IR 05000244/2018011: Difference between revisions
StriderTol (talk | contribs) (Created page by program invented by StriderTol) |
StriderTol (talk | contribs) (Created page by program invented by StriderTol) |
||
(5 intermediate revisions by the same user not shown) | |||
Line 2: | Line 2: | ||
| number = ML18137A043 | | number = ML18137A043 | ||
| issue date = 05/16/2018 | | issue date = 05/16/2018 | ||
| title = | | title = LLC - NRC Biennial Problem Identification and Resolution Inspection Report 05000244/2018011 | ||
| author name = Catts M | | author name = Catts M | ||
| author affiliation = NRC/RGN-I/DRP/PB1 | | author affiliation = NRC/RGN-I/DRP/PB1 | ||
Line 21: | Line 21: | ||
==SUBJECT:== | ==SUBJECT:== | ||
R.E. GINNA NUCLEAR POWER PLANT, LLC | R.E. GINNA NUCLEAR POWER PLANT, LLC - NRC BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000244/2018011 | ||
- NRC BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000244/2018011 | |||
Dear Mr. Hanson | ==Dear Mr. Hanson:== | ||
On March 22, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed on-site inspection activities at your R.E. Ginna Nuclear Power Plant, LLC (Ginna) and discussed the results of this inspection with Mr. William Carsky, Site Vice President, and other members of the Ginna staff. During that discussion your staff requested to provide additional information for consideration. In-office review of the additional information continued by the NRC, and a telephonic exit meeting was conducted on April 19, 2018, with Kyle Garnish, Ginna Regulatory Assurance Manager and other members of the Ginna staff. The results of this inspection are documented in the enclosed report. | |||
and discussed the results of this inspection with Mr. William Carsky, Site Vice President, and other members of the Ginna | |||
, with Kyle Garnish, Ginna Regulatory Assurance Manager and other members of the Ginna staff | The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety. The team identified two findings in the area of Corrective Action Program, Problem Identification. | ||
. The results of this inspection are documented in the enclosed | |||
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments. | |||
, the team found no evidence of challenges to your | |||
in this | Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety. | ||
Finally the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews, the team found no evidence of challenges to your organizations safety-conscious work environment. | |||
Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available. | |||
NRC inspectors documented two findings of very low safety significance (Green) in this report. | |||
Both of these findings involved violations of NRC requirements and are being treated as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy. If you contest the violations or significance, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspectors at Ginna. In addition, if you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region I, and the NRC Resident Inspectors at Ginna. | |||
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Part 2.390, Public Inspections, Exemptions, Requests for Withholding. | |||
Sincerely, | Sincerely, | ||
/RA/ Michelle Catts , Acting Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Number: 50-244 License Number: DPR-18 | /RA/ | ||
Michelle Catts, Acting Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Number: 50-244 License Number: DPR-18 | |||
===Enclosure:=== | ===Enclosure:=== | ||
Line 40: | Line 50: | ||
==Inspection Report== | ==Inspection Report== | ||
Docket Number: 50-244 License Number: DPR-18 Report Number: 05000244/2018011 Enterprise Identifier: | Docket Number: 50-244 License Number: DPR-18 Report Number: 05000244/2018011 Enterprise Identifier: I-2018-011-0028 Licensee: Exelon Generation Company, LLC (Exelon) | ||
I-2018-011-0028 Licensee: Exelon Generation Company, LLC (Exelon) | |||
Facility: R.E. Ginna Nuclear Power Plant, LLC (Ginna) | Facility: R.E. Ginna Nuclear Power Plant, LLC (Ginna) | ||
Location: Ontario, New York Dates: March 5 to April 19, 2018 Inspectors: | Location: Ontario, New York Dates: March 5 to April 19, 2018 Inspectors: J. Hawkins, Senior Resident Inspector, Team Leader C. Lally, Reactor Inspector L. McKown, Resident Inspector S. Obadina, Project Engineer Observer(s): A. Rosebrook, Senior Project Engineer Approved By: M. Catts, Acting Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure | ||
J. Hawkins, Senior Resident Inspector, Team Leader C. Lally, Reactor Inspector L. McKown, Resident Inspector S. Obadina, Project Engineer Observer(s): | |||
A. Rosebrook, Senior Project Engineer Approved By: | |||
M. Catts, Acting Chief Reactor Projects Branch 1 Division of Reactor Projects | |||
=SUMMARY= | =SUMMARY= | ||
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring | The U.S. Nuclear Regulatory Commission (NRC) continued monitoring Exelons performance at | ||
Ginna by conducting the biennial problem identification and resolution inspection in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. | |||
Based on the samples selected for review, the inspection team concluded that Exelon was generally effective in identifying, evaluating, and resolving problems and that the Exelon effectively used operating experience and self-assessments. The inspectors found no evidence of significant challenges to | Based on the samples selected for review, the inspection team concluded that Exelon was generally effective in identifying, evaluating, and resolving problems and that the Exelon effectively used operating experience and self-assessments. The inspectors found no evidence of significant challenges to Exelons safety conscious work environment at Ginna and concluded that the staff are willing to raise nuclear safety concerns through at least one of the several means available. | ||
NRC identified and self-revealing findings and violations are summarized in the table below. | NRC identified and self-revealing findings and violations are summarized in the table below. | ||
List of Findings and Violations Potential Preconditioning of Turbine Driven Auxiliary Feedwater Surveillance Testing Cornerstone Significance Cross-Cutting Aspect | List of Findings and Violations Potential Preconditioning of Turbine Driven Auxiliary Feedwater Surveillance Testing Cornerstone Significance Cross-Cutting Report Aspect Section Reactor Safety - Green NCV None. 71152B Mitigating 05000244/2018011-01 Systems Closed The NRC identified a Green non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XI, Test Control, because Exelon established unevaluated preconditioning, with a reasonable doubt of whether the preconditioning was acceptable, prior to testing of the turbine driven auxiliary feedwater pump. | ||
-01 Closed | |||
, with a reasonable doubt of whether the preconditioning was acceptable | |||
, prior to testing of the turbine driven auxiliary feedwater pump. | |||
This results in the loss of as-found conditions which challenge the capability of the test to assure that the turbine driven auxiliary feedwater pump will perform satisfactorily in service. | |||
Failure to Procedurally Verify Fuel Transfer Cart Results in Fuel Interference Event Cornerstone Significance Cross-Cutting Report Aspect Section Reactor Safety - Green NCV H.12 - HU - 71152B Barrier Integrity 05000244/2018011-02 Avoid Closed Complacency A self-revealing Green non-cited violation (NCV) of Technical Specification 5.4.1.a, | |||
- | Procedures, was identified for the failure of Exelon to operate refueling equipment in accordance with technical procedures in April and May of 2017, which resulted in a fuel interference event, damage to the rod cluster control assembly, and the need for a detailed inspection of a fuel assembly. | ||
- | |||
- | |||
=INSPECTION SCOPES= | |||
This inspection was conducted using the appropriate portions of the inspection procedures (IPs)in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess Exelons performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards. | |||
- | |||
== | ==OTHER ACTIVITIES - BASELINE== | ||
== | ==71152 - Problem Identification and Resolution Biennial Team Inspection== | ||
{{IP sample|IP=IP 71152|count=1}} | {{IP sample|IP=IP 71152|count=1}} | ||
The inspectors performed a biennial assessment of | The inspectors performed a biennial assessment of Exelons corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment. The assessment is documented below. | ||
: (1) Corrective Action Program Effectiveness | : (1) Corrective Action Program Effectiveness - The inspection team evaluated Exelons effectiveness in identification, prioritization and evaluation, and correcting problems, and verified the station complied with NRC regulations and Exelons standards for corrective action programs. | ||
- The inspection team | : (2) Operating Experience - The team evaluated Exelons effectiveness in its use of industry and NRC operating experience information and verified the station complied with Exelons standards for the use of operating experience. | ||
: (2) Operating Experience | : (3) Self-Assessments and Audits - The team evaluated the effectiveness of Exelons audits and self-assessments and verified the station complied with Exelons standards for the use of operating experience. | ||
- The team evaluated | : (4) Safety Conscious Work Environment - The team reviewed Exelons programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. | ||
: (3) Self-Assessments and Audits | |||
- The team evaluated the effectiveness of | |||
: (4) Safety Conscious Work Environment | |||
- The team reviewed | |||
-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. | |||
==INSPECTION RESULTS== | ==INSPECTION RESULTS== | ||
Evaluation of the Ginna PI&R Program | Evaluation of the Ginna PI&R Program 71152B The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined Exelon staffs performance in each of these areas adequately supported nuclear safety. The team identified two findings in the area of Corrective Action Program, Problem Identification, and identified some weaknesses in the implementation of the stations Maintenance Rule (MR) program. | ||
The team also evaluated the | The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments. | ||
-assessments | |||
Based on the samples reviewed, the team determined that Exelons performance in each of these areas adequately supported nuclear safety. | |||
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to Exelons safety-conscious work environment. Site employees appeared willing to raise nuclear safety concerns through at least one of the several means available. | |||
- | |||
Potential Preconditioning of Turbine Driven Auxiliary Feedwater Surveillance Testing Cornerstone Significance Cross-Cutting Report Aspect Section Reactor Safety - Green NCV None. | |||
71152B Mitigating 05000244/2018011-01 Systems Closed The NRC identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XI, Test Control," | |||
because Exelon established unevaluated preconditioning, with a reasonable doubt of whether the preconditioning was acceptable, prior to testing of the turbine driven auxiliary feedwater pump. This results in the loss of as-found conditions which challenge the capability of the test to assure that the turbine driven auxiliary feedwater pump will perform satisfactorily in service. | |||
=====Description:===== | |||
, | The inspectors observed implementation of licensee Procedure STP-O-16-COMP-T, Auxiliary Feedwater Turbine Pump - Comprehensive Test, on March 7, 2018. | ||
