IR 05000220/2017007

Design Bases Assurance Inspection Report 05000220/2017007 and 05000410/2017007 on 11/15/2017

ML17320A210
Person / Time
Site:	Nine Mile Point
Issue date:	11/15/2017
From:	Mel Gray Engineering Region 1 Branch 1
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
Gray M
References
IR 2017007
Download: ML17320A210 (30)

Text

ber 15, 2017

SUBJECT:

NINE MILE POINT NUCLEAR STATION - DESIGN BASES ASSURANCE INSPECTION REPORT 05000220/2017007 AND 05000410/2017007

Dear Mr. Hanson:

On October 5, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the Nine Mile Point Nuclear Station, Unit Nos. 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on October 5, 2017, with Mr. P. Orphanos, Nine Mile Point Site Vice President, and other members of your staff.

The inspection examined activities conducted under your licenses as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your licenses. In conducting the inspection, the team examined the adequacy of selected components and modifications to mitigate postulated transients or accidents, maintain containment integrity, and/or minimize the potential for initiating events. The inspection involved field walkdowns, examination of selected procedures, calculations and records, and interviews with station personnel.

The NRC inspectors did not identify any finding or violation of more than minor significance.

In accordance with 10 CFR Part 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for the public inspection in the NRC Public Docket Room or from the Publicly Available Records component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Mel Gray, Chief Engineering Branch 1 Division of Reactor Safety Docket Nos. 50-220 and 50-410 License Nos. DPR-63 and DPR-69

Enclosure:

Inspection Report 05000220/2017007 and 05000410/2017007 w/Attachment: Supplementary Information

REGION I==

Docket Nos. 50-220 and 50-410 License Nos. DPR-63 and DPR-69 Report Nos. 05000220/2017007 and 05000410/2017007 Licensee: Exelon Generation Company, LLC (Exelon)

Facility: Nine Mile Point Nuclear Station, LLC (NMPNS)

Units 1 and 2 Location: Oswego, NY Inspection Period: September 18, 2017 - October 5, 2017 Inspectors: J. Kulp, Senior Reactor Inspector, Team Leader, Division of Reactor Safety (DRS)

J. Schoppy, Senior Reactor Inspector, DRS T. OHara, Reactor Inspector, DRS J. Vazquez, Reactor Engineer, Division of Reactor Projects (DRP)

C. Hobbs, Reactor Inspector, DRS F. Arner, Senior Reactor Analyst, DRS S. Kobylarz, NRC Electrical Contractor M. Yeminy, NRC Mechanical Contractor Approved By: Mel Gray, Chief Engineering Branch 1 Division of Reactor Safety i Enclosure

SUMMARY

Inspection Report (IR) 05000220/2017007, 05000410/2017007; 09/18/2017 - 10/05/2017; Nine

Mile Point Nuclear Station, Units 1 and 2; Engineering Team Inspection.

The report covers the Design Basis Assurance Inspection conducted by a team of five U.S. Nuclear Regulatory Commission (NRC) inspectors and two NRC contractors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 6, dated July 2016.

No findings were identified.

ii

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R21 Design Basis Assurance Inspection (IP 71111.21M)

.1 Inspection Sample Selection Process

The team selected six risk significant components for review using information contained in the Nine Mile Point Probabilistic Risk Assessment (PRA) and the U.S. Nuclear Regulatory Commissions (NRCs) Standardized Plant Analysis Risk (SPAR) model for Nine Mile Point Nuclear Station (NMPNS). Additionally, the team referenced the risk-informed inspection notebook for NMPNS in the selection of potential components for review. In general, the selection process focused on components that had a risk achievement worth (RAW) factor greater than 1.3 or a risk reduction worth (RRW) factor greater than 1.005. The components selected were associated with safety-related systems and included a variety of components such as pumps, batteries, ventilation fans, electrical breakers, and safeguards equipment control sequencers.

