ML093160122

IR 05000244-09-008; 06/15/2009 - 06/19/2009 and 08/24/2009 - 08/27/2009; R. E. Ginna Nuclear Plant; Special Inspection Team Report

ML093160122
Person / Time
Site:	Ginna
Issue date:	11/12/2009
From:	David Lew Division Reactor Projects I
To:	John Carlin Ginna
Clifford J
References
EA-09-249 IR-09-008
Download: ML093160122 (29)

See also: IR 05000244/2009008

Text

UNITED STATES NUCLEAR REGULATORY

COMMISSION

REGION I 475 ALLENDALE

ROAD KING OF PRUSSIA, PA 19406-1415

November 12, 2009 EA-09-249

Mr. John T. Carlin Vice President, RE. Ginna Nuclear Power Plant RE. Ginna Nuclear Power Plant, LLC 1503 Lake Road Ontario, New York 14519

RE. GINNA NUCLEAR POWER PLANT -NRC SPECIAL INSPECTION

TEAM REPORT 05000244/2009008;

PRELIMINARY

WHITE FINDING Dear Mr. Carlin: On June 16-20, 2009, and August 24-27,2009, the U.S. Nuclear Regulatory

Commission (NRC) conducted

the onsite portions of a special inspection

at RE. Ginna Nuclear Power Plant. office inspection

reviews were conducted

in the intervening

weeks. The enclosed report documents

the inspection

team's findings and observations

which were discussed

with you and others members of your staff on August 27, 2009, during a preliminary

exit briefing, and on October 7, 2009, during the final exit meeting. The special inspection

was conducted

in response to a turbine driven auxiliary

feedwater (TDAFW) pump overspeed

trip on May 26, 2009. The team included a subsequent

overspeed

trip on July 2,2009 into its inspection

scope. The NRC's initial evaluation

of this condition

satisfied

the criteria in NRC Inspection

Manual Chapter 0309, "Reactive

Inspection

Decision Basis for Reactors," for conducting

a special inspection.

The basis for initiating

this special inspection

is further discussed

in the inspection

team's charter that is included in this report as Attachment

B. The inspection

examined activities

conducted

under your license as they relate to safety and compliance

with the Commission's

rules and regulations

and with the conditions

of your license. The inspectors

reviewed selected procedures

and records, observed activities, and interviewed

personnel.

This letter transmits

one self-revealing

finding that, using the reactor safety Significance

Determination

Process (SOP), has preliminarily

been determined

to be White, a finding with low to moderate safety significance.

The finding is associated

with the failure to preclude recurrence

of a significant

condition

adverse to quality associated

with the corrosion

of the governor control valve of the turbine driven auxiliary

feedwater (TDAFW) pump, that led to a failure of the TDAFW pump during surveillance

testing on July 2, 2009 and was the likely cause of the overspeed

trip on May 26, 2009. Following

the July test failure, Ginna replaced the

J. Carlin 2 governor control valve stem and conducted

weekly monitoring

of the governor control valve during surveillance

testing to identify any potential

for stem binding. In addition, corrective

actions included a follow-up

inspection

of the governor control valve during the fall 2009 refueling

outage. There is no immediate

safety concern present due to this finding

because the system is now operable and the long term corrective

actions are being implemented

in Ginna's corrective

action program. The final resolution

of this finding

will be conveyed in a separate correspondence.

As discussed

in the attached Inspection

report. the tinding is also an apparent violation

of NRC requirements.

specifically, 10 CFR Appendix B, Criterion

XVI. "Corrective

Actions." and is therefore

being considered

for escalated

enforcement

action in accordance

with the Enforcement

Policy, which can be found on the NRC's Web site at http://www.nrc.gov/readingrm/doc-collections/enforcementl.

Following

a discussion

of the preliminary

safety Significance

of this finding during the initial exit briefing on August 27,2009. a phone call was held between Glenn Dentel, Branch Chief, Division of Reactor Projects.

and yourself on October 1. 2009. During this call, you indicated

that R.E. Ginna Nuclear Power Plant does not contest the characterization

of the rIsk significance

of this finding, and therefore

you have declined to further discuss this issue at a Regulatory

Conference

or provide a written response.

Please note that by declining

to request a Regulatory

Conference

or submit a written response, you relinquished

your right to appeal the final SOP determination.

in that by not doing either, you would not meet the appeal requirements

stated in the Prerequisite

and Limitation

sections of Attachment

2 of IMC 0609. You will be advised by a separate correspondence

of the results of our deliberations

on this matter. In addition.

the report documents

two findings of very low safety significance (Green). The findings involved violations

of NRC requirements.

However, because of the very low safety significance

and because they are entered into your corrective

action program (CAP). the NRC is treating these findings as non-cited

violations (NeVs) consistent

with Section VI.A.1 of the NRC Enforcement

Policy. If you contest any NCV in this report, you should provide a response within 30 days of the date of this inspection

report, with the basis for your denial, to the Nuclear Regulatory

Commission, A TIN.: 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. In addition.

if you disagree with the characterization

of any finding 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 Regional Administrator, Region I, and the NRC Resident Inspector

at R.E. Ginna Nuclear Power Plant. The information

you provide will be considered

in accordance

with Inspection

Manual Chapter 030? In accordance

with 1 0 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure, and your response (if any) will be available

electronically

for public inspection

in the

J. 3 NRC Public Document Room or from the Publicly Available

Records (PARS) component

of the NRC's document system (ADAMS). ADAMS is accessible

from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html(the

Public Electronic

Reading Room). Sincerely, ,/;I,/;tJ--fbr-Division of Reactor Projects Docket No.: 50-244 License No.: DPR-18

Inspection

Report 05000244/2009008

w/Attachment

A: Supplemental

Information

w/Attachment

B: Special Inspection

Charter cc w/encl: Distribution

via ListServ

J. 2 NRC Public Document Room or from the Publicly Available

Records (PARS) component

of the NRC's document system (ADAMS). ADAMS is accessible

from the NRC Web Site at httg:llwww.nrc.gov/reading*rm/adams.html(the

Public Electronic

Reading Room). Sincerely, IRAJ James W. Clifford for: David C. lew, Director Division of Reactor Projects Docket No.: 50-244 License No.: DPR-18

Inspection

Report 05000244/2009008

w/Attachment

A: Supplemental

Information

w/Attachment

B: Special Inspection

Charter cc w/encl: Distribution

via

SUNSI Review Complete:

gtd (Reviewer's

DOCUMENT NAME: G:\DRP\BRANCH1\Ginna\TDAFW

SIT\AED Track Changes Ginna Report Rev 4 After declaring

this document "An Official Agency Record" it will be released to the To receive I!I copy of this document, indicate in the box: "C' =Copy without attachmenVenclosure "e" =Copy with attaclhmentlenclosure "N";:; No co ML093160122

RI/ENF OFFICE RI/DRS RI/DRP NAME CCahill/cc*

JClifford/jwc

DATE 10/21109 11/05/09 *see prior concurrence

OFFICIAL RECORD COpy Distribution

w/encl: S. Collins, RA (R10RAMaii

Resource)

ROPreports@nrc.gov

M. Dapas, ORA (R10RAMaii

Resource)

D. Lew, DRP (R1DRPMaii

Resource)

J. Clifford, DRP (R1DRPMail

Resource)

l. Trocine, RI OEDO RidsNrrPMREGinnaResource

RidsNrrDorlLpl1-1

Resource G. Dentel, DRP N. Perry, DRP J. Hawkins, DRP K. Kolaczyk, DRP, SRI S. Kennedy, DRP, SRI L. Casey, DRP, RI M. Rose, DRP, OA D. Bearde, DRP

Docket License Report Team

Approved U.S. NUCLEAR REGULATORY

REGION 50-244 DPR-18 05000244/2009008

Constellation

Energy, R. E. Ginna Nuclear Power Plant, LLC R. E. Ginna Nuclear Power Plant Ontario. New York June 15-19, 2009 and August 24-27.2009

C. cahill, Senior Reactor Analyst, Division of Reactor Safety S. Kennedy, Senior Resident Inspector, Division of Reactor Projects K. Kolaczyk, Senior Resident Inspector, Division of Reactor Projects J. Bream, Project Engineer.

Division of Reactor Projects Glenn T. Dentel, Chief Projects Branch 1 Division of Reactor Projects

2 SUMMARY OF FINDINGS IR 05000244/2009008;

06/15-19/2009

and 08/24-2'712009;

R. E. Ginna Nuclear Plant; Special Inspection

Team Report. The report covered two on-site inspection

visits and related in-office

inspection

activities

by a special inspection

team consisting

of a Senior Reactor Analyst. two Senior Resident Inspectors.

and one Project Engineer.