During review of licensee Procedure STP-O-16-COMP-T and the quarterly test, Procedure STP-O-16QT, Auxiliary Feedwater Turbine Pump - Quarterly, the inspectors found that immediately prior to the cold pump start, Exelon altered, manipulated, and adjusted a number turbine driven auxiliary feedwater pump train components as directed by the surveillance procedures. These included flushing the condensate storage tank water aligned to the pump suction through the pump to a drain at the pump discharge for approximately 30 minutes, removing and cleaning the auxiliary feedwater pump lubricating oil cooling water (service water) strainer, validating the functionality of the lubricating oil cooling water (service water)strainer bypass valve and bypass valve controlling differential pressure pressure switch, stopping and starting the alternating current and direct current lubricating oil pumps, and verifying the low oil pressure trip functionality of the turbine trip and throttle valve which fully cycles the trip and throttle valve as well as the governor control valve under no load conditions. Consistent with NRC Inspection Manual Part 9900: Technical Guidance, Maintenance - Preconditioning of Structures, Systems and Components before Determining Operability, the inspectors identified these activities, executed immediately prior to cold pump start, as potential preconditioning and discussed the observations with Exelon staff. | |||
-O-16QT | |||
Exelon established processes associated with the assessment of preconditioning under Procedures IP-IIT-2, Inservice Testing Program for Pumps and Valves, and CTP-IST-001, Corporate Technical Position - Preconditioning of Inservice Testing Program Components, which states in part, Preconditioning SHALL be avoided unless an evaluation has been performed to determine that the preconditioning is acceptable. The inspectors asked the licensee if a preconditioning evaluation for Procedures STP-Q-16-COMPT or STP-O-16QT was conducted. | |||
- | |||
, which | |||
, is acceptable for | |||
Exelon | After the pump run on March 7, Exelon chose to perform an evaluation of preconditioning acceptability for the flushing of the pump. The justification for acceptability of this preconditioning was protection of the steam generators from low quality water sitting within the pump. Exelon asserted that impact on the pump test results are negligible without providing the details of the potential as-found conditions masked, failure mechanisms against which the activity was evaluated, or why the lower quality water, which is always with the pump while in a standby lineup, is acceptable for event mitigation. | ||
The inspectors determined this 2010 preconditioning evaluation was narrowly focused on governor control valve stem binding and did not address any other pump parameters or failure modes that could be masked due to cycling the low oil trip or the cycling of the trip mechanism prior to the surveillance test. | Exelon discovered a preconditioning evaluation had been performed for the cycling of the turbine trip mechanism on April 13, 2010. The inspectors determined this 2010 preconditioning evaluation was narrowly focused on governor control valve stem binding and did not address any other pump parameters or failure modes that could be masked due to cycling the low oil trip or the cycling of the trip mechanism prior to the surveillance test. | ||
Since Exelon performed a technically inadequate preconditioning evaluation associated with low oil trip testing of the turbine trip function and Exelon had not | Since Exelon performed a technically inadequate preconditioning evaluation associated with low oil trip testing of the turbine trip function and Exelon had not performed preconditioning evaluations of the impact of flushing water through the pump, the lubricating oil cooling water (service water) activities, or stopping and starting of the lubricating oil pumps in advance of the surveillance as of the end of the inspection, the inspectors have concluded that the activities performed immediately prior to cold pump start during comprehensive and quarterly turbine driven auxiliary feedwater pump surveillance testing are examples of unevaluated preconditioning with a reasonable doubt of whether the preconditioning was acceptable, consistent with NRC Inspection Manual Part 9900 Technical Guidance and Exelon program guidance. | ||
This included a preconditioning evaluation of all of the identified issues. Exelon concluded there was no unacceptable preconditioning and that the operability of the turbine driven auxiliary feedwater system was not adversely affected. | Corrective Actions: Exelon entered this concern into the corrective action program for prioritization, assessment, and resolution. This included a preconditioning evaluation of all of the identified issues. Exelon concluded there was no unacceptable preconditioning and that the operability of the turbine driven auxiliary feedwater system was not adversely affected. | ||
The inspectors have no current operability concerns. | The inspectors have no current operability concerns. This evaluation will be fully reviewed under the baseline inspection program. | ||
Corrective Action Reference: Action requests (ARs) 4111709 and 04119043 | |||
=====Performance Assessment:===== | |||
Performance Deficiency: The inspectors determined that Exelon did not adequately evaluate pre-test activities for the turbine driven auxiliary feedwater pump comprehensive and quarterly tests for preconditioning as discussed in NRC Inspection Manual Part 9900 Technical Guidance, and required by Ginnas Inservice Test Program guidance and Exelons corporate technical position on preconditioning; and failed to identify that those activities may have constituted unacceptable preconditioning. This performance deficiency was reasonably within the licensees ability to foresee and correct and should have been prevented. | |||
The inspectors determined that Exelon did not adequately evaluate pre-test activities for the turbine driven auxiliary feedwater pump comprehensive and quarterly | |||
This is also similar to IMC 0612 Appendix E, Examples of Minor Issues, examples 3J and 3K. | Screening: This finding was more than minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated January 1, 2018, because the performance deficiency is associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. This is also similar to IMC 0612 Appendix E, Examples of Minor Issues, examples 3J and 3K. Specifically, preconditioning of components could mask the actual as-found conditions of the system resulting in an inability to verify operability of the system. | ||
Significance: The inspectors assessed significance of this condition using IMC 0609, 4, Phase 1 - Initial Screening and Characterization of Findings worksheet, which directs the user to IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. In accordance with IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, Section A, Mitigating Systems, Structures or Components and Functionality, the finding screened to be of very low safety significance (Green), because the performance deficiency did not affect system design or qualification, did not result in a loss of safety function, and did not result in the turbine driven auxiliary feedwater train to be out of service for greater than its technical speciation allowed outage time. | |||
The inspectors assessed significance of this condition using IMC 0609, | |||
- Initial Screening and Characterization of Findings | |||
-Power. | |||
Cross Cutting Aspect: No cross cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance. | |||
: | |||
=====Enforcement:===== | |||
Violation: Title 10 CFR Part 50, Appendix B, Criterion XI, Test Control, states, in part, that a test program shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. | |||
Contrary to the above, from April 13, 2010 to present, Exelon did not establish an adequate test program, which assured that all testing required to demonstrate the turbine driven auxiliary feedwater system will perform satisfactorily in service, due to potential preconditioning. | |||
Disposition: This violation is being treated as a NCV, consistent with Section 2.3.2 of the Enforcement Policy. | |||
Failure to Procedurally Verify Fuel Transfer Cart Results in Fuel Interference Event Cornerstone Significance Cross-Cutting Report Aspect Section Reactor Safety - Green NCV H.12 - HU - 71152B Barrier Integrity 05000244/2018011-02 Avoid Closed Complacency A self-revealing Green NCV of Technical Specification 5.4.1.a, Procedures, was identified for the failure of Exelon to operate refueling equipment in accordance with technical procedures in April and May of 2017, which resulted in a fuel interference event, damage to the rod cluster control assembly, and the need for a detailed inspection of a fuel assembly. | |||
- | |||
=====Description:===== | |||
The inspectors identified two examples of failure to follow a required procedure. | |||
Specifically, Exelon Procedures RF-200, Fuel Handling System Checkouts, and RF-302, Fuel Handling Tool Checkout and Operation in Containment, were not followed as discussed below. | |||
: (1) In advance of the Spring 2017 refueling outage on April 20, 2017, Exelon implemented a modification to the fuel transfer system to improve fuel moves between containment and the spent fuel pool. This modification changed the alignment of the transfer cart rails, which resulted in a change to the match-mark locations where the encoder stops the fuel assembly. | |||
- | |||
The | The licensee failed to perform adequate post modification testing including verification of fuel transfer cart to rail alignment at these match-marked locations in accordance with Steps 6.2.4.16 and 6.2.4.20 of licensee Procedure RF-200. | ||
. | : (2) During the Spring 2017 refueling outage, Exelon performed a complete core offload of all 121 fuel assemblies using the modified fuel transfer system in accordance with Procedure RF-302, Attachment 3, Fuel Transfer System Operating Instructions. The licensee did not perform Step 4.6.4 of Procedure RF-302, Attachment 3, which required the operators to verify pointer and target match-marks to confirm fuel transfer cart to rail alignment on the spent fuel pool side. During core reload on May 4, 2017, upon sending the fifth fuel assembly, which was a new fuel assembly, from the spent fuel pool to the reactor side, the fuel transfer system operator confirmed location of the fuel assembly using the encoder position as provided by a lit indication instead of the pointer and target match-marks as required by Step 4.5.4 of Procedure RF-302, Attachment 3. When the fuel transport system operator up-ended the fuel assembly on the reactor side, the rod cluster control assembly installed with the fuel assembly struck the fuel transport tube. The fuel assembly and rod cluster control assembly were immediately sent back to the spent fuel pool for evaluation of potential damage. | ||
Exelon found the affected rod cluster control assembly to be damaged and was removed from service. The licensee performed a detailed inspection of the associated fuel assembly and determined the fuel cladding remained operable. The NRC inspectors reviewed Exelons apparent cause evaluation for this issue and determined that while applicable sections of Procedures RF-200 and RF-302 were documented as completed, fuel handlers did not use cart alignment match-marks to verify fuel assembly position. They had instead relied upon the encoder position of the cart as provided by a lit indication. | |||
Corrective Actions: Exelon revised Procedures RF-200 and RF-302 requiring verification of match-marks via remote visual observation (e.g., camera), including staff signatures for all steps that verify cart fuel and target match-marks, and added a caution identifying the lit encoder position indication as not a valid indication of cart position. | |||
Corrective Action Reference: AR 04006765 | |||
Exelon Procedures RF-200 | =====Performance Assessment:===== | ||
Performance Deficiency: Inspectors found that Exelon did not operate refueling equipment in accordance with l Procedures, RF-200 and RF-302, during pre-outage activities, core offload, and core reload in April and May of 2017, which resulted in a fuel interference event, damage to the rod cluster control assembly, and the need for a detailed inspection of a fuel assembly. | |||
, | |||
This performance deficiency was reasonably within the licensees ability to foresee and correct and should have been prevented. | |||
Screening: This finding was more than minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated January 1, 2018, because if left uncorrected, the performance deficiency would have the potential to lead to a more significant safety concern. Specifically, the repetitive failure to perform the procedurally required fuel transfer cart position verifications, which resulted in the interference event, the actual damage sustained by the rod cluster control assembly, and the need for a detailed inspection of the fuel assembly, if left uncorrected, would have the potential to result in actual damage to a spent fuel assembly which could challenge the ability of the fuel cladding to remain intact. | |||