The team also selected six modifications that potentially affected the design bases, licensing bases, and performance capability of the associated structures, systems, and components (SSCs). The team selected modifications completed in the last three years that had not been previously inspected by an NRC modification team using inspection procedure 71111.17T. The team selected modifications that were performed on risk significant components that were associated with the initiating events, mitigating systems, or containment integrity cornerstones. The complexity of the modification was also considered in selecting the modifications reviewed.

The team initially compiled a list of components based on the risk factors previously mentioned and risk significant modifications that had been completed. Additionally, the team reviewed the previous NRC Component Design Bases Inspection (CDBI) and Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications inspection reports and excluded those components and modifications previously inspected. The team then performed an assessment to narrow the focus of the inspection to six components, six modifications, and three operating experience (OE)items. The team selected one sample (Unit 2 suppression pool) based on large early release frequency (LERF) implications. The teams assessment evaluated possible low design margin including consideration of original design issues, margin reductions due to modifications, or margin reductions identified as a result of material condition/equipment reliability issues. The assessment also included items such as instances where performance test results were not met, corrective action history, repeated maintenance, Maintenance Rule (a)(1) status, operability reviews for degraded conditions, NRC resident inspector insights, and industry OE. Finally, consideration was given to the uniqueness and complexity of the design and the available defense-in-depth margins.

The team performed the inspection as outlined in NRC Inspection Procedure (IP)71111.21M. This inspection effort included walkdowns of selected components and modifications; interviews with operators, system engineers, and design engineers; and reviews of associated design documents and calculations to assess the adequacy of the components to meet design basis, licensing basis, and risk-informed beyond design basis requirements.

Additionally, for the modification portion of the inspection, the team evaluated whether the modifications were adequately implemented; and if procedures and design and license basis documentation affected by modifications had been adequately updated to reflect any changes to the design or license basis of the facility after the change had been performed. The team also verified that changes to the design and/or licensing bases had been performed in accordance with NRC guidance. Summaries of the reviews performed for each component, modification, and OE sample are discussed in the subsequent sections of this report. Documents reviewed for this inspection are listed in the Attachment.

.2.1.1 Unit 1 Emergency Diesel Generator (EDG) 103 (EG-EDG-103)

a. Inspection Scope

The team inspected the adequacy of control power voltage at selected diesel starting and generator operating control components (generator field and field flash controls, diesel starting air solenoids, generator breaker closure circuit, and selected diesel engine control relays) to confirm the capability of the emergency diesel generators to start and provide emergency power during design basis conditions and to recover from a postulated station blackout condition. The team interviewed system and design engineers, and reviewed vendor documentation and the results of the 125VDC system voltage analysis to evaluate the adequacy of voltage at the selected components. The team reviewed the maintenance strategy, corrective maintenance history, and the preventive maintenance actions performed on the above components for adequacy, issues identified, and the effectiveness of the preventive and corrective maintenance actions. The team reviewed the corrective action program history for the selected control components to identify recurring issues affecting reliability and to evaluate whether plant staff adequately identified and corrected adverse conditions. The team inspected the EDG during a walkdown to assess material condition, verify equipment configuration, and to identify conditions that could affect the reliable operation of the generator and the diesel engine starting control components.

b. Findings

No findings were identified.

.2.1.2 Unit 2 Suppression Pool

a. Inspection Scope

The team inspected the Unit 2 suppression pool to verify that it was capable of meeting its design basis requirements. The NMPNS Unit 2 primary containment is a Mark II design that incorporates a drywell pressure suppression system and utilizes a large reservoir (pool) of water to function as a heat sink to absorb energy. The primary containment is a steel-lined, reinforced-concrete enclosure housing the reactor and the suppression pool. The suppression pool serves both as a heat sink for transients and accidents and as a reservoir of water for the core standby cooling systems. It is the primary source of water for the low-pressure core spray (LPCS) and low-pressure coolant injection (LPCI) systems, and provides a safety-related source of water for the reactor core isolation cooling (RCIC) and high-pressure core spray (HPCS) systems.

Suppression pool water level, pressure, and temperature are continuously displayed in the main control room.