One apparent violation (A V) with potential

for greater than Green safety significance

and two Green findings were identified.

The significance

of most findings is indicated

by its color (Green. White, Yellow, or Red) using Inspection

Manual Chapter (lMC) 0609, "Significance

Determination

Process." Findings for which the significance

determination (SDP) process does not apply may be Green or be assigned a severity level after NRC management

review. The NRC program for overseeing

the safe operation

of commercial

nuclear power reactors is described

in NUREG-1649, "Reactor Oversight

Process," Revision 4, dated December 2006. NRC Identified

and Self-Revealing

Findings Cornerstones:

Mitigating

Systems Preliminary

White: A self-revealing

apparent violation (A V) of 10 CFR 50, Appendix B, Criterion

XVI, uCorrective

Actions," was identified

for the failure to preclude recurrence

of a signIficant

condition

adverse to quality (SCAQ) associated

with the Turbine Driven Auxiliary

Feedwater (TDAFW) pump governor control valve. Specifically, after identifying

corrosion

of the govemor control valve stem in April 2005, Ginna did not take adequate corrective

actions to preclude the recurrence

of corrosion

which led to the binding of the gave mar control valve and failure of the TDAFW pump on July 2,2009. In addition, the inspectors

concluded

that governor control valve stem binding was the likely cause of the failure of the TDAFW pump on May 26,2009. The overspeed

trip of the TDAFW pump on May 26. 2009. was originally

determined

by Ginna to be failure of the governor control system relay valve. Governor control valve stem corrosion

is a SCAQ because corrosion

of the stem can IHad to governor control valve stem binding and failure of the TDAFW pump as discussed

in NRC Information

Notice (IN) 94-66: "Overspeed

of Turbine-Driven

Pumps Caused by Governor Valve Stem Binding" and other related industry operating

experience

documents.

Immediate

corrective

actions inCluded entering this condition

in the corrective

action program (CAP). conducting

a root cause analysis (RCA). replacing

the governor control valve stem, and conducting

weekly monitoring

of the governor control valve during surveillance

testing to identify any potential

for stem binding. In addition, corrective

actions included a follow-up

inspection

of the governor control valve during the fall 2009 refueling

outage. Ginna will continue to monitor the govemor control valve under an enhanced TDAFW surveillance

program to ensure TDAFW pump operability.

The finding is more than minor because it is associated

with the equipment

performance

attribute

of the Mitigating

System cornerstone

and affects the cornerstone

objective

to ensure the availability, reliability, and capability

of systems that respond to initiating

events to prevent undesirable

consequences.

Specifically.

stem corrosion

caused binding of the governor control valve and led to the failure of the TDAFW pump. This finding was assessed using IMC 0609 and preliminarily

determined

to be White (lOW to moderate safety significance)

based on a Phase 3 analysis with a total (internal

and Enclosure

external contributions)

calculated

conditional

core damage frequency (CCDF) of B.6E-6. This finding has a cross-cutting

aspect in the area of Problem Identification

and Resolution, Corrective

Action Program, because Ginna did not implement

a corrective

action program with a low threshold

for identifying

issues completely, accurately, and in a timely manner commensurate

with their safety significance

P.1(a} per IMC 0305]. Specifically, Ginna did not identify issues

with corrosion

of the governor control valve within the corrective

action program. (Section 2.1.1) Green: A self-revealing

non-cited

violation (NCV) of 10 CFR 50, Appendix B, Criterion

XVI, "Corrective

Actions," was identified

for the failure to establish

adequate measures to correct a longstanding

issue associated

with steam admission

valves leakage. As a result, the leakage most likely contributed

to the build-up of corrosion

on the TDAFW pump governor control valve stem and contributed

to the failure of the TDAFW pump on May 26, 2009, and on July 2, 2009. The steam admission

valves had been leaking since at least 2005. However, G.inna did not take adequate measures to correct the leakage or minimize the impact of the leakage on governor control valve performance.

Immediate

corrective

actions included entering this condition

in the corrective

action program, conducting

a root cause analysis, replacing

the governor control valve stem, and conducting

weekly monitoring

of the governor control valve during surveillance

testing to identify any potential

for stem binding. Additionally, the steam admission

valves were inspected

and re-worked

and the governor control valve was inspected

during the fall 2009 outage. Ginna will continue to monitor the governor control valve under an enhanced TDAFW surveillance

program to ensure TDAFW pump operability.

Planned corrective

actions include

the steam admission

valves in May 2011. The finding is more than minor because it is associated

with the equipment

performance

attribute

of the Mitigating

Systems cornerstone

and affects the cornerstone

objective

to ensure the availability

and reliability

of systems that respond to initiating

events to prevent undesirable

consequences.

Specifically, leakage through the steam admission

valves can result in continuous

wetting of the governor control valve stem and lead to or accelerate

corrosion

of the governor control valve. This could result in a stem binding of the governor control valve and failure of the TDAFW pump. The inspectors

evaluated

the signifiCance

of this finding using IMC 0609, Attachment

4, "'Phase 1 -Initial Screening

and Characterization

of Findings." The finding is of very low safety significance

because it is not a design or qualification

deficiency, did not represent

a loss of a safety function of a system or a single train greater than its technical

speCification (TS) allowed outage time, and did not screen as potentially

risk Significant

due to external events. This finding has a cross-cutting

aspect in the area of Problem Identification

and Resolution, Corrective

Action Program, because Ginna did not thoroughly

evaluate problems such that the resolutions

address causes and extent of conditions, as necessary, In a timely manner, commensurate

with their significance

[P.1 (c) per IMC 0305]. Specifically, Ginna did not thoroughly

evaluate the potential

effect of the steam admission

valve leakage on the governor control valve performance. (Section 2.1.2) Green: The inspectors

identified

an NCVof 10 CFR 50, Appendix B. Criterion

III, "Design Control," for the failure to establish

measures to ensure that a modification

performed

on the governor control valve bushing was a suitable application

of materials

for the TDAFW pump. During a review of the RCA associated

with the TDAFW pump failures, the inspectors

noted that Ginna did not consider the potential

impact of Enclosure

removing some of the hardened layer of the bushing on the corrosion

rate of the governor control valve. Following

concerns raised by the inspectors, Ginna inspected

the governor control valve bushing during the fall 2009 refueling

outage and observed corrosion

of the bushings.

Ginna noted that the corrosion

of the bushings appeared to have been caused by the lapping of the bushing to achieve the increased

clearance

between the stem and the bushings.

Immediate

corrective

actions following

the inspection

of the governor control valve during the fall 2009 refueling

outage included entering this condition

in the CAP and refurbishing

the governor control valve with a new stem and bushing. The finding is more than minor because it is associated

with the equipment

performance

attribute

of the Mitigating

System cornerstone

and affects the cornerstone

objective

to ensure the availability, reliability, and capability

of systems that respond to initiating

events to prevent undesirable

consequences.

Specifically, lapping of the valve bushing resulted in an unanticipated

corrosion

mechanism

of the govemor control valve that impacted the reliability

of the TDAFW pump" The inspectors

evaluated

the significance

of this finding using IMC 0609, Attachment

4. "Phase 1 Initial Screening

and Characterization

of Findings." The finding is of very low safety significance

because it is a design or qualification

deficiency confirmed not

to result in the loss of operability

or functionality.

The inspectors

determined

that this finding has a cross-cutting

aspect in the area of Human Performance, Decision Making. because Ginna did not make a safety-significant

or risk-significant

decision using a systematic

process, especially

when faced with uncertain

or unexpected

plant conditions, to ensure safety was maintained

H.1(a) per IMC 0305]. Specifically, Ginna did not use a systematic

process such as an engineering

evaluation

to properly evaluate the potential

impact of removing some of the hardened layer of the bushing. [H.1 (a) per IMC 0305] (Section 2.3) Licensee Identified

Violations

None Enclosure

REPORT DETAILS 1. INTRODUCTION

1.1 Background

and Event Description

On May 26, 2009, and July 2, 2009, the TDAFW pump tripped on overspeed

during the performance

of surveillance

testing activities.

These were the second and third times the TDAFW pump had failed a surveillance

test in a six month period. The previous test failure occurred on December 2, 2008, when the TDAFW pump failed to develop acceptable

discharge

pressure during a quarterly

surveillance

test. Details surrounding

the December test failure including

Ginna corrective

actions are discussed

in NRC Integrated

Inspection

Report 50-244/2009002.

