Documents
Resulting from
Inspection
04312620
04312630
Procedures
STP-O-30.1
Safety Injection System valve and Breaker Position
Verification
Revision 002
STP-O-30.2
RHR System Valve and Breaker Position Verification
Revision 001
STP-O-30.3
Containment Spray System Valve and Breaker Position
Verification
Revision 002
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
STP-O-30.4
Auxiliary Feedwater System Valve and Breaker Position
Verification
Revision 006
STP-O-30.5
Standby Auxiliary Feedwater Pumps Valves and Breakers
Revision 006
Corrective Action
Documents
Resulting from
Inspection
04312954
Work Orders
C93694434
Perform manhole Inspections for the Off-Site Power Circuits
01/16/2019
71111.07A Procedures
C93681177-130
Standby Auxiliary Feedwater Room Cooler B
Service Water Heat Exchanger Inspection Guide
Revision 9
Procedures
OPG-Protected-Equipment Operations Protected
Equipment Program
Revision 22
Corrective Action
Documents
04313757
SAFW bearing
Operability
Evaluations
Kiene Valve
Low frequency 'A' EDG
OPEVAL-20-001
'B' MDAFW pump service water flow, SOV-4326
Procedures
ECP-20-000053
SAFW Pump Outboard Bearing Oil Level and Housing
Conditions
Revision 001
Corrective Action
Documents
Pitting Discovered During Eddy Current Exam of AFA01B
room cooler coil, maintains Standby Auxiliary Feedwater
Pump Building less than 120F during accident conditions
01/28/2020
Drawings
33013-1238
Standby Auxiliary Feedwater (FW) P&ID
Procedures
CPI-FLO-4085
Calibration of Standby Auxiliary Feedwater Pump D Flow
4085
Revision 019
CPI-TEMP-
CNTRL-4012
Calibration of SAFW Pump Room Cooling Unit B
Instrumentation TS-4012, FS-4014, and TS-4015
Revision
00700
STP-O-16QA
Auxiliary Feedwater Pump A - Quarterly
Revision 21
STP-O-36-
COMP-D
Standby Auxiliary Feedwater Pump D-Comprehensive Test
Revision 018
Work Orders
C93699666
Swap Out RV-9709B with a Tested Spare
03/01/2019
Work Orders
C93683207
20 New Fuel Receipt
10/09/2018
Corrective Action
Documents
04313852
04320096
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Resulting from
Inspection
04310143
04314976
04310287
Procedures
STP-E-10.10
Station Battery A Quarterly Surveillance
Revision 002
STP-O-12.1
Revision 32
STP-O-2.1-
COMP-A
Safety Injection Pump A Comprehensive Test
Revision 017
STP-O-2.1-
Comp-C
Safety Injection Pump C Comprehensive Test
Revision 012
STP-O-2.2QA
Residual Heat Removal Pump A Inservice Test
Revision 020
STP-O-2.8Q
Component Cooling Water Pump Quarterly Test
Revison 017
STP-O-30.10
Emergency Diesel Generator A Pre-Startup Alignment
Revision 14
71151
Corrective Action
Documents
Resulting from
Inspection
04331235
04330853
Corrective Action
Documents
04092244
04192168
04192755
214234
259000
259035
260128
278159
04310109*
- Initiated in response to this inspection
Corrective Action
Documents
Resulting from
Inspection
04310109
04313239
Work Orders
C93262117