This | |||
Significance: The inspectors assessed significance of this condition using IMC 0609, 4, Phase 1 - Initial Screening and Characterization of Findings worksheet, which directs the user to IMC 0609 Appendix G, Shutdown Operations Significance Determination Process. However, criteria for evaluating fuel handling issues are only contained in IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Since no criteria exist to evaluate this issue in IMC, Appendix G, the inspectors used the most applicable screening criteria available to make a bounding case and characterize this finding as allowed by IMC 0609, Appendix M, Significance Determination Process Using Qualitative Criteria. The inspectors assessed significance of this fuel handling event in accordance with IMC 0609, Appendix A, Exhibit 3, Barrier Integrity Screening Questions, Section D, Spent Fuel Pool. The finding was determined to be of very low safety significance (Green), because the performance deficiency did not affect fuel pool temperature or level, did not affect neutron absorber capability or result in a fuel bundle being misplaced, and although the performance deficiency resulted in fuel handling errors, it did not cause mechanical damage to fuel clad and a detectible release of radionuclides. | |||
. However, | |||
This | Cross Cutting Aspect: This finding in accordance with IMC 0310, Aspects within the Cross-Cutting Areas, dated December 04, 2014, has a cross-cutting aspect in the area of Human Performance associated with Avoid Complacency, in that Exelon fuel transfer system operators did not recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Specifically, operators failed to recognize the latent issues associated with misalignment of the fuel transfer cart and the inherent risk incurred by the inappropriate cart position verification method used, and did not complete the appropriate procedure step a number of times prior to the interference event occurring. (H.12) | ||
. | |||
=====Enforcement:===== | |||
Violation: Technical Specification 5.4.1.a, Procedures, states in part, Written procedures shall be established, implemented, and maintained covering the following activities: The applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Revision 2, Appendix A, Section 2.k, identifies Refueling Equipment Operation, as a recommended procedure. Exelon Procedures RF-200, Fuel Handling System Checkouts, and RF-302, Fuel Handling Tool Checkout and Operation in Containment, implement this requirement. | |||
4 | Contrary to the above, from April 20, 2017 to May 4, 2017, Exelon staff did not properly implement written procedures RF-200 and RF-302, which resulted in a fuel interference event on May 4, 2017, damage to the rod cluster control assembly, and the need for a detailed inspection of a fuel assembly. | ||
- | |||
Disposition: This violation is being treated as a NCV, consistent with Section 2.3.2 of the Enforcement Policy. | |||
Exelon documented the | Observations and Minor Violations/Performance Deficiencies 71152B Corrective Action Program: The team concluded that Exelons corrective action program was generally effective. However, some observations were noted; particularly, a number of issues in the MR program. Specifically, 1. The inspectors reviewed maintenance preventable functional failures (MPFFs) that occurred on the service air system since 2016. The inspectors noted that diesel driven service air compressor failures on January 12 and December 27, 2017, were documented by Ginna to be the result of vendor guidance not being used correctly in the development of online monitoring of equipment. Based on Ginnas documentation, the inspectors determined that Ginnas basis for the December 2017 failure not being a repetitive MPFF was not adequately justified. Ginna presented the inspectors additional analysis and evaluation of the failure from December 2017, that had not been documented originally, which showed that the maintenance related cause was different than the cause of the failure in January 2017. Therefore, the issue was not a repetitive MPFF and did not constitute a violation of 10 CFR 50.65 (a)(2). Exelon documented the inspectors observation concerning adequate documentation of MPFF causes in AR 04122176. This observation is related to the assessment of the Corrective Action Program Area of Problem Evaluation. | ||
. | |||
2. The inspectors reviewed 22 maintenance rule functional failures (MRFFs) that occurred over the last two years, 13 of which were determined to be not maintenance preventable, 9 MPFFs, and zero were repetitive MPFFs. The inspectors determined that three of the 13 issues that Exelon determined were not MPFFs, were maintenance preventable (ARs 02625128, 02630466, and 02633768). The inspectors also noted inconsistencies regarding Exelons documented basis for why MPFFs were or were not determined to be repeat MPFFs. The inspectors determined that all of these MR issues represented performance deficiencies because Exelon was not following their MR performance monitoring Procedure, ER-AA-310-1004. Exelon documented the issue in ARs 04117878 and 04118265. The inspectors determined that these issues do not constitute a violation of 10 CFR 50.65 (a)(2) per the guidance in the NRC Enforcement Manual because the additional MPFFs did not cause any of Exelons MR systems to exceed their performance criteria and the performance deficiency was minor because the issues did not represent a significant programmatic deficiency within the MR program This observation is related to the assessment of the Corrective Action Program Area of Problem Evaluation. | |||
The | |||
3. The inspectors reviewed two failures of the B containment hydrogen monitor (ARs 02630466 and 02633768) that occurred in February 2016. The failures were the result of failed 480 VAC current voltage transformers that had internal non-electrolytic capacitors fail due to age. Exelons evaluation of the failures determined that their procurement procedure for the tracking of component shelf-life, PES-S-002, had not been revised to include updated industry guidance that would ensure the appropriate shelf-life of safety-related and augmented quality components are appropriately tracked. The inspectors determined that Exelons corrective action to revise the procedure had not been completed yet and had been extended multiple times leaving the program vulnerable to the same failure mode. The inspectors also determined that no extent of condition had been performed on other components tracked by the shelf-life program. This performance deficiency is of minor risk significance because the aged components either were not yet installed in the plant, failures were identified during post maintenance testing, and the equipment failures did not impact the Barrier Integrity cornerstone objective. Exelon documented these issues in ARs 02657276 and 02657285. This observation is related to the assessment of the Corrective Action Program Area of Problem Evaluation. | |||
4. The inspectors reviewed corrective actions associated with NCV 05000244/2015002-02, Inadequate Procedure Implementation Results in Inadvertent Entry into 72-Hour Technical Specification Action Statement. Exelons evaluation of the event determined that improper tool usage, while lifting leads to support a power supply replacement, caused the inverter swap. Exelons corrective actions included revising Procedure M-71.4, Removal and/or Installation of Modules Within Defeated or Out of Service Instrument Loops, to provide clear direction that only nonconductive tools should be used to perform the activity. The inspectors determined that the 2015 procedure included the caution, however subsequent versions did not include this caution, and that there were no procedure change request forms that accounted for the revisions not including the caution. The inspectors reviewed this issue using IMC 0612, Appendix B, Issue Screening, and determined this issue was a minor violation of Technical Specification 5.4.1.a, Procedures, because the issue was administrative in nature, workers had knowledge of the precaution due to previously completed corrective actions, and the issue had not repeated. Exelon documented the issue in AR 04114953. This observation is related to the assessment of the Corrective Action Program Area of Timely and Effective Corrective Actions. | |||
Observation | Observation and Minor Performance Deficiency 71152B Operating Experience: The team identified some issues in Exelons incorporation of lessons learned from industry and NRC operating experience into station programs, processes, and procedures. This observation also supports the assessment of the MR. | ||
The team identified some issues in | |||
The inspectors reviewed two equipment failures in the service air system (ARs 02639792 and 03962433) both of which had similar industry operating experience that were determined to have not been reviewed by Exelon prior to each failure. Exelon documented the issue in the ARs noted above. For these failures, Exelon identified that valid operating experience had not been evaluated; however, the failures were appropriately classified as MRFFs when this fact was identified. The failures did not result in a loss of system or train function. Therefore this does not constitute a violation of NRC requirements and the performance deficiency is minor. | |||
Observation 71152B Self-Assessments and Audits: The team identified some issues in Exelons use of audits and self-assessments. These issues support the observation of weakness in the MR program. | |||
1. Maintenance Rule Program Focused Area Self-Assessment (FASA) dated June 30, 2016 (FASA 02565710) - The inspectors noted that the FASA did not meet Objective #3 of the self-assessment, to review equipment failures of two MR systems since the last FASA, specifically only one system was reviewed. Exelon documented the issue in AR 04117874. | |||
2. Nuclear Oversight (NOS) Corrective Action Program Audit dated March 29, 2017 (AR 3977544) - The inspectors noted the audit did not include a review of the MR program and that the audits corrective actions did not address that three of eight operating experience reviews contained errors related to accurate documentation. | |||
Exelon documented the issue in AR 04117882. | |||
Observation 71152B Safety Conscious Work Environment: The team found no evidence of challenges to Exelons organizations safety-conscious work environment. Site employees appeared willing to raise nuclear safety concerns through at least one of the several means available. | |||
Observation 71152B Review of Corrective Actions Related to Greater-than-Green Findings That Were Not Completed by the End of the Associated Supplemental Inspection: The team reviewed the corrective actions, open at the time of completion of the documented IP 95001 Supplemental Inspection (ML16333A024), dated November 28, 2016, associated with a White NOV in the Emergency Preparedness Cornerstone. The team verified these corrective actions had been completed as scheduled. The team did not identify any new performance deficiencies and did not document any additional observations. | |||
Inspectors verified no proprietary information was retained or documented in this report. | ==EXIT MEETINGS AND DEBRIEFS== | ||
On March 22, 2018, the inspectors presented the biennial problem identification and resolution initial inspection results to Mr. William Carsky, Site Vice President, and other members of the Ginna staff. During that discussion your staff requested to provide additional information for consideration. In-office review of the additional information continued by the NRC, and a telephonic exit meeting was conducted on April 19, 2018 with Kyle Garnish, Ginna Regulatory Assurance Manager and other members of the Ginna staff. Inspectors verified no proprietary information was retained or documented in this report. | |||