Following

each of the three test failures, Ginna declared the TDAFW pump inoperable

and entered the limiting Condition

for Operation

for TS 3.7.5 "Auxiliary

Feedwater." Following

the May 26, 2009, test failure, Ginna troubleshooting

activities

were focused on the TDAFW lubricating

oil system where system pressure oscillations

were noted by test personnel

prior to the pump overspeed

trip. As part of the troubleshooting

efforts, the TDAFW lubricating

oil system was drained and refilled with fresh oil, filters in the lubrication

system were examined and replaced, and several components

in the lubricating

oil system including

the relay and pressure regulating

valves were replaced.

Additionally

the turbine governor linkage was adjusted to original specifications

outlined in the vendor technical

documents.

Although several out of speCification

and missing components

were identified

during this troubleshooting

effort, a definitive

cause for the surveillance

failure was not identified.

Nevertheless, following

the successful

completion

of post maintenance

testing activities, Ginna declared the TDAFW pump operable and commenced

an augmented

surveillance

testing program for the TDAFW pump that tested the pump on a weekly basis. On July 2, 2009, another TDAFW pump overspeed

failure occurred when the pump was undergoing

the augmented

testing program. Troubleshooting

activities

following

this failure were focused on the turbine control system, which did not appear to have functioned

properly during the test. Accordingly, the turbine control and relay valves were disassembled

and inspected, and the governor linkage system was adjusted.

Additionally.

the lubricating

oil system was flushed and examined for particulates.

However, unlike the May 26 failure, these troubleshooting

activities

identified

a definitive

cause, a stuck governor control valve stem, that resulted in the surveillance

test failure. Visual inspection

of the stem, which had become bound to its bushing and had to be forcibly removed, revealed corrosion

buildup where the stem contacted

the upper valve bushing. To restore the control valve to an operable status, Ginna replaced the valve stem and increased

the bushing clearances

to dimensions

specified

by the Ginna TDAFW pump inspection

procedure.

The pump was successfully

tested and declared operable subject to an augmented

testing program. Ginna assigned an RCA team to investigate

the surveillance

test failures.

The Ginna RCA team concluded

that the primary root cause of the failure of the governor contrOl valve to control turbine speed on July 2,2009, was binding caused by a corrosion

mechanism

that occurred between the valve stem and the valve bushings.

The RCA team also concluded

that stem binding appeared to be an intermittent

problem and that Enclosure

station members missed opportunities

to identify the failure mode during previous surveillances

and failures.

As such, the RCA team determined

that governor control valve stem binding could not be ruled out as a possible failure mode during the December 2008 and the May 2009 TDAFW pump failures.

At Ginna's request, an independent

vendor reviewed the issues associated

with the governor control valve stem binding to determine

the failure mechanism

that was the cause of the TDAFW pump overspeed

trips. The vendor determined

that the most likely cause of the corrosion

of the governor control valve stem was fresh-water

corrosion (Langelier

corrosion)

that was the result of galvanic interactions

between the nitrided case and the base material of the governor control valve stem. The vendor considered

several variables

that contributed

to the corrosion

mechanism

such as material composition

of the stem and bushing, stem-to-bushing

clearance, steam admission

valve leakage, and TDAFW pump surveillance

frequency

and duration.

1.2 Special Inspection

Scope The NRC conducted

this inspection

to gain a better understanding

of the circumstances

involving

the TDAFW pump overspeed

trips during surveillance

testing on May 26, 2009, and on July 2,2009. The inspection

team used NRC Inspection

Procedure

93812, "Special Inspection," as a guide to complete their review. Additional

inspection

and review activities

were outlined in the special inspection

team charter, provided as Attachment

B. The special inspection

team reviewed procedures, corrective

action documents, work orders, engineering

analyses, and the root cause evaluation

prepared by Ginna. In addition.

the team conducted

equipment

walkdowns

and interviewed

key plant personnel

regarding

the discovery

and resolution

of the condition.

A list of site personnel

interviewed

and documents

reviewed are provided in Attachment

A to this report. 1.3 Preliminary

Conditional

Risk Assessment

Using IMC 0309, "Reactive

Inspection

Decision Basis for Reactors," IMe 0609, "Significance

Determination

Process," and the Ginna Standardized

Plant Analysis Risk (SPAR) model in conjunction

with the Graphical

Evaluation

Module (GEM). the Region I Senior Reactor Analyst (SRA) evaluated

the increase in conditional

core damage probability

for the failure of the TDAFW pump. Based on the nature of the failure and the subsequent

overspeed

trip on an instrumented

diagnostic

run, the condition

was evaluated

as being non-recoverable

in the event of actual demand. Based upon best available

information, an incremental

conditional

core damage probability (ICCDP) in the upper E-6 range (8E-6 per the 82 day exposure period), was calculated.

The exposure period was based on the assumption

that the TDAFW pump would not have started since the last time it passed a surveillance

test on March 5 until May 26 (82 days). The dominant core damage sequence was a station blackout (loss of offsite power (LOOP) with failure of both emergency

diesel generators (EDGs), with no TOAFW and failure to recover offsite power or an EDG in one hour. Based upon this conservative

conditional

core damage probability (CCDP) value, and having satisfied

an IMC 0309 deterministic

criterion, the May 26 degraded TDAFW pump Enclosure

condition

fell within the Special Inspection

to Augmented

Inspection

Team range for reactive inspections.

2. SPECIAL INSPECl"ION

AREAS 2.1 Review of Maintenance

a. Inspection

Scope The team evaluated

the adequacy and completeness

of the maintenance

on the TDAFW system, including

preventive

maintenance, procedural

guidance, post-maintenance

testing, and supervisory

oversight.

The team independently

evaluated

selected procedures, preventive

maintenance

strategies.

condition

reports (CRs). system health reports. and associated

work orders. In addition, the team reviewed the RCA, conducted

equipment

walkdowns

and interviewed

key station personnel.

For the weaknesses

identified, the inspectors

verified that appropriate

corrective

actions have been planned or taken. b. Findings and Observations

1. Failure to Preclude Recurrence

of a Significant

Condition

Adverse to Quality Introduction:

A self-revealing

AV of 10 CFR 50, Appendix S, Criterion

XVI, "Corrective

Actions," was identified

for the failure to preclude recurrence

of a SCAQ associated

with the TDAFW pump governor control valve. Specifically, after identifying

corrosion

of the governor control valve stem in April 2005, Ginna did not take adequate corrective

actions to preclude the recurrence

of corrosion

which led to the binding of the governor control valve and failure of the TDAFW pump on July 2, 2009. In addition, governor control valve stem binding was a fikely failure of the May 26, 2009, TDAFW pump overspeed

trip. This finding was preliminarily

determined

to be White. Description:

On April 11, 2005, Glnna conducted

a periodic major inspection

of the TDAFW pump governor control valve under work order #20401907.

During the disassembly

of the valve, mechanics

noted corrosion

in the bushing area of the stem plug. The vendor recommended

replacing

the valve stem and plug due to the corrosion.

However, Ginna did not recognize

stem corrosion

as a condition

adverse to quality and did not initiate a CR in accordance

with station guidance in IP-CAP-1 r "Condition

Reporting." As a result, Ginna did not conduct any further analysis or evaluation

to determine

the cause of the corrosion.

On July 2, 2009, during surveillance

testing, the TDAFW pump tripped due to overspeed. Ginna

formed an Issue Response Team and developed

a comprehensive

troubleshooting

plan to determine

the cause(s) of the failure. The troubleshooting

plan consisted

of all possible failure modes, possible causes of each failure mode, and actions to validate or refute each "failure mode. Upon disassembly

of the governor control valve, the stem was found seized within its bushings and had to be forcibly removed. Visual inspection

showed pitting on the surface of the stem Where it contacted

the upper valve bushing. Following

completion

of the troubleshooting

activities, Ginnaconcluded

that TDAFW pump failure was due to binding of the governor control valve and that the binding was caused by the build up of corrosion

on the valve stem. Enclosure

Governor control valve stem corrosion

is an SCAQ because corrosion

of the stem can lead to govemor control valve stem binding and failure of the TDAFW pump as discussed

in NRC IN 94-66: "Overspeed

of Turbine-Driven

Pumps caused by Governor Valve Stem Binding," and other related industry operating

experience

documents.

Immediate

corrective

actions included entering this condition

in the CAP, conducting

an RCA, replacing

the governor control valve stem, and conducting

weekly monitoring

of the governor control valve during surveillance

testing to identify any potential

for stem binding. In addition, corrective

actions included a follow-up

inspection

of the governor control valve during the fall 2009 refueling

outage. Because additional

corrosion

was found during this inspection

on September

18, 2009, the control valve was sent to the vendor to be refurbished.

Ginna will continue to monitor the governor control valve under an enhanced TDAFW surveillance

program to ensure TDAFW pump operability.