The team reviewed the Updated Final Safety Analysis Report (UFSAR), calculations, drawings, associated licensing bases documents, and procedures to identify the most limiting requirements for the suppression pool SSCs. The team also reviewed suppression pool inspection (including suction strainer and T-quencher video recordings)and leak rate testing results to assess the material condition and structural integrity of the suppression pool. The team reviewed recent pressure suppression pool to drywell vacuum breaker surveillance tests to verify that the vacuum breakers remained operable and capable of performing their design function supporting primary containment integrity and suppression capability. The team conducted several walkdowns of the accessible portions of the exterior of the suppression pool structure to assess the material condition (including evidence of leakage), suction piping structural supports, potential hazards, and configuration control. The team also conducted several walkdowns of suppression pool instrumentation in the main control room and remote shutdown panel rooms to assess the material condition, functionality, operating range, and configuration control.

The team also reviewed associated corrective action issue reports, operator logs, and applicable instrumentation and control test results for the suppression pool temperature, pressure, and level instruments to determine if there were adverse trends and to ensure that Exelon staff at NMPNS adequately identified and addressed adverse conditions.

b. Findings

No findings were identified.

.2.1.3 Unit 1 Battery 12 (BAT-12)

a. Inspection Scope

The team inspected the design, testing, and operation of Unit 1 Battery 12 to verify its capability to perform the intended design basis functions to provide 125 volt direct current (VDC) power to connected loads during normal, transient, and postulated accident conditions, including station blackout and post-fire safe shutdown events.

Specifically, the team reviewed design calculations, including battery sizing and voltage drop calculations, load profile studies, and battery terminal connection resistances to evaluate whether the battery capacity was adequate for the equipment load and duration required by design and licensing basis conditions. The team reviewed battery calculations to determine whether adequate voltage was available to meet minimum voltage specifications for connected loads during worst case loading conditions. The team reviewed the battery hydrogen generation analysis and battery room ventilation design to determine whether hydrogen concentration levels would remain below acceptable levels during normal and postulated accident conditions.

The team also reviewed the recently performed cell replacement work order instructions following Unit 1 replacement of safety related batteries earlier in the year. In addition, routine surveillance tests performed since battery replacement were reviewed to assess whether the testing and maintenance were sufficient and performed in accordance with approved procedures, vendor recommendations, industry standards, as well as design and licensing basis requirements. The team interviewed design and system engineers regarding the design, operation, testing, and maintenance of the battery. The team interviewed licensed operators and conducted walkdowns to determine if operator actions could be successfully accomplished as assumed in the NMPNS Unit 1 design basis calculations for Appendix R fire, loss-of-offsite power, and station blackout events.

Finally, the team reviewed corrective action documents to ensure adverse conditions were being properly evaluated and corrected.

b. Findings

No findings were identified.

.2.1.4 Normal Power Breaker From Offsite for Division-1 4.16 kV Bus (2ENS*SWG101-13)

a. Inspection Scope

The team inspected the normal offsite power supply breaker (2ENS*SWG101-13), which provides normal offsite power supply to the Division-1 4.16-kV safety-related bus via the associated reserve station service transformer, to verify that it was capable of performing its design functions. The team reviewed one-line diagrams, control schematics, and the design basis as described in the UFSAR to verify the adequacy of the breaker to provide adequate supply power to the bus and operate as required. The team reviewed the breaker closing interlocks to verify that the breaker opening and closing control circuits functioned as designed. The team reviewed a sample of preventive and corrective maintenance test results to verify that the applicable test acceptance criteria were satisfied and that maintenance activities were performed in accordance with established frequency requirements. The team reviewed applicable maintenance rule documentation and plant technical specifications to ensure that functional failures were adequately addressed by the stations maintenance rule program. The team interviewed system and design engineers to answer questions that arose during document reviews to determine the adequacy of maintenance and configuration control. The team conducted several walkdowns of the 4.16-kV breaker cubicle, inspected observable material condition, and reviewed selected drawings and calculations to assess the installed configuration, operating environment, and potential vulnerability to hazards.