THIRD PARTY REVIEWS Inspectors reviewed Institute on Nuclear Power Reactor reports that were issued during the inspection period. | THIRD PARTY REVIEWS Inspectors reviewed Institute on Nuclear Power Reactor reports that were issued during the inspection period. | ||
Line 327: | Line 200: | ||
=DOCUMENTS REVIEWED= | =DOCUMENTS REVIEWED= | ||
71152B | |||
Procedures | |||
CC-AA-211, Fire Protection Program, Revision 8 | CC-AA-211, Fire Protection Program, Revision 8 | ||
CC-AA-501-1008, Exelon Nuclear Welding Program Welding General Requirements | CC-AA-501-1008, Exelon Nuclear Welding Program Welding General Requirements | ||
CTP-IST-001, Corporate Technical Position | CTP-IST-001, Corporate Technical Position - Preconditioning of IST Program Components, | ||
- Preconditioning of IST Program Components, Revision 1 | Revision 1 | ||
EI-AA-1, Safety Conscious Work Environment, Revision 4 | EI-AA-1, Safety Conscious Work Environment, Revision 4 | ||
EI-AA-101, Employee Concerns Program, Revision 11 | EI-AA-101, Employee Concerns Program, Revision 11 | ||
Line 339: | Line 213: | ||
EP-CE-111-F-03, Ginna Protective Action Recommendation Flowchart, Revision B | EP-CE-111-F-03, Ginna Protective Action Recommendation Flowchart, Revision B | ||
EP-CE-114-100, Emergency Notifications, Revision 6 | EP-CE-114-100, Emergency Notifications, Revision 6 | ||
EPG-EPAC, Emergency Preparedness Advisory Committee Subcommittee for Excellence in Emergency Preparedness Guideline, Revision 00000 | EPG-EPAC, Emergency Preparedness Advisory Committee Subcommittee for Excellence in | ||
Emergency Preparedness Guideline, Revision 00000 | |||
EPJA-0, Ginna Station Event Evaluation and Classification, Revision 2 | EPJA-0, Ginna Station Event Evaluation and Classification, Revision 2 | ||
ER-AA-310, Implementation of the Maintenance Rule, Revision 11 | ER-AA-310, Implementation of the Maintenance Rule, Revision 11 | ||
ER-AA-310-1004, Maintenance Rule | ER-AA-310-1004, Maintenance Rule - Performance Monitoring, Revision 14 | ||
- Performance Monitoring, Revision 14 | ER-AA-310-1005, Maintenance Rule - Dispositioning Between (a)(1) and (a)(2), Revision 7 | ||
ER-AA-310-1005, Maintenance Rule | ER-AA-310-1006, Maintenance Rule-Expert Panel Roles and Responsibilities, Rev. 7 | ||
- Dispositioning Between (a)(1) and (a)(2), Revision 7 | ER-AA-310-1007, Maintenance Rule - Periodic (a)(3) Assessment, Revision 5 | ||
ER-AA-310-1006, Maintenance Rule | |||
-Expert Panel Roles and Responsibilities, Rev. 7 | |||
ER-AA-310-1007, Maintenance Rule | |||
- Periodic (a)(3) Assessment, Revision 5 | |||
ER-INST.3, Instrument Bus Power Restoration, Revision 01200 | ER-INST.3, Instrument Bus Power Restoration, Revision 01200 | ||
GMM-24-02-ISFSI01A, ISFSI Operations using Areva equipment | GMM-24-02-ISFSI01A, ISFSI Operations using Areva equipment | ||
Line 355: | Line 226: | ||
HU-AA-104-101, Procedure Use and Adherence, Revision 5 | HU-AA-104-101, Procedure Use and Adherence, Revision 5 | ||
IP-IIT-2, Inservice Testing Program for Pumps and Valves, Revision 016 | IP-IIT-2, Inservice Testing Program for Pumps and Valves, Revision 016 | ||
M-71.4, Removal and/or installation of modules within defeated or out of service instrument loops, Revision 02501, 02600, 02700 | M-71.4, Removal and/or installation of modules within defeated or out of service instrument | ||
loops, Revision 02501, 02600, 02700 | |||
MA-AA-716-003, Tool Pouch / Minor Maintenance, Revision 10 | MA-AA-716-003, Tool Pouch / Minor Maintenance, Revision 10 | ||
MA-AA-716-004, Conduct of Troubleshooting, Revision 15 | MA-AA-716-004, Conduct of Troubleshooting, Revision 15 | ||
MA-AA-716-234, FIN Team Process, Revision | MA-AA-716-234, FIN Team Process, Revision 12 | ||
NO-AA-21, Nuclear Oversight Audit Process Descriptions, Revision 9 | NO-AA-21, Nuclear Oversight Audit Process Descriptions, Revision 9 | ||
OP-AA-108-115, Operability Determinations, Revision 20 | OP-AA-108-115, Operability Determinations, Revision 20 | ||
OP-AA-108-115-1002, Supplemental Consideration for on | OP-AA-108-115-1002, Supplemental Consideration for on-shift Immediate Operability | ||
-shift Immediate Operability Determination, Revision 3 | Determination, Revision 3 | ||
OP-AA-112-101, Shift Turnover and Relief, Rev 13 | OP-AA-112-101, Shift Turnover and Relief, Rev 13 | ||
OU-AA-630-1000 R007, Spent Fuel Loading Campaign Management | OU-AA-630-1000 R007, Spent Fuel Loading Campaign Management | ||
Line 375: | Line 247: | ||
PI-AA-125-0004, Effectiveness Review Manual, Revision 2 | PI-AA-125-0004, Effectiveness Review Manual, Revision 2 | ||
PI-AA-125-001-F-01, CAPCO Indoctrination Guide, Revision 1 | PI-AA-125-001-F-01, CAPCO Indoctrination Guide, Revision 1 | ||
PI-AA-125-1001, Root Cause Analysis Manual, Revision 3 | PI-AA-125-1001, Root Cause Analysis Manual, Revision 3 | ||
PI-AA- | PI-AA-125-1003, Corrective Action Program Evaluation Manual, Revision 4 | ||
PI- | PI-AA-125-1006, Investigation Techniques Manual, Revision 3 | ||
PI-AA-126, Self-Assessment and Benchmark Program, Revision 2 | PI-AA-126, Self-Assessment and Benchmark Program, Revision 2 | ||
PI-AA-126-1001, Self | PI-AA-126-1001, Self-Assessments, Revision 2 | ||
-Assessments, Revision 2 | |||
PI-AA-126-1006, Benchmark Program, Revision 2 | PI-AA-126-1006, Benchmark Program, Revision 2 | ||
PI-AA-127, Passport Action Tracking Management Procedure, Revision 2 | PI-AA-127, Passport Action Tracking Management Procedure, Revision 2 | ||
RE-100, Preparation, Review, and Approval of Fuel Movement Sequence Sheets and Document Closeout, Rev. 3 | RE-100, Preparation, Review, and Approval of Fuel Movement Sequence Sheets and | ||
RF-200, Fuel Handling System Checkouts (Dry and Wet), | Document Closeout, Rev. 3 | ||
RF-200, Fuel Handling System Checkouts (Dry and Wet), Revision 015 | |||
RF-302, Fuel Handling Tool Checkout and Operation in Containment, Revision 011 | |||
RF-602, Irradiated Fuel Assembly Visual Inspection, Revision 00200 | RF-602, Irradiated Fuel Assembly Visual Inspection, Revision 00200 | ||
S-16.2, Nitrogen Make | S-16.2, Nitrogen Make-up to the SI Accumulators, Revision 034 | ||
-up to the SI Accumulators, Revision 034 | |||
SA-AA-129-2118, Management and Control of Temporary Power, Revision 9 | SA-AA-129-2118, Management and Control of Temporary Power, Revision 9 | ||
SM-AA-3019, Parts Quality Initiative (PQI), Revision 6 | SM-AA-3019, Parts Quality Initiative (PQI), Revision 6 | ||
SM-AA-4003, Supply Critical Spare Guideline, Revision 10 | SM-AA-4003, Supply Critical Spare Guideline, Revision 10 | ||
STP-O-16-COMP-T, Auxiliary Feedwater Turbine Pump | STP-O-16-COMP-T, Auxiliary Feedwater Turbine Pump - Comprehensive Test, Revision 024 | ||
- Comprehensive Test, Revision 024 | STP-O-16QT, Auxiliary Feedwater Turbine Pump - Quarterly, Revision 013 | ||
STP-O-16QT, Auxiliary Feedwater | STP-O-36-COMP-C, Standby Auxiliary Feedwater Pump C - Comprehensive Test, Revision 18 | ||
Turbine Pump | STP-O-36-COMP-D, Standby Auxiliary Feedwater Pump D - Comprehensive Test, Revision 16 | ||
- Quarterly, Revision 013 | STP-O-R-19(-20), Diesel Generator A(B) - Auto-Start Undervoltage Logic Test, Revision 2 | ||
STP-O-36-COMP-C, Standby Auxiliary Feedwater Pump C | |||
- Comprehensive Test, Revision 18 | |||
STP-O-36-COMP-D, Standby Auxiliary Feedwater Pump D | |||
- Comprehensive Test, Revision 16 | |||
STP-O-R-19(-20), Diesel Generator A(B) | |||
- | |||
STP-O-R-2.1A, Safety Injection Functional Test Alignment/Realignment, Revision 9 | STP-O-R-2.1A, Safety Injection Functional Test Alignment/Realignment, Revision 9 | ||
STP-O-R-2.2-TR-A, Diesel Generator Load and Safeguard Sequence Test | STP-O-R-2.2-TR-A, Diesel Generator Load and Safeguard Sequence Test - Train A, Revision 0 | ||
- Train A, Revision 0 | STP-O-R-2.2-TR-B, Diesel Generator Load and Safeguard Sequence Test - Train B, Revision 1 | ||
STP-O-R-2.2-TR-B, Diesel Generator Load and Safeguard Sequence Test | |||
- Train B, Revision 1 | |||
STP-O-R-2.3A, Diesel Generator A Trip Testing, Revision 5 | STP-O-R-2.3A, Diesel Generator A Trip Testing, Revision 5 | ||
STP-O-R-22, Feedwater Pump DC Oil Pump Time Delay Relay Test, Revision 2 | STP-O-R-22, Feedwater Pump DC Oil Pump Time Delay Relay Test, Revision 2 | ||
Line 416: | Line 278: | ||
WC-AA-106, Work Screening and Processing, Revision 17 | WC-AA-106, Work Screening and Processing, Revision 17 | ||
Condition Reports (*initiated in response to inspection) | Condition Reports (*initiated in response to inspection) | ||
04114953* 04114953* 04111374* 04111322* 04111374* 04111669* 04111709* 04112168* 04112392* 04112598* 04112750* 04112800* 04112812* 04116888* 04110783* 04117873* 04117874* 04117878* | 04114953* 04117882* 02405851 02492151 02535825 | ||
04114953* 04118265* 02409910 02494125 02535895 | |||
04111374* 04119043* 02424722 02494412 02535900 | |||
Maintenance Rule Program Focused Area Self | 04111322* 01701238 02429230 02500256 02535909 | ||
-Assessment dated June 30, 2016 Nuclear Oversight (NOS) Corrective Action Program Audit dated March 29, 2017 | 04111374* 01701311 02434592 02502343 02544137 | ||
QA-NOSA-GIN-17-03 GINNA EMERGENCY PREPAREDNESS AUDIT REPORT, PLAN AND TECHNICAL SPECIALIST ORIENTATION GUIDE dated 4/12/17 | 04111669* 01933869 02502359 02546188 | ||
QA-NOSA-GIN-16-03 EMERGENCY PREPAREDNESS AUDIT REPORT AND PLAN dated 4/28/16 Maintenance Rule (a)(3) Periodic Maintenance Effectiveness Assessment, November 7, 2015 | 2434979 | ||
04111709* 01938885 02506563 | |||
04112168* 02439937 02573642 | |||
01948599 02509756 | |||
04112392* 02449963 02574211 | |||
01950285 02512443 | |||
04112598* 02458481 02575341 | |||
01956230 02514628 | |||
04112750* 02458739 02577596 | |||
01961032 02514655 | |||
04112800* 01962316 02465416 02577698 | |||
2514772 | |||
04112812* 02470437 02516547 02580574 | |||
01962318 | |||
04116888* 02471785 02582826 | |||
01963575 02516554 | |||
04110783* 02473775 02585574 | |||
04117873* 02132702 02516978 | |||
2178745 02475400 02523193 02592360 | |||
04117874* | |||
2397449 02476668 02528317 02601330 | |||
04117878* | |||
2399951 02483272 02530555 02609057 | |||
04117880* | |||
2609137 02665316 02713354 03965439 04029514 | |||
2610810 02665838 02714782 03966140 04034008 | |||
2612275 02666602 02715246 03970849 04035608 | |||
2615048 02666793 02715731 03970993 04045306 | |||
2617579 02666866 02716996 03972024 04049372 | |||
2618563 02669156 02724064 03973119 04050245 | |||
2619403 02669354 02730010 03973323 04050403 | |||
2620316 02670975 02730711 03973710 04057555 | |||
2620792 02671948 02732752 03975046 04059218 | |||
2620843 02673198 02735369 03977182 04063272 | |||
2625128 02674062 02735697 03980222 04064822 | |||
2626369 02674062 02735709 03982757 04065573 | |||
2628278 02679127 02735815 03985259 04065575 | |||
2629046 02680604 02736095 03988081 04070378 | |||
2630625 02681417 02736152 03988754 04070436 | |||
2630722 02682945 02736383 03994820 04074362 | |||
2631153 02683617 02736488 03996769 04074792 | |||
2633355 02684098 02736494 03997830 04074828 | |||
2633728 02684215 02736495 03998922 04074961 | |||
2634523 02684662 02736543 03999507 04075248 | |||
2634583 02684850 02736798 03999538 04075866 | |||
2634645 02685880 02737109 04001424 04077758 | |||
2635546 02693831 02737173 04002200 04078493 | |||
2636117 02695299 02737475 04004545 04084880 | |||
2636164 02695445 02738390 04005936 04084950 | |||
2638320 02695917 02739509 04005948 04086960 | |||
2639723 02695937 02741463 04006292 04087519 | |||
2639792 02696733 02742213 04006765 04087990 | |||
2640633 02696981 02742444 04007556 04091114 | |||
2640712 02698012 02769127 04007570 04091598 | |||
2640720 02698549 03943647 04009546 04092244 | |||
2641476 02702341 03949351 04009869 04092597 | |||
2646017 02702383 04009990 04092735 | |||
03950704 | |||
2646791 04010037 04093825 | |||
2702771 03952606 | |||
2648547 03954743 04010823 04094539 | |||
2703675 | |||
2649359 03960291 04011557 04096206 | |||
2706311 04096294 | |||
2655409 03961753 04011603 | |||
2657276 02707246 04014045 04097001 | |||
2707249 03962433 | |||
2657285 04020146 04097005 | |||
03963060 | |||
2659732 02709964 04020622 04097015 | |||
2710347 03963193 | |||
2661766 04021265 04097056 | |||
03964222 | |||
2664538 02711117 04022430 04097393 | |||
2711794 03964471 | |||
2664640 04028605 04111709 | |||
2712688 03965151 | |||
2665131 04029298 | |||
2009-003680 | |||
2009-002332 | |||