Ginna also was evaluating

longer term corrective

actions to address the corrosion

including

more frequent governor control valve stem replacement, change of the stem material, and other modifications

to the system design. Planned corrective

actions include replacing

the stem admission

valves in May 2011. The inspectors

noted that governor control valve stem binding also could have been a contributor

to the December 2, 2008, TDAFW pump failure to develop the minimum acceptable

discharge

flow and pressure, and the likely cause of the May 26, 2009, TDAFW pump overspeed

trip. Following

these events, Ginna missed opportunities

to identify potential

stem binding problems after identifying

possible indicators

of this failure mode such as leaking steam admission

valves and rust/corrosion

on the visible portion of the governor valve stem. In addition, during troubleshooting

efforts in May 2009, . Ginna missed an opportunity

to exercise the governor control valve stem with the linkage disconnected

and lube oil pressure not applied. Operating

experience

suggested

that cycling the valve by hand without hydraulics

applied is a prudent action to validate or refute governor control valve stem binding. Analysis:

The performance

deficiency

is that Ginna did not take adequate measures to correct a condition

that had the potential

to impact the operability

of the TDAFW pump. Specifically, after identifying

corrosion

on the governor control valve stem in 2005, Ginna did not take adequate corrective

actions to preclude the recurrence

of corrosion

which led to the binding of the governor control valve and failure of the TDAFW pump. The finding is more than minor because it is associated

with the equipment

performance

attribute

of the Mitigating

System cornerstone

and affects the cornerstone

objective

to ensure the availability, reliability, and capability

of systems that respond to initiating

events to prevent undesirable

consequences.

Specifically, stem corrosion

caused binding of the governor control valve and led to the failure of the TDAFW pump. In accordance

with IMe 0609, Attachment

4, "Phase 1 -Initial Screening

and Characterization

of Findings," a Phase 2 risk analysis was required because the finding represents

an actual loss of safety function of a single train for greater than the TS allowed outage time of 7 days. The Phase 2 risk evaluation

was performed

in accordance

with IMC 0609, Appendix A, Attachment

1, "User Guidance for Phase 2 and Phase 3 Reactor Inspection

Findings for At*,power

Situations." Because the precise time is unknown for the inception

of TDAFW pump inoperability, an exposure time of one-half of the time period (t/2) between discovery (May 26, 2009) to the last successfully

completed

quarterly

surveHlance

test (March 5, 2009) was used. This t/2 exposure time Enclosure

9 equals 51 days. Using Ginna's Phase 2 SDP notebook, pre-solved

worksheets, and an initiating

event likelihood

of 1 year (>30-days

exposure time), the inspector

identified

that this finding is of potentially

substantial

safety significance (Yellow).

The dominant sequence identified

in the Phase 2 notebook involves a loss of offsite power (LOOP), failure of both EDGs, and the subsequent

loss of the TDAFW pump, with the failure of operators

to restore offsite power within 1 hour: LOOP (2) + EAC (3) + TDAFW (0) + REC1 (0) = 5 (Yellow).

In recognition

that the Phase 2 notebook typically

yields a conservative result, a

NRC Region I Senior Reactor Analyst (SRA) performed

a Phase 3 risk assessment

of this finding. The SRA used Ginna's Standardized

Plant Analysis Risk (SPAR) model, Revision 3.45, dated June 2008. and graphical

evaluation

module, in conjunction

with the System Analysis Programs for Hands-On Integrated

Reliability

Evaluations (SAPHIRE).

Version 7, to estimate the internal risk contribution

of the Phase 3 risk assessment.

The following

assumptions

were used for this assessment: Based on the guidance provided in the Risk Assessment

of Operational

Events Handbook, Revision 1.01, the calculated

exposure was determined

to be 1198 hrs. The summation

of this exposeure

time was determined

as follows: One half the exposure time, (tI2), was applied for the period between March 5 -May 26, 2009 The full exposure time, (t). was applied for the unavailability

and troubleshooting

from May 26 -May 29, 2009. One half the exposure time. (tI2), was applied for the period between June 25 -July 2, 2009 The full exposure time, (t), was applied for the unavailability

and troubleshooting

from July 2 -July 5, 2009 To closely approximate

the type of f*lilure exhibited

by the TDAFW pump, the fail to start basic event <AFW-TDP-FS-TDP>

was changed from its baseline failure probability

to 1.0, representing

a 100 percent failure to start condition. Based on the nature of the failure. and no recovery procedures

in place, there was no recovery credit assigned to the May failure. The loss of service water initiating

event frequency (IE-LOSWS)

was increased

from its nominal value of 4.0E-4 to 2.0E*3 to more closely model the risk of a LOSWS at the Ginna station. This is consistent

with Ginna's understanding

of the risk of this event. All remaining

events were left at their nominal failure probabilities. The model was modified by Idaho National Laboratory (INL) to include convolution

correction

factors. Convolving

the failure distribution

eliminates

the simplifying

assumption

that all failure to run events happen at time=O. Inclusion

of this correction

can reduce station blackout (SBO) core damage frequency (CDF) significantly

for plants like Ginna that have low EDG redundancy. Since all observed failures happened upon the initiation

of the TDAFW system, the period between May 29 and June 25 2009, was not included in the exposure period because the system successfully

completed

increased, weekly, surveillance

testing. The team could not conclude that the stem binding condition

would occur after the pump had been successfully

started and run. Cutset probability

calculation

truncation

was set at 1 E-13. Enclosure

Based upon the above assumptions, the Ginna SPAR model calculated

an increase in internal event contribution

to conditional

core damage probability (CCDP) of 2.9E-6. This low-ta-mid

E-6 delta CCDP value represents

a low to moderate safety significance (White). The dominant internal event sequence involved a LOOP with subsequent

failure of the EDGs (station blackout event), the failure of the TDAFW train and the failure to recover AC power. The Phase 3 SPAR model results correlate

well to the Phase 2 SDP Notebook dominant core damage sequences.

External Events Risk Contribution

The Ginna Probablistic

Safety Assessment (PSA) includes a Level 1 analysis of fires and flooding external events. The PSA summarizes

the fire contribution

as representing

approximately

48% of the total (internal

and external)

core damage frequency, or nearly half of the annualized

risk. The NRC does not have an external event risk model for Ginna. Consequently, the SRA, after review of the licensee's

Individual

Plant Examination

of External Events (IPEEE), utilized the licensee's

external events assessment

to quantify the fire and flooding events risk contribution

for this condition.

Seismic event likelihood

was considered

to be very low and determined

not to be a significant

contributor

to the risk of this condition.

The results of the PSA for this condition

calculated

a CCDP contribution

from fire events at 5E-6 and from flooding at 7E-7. The most significant

fire initiated

core damage sequence involved a spectrum of control room fires, with a failure of automatic

and manual suppression, a failure of the TDAFW pump and a failure of the 'C' standby auxiliary

feed water pump for decay heat removal via the steam generators.

The most Significant

flooding core damage sequence quantified

in the PSA for this condition, Involved flooding in the relay room, failure of the TDAFW pump and a failure to align standby auxiliary

feed water pump for decay heat removal via the steam generators.

Large Early Release Frequency (LERF) Evaluation

The SRA used IMC 0609, Appendix H, "Containment

Integrity

Significance

Determination

Process," to determine

if this finding was a significant

contributor

to a large early release. The Ginna containment

is classified

as a pressurized

water reactor large-dry

containment

deSign. Based upon the dominant sequences

involving

LOOP and station blackout (S80) initiating

events, per Appendix H, Table 5.2, "Phase 2 Assessment

Factors -Type A Findings at Full Power," the failure of the TDAFW pump does not represent

a significant

challenge

to containment

integrity

early in the postUlated

core damage sequences.

Consequently, this finding does not screen as a significant

large early release contributor

because the close-in populations

can be effectively

evacuated

far in advance of any postulated

release due to core damage, Accordingly, the risk significance

of this finding is associated

with the delta CDF value, per IMC 0609, Appendix H, Figure 5.1, and not delta LERF. Risk Assessment

Summary The calculated

total risk significance

of this finding is based upon the summation

of internal and external risk contributions (delta CCDP internal + delta CCDP external (fires and floods).=

delta CCDP total). 2.9E-6 + 5E-6 + 7E-7 = 8.6E-6 delta ceDP. Enclosure

Annualized, this value of 8.6E-6 delta CDF represents

a low to moderate safety significance

or White finding. Licensee's

Risk Assessment

Summary Constellation's

risk assessment

for the given condition, assuming no operator recovery, resulted in a total delta CDF value of 1.028E-5.