The team reviewed the maintenance and operating history of the breaker and similar breakers, associated corrective action issue reports, associated engineering service requests, and applicable test results to determine if there were any adverse operating trends and to ensure that Exelon staff at NMPNS adequately identified and addressed any adverse conditions, including conditions indicative of a potential common-cause vulnerability.

b. Findings

No findings were identified.

.2.1.5 2A Emergency Diesel Generator (EDG) Room Exhaust Fan and EDG Control Room Unit

Cooler

a. Inspection Scope

The team inspected the 2A EDG room exhaust fans and the associated control room area unit cooler to verify that they were capable of performing their safety related design functions. The team reviewed applicable portions of NMPNS Unit 2s technical specifications and UFSAR to identify design basis requirements for the EDG room exhaust fans and EDG control room unit cooler. The team reviewed plant drawings of the EDG ventilation system to verify that they were consistent with the as-installed configuration. The team reviewed design margin calculations to ensure that the exhaust fans and unit cooler could successfully operate under postulated limiting conditions and that the design temperature limits were satisfied. The team reviewed design specifications and vendor documents to verify that the ventilation and cooling systems would function as designed when required and support proper operation of the components located in the area. The team reviewed flow paths, design of fans and inlet power dampers as well as the exhaust power dampers and their capability to modulate based on temperature. The team reviewed the design of the recirculation dampers and their capability to modulate based on temperature as well as their capability to fail closed when the room temperature reached the set point. The team reviewed the design of the gravity tornado dampers to assure that they would not become inadvertent (no tornado)choke points which could restrict air flow. Additionally, the team reviewed the design of the supply of service water piping to the EDG control room unit cooler, the flow rate of the recirculation fan, the coolers design fouling factor, and its performance testing results to assess the systems ability to cool and maintain proper operating temperatures in the control room. The team reviewed the maintenance history, preventive maintenance frequency, and EDG surveillance test results to assess the adequacy of maintenance activities as well as the overall capability of the ventilation and cooling systems to support the proper operation of the EDG.

The team discussed the design, operation, corrective maintenance, and preventive maintenance of the exhaust fans and the unit cooler with the engineering staff to gain an understanding of the performance history and overall component health. The team performed several walkdowns of the EDG ventilation system and its control room cooling to assess the material condition, operating environment, and configuration control and to verify that the as-built condition was consistent with the design. The team reviewed the maintenance and operating history of the supply fans, and cooler and applicable test results to determine if there were any adverse operating trends and to ensure that Exelon staff adequately identified and addressed adverse conditions.

b. Findings

No findings were identified.

.2.1.6 Unit 1 1-2 HPCI/FW Pump and Control Valve (PMP-29-03, FCV-29-137)

a. Inspection Scope

The team inspected the 1-2 HPCI/feedwater pump (PMP-29-03) and its associated feedwater control valve (FCV-29-137) to verify that they were capable of performing their design functions. The team reviewed applicable portions of NMPNSs technical specification, the Updated Final Safety Analysis Report (UFSAR), and the condensate and feedwater/HPCI design basis document to identify design basis requirements for the pump and valve. The team performed a walkdown of the 1-2 pump and the control valve to assess material condition, operating environment, and potential hazards. The team reviewed design documentation to verify that pump flow rates and valve stroke times and capabilities were adequately evaluated and verified through surveillance and inservice testing. The team reviewed the maintenance and operating history of the 1-2 feedwater pump and control valve, associated corrective action documents, system health reports, and applicable surveillance and inservice test results to determine if there were adverse operating trends and to determine whether NMPNS staff adequately identified and addressed adverse conditions.

b. Findings

No findings were identified.

.2.2.1 Speed switch upgrade for Unit 2 Division III (High Pressure Core Spray) Emergency

Diesel Generator (2EGS-EB2)

a. Inspection Scope

The team reviewed Engineering Change Package (ECP) 16-000478 for the speed transmitter and electronic sequencing switch upgrade for the Unit 2 Division III Emergency Diesel Generator (EDG). The original electronic sequencing switch installed on the High Pressure Core Spray (HPCS) EDG was obsolete and required replacement.