2011-000411 | |||
Self-Assessment and Audits | |||
Maintenance Rule Program Focused Area Self-Assessment dated June 30, 2016 | |||
Nuclear Oversight (NOS) Corrective Action Program Audit dated March 29, 2017 | |||
QA-NOSA-GIN-17-03 GINNA EMERGENCY PREPAREDNESS AUDIT REPORT, PLAN AND | |||
TECHNICAL SPECIALIST ORIENTATION GUIDE dated 4/12/17 | |||
QA-NOSA-GIN-16-03 EMERGENCY PREPAREDNESS AUDIT REPORT AND PLAN dated | |||
4/28/16 | |||
Maintenance Rule (a)(3) Periodic Maintenance Effectiveness Assessment, November 7, 2015 - | |||
May 14, 2017 | |||
PI&R FASA dated December 29, 2017 | PI&R FASA dated December 29, 2017 | ||
2016 Self-Assessment: Pre | 2016 Self-Assessment: Pre-NRC 95001 Inspection (EAL Basis) | ||
-NRC 95001 Inspection (EAL Basis) | 26359732-23, Effectiveness Revie for Root Cause Evaluation 02659732, EAL Classification | ||
26359732-23, Effectiveness Revie for Root Cause Evaluation 02659732, EAL Classification Inaccuracy | Inaccuracy | ||
277135, Operability Evaluation Focused Area Self | 277135, Operability Evaluation Focused Area Self-Assessment, dated May 16, 2010 | ||
-Assessment, dated May 16, 2010 | 2434592 02434979 02458481 02575250 02575290 02582826 | ||
2434592 02434979 02458481 02575250 02575290 02582826 | 2583237 02592360 03974705 04031441 | ||
C20805095 C20805095 C90640029 C92925824 C92925829 C92939169 C93051676 C93641214 C93765443 | Maintenance Orders/Work Orders | ||
201-0102, 120V AC Instrument Bus One | C20805095 C20805095 C90640029 C92925824 C92925829 C92939169 | ||
-Line Diagram | C93051676 C93641214 C93765443 | ||
Calculations | |||
201-0102, 120V AC Instrument Bus One-Line Diagram | |||
ES-4.003, 125 Volt DC Short Circuit and System Voltage Drop Calculation, Revision 10 | ES-4.003, 125 Volt DC Short Circuit and System Voltage Drop Calculation, Revision 10 | ||
Engineering Changes / Evaluations | Engineering Changes / Evaluations | ||
70108834, Change Current 6Y Replacement Scope of all Thirty Three SW Expansion Joint to 2Y Evisive Scan Testing and Visual/Physical Inspections, dated June 24, 2010 | 70108834, Change Current 6Y Replacement Scope of all Thirty Three SW Expansion Joint to | ||
ECP-14-000942-103-C-01, Fuel Transfer System | 2Y Evisive Scan Testing and Visual/Physical Inspections, dated June 24, 2010 | ||
Modification, Revision 0002 | ECP-14-000942-103-C-01, Fuel Transfer System Modification, Revision 0002 | ||
G1-MSPI-001, MSPI Basis Document, Revision 2 | G1-MSPI-001, MSPI Basis Document, Revision 2 | ||
PCAQ 92-035, Assessment of Block Wall Impact on Safety Related Service Water Piping during a Seismic Event | PCAQ 92-035, Assessment of Block Wall Impact on Safety Related Service Water Piping during | ||
RE-100, Preparation, Review, and Approval of Fuel Movement Sequence Sheets and Document Closeout, Revision 018 | a Seismic Event | ||
Drawings | RE-100, Preparation, Review, and Approval of Fuel Movement Sequence Sheets and | ||
-Line Diagram | Document Closeout, Revision 018 | ||
211630-B-9532 Sheet 1, No. 1 Unit No. 1A, 1B and 1C Vital Buses Safeguard Equipment Control System Schematic Controls, Revision 8 | Drawings | ||
201-0102, 120V AC Instrument Bus One-Line Diagram | |||
211630-B-9532 Sheet 1, No. 1 Unit No. 1A, 1B and 1C Vital Buses Safeguard Equipment | |||
Control System Schematic Controls, Revision 8 | |||
33013-1237, Auxiliary Feedwater, Revision 73 | 33013-1237, Auxiliary Feedwater, Revision 73 | ||
Operating Experience | Operating Experience | ||
2016-57-0152324 (EN 52324) | 2016-57-0152324 (EN 52324) - PART 21 - Potential Issue with Seismic Qualification of Type | ||
- PART 21 - Potential Issue with Seismic Qualification of Type 546ns Electro | 546ns Electro-Pneumatic Transducers (Emerson Fisher Controls, Intl. LLC) 11/28/16 | ||
-Pneumatic Transducers (Emerson Fisher Controls, Intl. LLC) 11/28/16 | 2016-44-0152216 (EN 52216) - PART 21 - Potential Failure of Battery System Connections | ||
2016-44-0152216 (EN 52216) | (ENERSYS) 9/2/16 | ||
2015-34-00, Related to Possible Cracking in KCR-13 Standby Battery Jars (C&D Technologies) | |||
2015-34-00 , Related to Possible Cracking in KCR | 6/8/15 | ||
-13 Standby Battery Jars (C&D Technologies) 6/8/15 | |||
2458739 02546188 02684864 02720218 04038690 | |||
ALCO-MI-11272C (Ginna VTD | 2470437 02605068 02685880 02723588 04040386 | ||
-A0152-4070) Engine Maintenance Schedule Nuclear Standby Engines, Rev. 3 | 2470437 02605068 02695299 02725362 04043070 | ||
2473775 02605068 02702977 03962433 04045306 | |||
2475400 02626369 02703851 03962443 04059150 | |||
2494125 02639792 02704389 03977602 04087519 | |||
2500256 02645234 02714782 03979499 04096294 | |||
2509756 02664538 02714782 04013155 | |||
2516978 02673403 02714782 04018594 | |||
Miscellaneous | |||
ALCO-MI-11272C (Ginna VTD-A0152-4070) Engine Maintenance Schedule Nuclear Standby | |||
Engines, Rev. 3 | |||
Auxiliary Feedwater System, Health Group Issues/Action Plan, presented March 7, 2018 | Auxiliary Feedwater System, Health Group Issues/Action Plan, presented March 7, 2018 | ||
Emergency Preparedness Advisory Committee Subcommittee for Excellence in Emergency Preparedness, meeting minutes, February 5, 2018, October 16, 2017, and August 14, 2017 | Emergency Preparedness Advisory Committee Subcommittee for Excellence in Emergency | ||
Exelon Generation Company, LLC, Quality Assurance Topical Report (QATR), NO | Preparedness, meeting minutes, February 5, 2018, October 16, 2017, and August 14, | ||
-AA-10, Revision 92 | 2017 | ||
GIN-16-0078, Ginna | Emergency Preparedness Command and Control Transition Project, Change Management | ||
Auxiliary Transformer Replacement Plan, dated December 5, 2017 | Plan, presented January 22, 2018 | ||
Ginna Maintenance Rule (a)(1) Action Plans dated between January 1, 2016, and February 1, 2018 MRC and SOC Agendas dated March 5 | Exelon Generation Company, LLC, Quality Assurance Topical Report (QATR), NO-AA-10, | ||
-8, and 19-22, 2018 NRC IMC Part 9900: Technical Guidance, Maintenance - Preconditioning of Structures, Systems and Components before Determining Operability | Revision 92 | ||
GIN-16-0078, Ginna Auxiliary Transformer Replacement Plan, dated December 5, 2017 | |||
Ginna Maintenance Rule (a)(1) Action Plans dated between January 1, 2016, and February 1, | |||
2018 | |||
MRC and SOC Agendas dated March 5-8, and 19-22, 2018 | |||
NRC IMC Part 9900: Technical Guidance, Maintenance - Preconditioning of Structures, | |||
Systems and Components before Determining Operability | |||
Ginna Surveillance Frequency Control Program (SFCP), Revision 7 | Ginna Surveillance Frequency Control Program (SFCP), Revision 7 | ||
Ginna Updated Final Safety Analysis Report | Ginna Updated Final Safety Analysis Report | ||
Ginna ECP Logs dated from January 1, 2015, through February 1, 2018 | Ginna ECP Logs dated from January 1, 2015, through February 1, 2018 | ||
Ginna Safety Culture Monitoring Panel Meeting Minutes dated from January 1, 2015, through February 1, 2018 | Ginna Safety Culture Monitoring Panel Meeting Minutes dated from January 1, 2015, through | ||
Transition North East Sites Command and Control Structure along with select Exelon Emergency Response Organization Checklist adoption, presented February 2, 2018 | February 1, 2018 | ||
Transition North East Sites Command and Control Structure along with select Exelon | |||
Emergency Response Organization Checklist adoption, presented February 2, 2018 | |||
TRM 3.9.1, Fuel Storage in Spent Fuel Pool (SFP), Rev. 43 | TRM 3.9.1, Fuel Storage in Spent Fuel Pool (SFP), Rev. 43 | ||
Updated Final Safety Analysis Report, Revision 27 | Updated Final Safety Analysis Report, Revision 27 | ||
VTD-D0245-4001, Worthington WT Multistage Centrifugal Pump, Revision 004 | VTD-D0245-4001, Worthington WT Multistage Centrifugal Pump, Revision 004 | ||
Westinghouse Technical Bulletin 15 | Westinghouse Technical Bulletin 15-01, Reactor Coolant System Temperature and Pressure | ||
-01, Reactor Coolant System Temperature and Pressure Limits for No. 2 Reactor Coolant Pump Seal | Limits for No. 2 Reactor Coolant Pump Seal | ||
}} | }} |
Latest revision as of 21:40, 18 December 2019
ML18137A043 | |
Person / Time | |
---|---|
Site: | Ginna ![]() |
Issue date: | 05/16/2018 |
From: | Michelle Catts Reactor Projects Branch 1 |
To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
References | |
IR 2018011 | |
Download: ML18137A043 (19) | |
Text
May 17, 2018
SUBJECT:
R.E. GINNA NUCLEAR POWER PLANT, LLC - NRC BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000244/2018011
Dear Mr. Hanson:
On March 22, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed on-site inspection activities at your R.E. Ginna Nuclear Power Plant, LLC (Ginna) and discussed the results of this inspection with Mr. William Carsky, Site Vice President, and other members of the Ginna staff. During that discussion your staff requested to provide additional information for consideration. In-office review of the additional information continued by the NRC, and a telephonic exit meeting was conducted on April 19, 2018, with Kyle Garnish, Ginna Regulatory Assurance Manager and other members of the Ginna staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety. The team identified two findings in the area of Corrective Action Program, Problem Identification.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews, the team found no evidence of challenges to your organizations safety-conscious work environment.
Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
NRC inspectors documented two findings of very low safety significance (Green) in this report.
Both of these findings involved violations of NRC requirements and are being treated as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy. If you contest the violations or significance, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspectors at Ginna. In addition, if you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region I, and the NRC Resident Inspectors at Ginna.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Part 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Michelle Catts, Acting Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Number: 50-244 License Number: DPR-18
Enclosure:
Inspection Report 05000244/2018011
Inspection Report
Docket Number: 50-244 License Number: DPR-18 Report Number: 05000244/2018011 Enterprise Identifier: I-2018-011-0028 Licensee: Exelon Generation Company, LLC (Exelon)
Facility: R.E. Ginna Nuclear Power Plant, LLC (Ginna)
Location: Ontario, New York Dates: March 5 to April 19, 2018 Inspectors: J. Hawkins, Senior Resident Inspector, Team Leader C. Lally, Reactor Inspector L. McKown, Resident Inspector S. Obadina, Project Engineer Observer(s): A. Rosebrook, Senior Project Engineer Approved By: M. Catts, Acting Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring Exelons performance at
Ginna by conducting the biennial problem identification and resolution inspection in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
Based on the samples selected for review, the inspection team concluded that Exelon was generally effective in identifying, evaluating, and resolving problems and that the Exelon effectively used operating experience and self-assessments. The inspectors found no evidence of significant challenges to Exelons safety conscious work environment at Ginna and concluded that the staff are willing to raise nuclear safety concerns through at least one of the several means available.
NRC identified and self-revealing findings and violations are summarized in the table below.
List of Findings and Violations Potential Preconditioning of Turbine Driven Auxiliary Feedwater Surveillance Testing Cornerstone Significance Cross-Cutting Report Aspect Section Reactor Safety - Green NCV None. 71152B Mitigating 05000244/2018011-01 Systems Closed The NRC identified a Green non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XI, Test Control, because Exelon established unevaluated preconditioning, with a reasonable doubt of whether the preconditioning was acceptable, prior to testing of the turbine driven auxiliary feedwater pump.
This results in the loss of as-found conditions which challenge the capability of the test to assure that the turbine driven auxiliary feedwater pump will perform satisfactorily in service.