This increase in CDF value comprised

of: 4.6E-6 due to intemal events; 0.7E-6 due to intemal flooding events; and 5E-6 fire/external

events. Similar to the NRC internal risk contribution, the largest percentage

of intemal risk was derived from station blackout events. The licensee conducted

refinements

in their modeling to credit additional

recovery options in the event that the TDAFW pump failed. By crediting

these recovery actions, the delta CDF was reduced from 1.028E-5 to 9.2 E-6, or by approximately

10%. The specific recovery actions are as follows: . The potential

for operators

to use standby auxiliary

feedwater (SAFW) pump C, in lieu of the TDAFW pump during fire and flood scenarios

which require use of alternate

shutdown procedures

was modeled. Although use of an SAFW pump is not specifically

called out in these procedures, the procedures

do explicitly

recognize

that if the TDAFW pump is not functioning, a loss of secondary

heat sink will result, and direct operators

to refer to other emergency procedures

for alternate

methods of establishing

a heat sink (see ER-FIRE.1

step 4.3.4.2, FIRE.2 step 4.3.12, etc.}. In response to this hypothetical

scenario, an operations

Shift Manager (SM) indicated

that upon a failure of the TDAFW to provide flow, a SAFW pump could be manually started by locally opening the service water suction valve to the pump and locally closing the breaker to the pump motor. The steps necessary

to align an SAFW pump to the steam generators (SG) are contained

in emergency

operating

procedures (EOP) Attachment

5.1 'Attachment

SAFW'. Since only Busses 14 and 18 are energized

during ER-FIRE scenarios, SAFW pump C would be used. Following

the May 26th overs peed trip of the TDAFW pump, new section 2.2 was added to procedure

P-15.6, 'Operation

of the TDAFW Pump Trip Throttle Valve.' Revision 00200. This step provides instructions

for a 'slow start' of the TDAFW pump manually, following

an overspeed

trip of the pump, by using the trip throttle valve. This allows for starting of the pump even if the governor control valve is stuck in the full open position following

the overspeed

trip. This procedure

step was successfully

used following

both the May 26th failure and the July 2nd failure. Per Operations

management, the shift managers, who would be directing

use of this procedure, were briefed on the updated procedure

to ensure they were aware that new step was available

for use and understood

how it was to be performed.

A controlled

copy of the procedure

is located at the TDAFW pump for use by the operator.

Since this procedure

was in effect prior to the July failure exposure period (Le., prior to the last successful

TDAFW pump test on June 25, 2009), it is considered

as a recovery for failures of the TDAFW pump. Recovery actions identified

in #1 above were not quantified

by the team however the evaluation

approach appears to be appropriate.

Prior to the licensee crediting

recovery actions identified

in #2 above, the team was able to verify that the procedures

were in Enclosure

place and observed troubleshooting

video in which the licensee started the TDAFW pump with this method. As a result the SRA concluded

that the licensee's

modeling demonstrating

a risk reduction

was appropriate.

Based upon the close comparison

between NRC and Constellation

risk estimates, no sensitivity

analyses were warranted.

The use of V2 to approximate

the exposure time was determined

to be appropriate

for standby or periodically

operated components

that fail due to a degradation

mechanism

that gradually

affects the component

during the standby time period. Inclusion

of the unavailability

time hours, due to troubleshooting

and repairs, is also appropriate

and consistent

with the guidance promulgated

in Risk Assessment

of Operational

Events Handbook, Revision 1.01, dated January 2008. This finding has a cross-cutting

aspect in the area of Problem Identification

and Resolution, Corrective Action Program, because Ginna did not implement

a corrective

action program with a low threshold

for identifying

issues completely, accurately, and in a timely manner commensurate

with their safety

significance.

Specifically, Ginna did not identify issues associated

with corrosion

of the governor control valve within the corrective

actions program. The inspectors

concluded

that the performance

deficiency

is reflective

of current performance

because Ginna had reasonable

opportunities

to identify the issue during troubleshooting

in December 2008 and May 2009. P.1(a) per IMC 0305] Enforcement:

10 CFR 50, Appendix B, Criterion

XVI, "Corrective

Actions," states, in part, "Measures

shall be established

to assure that conditions

adverse to quality, such as failures, malfunctions, defiCiencies, deviations, defective

material and eqUipment, and nonconformances

are promptly identified

and corrected.

In the case of significant

conditions

adverse to quality, the measures shall assure that the cause of the condition

is determined

and corrective

action taken to preclude repetition." Contrary to the above, after identifying

corrosion

on the TDAFW pump governor control valve stem on April 11, 2005, which is a significant

condition

adverse to quality, Ginna did not take adequate measures to determine

the cause and prevent recurrence.

The cause of the condition

was left uncorrected

and resulted in additional

stem corrosion

that led to binding of the governor control valve and the failure of the TDAFW pump on July 2, 2009. In addition, stem corrosion

was the likely cause of the TDAFW pump failure on May 26, 2009. This issue was entered into Ginna's CAP as CR-:2009-003680

and CR-2009-004577.

Pending final determination

of significance, this finding is identified

as an AV. (AV 0500024412009008*01:

Inadequate

Corrective

Actions Associated

with the TDAFW Pump Governor Control Valve) 2. Untimely Corrective

Actions Associated

with Steam Admission

Valves Introduction:

A self-revealing

NeVof 10 CFR 50, Appendix B, Criterion

XVI, "Corrective

Actions," was identified

for the failure to establish

adequate measures to correct a longstanding

issue associated

with steam a(]mission

valves leakage. As a result, the leakage most likely contributed

to the build-up of corrosion

on the TDAFW pump governor control valve stem on May 26, 2009 and contributed

to the failure of the TDAFW pump on July 2, 2009. Description:

During a review of failures associated

with the TDAFW pump, the inspectors

noted that the steam admission

valves had a history of leaking. Based on a review of the RCA report, industry operating

experience, and associated

CRs, the Enclosure

inspectors

determined

that the steam admission

valve leakage was a contributing

factor in the development

of corrosion

of the governor control valve and contributed

to the failure of the TDAFW pump on July 2, 2009, and most likely the failure of the TDAFW pump overspeed

trip failure on May 26, 2009. Based on a review of eRs and interviews

of personnel, the inspectors

determined

that the steam admission

valves had been leaking since at least 2005. In July 2005,

documented

that steam admission

valve 3505A was leaking past its seat. However, Ginna did not take or plan any corrective

actions associated

with the issue. By October 2006, steam admission

valve 3505A leakage had increased

such that the TDAFW pump turbine was rotating approximately

100 rpm. Ginna cycled the valve to reduce seat leakage, generated

a work order to repair the valve in May 2008, and conducted

an evaluation

of past operability.

Ginna concluded

that there was no potential

for increased

consequences

with time if the condition

continued.

During the May 2008 refueling

outage, Ginna conducted

a repair of steam admission

valve 3505A. However, this corrective

action was not effective;

by September

2008, the valve was leaking again although at a reduced rate. The inspectors

determined

that Ginna did not recognize

or consider the potential

impact of the steam admission

valve leakage on the governor control valve stem. Immediate

corrective

actions included entering this condition

in the CAP, replacing

the govemor control valve stem, and conducting

weekly monitOring

of the governor control valve during surveillance

to identify any potential

for stem binding. Additionally, the steam admission

valves were inspected

and re-worked

and the govemor control valve was Inspected

during the fall 2009 outage. Ginna will continue to monitor the governor control valve under an enhanced TDAFW surveillance

program to ensure TDAFW pump operability.

Planned corrective

actions include replacing

the stem admission

valves in May 2011. Analysis:

The performance

deficiency

is that Ginna did not adequately

address deficiencies

associated

with steam admission

valve leakage in that the leakage likely resulted in accelerated

corrosion

of the governor control valve and contributed

to the failure of the TDAFW pump. The finding is more than minor because it is associated

with the equipment

performance

attribute

of the Mitigating

Systems cornerstone

and affects the cornerstone

objective

to ensure the availability

and reliability

of systems that respond to initiating

events to prevent undesirable

consequences.

Specifically, leakage through the steam admission

valves can res.ult in continuous

wetting of the governor control valve stem and lead to or accelerate

corrosion

of the governor control valve. This could result in a stem binding of the govemor control valve and failure of the TDAFW pump. The inspectors

evaluated

the significance

of this finding using IMC 0609, Attachment

4, "Phase 1 -Initial Screening

and Characterization

of Findings." The finding is of very low safety significance

because it is not a design or qualification

deficiency, did not represent

a loss of a safety function of a system or a single train greater than its TS allowed outage time, and did not screen as potentially

risk Significant

due to external events. The inspectors

determined

that the steam admission

valve leakage was not a direct cause of the failure of the TDAFW pump overspeed

events. The steam admission

valve leakage was a contributing

factor in the development

of governor control valve stem corrosion

and contributed

to the failure of the TDAFW pump. Enclosure

This finding has a cross-cutting

aspect in the area of Problem Identification Resolution, Corrective

Action Program, because Ginna did not thoroughly

problems such that the resolutions

address causes and extent of conditions, r:eecessary, in a timely manner, commensurate

with their significance.