This speed switch is part of the control circuit for startup of the Division III HPCS EDG (2EGS*EG2). The speed switch provides speed related signals to the EDG starting control logic to allow the EDG to start, to transition from starting to running mode and to allow the generator output breaker to shut when the EDG is up to operating speed.

Additionally, two tachometers and a computer point output are driven by the 125 VDC speed transmitter circuit. This speed switch does not provide overspeed protection for the diesel engine.

The team reviewed the modification to verify that the design bases, licensing bases and performance capability of the Division III EDG and its support systems had not been degraded by the modification. The team reviewed the associated work order instructions and documentation to verify that maintenance implemented the modification as designed. The team conducted walkdowns of the Unit 2 Division III EDG room to ensure that maintenance staff installed the modification in accordance with design instructions and to independently assess configuration control and material condition of SSCs in the area. The team also reviewed corrective action issue reports and system health reports to determine if there were reliability or performance issues that may have resulted from the modification. Additionally, the team reviewed the 10 CFR 50.59 screening and engineering evaluation associated with this modification. The documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.2.2.2 Replace 4 Horsepower (HP) motor on 2RCS-MOV18A-ACT with a 2.6 HP motor

a. Inspection Scope

The team reviewed ECP 16-000752 that replaced the 4 HP motor on reactor recirculation system valve actuator 2RCS-MOV18A-ACT with a 2.6 HP motor. Exelon staff implemented the modification in November 2016, when the existing actuator motor failed and replacement parts were not available. As a result, Exelon staff at NMPNS Unit 2 replaced the 4HP motor with an available 2.6 HP motor.

The team reviewed Exelon staffs evaluation documenting the minor reduction in valve operating speed resulting in a minor increase in stroke time, as well as the equivalency of voltage, frequency, service factor, and insulation class of the new motor. The team also reviewed the change in full load amps and locked rotor amps as well as the difference in starting torque, the difference in running torque, and the unchanged limit switch and torque switch. The team noted that the weight and the center of gravity of the replacement motor were lower than the weight of the failed motor and therefore the seismic evaluation was not affected.

The team reviewed the modification package to determine if the design basis, licensing basis, or performance capability of the valves and/or electrical system had been degraded by the modification. The team interviewed engineers to gain understanding of overall reliability of the valve, and reviewed the associated work order instructions and documentation to verify that maintenance personnel had implemented the modification as designed. The team also reviewed the 10 CFR 50.59 applicability review and screening associated with the modification.

b. Findings

No findings were identified.

.2.2.3 Speed sensing panel upgrade for Unit 1 Emergency Diesel Generators (EG-EDG102

and EG-EDG103)

a. Inspection Scope

The team reviewed the design modification that installed an upgraded emergency diesel generator speed sensing panel for EDG 102 and EDG 103. Exelon staff determined the existing speed sensing panel was obsolete and attributed a recent failure to start to a degraded speed sensing panel assembly. The team reviewed the design consideration summary and the configuration change acceptance criteria to evaluate whether key design parameters were identified and that modification testing adequately verified design requirements. The team reviewed the 10CFR50.59 screening performed to confirm that a 50.59 evaluation was not required. The team also confirmed the design modification adequately identified calibration procedures, preventive maintenance procedures, and preventive maintenance requirements to assure continued reliable operation of the equipment.

b. Findings

No findings were identified.

.2.2.4 Alternate Stuffing Box Gland Assembly for RCIC Turbine (2ICS*T1)

a. Inspection Scope

The team reviewed ECP 16-000226 and item equivalency evaluation 0001714241-1 which assessed the acceptability of changes in material and configuration of the RCIC turbine casing packing gland assemblies from that received from the original equipment manufacturer. The team assessed whether the modification was consistent with the design and licensing bases and operational requirements. The team conducted interviews with responsible engineers and walked down hardware installations. The team evaluated whether affected evaluations, calculations, maintenance and supply documents and component drawings were properly updated to reflect the post-modification configuration. Finally, the team reviewed the 10 CFR 50.59 screening determination associated with this modification.

b. Findings

No findings were identified.