Failure to Procedurally Verify Fuel Transfer Cart Results in Fuel Interference Event Cornerstone Significance Cross-Cutting Report Aspect Section Reactor Safety - Green NCV H.12 - HU - 71152B Barrier Integrity 05000244/2018011-02 Avoid Closed Complacency A self-revealing Green non-cited violation (NCV) of Technical Specification 5.4.1.a,
Procedures, was identified for the failure of Exelon to operate refueling equipment in accordance with technical procedures in April and May of 2017, which resulted in a fuel interference event, damage to the rod cluster control assembly, and the need for a detailed inspection of a fuel assembly.
INSPECTION SCOPES
This inspection was conducted using the appropriate portions of the inspection procedures (IPs)in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess Exelons performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
OTHER ACTIVITIES - BASELINE
71152 - Problem Identification and Resolution Biennial Team Inspection
The inspectors performed a biennial assessment of Exelons corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment. The assessment is documented below.
- (1) Corrective Action Program Effectiveness - The inspection team evaluated Exelons effectiveness in identification, prioritization and evaluation, and correcting problems, and verified the station complied with NRC regulations and Exelons standards for corrective action programs.
- (2) Operating Experience - The team evaluated Exelons effectiveness in its use of industry and NRC operating experience information and verified the station complied with Exelons standards for the use of operating experience.
- (3) Self-Assessments and Audits - The team evaluated the effectiveness of Exelons audits and self-assessments and verified the station complied with Exelons standards for the use of operating experience.
- (4) Safety Conscious Work Environment - The team reviewed Exelons programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs.
INSPECTION RESULTS
Evaluation of the Ginna PI&R Program 71152B The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined Exelon staffs performance in each of these areas adequately supported nuclear safety. The team identified two findings in the area of Corrective Action Program, Problem Identification, and identified some weaknesses in the implementation of the stations Maintenance Rule (MR) program.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that Exelons performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to Exelons safety-conscious work environment. Site employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
Potential Preconditioning of Turbine Driven Auxiliary Feedwater Surveillance Testing Cornerstone Significance Cross-Cutting Report Aspect Section Reactor Safety - Green NCV None.
71152B Mitigating 05000244/2018011-01 Systems Closed The NRC identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XI, Test Control,"
because Exelon established unevaluated preconditioning, with a reasonable doubt of whether the preconditioning was acceptable, prior to testing of the turbine driven auxiliary feedwater pump. This results in the loss of as-found conditions which challenge the capability of the test to assure that the turbine driven auxiliary feedwater pump will perform satisfactorily in service.
Description:
The inspectors observed implementation of licensee Procedure STP-O-16-COMP-T, Auxiliary Feedwater Turbine Pump - Comprehensive Test, on March 7, 2018.
During review of licensee Procedure STP-O-16-COMP-T and the quarterly test, Procedure STP-O-16QT, Auxiliary Feedwater Turbine Pump - Quarterly, the inspectors found that immediately prior to the cold pump start, Exelon altered, manipulated, and adjusted a number turbine driven auxiliary feedwater pump train components as directed by the surveillance procedures. These included flushing the condensate storage tank water aligned to the pump suction through the pump to a drain at the pump discharge for approximately 30 minutes, removing and cleaning the auxiliary feedwater pump lubricating oil cooling water (service water) strainer, validating the functionality of the lubricating oil cooling water (service water)strainer bypass valve and bypass valve controlling differential pressure pressure switch, stopping and starting the alternating current and direct current lubricating oil pumps, and verifying the low oil pressure trip functionality of the turbine trip and throttle valve which fully cycles the trip and throttle valve as well as the governor control valve under no load conditions. Consistent with NRC Inspection Manual Part 9900: Technical Guidance, Maintenance - Preconditioning of Structures, Systems and Components before Determining Operability, the inspectors identified these activities, executed immediately prior to cold pump start, as potential preconditioning and discussed the observations with Exelon staff.
Exelon established processes associated with the assessment of preconditioning under Procedures IP-IIT-2, Inservice Testing Program for Pumps and Valves, and CTP-IST-001, Corporate Technical Position - Preconditioning of Inservice Testing Program Components, which states in part, Preconditioning SHALL be avoided unless an evaluation has been performed to determine that the preconditioning is acceptable. The inspectors asked the licensee if a preconditioning evaluation for Procedures STP-Q-16-COMPT or STP-O-16QT was conducted.
After the pump run on March 7, Exelon chose to perform an evaluation of preconditioning acceptability for the flushing of the pump. The justification for acceptability of this preconditioning was protection of the steam generators from low quality water sitting within the pump. Exelon asserted that impact on the pump test results are negligible without providing the details of the potential as-found conditions masked, failure mechanisms against which the activity was evaluated, or why the lower quality water, which is always with the pump while in a standby lineup, is acceptable for event mitigation.
Exelon discovered a preconditioning evaluation had been performed for the cycling of the turbine trip mechanism on April 13, 2010. The inspectors determined this 2010 preconditioning evaluation was narrowly focused on governor control valve stem binding and did not address any other pump parameters or failure modes that could be masked due to cycling the low oil trip or the cycling of the trip mechanism prior to the surveillance test.
Since Exelon performed a technically inadequate preconditioning evaluation associated with low oil trip testing of the turbine trip function and Exelon had not performed preconditioning evaluations of the impact of flushing water through the pump, the lubricating oil cooling water (service water) activities, or stopping and starting of the lubricating oil pumps in advance of the surveillance as of the end of the inspection, the inspectors have concluded that the activities performed immediately prior to cold pump start during comprehensive and quarterly turbine driven auxiliary feedwater pump surveillance testing are examples of unevaluated preconditioning with a reasonable doubt of whether the preconditioning was acceptable, consistent with NRC Inspection Manual Part 9900 Technical Guidance and Exelon program guidance.
Corrective Actions: Exelon entered this concern into the corrective action program for prioritization, assessment, and resolution. This included a preconditioning evaluation of all of the identified issues. Exelon concluded there was no unacceptable preconditioning and that the operability of the turbine driven auxiliary feedwater system was not adversely affected.
The inspectors have no current operability concerns. This evaluation will be fully reviewed under the baseline inspection program.
Corrective Action Reference: Action requests (ARs) 4111709 and 04119043
Performance Assessment:
Performance Deficiency: The inspectors determined that Exelon did not adequately evaluate pre-test activities for the turbine driven auxiliary feedwater pump comprehensive and quarterly tests for preconditioning as discussed in NRC Inspection Manual Part 9900 Technical Guidance, and required by Ginnas Inservice Test Program guidance and Exelons corporate technical position on preconditioning; and failed to identify that those activities may have constituted unacceptable preconditioning. This performance deficiency was reasonably within the licensees ability to foresee and correct and should have been prevented.
Screening: This finding was more than minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated January 1, 2018, because the performance deficiency is associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. This is also similar to IMC 0612 Appendix E, Examples of Minor Issues, examples 3J and 3K. Specifically, preconditioning of components could mask the actual as-found conditions of the system resulting in an inability to verify operability of the system.
Significance: The inspectors assessed significance of this condition using IMC 0609, 4, Phase 1 - Initial Screening and Characterization of Findings worksheet, which directs the user to IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. In accordance with IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, Section A, Mitigating Systems, Structures or Components and Functionality, the finding screened to be of very low safety significance (Green), because the performance deficiency did not affect system design or qualification, did not result in a loss of safety function, and did not result in the turbine driven auxiliary feedwater train to be out of service for greater than its technical speciation allowed outage time.
Cross Cutting Aspect: No cross cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion XI, Test Control, states, in part, that a test program shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents.
Contrary to the above, from April 13, 2010 to present, Exelon did not establish an adequate test program, which assured that all testing required to demonstrate the turbine driven auxiliary feedwater system will perform satisfactorily in service, due to potential preconditioning.
Disposition: This violation is being treated as a NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Procedurally Verify Fuel Transfer Cart Results in Fuel Interference Event Cornerstone Significance Cross-Cutting Report Aspect Section Reactor Safety - Green NCV H.12 - HU - 71152B Barrier Integrity 05000244/2018011-02 Avoid Closed Complacency A self-revealing Green NCV of Technical Specification 5.4.1.a, Procedures, was identified for the failure of Exelon to operate refueling equipment in accordance with technical procedures in April and May of 2017, which resulted in a fuel interference event, damage to the rod cluster control assembly, and the need for a detailed inspection of a fuel assembly.
Description:
The inspectors identified two examples of failure to follow a required procedure.
Specifically, Exelon Procedures RF-200, Fuel Handling System Checkouts, and RF-302, Fuel Handling Tool Checkout and Operation in Containment, were not followed as discussed below.
- (1) In advance of the Spring 2017 refueling outage on April 20, 2017, Exelon implemented a modification to the fuel transfer system to improve fuel moves between containment and the spent fuel pool. This modification changed the alignment of the transfer cart rails, which resulted in a change to the match-mark locations where the encoder stops the fuel assembly.
The licensee failed to perform adequate post modification testing including verification of fuel transfer cart to rail alignment at these match-marked locations in accordance with Steps 6.2.4.16 and 6.2.4.20 of licensee Procedure RF-200.
- (2) During the Spring 2017 refueling outage, Exelon performed a complete core offload of all 121 fuel assemblies using the modified fuel transfer system in accordance with Procedure RF-302, Attachment 3, Fuel Transfer System Operating Instructions. The licensee did not perform Step 4.6.4 of Procedure RF-302, Attachment 3, which required the operators to verify pointer and target match-marks to confirm fuel transfer cart to rail alignment on the spent fuel pool side. During core reload on May 4, 2017, upon sending the fifth fuel assembly, which was a new fuel assembly, from the spent fuel pool to the reactor side, the fuel transfer system operator confirmed location of the fuel assembly using the encoder position as provided by a lit indication instead of the pointer and target match-marks as required by Step 4.5.4 of Procedure RF-302, Attachment 3. When the fuel transport system operator up-ended the fuel assembly on the reactor side, the rod cluster control assembly installed with the fuel assembly struck the fuel transport tube. The fuel assembly and rod cluster control assembly were immediately sent back to the spent fuel pool for evaluation of potential damage.
Exelon found the affected rod cluster control assembly to be damaged and was removed from service. The licensee performed a detailed inspection of the associated fuel assembly and determined the fuel cladding remained operable. The NRC inspectors reviewed Exelons apparent cause evaluation for this issue and determined that while applicable sections of Procedures RF-200 and RF-302 were documented as completed, fuel handlers did not use cart alignment match-marks to verify fuel assembly position. They had instead relied upon the encoder position of the cart as provided by a lit indication.
Corrective Actions: Exelon revised Procedures RF-200 and RF-302 requiring verification of match-marks via remote visual observation (e.g., camera), including staff signatures for all steps that verify cart fuel and target match-marks, and added a caution identifying the lit encoder position indication as not a valid indication of cart position.
Corrective Action Reference: AR 04006765
Performance Assessment:
Performance Deficiency: Inspectors found that Exelon did not operate refueling equipment in accordance with l Procedures, RF-200 and RF-302, during pre-outage activities, core offload, and core reload in April and May of 2017, which resulted in a fuel interference event, damage to the rod cluster control assembly, and the need for a detailed inspection of a fuel assembly.
This performance deficiency was reasonably within the licensees ability to foresee and correct and should have been prevented.
Screening: This finding was more than minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated January 1, 2018, because if left uncorrected, the performance deficiency would have the potential to lead to a more significant safety concern. Specifically, the repetitive failure to perform the procedurally required fuel transfer cart position verifications, which resulted in the interference event, the actual damage sustained by the rod cluster control assembly, and the need for a detailed inspection of the fuel assembly, if left uncorrected, would have the potential to result in actual damage to a spent fuel assembly which could challenge the ability of the fuel cladding to remain intact.