Ginna did not thoroughly

evaluate the potential

effect of the steam admission leakage on the governor control valve performance.

The inspectors

determined

that issue is reflective

of current licensee performance

because each time the issue identified

and a CR was generated

represented

an opportunity

for Ginna to

evaluate the issue and assign appropriate

corrective

actions. [P.1 (c) per IMC Enforcement:

10 CFR Part 50, Appendix B, Criterion

XVI, "Corrective

Actions," states, in part. "Measures

shall be established

to assure that conditions

adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective

material and equipment, and nonconformances

are promptly identified

and corrected." Contrary to this requirement, from at least July 2005 to July 2, 2009, Ginna did not established

adequate measures to correct longstanding

steam admission

valves leakage and/or minimize the impact of the leakage on the TDAFW pump governor control valve performance.

As a result, leakage I*I through the steam admission

valves contributed

to the corrosion

of the governor valve and contributed

to the failure of the TDAFW pump on July 2, 2009 and most the failure of the TDAFW pump on May 26, 2009. Because this violation

is of very safety significance (Green) and Ginna entered this issue into their CAP for resolution CR-2009-003680

and CR-2009-004577, this violation

is being treated as an consistent

with the NRC Enforcement

Policy. (NCV 0500024412009008-02:

Corrective

Actions Associated

with Stearn Admission

Valve

2.2 Review of Operating

Experience

a. Inspection

ScoQe The team reviewed operating

experience

involving

TDAFW pump failures and taken by the Ginna staff to identify and address these types of failures.

In addition, team examined the specific issues associated

with governor control valve stem to assess any new generic issues of industry interest for prompt communication dissemination.

As part of this evaluation, the inspectors

reviewed pertinent

operating

experience, Ginna's response to NRC Information

Notices, and

key plant

b. Findings and Observations

No Findings of Significance

Identified.

The inspectors

determined

that there were no new generic issues identified

as a result of this event. However, the inspectors

noted that Ginna missed opportunities

to utilize industry operating

experience

to identify precursors

associated

with this event and to conduct effective

troubleshooting.

Specifically, following

the discovery

of corrosion

on the exposed portion of the TDAFW pump govemor control valve stem in May 2005, Ginna did not enter this issue in to their CAP. As a result Ginna missed an opportunity

to revisit operating

experience

from NRC IN 94-66 conceming

governor control valve stem binding. In several examples in NRC IN 94-66, sites that experienced

governor control valves stem binding identified

stem corrosion

following

valve disassembly.

Ginna Enclosure

had originally

determined

that NRC IN 94-66 was not applicable

to Ginna because the governor control valve was of a different

configuration

and material as those discussed

in the IN and that corrosion

of the stem had not been previously

identified.

Although this may have been a reasonable

assessment

during the original review of the NRC IN 94-66 in 1994, the inspectors

determined

that once corrosion

of the stem was identified

in'May 2005, Ginna missed an opportunity

to revisit this operating

experience.

In addition, as discussed

in Section 2.1.2 of this report. Ginna did not utilize Industry operating

experience

in evaluating

a condition

associated

with steam admission

valve leakage. NRC IN 94-66, other industry operating

experience, and the vendor technical

manual stated that steam admission

valve leakage is a cause related to governor control valve stem binding. However, Ginna did not consider the impact of steam admission

valve leakage on the governor control valve performance.

Finally, the inspectors

noted that Ginna missed opportunities

to incorporate

industry operating

experience

during troubleshooting

efforts during the May 2009 TDAFW pump failure. NRC IN 94-66 discussed

several examples where a freedom of motion test was performed

to test for stem binding with the governor control valve linkage disconnected

and hydraulics

not applied. However, during the May 2009 event, Ginna missed an opportunity

to conduct this test and consequently, missed an opportunity

to potentially

identify the failure mode prior to the July 2, 2009, overspeed

trip. Ginna captured these issues in their CAP under CR-2009-003680

and CR-2009-004577

.. 2.3 Review of Root Cause and Extent-ot-Condition

a. Inspection

Scope The team evaluated

the adequacy of Ginna's RCA and completed

interim corrective

actions. In addition the team evaluated

the adequacy of Ginna's initial extent of condition

for the TDAFW pump failures.

The team reviewed plant drawings, procedures, and associated

system modifications.

In addition, the team conducted

a walkdown of the TDAFW system and interviewed

key Ginna personnel.

b. Findings and Observations

Introduction:

The inspectors

identified

an NCV of 10 CFR 50, Appendix B, Criterion

III, "Design Control," for the failure to establish

measures to ensure that a modification

performed

on the governor control valve bushing was a suitable application

of materials

for the TDAFW pump. Description:

During the troubleshooting

and repair of the TDAFW pump in July 2009, Ginna incorrectly

evaluated

that a vendor service bulletin allowed for larger bushing clearance

than was prescribed

in their current technical

documents.

Since there was overlap between the station technical

information

and the vendor service bulletin, Ginna decided to increase the clearance, by lapping the bushings, to reduce the likelihood

that corrosion

products would cause the stem to bind. To increase the clearance, Ginna removed some of the hardened layer on the bushing. During a review of the RCA, the inspectors

determined

that Ginna did not consider the potential

impact of removing some ot the hardened layer on the corrosion

rate of the governor control valve. The inspectors

noted that by removing some of the hardened layer, the material property of the bushing could have been changed and/or additional

micro-cracks

could have been created or exposed that could increase the corrosion

rate or potentially

cause other Enclosure

problems such as

galling. The inspectors

noted that if the corrosion

rate is greater than predicted, then planned corrective

actions may not be adequate to maintain the TDAFW pump operable.

Additionally, the team was concerned, that by increasing

the stem to bushing clearances, the stem would be susceptible

to larger steam exposure and that this could further accelerate

the corrosion.

Following

concerns raised by the inspectors, Ginna initiated

CR-2009-005959

to ensure that all possible consequences

of lapping the TDAFW pump control valve bushing were fully evaluated.

In addition, Ginna assigned corrective

actions to inspect the control valve bushing during the fall 2009 refueling

outage. During performance

of the refueling

inspection

under WO C90623685, pitting of the stem and corrosion

of the bushings were observed.

Constellation

initiated

and noted that the corrosion

of the bushings appeared to have been caused by the lapping of the bushing to achieve the desired clearance

between the stem and the bushings.

The development

of corrosion

on the bushing reduced the margin that was predicted

to ensure adequate stem movement.

Immediate

corrective

actions following

the inspection

of the governor control valve during the fall 2009 refueling

outage included entering this condition

in the CAP and refurbishing

the governor control valve with a new stem and bushing. Analysis:

The performance

deficiency

is that Ginna failed to establish

measures to ensure that a modification

performed

on the governor control valve bushing was a suitable application

of materials

for the TDAFW pump. The finding is more than minor because it is associated

with the equipment

performance

attribute

of the Mitigating

Systems cornerstone

and affects the cornerstone

objective

to ensure the availability

and reliability

of systems that respond to initiating

events to prevent undesirable

consequences.

Specifically, lapping of the valve bushing resulted in an unanticipated

corrosion

mechanism

of the governor control valve that impacted the reliability

of the TDAFW pump. The inspectors

evaluated

the Significance

of this finding using IMC 0609, Attachment

4, "Phase 1 -Initial Screening

and Characterization

of Findings." The finding is of very low safety significance

because it is not a design or qualification

deficiency, did not represent

a loss of a safety fUnction of a system or a single train greater than its TS allowed outage time, and did not screen as potentially

risk significant

due to external events. The inspectors

determined

that this finding has a cross-cutting

aspect in the area of Human Performance, Decision Making, because Ginna did not make a safety-significant

or risk-significant

decision using a systematic

process, especially

when faced with uncertain

or unexpected

plant conditions, to ensure safety was maintained.

Specifically, Ginna did not use a systematic

process such as an engineering

evaluation

to properly evaluate the potential

impact of removing some of the hardened layer of the bushing. H.1(a) per IMC 0305] Enforcement: 10

CFR 50, Appendix B, Criterion

III, "Design Control" states, in part, "Measures

shall also be established

for the selection

and review for suitability

of application

of materials, parts, equipment, and processes

that are essential

to the related functions

of the structures, systems and components." Contrary to the requirements, in July 2009, Ginna failed to establish

measures to ensure that a modification

performed

on the governor control valve bushing was a suitable application

of materials

for the TDAFW pump. Specifically, lapping of the valve bushing resulted in an unanticipated

corrosion

mechanism

of the governor control valve that had the Enclosure

potential

to impact the performance

of the TDAFW pump if not corrected.