.2.2.5 Install a graphite pressure seal for 2ICS*MOV120 (RCIC)

a. Inspection Scope

The team reviewed ECP 16-000260 that replaced the pressure seal for the reactor core isolation cooling (RCIC) steam admission valve (2ICS*MOV120). While performing repairs to address an internal leak on the valve in April 2016, the valve was disassembled. In accordance with standard site practice, while reassembling the valve following the repairs, the existing silver-plated soft iron pressure seal gasket was replaced with a graphite pressure seal. The team reviewed the modification to verify that the design bases, licensing bases, mechanical joint design capability, and sealing characteristics had not been degraded by the change. The team interviewed design engineers and reviewed design consideration documentation, vendor instructions and recommendations, and 10 CFR 50.59 screening requirements to ensure that Exelon staff properly categorized this modification as an equivalent change. The team reviewed the associated design specifications and work orders to verify that Exelon staff appropriately implemented the gasket material replacement. The team conducted walkdowns of the accessible portions of the RCIC system to observe the material condition of the modified valve and ensure that the system configuration was maintained in accordance with design instructions. The team also reviewed corrective action program documentation to determine if there were reliability or performance issues that may have resulted from the modification.

b. Findings

No findings were identified.

.2.2.6 Evaluate Alternate Replacement Valve for 2RHS*V214/V215

a. Inspection Scope

The team reviewed modification 16-000010 that replaced two in-series valves (2RHS*V214 and 2RHS*V215) on a residual heat removal (RHR) system discharge drain line. These valves were replaced with an alternate model because the existing model was no longer available from the vendor. The team reviewed the modification to verify that the design bases, licensing bases and structural integrity of the RHR system and supporting SSCs had not been degraded by the modification. The team interviewed system and design engineers and reviewed evaluations, post maintenance testing results, and associated maintenance work orders to verify that the valve replacement activities were appropriately implemented. The team reviewed 10 CFR 50.59 screening requirements to ensure that Exelon staff properly categorized this modification as an equivalent change. The team reviewed welding logs and NMPNS welding specifications to verify that welds were performed in accordance with applicable portions of the ASME Boiler and Pressure Vessel Code requirements and that relevant operating experience associated with socket welds was adequately accounted for. The team also reviewed corrective action program documentation to determine if there were reliability or performance issues that may have resulted from the modification.

b. Findings

No findings were identified.

.2.3 Review of Industry Operating Experience (OE) and Generic Issues (3 samples)

The team reviewed selected OE issues for applicability to the NMPNS Units. The team performed a detailed review of the OE issues listed below to verify that Exelon staff had appropriately assessed potential applicability to site equipment and initiated corrective actions when necessary.

.2.3.1 Information Notice 15-01, Degraded Ability To Mitigate Flooding Events

a. Inspection Scope

The team assessed Exelon staffs applicability review and disposition of NRC Information Notice 2015-01. The NRC issued this information notice to inform licensees of recent OE related to external flood protection where deficiencies with equipment, procedures, and analyses relied on to either prevent or mitigate the effects of external flooding at licensed facilities resulted in degraded ability to mitigate flooding events.

The team reviewed Exelons NMPNS external flood related calculations, analyses, structural inspection results, abnormal operating procedures, operator training (including any time critical operator actions), and corrective action documents to assess Exelon staffs performance in considering the applicability of this OE to NMPNS. The team reviewed the potential impact of external flooding events to safety-related equipment and structures, the condition and readiness of flood mitigation equipment, procedure adequacy, and corrective action implementation (including problem identification and resolution). The team performed a walkdown of accessible portions of the NMPNS site flood berm, flood culvert, revetment ditch, flood protection equipment trailer, Unit 2 diesel building, Unit 1 diesel and 4kV powerboard rooms, and reactor building elevations below the maximum expected flood levels at both units to assess the observable material condition (including evidence of in-leakage), potential hazards, and Exelons design control.

b. Findings

No findings were identified.