Significance: The inspectors assessed significance of this condition using IMC 0609, 4, Phase 1 - Initial Screening and Characterization of Findings worksheet, which directs the user to IMC 0609 Appendix G, Shutdown Operations Significance Determination Process. However, criteria for evaluating fuel handling issues are only contained in IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Since no criteria exist to evaluate this issue in IMC, Appendix G, the inspectors used the most applicable screening criteria available to make a bounding case and characterize this finding as allowed by IMC 0609, Appendix M, Significance Determination Process Using Qualitative Criteria. The inspectors assessed significance of this fuel handling event in accordance with IMC 0609, Appendix A, Exhibit 3, Barrier Integrity Screening Questions, Section D, Spent Fuel Pool. The finding was determined to be of very low safety significance (Green), because the performance deficiency did not affect fuel pool temperature or level, did not affect neutron absorber capability or result in a fuel bundle being misplaced, and although the performance deficiency resulted in fuel handling errors, it did not cause mechanical damage to fuel clad and a detectible release of radionuclides.
Cross Cutting Aspect: This finding in accordance with IMC 0310, Aspects within the Cross-Cutting Areas, dated December 04, 2014, has a cross-cutting aspect in the area of Human Performance associated with Avoid Complacency, in that Exelon fuel transfer system operators did not recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Specifically, operators failed to recognize the latent issues associated with misalignment of the fuel transfer cart and the inherent risk incurred by the inappropriate cart position verification method used, and did not complete the appropriate procedure step a number of times prior to the interference event occurring. (H.12)
Enforcement:
Violation: Technical Specification 5.4.1.a, Procedures, states in part, Written procedures shall be established, implemented, and maintained covering the following activities: The applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Revision 2, Appendix A, Section 2.k, identifies Refueling Equipment Operation, as a recommended procedure. Exelon Procedures RF-200, Fuel Handling System Checkouts, and RF-302, Fuel Handling Tool Checkout and Operation in Containment, implement this requirement.
Contrary to the above, from April 20, 2017 to May 4, 2017, Exelon staff did not properly implement written procedures RF-200 and RF-302, which resulted in a fuel interference event on May 4, 2017, damage to the rod cluster control assembly, and the need for a detailed inspection of a fuel assembly.
Disposition: This violation is being treated as a NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Observations and Minor Violations/Performance Deficiencies 71152B Corrective Action Program: The team concluded that Exelons corrective action program was generally effective. However, some observations were noted; particularly, a number of issues in the MR program. Specifically, 1. The inspectors reviewed maintenance preventable functional failures (MPFFs) that occurred on the service air system since 2016. The inspectors noted that diesel driven service air compressor failures on January 12 and December 27, 2017, were documented by Ginna to be the result of vendor guidance not being used correctly in the development of online monitoring of equipment. Based on Ginnas documentation, the inspectors determined that Ginnas basis for the December 2017 failure not being a repetitive MPFF was not adequately justified. Ginna presented the inspectors additional analysis and evaluation of the failure from December 2017, that had not been documented originally, which showed that the maintenance related cause was different than the cause of the failure in January 2017. Therefore, the issue was not a repetitive MPFF and did not constitute a violation of 10 CFR 50.65 (a)(2). Exelon documented the inspectors observation concerning adequate documentation of MPFF causes in AR 04122176. This observation is related to the assessment of the Corrective Action Program Area of Problem Evaluation.
2. The inspectors reviewed 22 maintenance rule functional failures (MRFFs) that occurred over the last two years, 13 of which were determined to be not maintenance preventable, 9 MPFFs, and zero were repetitive MPFFs. The inspectors determined that three of the 13 issues that Exelon determined were not MPFFs, were maintenance preventable (ARs 02625128, 02630466, and 02633768). The inspectors also noted inconsistencies regarding Exelons documented basis for why MPFFs were or were not determined to be repeat MPFFs. The inspectors determined that all of these MR issues represented performance deficiencies because Exelon was not following their MR performance monitoring Procedure, ER-AA-310-1004. Exelon documented the issue in ARs 04117878 and 04118265. The inspectors determined that these issues do not constitute a violation of 10 CFR 50.65 (a)(2) per the guidance in the NRC Enforcement Manual because the additional MPFFs did not cause any of Exelons MR systems to exceed their performance criteria and the performance deficiency was minor because the issues did not represent a significant programmatic deficiency within the MR program This observation is related to the assessment of the Corrective Action Program Area of Problem Evaluation.
3. The inspectors reviewed two failures of the B containment hydrogen monitor (ARs 02630466 and 02633768) that occurred in February 2016. The failures were the result of failed 480 VAC current voltage transformers that had internal non-electrolytic capacitors fail due to age. Exelons evaluation of the failures determined that their procurement procedure for the tracking of component shelf-life, PES-S-002, had not been revised to include updated industry guidance that would ensure the appropriate shelf-life of safety-related and augmented quality components are appropriately tracked. The inspectors determined that Exelons corrective action to revise the procedure had not been completed yet and had been extended multiple times leaving the program vulnerable to the same failure mode. The inspectors also determined that no extent of condition had been performed on other components tracked by the shelf-life program. This performance deficiency is of minor risk significance because the aged components either were not yet installed in the plant, failures were identified during post maintenance testing, and the equipment failures did not impact the Barrier Integrity cornerstone objective. Exelon documented these issues in ARs 02657276 and 02657285. This observation is related to the assessment of the Corrective Action Program Area of Problem Evaluation.
4. The inspectors reviewed corrective actions associated with NCV 05000244/2015002-02, Inadequate Procedure Implementation Results in Inadvertent Entry into 72-Hour Technical Specification Action Statement. Exelons evaluation of the event determined that improper tool usage, while lifting leads to support a power supply replacement, caused the inverter swap. Exelons corrective actions included revising Procedure M-71.4, Removal and/or Installation of Modules Within Defeated or Out of Service Instrument Loops, to provide clear direction that only nonconductive tools should be used to perform the activity. The inspectors determined that the 2015 procedure included the caution, however subsequent versions did not include this caution, and that there were no procedure change request forms that accounted for the revisions not including the caution. The inspectors reviewed this issue using IMC 0612, Appendix B, Issue Screening, and determined this issue was a minor violation of Technical Specification 5.4.1.a, Procedures, because the issue was administrative in nature, workers had knowledge of the precaution due to previously completed corrective actions, and the issue had not repeated. Exelon documented the issue in AR 04114953. This observation is related to the assessment of the Corrective Action Program Area of Timely and Effective Corrective Actions.
Observation and Minor Performance Deficiency 71152B Operating Experience: The team identified some issues in Exelons incorporation of lessons learned from industry and NRC operating experience into station programs, processes, and procedures. This observation also supports the assessment of the MR.
The inspectors reviewed two equipment failures in the service air system (ARs 02639792 and 03962433) both of which had similar industry operating experience that were determined to have not been reviewed by Exelon prior to each failure. Exelon documented the issue in the ARs noted above. For these failures, Exelon identified that valid operating experience had not been evaluated; however, the failures were appropriately classified as MRFFs when this fact was identified. The failures did not result in a loss of system or train function. Therefore this does not constitute a violation of NRC requirements and the performance deficiency is minor.
Observation 71152B Self-Assessments and Audits: The team identified some issues in Exelons use of audits and self-assessments. These issues support the observation of weakness in the MR program.
1. Maintenance Rule Program Focused Area Self-Assessment (FASA) dated June 30, 2016 (FASA 02565710) - The inspectors noted that the FASA did not meet Objective #3 of the self-assessment, to review equipment failures of two MR systems since the last FASA, specifically only one system was reviewed. Exelon documented the issue in AR 04117874.
2. Nuclear Oversight (NOS) Corrective Action Program Audit dated March 29, 2017 (AR 3977544) - The inspectors noted the audit did not include a review of the MR program and that the audits corrective actions did not address that three of eight operating experience reviews contained errors related to accurate documentation.
Exelon documented the issue in AR 04117882.
Observation 71152B Safety Conscious Work Environment: The team found no evidence of challenges to Exelons organizations safety-conscious work environment. Site employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
Observation 71152B Review of Corrective Actions Related to Greater-than-Green Findings That Were Not Completed by the End of the Associated Supplemental Inspection: The team reviewed the corrective actions, open at the time of completion of the documented IP 95001 Supplemental Inspection (ML16333A024), dated November 28, 2016, associated with a White NOV in the Emergency Preparedness Cornerstone. The team verified these corrective actions had been completed as scheduled. The team did not identify any new performance deficiencies and did not document any additional observations.
EXIT MEETINGS AND DEBRIEFS
On March 22, 2018, the inspectors presented the biennial problem identification and resolution initial inspection results to Mr. William Carsky, Site Vice President, and other members of the Ginna staff. During that discussion your staff requested to provide additional information for consideration. In-office review of the additional information continued by the NRC, and a telephonic exit meeting was conducted on April 19, 2018 with Kyle Garnish, Ginna Regulatory Assurance Manager and other members of the Ginna staff. Inspectors verified no proprietary information was retained or documented in this report.
THIRD PARTY REVIEWS Inspectors reviewed Institute on Nuclear Power Reactor reports that were issued during the inspection period.