Because this violation

is of very low safety significance (Green) and Ginna entered this issue into their CAP for resolution

as CR-2009-006765, this violation

is being treated as an NCV consistent

with the NRC Enforcement

Policy. (NeV 05000244/2009008-03:

Failure To Establish

Design Control Measures Associated

With The Turbine Driven Auxiliary

Feedwater

Pump Governor Control Valve) 2.4 Risk Assessment

of the As-Found Condition

a. Insoection

Scope Prior to the initiation

of the Special Inspection

Team, the Region I SRA performed

a CCDP assessment

which conservatively

bounded the potential

risk significance

of the degraded condition, assuming the TDAFW pump would fail to star on demand to mitigate the consequences

of an event. The initial CCDP estimate was performed

in accordance

with IMC 0309, "Reactive

Inspection

Decision Basis for Reactors." The SRA used the Ginna SPAR model and associated

GEM to evaluate the potential

risk significance

of this condition.

The results of the IMC 0309 assessment

are documented

in report section 2.1.b.1 above. b. Final Risk Estimate Following

team review and independent

verification

of the degraded turbine driven auxiliary

feed water pump governor control valve, the team concluded

that for approximately

119B hours, the TDAFW pump would not have been capable

of responding

to an event. Consistent

with IMC 0609 conditional

core damage probability

assessment

methodology, this degraded condition

resulted in a loss of operability

or safety function, and therefore

was of low to moderate (B.6E-6) safety significance.

4. OTHER ACTIVITIeS

40A6 Meetings, Including

Exit On August 27 and on October 7,2009 the team presented

the inspection

results to Mr. John Carlin and other members of the R. E. Ginna Nuclear Power Plant staff. The inspectors

verified that none of the

during the inspection

is considered

proprietary

in nature. Enclosure

A-1 ATTACHMENT

A SUPPLEMENTAL

KEY POINTS OF Licensee personnel

J. Carlin, Site Vice President

E. Larson, Plant General Manager D. Crowley, Senior Engineer E. Durkish, Associate

Engineer R. Everett, Supervisor, Primary Systems Engineering

T. Harding, Director, Licensing

R. Ruby, Principal

Engineer, Licensing

P. Swift, Engineering

Manager LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened 05000244/2009008-01

Opened/Closed 05000244/2009008-02

05000244/2009008-03 Failure to Preclude Recurrence

of a Significant

Condition

Adverse to Quality Associated

with the Turbine Driven Auxiliary

Feedwater

Pump Governor Control Valve. (Section 2.1.1) Inadequate

Corrective

Actions Associated

with Steam Admission

Valve Leakage. (Section 2.1.2) Failure to Establish

Design Control Measures Associated

with the Turbine Driven Auxiliary

Feedwater

Pump Governor Control Valve. (Section 2.3) I.IST OF DOCUMENTS

REVIEWED In addition to the documents

identified

in the body of this report, the inspectors

reviewed the following

documents

and records: Corrective

Actions CA-2009-002311

Condition

Reports CR-2003-2006

CR-2005-3660

CR-2006-006029

CR-2006-006341

CR-2005-1509

CR-2005-5513

CR-2006-006204

CR-2006-006962

Attachment

A

CR-2007 -000876 CR-2008-009911

CR-2009-004590

CR-2009-005959*

CR-2007-001302

CR-2009-003680

CR-2009-004591

CR-2009-006765*

CR-2008-003687

CR-2009-004222*

CR-2009-005964

CR-2008-007541

CR-2009-004577

• NRC Identified

During Inspection

Corrective

Action Tracking System CATS R007325 Procedures

AP-FVV.1, Abnormal MFW Pump Flow or NPSH, Revision 01702 PT-16QT-T, Auxiliary

Feedwater

Turbine Pump -Quarterly, Revision 05900 CNG-MN-1.01-1002, Troubleshooting, Revision 0001 CNG-CA-1.01 , Corrective

Action Program, Revision 0001 CNG-CA-1.01-1004, Root Cause Analysis, Revision 0001 CNG-CA-1.01-1005, Apparent Cause Evaluation, Revision 0100 CNG-CA-1.01-1006, Common Cause Analysis, Revision 0001 CNG-CA-1.01-1007, Trending, Revision 0000 CNG-CA-1.01-1010, Use of OE, Revision 0000 IP-CAP-1, Ginna Condition

Reporting, Revision 02800 M-11.5C, Auxiliary

Feedwater

Pump Motor Mechanical

Inspection

and Maintenance, Revision 03000 0-1.1, Plant Heatup From Cold Shutdown to Hot Shutdown, Revision 16301 PT-16Q-T, Auxiliary

Feedwater

Turbine Pump -Quarterly, Revision 05600. Completed

3/14/08,514108,5/5/08,6/11/08,9/4/08, 1213/08, 1214/08, 12111/08, 12/18/08,2/12/09, 5/26/09, 5/28/09 Surveillance

Tests PT-16Q-T, Auxiliary

Feedwater

Turbine Pump -Quarterly, Revision 05600, 03/14/2008

PT-16Q-T, Auxiliary

Feedwater

Turbine Pump -. Quarterly, Revision 05700, 05/04/2008

PT-16Q-T, Auxiliary

Feedwater

Turbine Pump _. Quarterly, Revision 05700,05/05/2008

PT-16Q-T, Auxiliary

Feedwater

Turbine Pump -Quarterly, Revision 05700. 06/11/2008

STP-0-16-COMP-T, Auxiliary

Feedwater

Turbine Pump -Comprehensive Test, Revision 00000, 06/11/2008

PT-16Q-T, Auxiliary

Feedwater

Turbine Pump -Quarterly.

Revision 05701, 09/03/2008

PT-16Q-T, Auxiliary

Feedwater

Turbine Pump -Quarterly, Revision 05701, 12/02/2008

PT-16Q-T, Auxiliary

FeedwaterTurbine

Pump -Quarterly.

Revision 05701,12103/2008

PT-16Q-T.

Auxiliary

Feedwater

Turbine Pump _. Quarterly, Revision 05701, 12/04/2008

PT-16Q-T, Auxiliary

Feedwater

Turbine Pump _. Quarterly, Revision 05702, 12/11/2008

PT-16Q-T, Auxiliary

Feedwater

Turbine Pump _. Quarterly, Revision 05702, 12/18/2008

PT-16Q-T, Auxiliary

Feedwater

Turbine Pump -Quarterly, Revision 05801, 01116/2009

PT -16Q-T, AUXiliary

Feedwater

Turbine Pump -Quarterly, Revision 05801, 02112/2009

PT-16Q-T, AUXiliary

Feedwater

Turbine Pump _. Quarterly.

Revision 05900,05/26/2009

PT-16Q-T, Auxiliary

Feedwater

Turbine Pump -Quarterly, Revision 05900,05/28/2009

STP-0-16-COMP-T, Auxiliary

Feedwater

Turbine Pump -Comprehensive

Test, Revision 00400, 05/28/2009

Attachment

A

Work Orders W020604989

W020401907

Drawings DWG No. 33013-1231, Main Steam System, Revision 37 DWG No. 33013-2285, Motor Driven and Turbine Driven Auxiliary

Feedwater

Pumps Lube Oil Skid, Revision 17 DWG No. LB-112541, Turbine Control and Quick Start System DWG No. T040-001A, TDAFW Control Oil System, Revision 0 DWG No. T040-002A, TDAFW Turbine Trip Valve, Revision 0 DWG No. T040-003A, Auxiliary

and Standby Aux. Feedwater

Systems, Revision 2 DWG No. T040-003B, SAFW System 1-Line Diagram, Revision 0 DWG No. T040-003C, AFW System 1-Une Diagram, Revision 1 DWG No. T040-004A, Auxiliary

Feedwater

Pump Auto Start Signals, Revision 0 DWG No. T830-004A, Blowdown Isolation

Solenoid Control Circuit, Revision 0 Other Documents

Vendor Report, Preliminary

Results of Stem Sticking Failure Mechanisms, July 20, 2009 Vendor Report 09-1929 Part 1, Equipment

Root Cause Analysis of AFWP Control Valve Stem Sticking Problem at Ginna Nuclear Power Station Vendor Technical

Question Response, August 26, 2009 Category I Root Causal Analysis, May and July 2009 Turbine Driven Auxiliary

Feedwater

Pump (TDAFWP) Failures;

Overspeed

Trip During Testing vrD-E9016-4001, Excerpts from EPRI Manual 1007461, Terry Turbine Maintenance

Guide, AFW Application, Revision 000 vrD-G0153-4001, Operating

Instructions

Easy Flow Body Combined Trip Throttle Valve, Revision 2 VrD-W0315-4001, Instructions