.2.3.2 Information Notice 16-05, Operating Experience Regarding Complications from a Loss of

Instrument Air

a. Inspection Scope

The team assessed Exelon staffs applicability review and disposition of NRC Information Notice 2016-05. The NRC issued this information notice to inform licensees about several reactor events during which operator response was complicated by a loss of instrument air (IA).

The team verified that Exelon staff at NMPNS maintained unit-specific air system operating procedures and abnormal operating procedures that addressed both failures of safety-related and non-safety related instrument air systems as well as restoration strategies. The team reviewed operator training lesson plans (including any time critical operator actions) and simulator scenario guides to ensure that Exelons operator training program adequately covered loss of IA scenarios. The team performed a walkdown of the instrument air compressors, receivers, and a portion of accessible air lines at both units to assess the observable material condition, configuration control, and operating environment. The team also reviewed instrument air related corrective action issue reports to determine if there were any adverse trends and to ensure that Exelon adequately identified and addressed any adverse conditions.

b. Findings

No findings were identified.

.2.3.3 Information Notice 15-09, Mechanical Dynamic Restraint (Snubber) Lubricant

Degradation Not Identified Due To Insufficient Service Life Monitoring

a. Inspection Scope

The team assessed the NMPNS staffs applicability review and disposition of IN 2015-09 associated with potential degradation of the lubricant (grease) in mechanical dynamic restraints (Snubbers) not previously identified at some nuclear power plants due to insufficient service life monitoring. Adequate snubber lubrication is essential to proper operation allowing free thermal movement of a component or piping during normal operating conditions and to restrain the component or piping during abnormal conditions.

NMPNS staff had identified an issue with degraded grease during a refueling outage in Unit 2 in 2010. In response to an unexpected number of snubber testing failures, NMPNS staff instituted an accelerated preventive maintenance effort which was aimed at replacing the grease in snubbers suspected of having grease subject to potential degradation. Additionally, in response to IN 2015-09, NMPNS staff took actions to revise the Exelon shelf life standard for grease used in mechanical snubbers to reflect that described in applicable industry guidance.

b. Findings

No findings were identified

4OA2 Identification and Resolution of Problems (IP 71152)

a. Inspection Scope

The team reviewed a sample of problems that Exelon staff previously identified and entered into its corrective action program. The team reviewed these issues to determine whether an appropriate threshold was met for identifying issues and to evaluate the effectiveness of corrective actions. In addition, the team reviewed condition reports written on issues identified during the inspection to verify adequate problem identification and incorporation of the problem into the corrective action program. The specific corrective action documents that the team sampled and reviewed are listed in the

.

b. Findings

No findings were identified.

4OA6 Meetings, including Exit

On October 5, 2017, the team presented the inspection results to Mr. P. Orphanos, Nine Mile Point Site Vice President, and other members of the Nine Mile Point staff. The team verified that no proprietary information was retained by the inspectors or documented in the report.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Exelon Personnel:

P. Orphanos, Site Vice President

M. Khan, Director Site Engineering

D. Moore, Manager Regulatory Assurance

P. Bartolini, Manager, Design Engineering (Mechanical)

R. Pritchard, Regulatory Assurance Engineer

B. Dempsy, Mechanical Design Engineer

D. Morley, Electrical Design Engineer

M. Cook, System Engineer

K. Johnson, Engineering Corrective Action Program Coordinator

D. Pokon, Electrical Design Engineer

J. Raymond, Systems Engineer

F. Sgroi, Systems Engineer

J. VanGorder, Procurement Engineer

R. Staley, 125 Vdc System Engineer

B. Felicita, Unit 2 EDG System Engineer

H. Gersbach, Structural Engineer

M. Faulkner, Equipment Operator

NRC personnel

E. Miller, Senior Resident Inspector

G. Stock, Resident Inspector

E.H. Gray, Senior Reactor Inspector

K. Mangan, Senior Reactor Inspector

LIST OF ITEMS

Opened

None.

Open and

Closed

None.

Closed

None.