DOCUMENTS REVIEWED
71152B
Procedures
CC-AA-211, Fire Protection Program, Revision 8
CC-AA-501-1008, Exelon Nuclear Welding Program Welding General Requirements
CTP-IST-001, Corporate Technical Position - Preconditioning of IST Program Components,
Revision 1
EI-AA-1, Safety Conscious Work Environment, Revision 4
EI-AA-101, Employee Concerns Program, Revision 11
EI-AA-101-1000, Employee Concerns Program Process, Revision 15
EP-AA-112-400, Emergency Operations Facility Activation and Operation, Revision 13
EP-CE-111, Emergency Classification and Protective Action Recommendations, Revision 4
EP-CE-111-F-03, Ginna Protective Action Recommendation Flowchart, Revision B
EP-CE-114-100, Emergency Notifications, Revision 6
EPG-EPAC, Emergency Preparedness Advisory Committee Subcommittee for Excellence in
Emergency Preparedness Guideline, Revision 00000
EPJA-0, Ginna Station Event Evaluation and Classification, Revision 2
ER-AA-310, Implementation of the Maintenance Rule, Revision 11
ER-AA-310-1004, Maintenance Rule - Performance Monitoring, Revision 14
ER-AA-310-1005, Maintenance Rule - Dispositioning Between (a)(1) and (a)(2), Revision 7
ER-AA-310-1006, Maintenance Rule-Expert Panel Roles and Responsibilities, Rev. 7
ER-AA-310-1007, Maintenance Rule - Periodic (a)(3) Assessment, Revision 5
ER-INST.3, Instrument Bus Power Restoration, Revision 01200
GMM-24-02-ISFSI01A, ISFSI Operations using Areva equipment
GMM-24-02-ISFSI15, ISFSI abnormal events and recovery actions
HU-AA-104-101, Procedure Use and Adherence, Revision 5
IP-IIT-2, Inservice Testing Program for Pumps and Valves, Revision 016
M-71.4, Removal and/or installation of modules within defeated or out of service instrument
loops, Revision 02501, 02600, 02700
MA-AA-716-003, Tool Pouch / Minor Maintenance, Revision 10
MA-AA-716-004, Conduct of Troubleshooting, Revision 15
MA-AA-716-234, FIN Team Process, Revision 12
NO-AA-21, Nuclear Oversight Audit Process Descriptions, Revision 9
OP-AA-108-115, Operability Determinations, Revision 20
OP-AA-108-115-1002, Supplemental Consideration for on-shift Immediate Operability
Determination, Revision 3
OP-AA-112-101, Shift Turnover and Relief, Rev 13
OU-AA-630-1000 R007, Spent Fuel Loading Campaign Management
PES-S-002, Shelf Life, Revision 8
PI-AA-1012, Safety Culture Monitoring, Revision 1
PI-AA-115, Operating Experience Program, Revision 2
PI-AA-115-1001, Processing of Level 1 OPEX Evaluations, Revision 2
PI-AA-115-1002, Processing of Level 2 OPEX Evaluations, Revision 3
PI-AA-115-1003, Processing of Level 3 OPEX Evaluations, Revision 3
PI-AA-120, Issue Identification and Screening Process, Revision 8
PI-AA-125, Corrective Action Program (CAP) Procedure, Revision 6
PI-AA-125-0004, Effectiveness Review Manual, Revision 2
PI-AA-125-001-F-01, CAPCO Indoctrination Guide, Revision 1
PI-AA-125-1001, Root Cause Analysis Manual, Revision 3
PI-AA-125-1003, Corrective Action Program Evaluation Manual, Revision 4
PI-AA-125-1006, Investigation Techniques Manual, Revision 3
PI-AA-126, Self-Assessment and Benchmark Program, Revision 2
PI-AA-126-1001, Self-Assessments, Revision 2
PI-AA-126-1006, Benchmark Program, Revision 2
PI-AA-127, Passport Action Tracking Management Procedure, Revision 2
RE-100, Preparation, Review, and Approval of Fuel Movement Sequence Sheets and
Document Closeout, Rev. 3
RF-200, Fuel Handling System Checkouts (Dry and Wet), Revision 015
RF-302, Fuel Handling Tool Checkout and Operation in Containment, Revision 011
RF-602, Irradiated Fuel Assembly Visual Inspection, Revision 00200
S-16.2, Nitrogen Make-up to the SI Accumulators, Revision 034
SA-AA-129-2118, Management and Control of Temporary Power, Revision 9
SM-AA-3019, Parts Quality Initiative (PQI), Revision 6
SM-AA-4003, Supply Critical Spare Guideline, Revision 10
STP-O-16-COMP-T, Auxiliary Feedwater Turbine Pump - Comprehensive Test, Revision 024
STP-O-16QT, Auxiliary Feedwater Turbine Pump - Quarterly, Revision 013
STP-O-36-COMP-C, Standby Auxiliary Feedwater Pump C - Comprehensive Test, Revision 18
STP-O-36-COMP-D, Standby Auxiliary Feedwater Pump D - Comprehensive Test, Revision 16
STP-O-R-19(-20), Diesel Generator A(B) - Auto-Start Undervoltage Logic Test, Revision 2
STP-O-R-2.1A, Safety Injection Functional Test Alignment/Realignment, Revision 9
STP-O-R-2.2-TR-A, Diesel Generator Load and Safeguard Sequence Test - Train A, Revision 0
STP-O-R-2.2-TR-B, Diesel Generator Load and Safeguard Sequence Test - Train B, Revision 1
STP-O-R-2.3A, Diesel Generator A Trip Testing, Revision 5
STP-O-R-22, Feedwater Pump DC Oil Pump Time Delay Relay Test, Revision 2
STP-O-R-27, A & B Hydrogen Recombiner Testing, Revision 2
WC-AA-101, On-line Work Control Process, Revision 27
WC-AA-101-1005, Work Scheduling and Grading, Revision 3
WC-AA-106, Work Screening and Processing, Revision 17
Condition Reports (*initiated in response to inspection)
04114953* 04117882* 02405851 02492151 02535825
04114953* 04118265* 02409910 02494125 02535895
04111374* 04119043* 02424722 02494412 02535900
04111322* 01701238 02429230 02500256 02535909
04111374* 01701311 02434592 02502343 02544137
04111669* 01933869 02502359 02546188
2434979
04111709* 01938885 02506563
04112168* 02439937 02573642
01948599 02509756
04112392* 02449963 02574211
01950285 02512443
04112598* 02458481 02575341
01956230 02514628
04112750* 02458739 02577596
01961032 02514655
04112800* 01962316 02465416 02577698
2514772
04112812* 02470437 02516547 02580574
01962318
04116888* 02471785 02582826
01963575 02516554
04110783* 02473775 02585574
04117873* 02132702 02516978
2178745 02475400 02523193 02592360
04117874*
2397449 02476668 02528317 02601330
04117878*
2399951 02483272 02530555 02609057
04117880*
2609137 02665316 02713354 03965439 04029514
2610810 02665838 02714782 03966140 04034008
2612275 02666602 02715246 03970849 04035608
2615048 02666793 02715731 03970993 04045306
2617579 02666866 02716996 03972024 04049372
2618563 02669156 02724064 03973119 04050245
2619403 02669354 02730010 03973323 04050403
2620316 02670975 02730711 03973710 04057555
2620792 02671948 02732752 03975046 04059218
2620843 02673198 02735369 03977182 04063272
2625128 02674062 02735697 03980222 04064822
2626369 02674062 02735709 03982757 04065573
2628278 02679127 02735815 03985259 04065575
2629046 02680604 02736095 03988081 04070378
2630625 02681417 02736152 03988754 04070436
2630722 02682945 02736383 03994820 04074362
2631153 02683617 02736488 03996769 04074792
2633355 02684098 02736494 03997830 04074828
2633728 02684215 02736495 03998922 04074961
2634523 02684662 02736543 03999507 04075248
2634583 02684850 02736798 03999538 04075866
2634645 02685880 02737109 04001424 04077758
2635546 02693831 02737173 04002200 04078493
2636117 02695299 02737475 04004545 04084880
2636164 02695445 02738390 04005936 04084950
2638320 02695917 02739509 04005948 04086960
2639723 02695937 02741463 04006292 04087519
2639792 02696733 02742213 04006765 04087990
2640633 02696981 02742444 04007556 04091114
2640712 02698012 02769127 04007570 04091598
2640720 02698549 03943647 04009546 04092244
2641476 02702341 03949351 04009869 04092597
2646017 02702383 04009990 04092735
03950704
2646791 04010037 04093825
2702771 03952606
2648547 03954743 04010823 04094539
2703675
2649359 03960291 04011557 04096206
2706311 04096294
2655409 03961753 04011603
2657276 02707246 04014045 04097001
2707249 03962433
2657285 04020146 04097005
03963060
2659732 02709964 04020622 04097015
2710347 03963193
2661766 04021265 04097056
03964222
2664538 02711117 04022430 04097393
2711794 03964471
2664640 04028605 04111709
2712688 03965151
2665131 04029298
2009-003680
2009-002332
2011-000411
Self-Assessment and Audits
Maintenance Rule Program Focused Area Self-Assessment dated June 30, 2016
Nuclear Oversight (NOS) Corrective Action Program Audit dated March 29, 2017
QA-NOSA-GIN-17-03 GINNA EMERGENCY PREPAREDNESS AUDIT REPORT, PLAN AND
TECHNICAL SPECIALIST ORIENTATION GUIDE dated 4/12/17
QA-NOSA-GIN-16-03 EMERGENCY PREPAREDNESS AUDIT REPORT AND PLAN dated
4/28/16
Maintenance Rule (a)(3) Periodic Maintenance Effectiveness Assessment, November 7, 2015 -
May 14, 2017
PI&R FASA dated December 29, 2017
2016 Self-Assessment: Pre-NRC 95001 Inspection (EAL Basis)
26359732-23, Effectiveness Revie for Root Cause Evaluation 02659732, EAL Classification
Inaccuracy
277135, Operability Evaluation Focused Area Self-Assessment, dated May 16, 2010
2434592 02434979 02458481 02575250 02575290 02582826
2583237 02592360 03974705 04031441
Maintenance Orders/Work Orders
C20805095 C20805095 C90640029 C92925824 C92925829 C92939169
C93051676 C93641214 C93765443
Calculations
201-0102, 120V AC Instrument Bus One-Line Diagram
ES-4.003, 125 Volt DC Short Circuit and System Voltage Drop Calculation, Revision 10
Engineering Changes / Evaluations
70108834, Change Current 6Y Replacement Scope of all Thirty Three SW Expansion Joint to
2Y Evisive Scan Testing and Visual/Physical Inspections, dated June 24, 2010
ECP-14-000942-103-C-01, Fuel Transfer System Modification, Revision 0002
G1-MSPI-001, MSPI Basis Document, Revision 2
PCAQ 92-035, Assessment of Block Wall Impact on Safety Related Service Water Piping during
a Seismic Event
RE-100, Preparation, Review, and Approval of Fuel Movement Sequence Sheets and
Document Closeout, Revision 018
Drawings
201-0102, 120V AC Instrument Bus One-Line Diagram
211630-B-9532 Sheet 1, No. 1 Unit No. 1A, 1B and 1C Vital Buses Safeguard Equipment
Control System Schematic Controls, Revision 8
33013-1237, Auxiliary Feedwater, Revision 73
Operating Experience
2016-57-0152324 (EN 52324) - PART 21 - Potential Issue with Seismic Qualification of Type
546ns Electro-Pneumatic Transducers (Emerson Fisher Controls, Intl. LLC) 11/28/16
2016-44-0152216 (EN 52216) - PART 21 - Potential Failure of Battery System Connections
(ENERSYS) 9/2/16
2015-34-00, Related to Possible Cracking in KCR-13 Standby Battery Jars (C&D Technologies)
6/8/15
2458739 02546188 02684864 02720218 04038690
2470437 02605068 02685880 02723588 04040386
2470437 02605068 02695299 02725362 04043070
2473775 02605068 02702977 03962433 04045306
2475400 02626369 02703851 03962443 04059150
2494125 02639792 02704389 03977602 04087519
2500256 02645234 02714782 03979499 04096294
2509756 02664538 02714782 04013155
2516978 02673403 02714782 04018594
Miscellaneous
ALCO-MI-11272C (Ginna VTD-A0152-4070) Engine Maintenance Schedule Nuclear Standby
Engines, Rev. 3
Auxiliary Feedwater System, Health Group Issues/Action Plan, presented March 7, 2018
Emergency Preparedness Advisory Committee Subcommittee for Excellence in Emergency
Preparedness, meeting minutes, February 5, 2018, October 16, 2017, and August 14,
2017
Emergency Preparedness Command and Control Transition Project, Change Management
Plan, presented January 22, 2018
Exelon Generation Company, LLC, Quality Assurance Topical Report (QATR), NO-AA-10,
Revision 92
GIN-16-0078, Ginna Auxiliary Transformer Replacement Plan, dated December 5, 2017
Ginna Maintenance Rule (a)(1) Action Plans dated between January 1, 2016, and February 1,
2018
MRC and SOC Agendas dated March 5-8, and 19-22, 2018
NRC IMC Part 9900: Technical Guidance, Maintenance - Preconditioning of Structures,
Systems and Components before Determining Operability
Ginna Surveillance Frequency Control Program (SFCP), Revision 7
Ginna Updated Final Safety Analysis Report
Ginna ECP Logs dated from January 1, 2015, through February 1, 2018
Ginna Safety Culture Monitoring Panel Meeting Minutes dated from January 1, 2015, through
February 1, 2018
Transition North East Sites Command and Control Structure along with select Exelon
Emergency Response Organization Checklist adoption, presented February 2, 2018
TRM 3.9.1, Fuel Storage in Spent Fuel Pool (SFP), Rev. 43
Updated Final Safety Analysis Report, Revision 27
VTD-D0245-4001, Worthington WT Multistage Centrifugal Pump, Revision 004
Westinghouse Technical Bulletin 15-01, Reactor Coolant System Temperature and Pressure
Limits for No. 2 Reactor Coolant Pump Seal