For 465 H.P. Non-Condensing

Steam Turbine Serial Number 26635, Revision 000 VrD-W0315-4002, Service Department

Standards

Book No. 10, Field Service Manual, Revision 000 Response to NRC Generic Letter 90-3, Relaxation

of Staff Position In Generic Letter 28, Item 2.2 Part 2 "Vendor Interface

for Safety Related Components, dated September

18, 1990 CATS 10 R04451, Response to NRC IN 94-66, OVERSPEED

OF TURBINE-DRIVEN

PUMPS CAUSED BY GOVERNOR VALVE STEM BINDING CMM-37-19-9519E, Worthington

Turbine Driven Auxiliary

Feedwater

Pump Hydraulic

Governor Control Valve Maintenance

for 9519E, Revision 00200 Constellation

Energy Nuclear Generating

Group Reply to a Notice of Violation; 045 Engineering

Change Package No. ECP-2009-0146, TDAFW Lube Oil Orifice Management

Review Committee

Agenda. August 5, 2009 Purchase Requisition

No. 58686, Dresser-Rand

Valve Stem Technical

Staff Request 97-199, Leakoff from TDAFW Govenor Valve 9519E Management

Review Committee

Agenda, August 5, 2009 Purchase Requisition

No. 58686, Dresser-Rand

Valve Stem Attachment

A

Technical

Staff Request 97-199, Leakofffrom

TDAFW Govenor Valve 9519E Turbine Driven Auxiliary

Feedwater

Pump Preventive

Maintenance

Strategies

Auxiliary

Feed Water System, 1 st Quarter 200S Auxiliary

Feed Water System. 2nd Quarter 200S Auxiliary

Feed Water System. 3rd Quarter 200S Auxiliary

Feed Water System, 4th Quarter 200S Auxiliary

Feed Water System, 1 st Quarter 2009 Operating

Experience

OE-200S-000397

OE-200S-000607

OE-200S-000847

o E-2 0 OS-00S60 OE-2008-001296

OE-2009-00212

OE*2009*001178

Oil Analysis Pump IB Oil Analysis.

2008-03 Pump OB Oil Analysis, 2008-03 Reservoir

Oil Analysis 2008-05 Reservoir

Oil Analysis 2008-08 Reservoir

Oil Analysis 2009-05 Attachment

A

AV CAP CCDP CDF CR DRP EDG GEM ICCDP IMC IN INL *IPEEE LERF LOOP LOSWS NCV NRC NRR PARS PSA RCA SAFW SBO SOP SPAR SRA SCAQ NCV TBD TDAFW TS A-4 LIST OF ACRONYMS Apparent Violation

Corrective

Action Program Conditional

Core Damage Probability

Core Damage Frequency

Condition

Report Division of Reactor Projects Emergency

Diesel Generator

Graphical

Evaluation

Module Incremental

Conditional

Core Damage Probability

Inspection

Manual Chapter Information

Notice Idaho National Labs Individual

Plant Examination

of External Events Large Early Release Frequency

Loss of Off site Power Loss of Service Water System Non Cited Violation

Nuclear Regulatory

Commission

Office of Nuclear Reactor Regulation

Publicly Available

Records Probabilistic

Safety Assessment

Root Cause Analysis Standby Auxiliary

Feedwater

Station Blackout Significance

Determination

Process Standardized

Plant Analysis Risk Senior Reactor Analyst Significant

Condition

Adverse to Quality Non-citied

Violation

To Be Determined

Turbine Driven Auxiliary

Feedwater

Technical

Specification

Attachment

A

8-1 Special Inspection R.E. Ginna Nuclear Power Failure of the Turbine-Driven

Auxiliary

Feedwater (TDAFW) on May 26, 2009 and July 2, Background:

On May 26, 2009, during routine

quarterly

surveillance

testing of the turbine driven auxiliary

feedwater (TDAFW) system, the TDAFW pump tripped on overspeed.

The test was repeated several hours later and the TDAFW pump tripped again on overspeed.

Fluctuations

in oil pressure were observed during the testing. After extensive

troubleshooting, Ginna

identified

a number of issues but no definitive

cause for the overspeed

trips. The lube/control

oil system was drained and cleaned due to the presence of fine particulates;

a pressure pulsation

dampener accumulator

bladder was replaced due to a below normal pressure condition;

the oil pressure regulating

bypass valve was replaced due to potential

cycling; a change to linkage setup was implemented;

governor relay valve, and trip and throttle valve parts were replaced due to out of specification

clearances;

and a miSSing oil line orifice was installed.

Following

these corrective

actions, the system was successfully

tested and declared operable.

Constellation

is completing

a root cause evaluation

and the resident inspectors

continue to conduct baseline inspections

with assistance

from DRS specialists.

Testing of the TDAFW system will be at an increased

frequency

until Constellation

has confidence

that the system is performing

as required.

On July 2, 2009, during the performance

of the increased

frequency

surveillance, the TDAFW pump again tripped on overspeed.

Glnna personnel

discovered

pitting and corrosion

on the stem of the governor control valve during troubleshooting

activities

to restore the pump to operable status. This Special Inspection

Team had raised concerns regarding

corrosion

on the stem of the Governor Control Valve during onsite inspection

activities

the week of June 15, 2009. Basis for the Formation

of the SIT: The failure of the TDAFW pump involved repetitive

failures of this

eqUipment.

There have been three failures of the TDAFW pump since December 2008. On December 2, 2008, a failure was attributed

to inadequate

implementation

of the preventive

maintenance

program. SpeCifically, the governor linkages were not lubricated

in March 2008 which resulted in the pump's inability

to achieve the required flow and pressure in December 2008. On July 2, 2009, the failure was preliminarily

determined

to be caused by pitting on the stem of the Governor Control valve and overly tolerances

causing binding of the stem. Although the specific failure modes (overspeed

trip, inability

to achieve the required flow or pressure)

were different, the underlying

cause of inadequate

or inappropriate

preventive

maintenance

may be the same. Attachment

8

Based upon best available

information, the Region I Senior Reactor Analyst (SRA) conducted

a preliminary

risk estimate of the May 26 TDAFW pump failure. An incremental

conditional

core damage probability (ICCDP) in the upper E-6 range (8E-6 per the 82 day exposure period), was calculated

using the Ginna SPAR model. assuming that the TDAFW pump would not have started since the last time it passed a surveillance

test on March 5 until May 26 (82 days). The dominant core damage sequence was a station blackout (LOOP with failure of both EDGs,) with no TDAFW and failure to recover offsite power or an EDG in one hour. Based upon the preliminary

conditional

core damage probability

estimate of upper E-6 range, in accordance

with IMC 0309, this event falls within the region for a Special Inspection

Team. Oblectives

of the Special Inspection:

The objectives

of the special inspection

are to review and assess: (1)

Constellation's

planning and execution

of the risk significant

work activities

on the TDAFW system; (2) equipment

issues related to the TDAFW testing; and (3) Constellation's

response to this significant

equipment

failure. To accomplish

these objectives, the following

will be performed: Evaluate the adequacy and completeness

of the maintenance

on the TDAFW system, including

preventive

maintenance, procedural

guidance, maintenance

testing, and supervisory

oversight. Evaluate Constellation's

application

of pertinent

industry operating

experience

and evaluation

of potential

precursors, including

the effectiveness

of any actions taken in response to the operating

experience

or precursors. Evaluate the adequacy of Constellation's

response to the TDAFW system failures, including

Constellation's

cause analysis and completed

interim corrective

actions. Evaluate the adequacy of Constellation's

initial extent of condition

for the TDAFW failures, as appropriate. Evaluate the failure modes for potential

generic implications

including

the need for generic communications

Additionally, the team leader will review lessons learned from the Special Inspection

and, if appropriate, prepare a feedback form on recommendations

for revising the reactor oversight

process (ROP) baseline inspection

procedures

in order to proactively

identify the issues and causes involved with the event. Guidance:

Inspection

Procedure

93812, "Special Inspection", provides additional

guidance to be used by the Special Inspection

Team. Team duties will be as described

in Inspection

Procedure

93812. The inspection

should emphasize

fact-finding

in its review of the circumstances

surrounding

the event. It is not the responsibility

of the team to examine Attachment

B

the regulatory

process. Safety concerns identified

that are not directly related to the event should be reported to the Region I office for appropriate

action. The Team will conduct an entrance meeting and begin the inspection

on June 8,2009. While on site, the Team Leader wi" provide daily briefings

to Region I management, who will coordinate

with the Office of Nuclear Reactor Regulation, to ensure that all other parties are kept informed.

A report documenting

the results of the inspection

should be issued within 45 days of the completion

of the inspection.

This Charter may be modified should the team develop significant

new information

that warrants review. Attachment

8