IR 05000244/2018011

R.E. Ginna Nuclear Power Plant, LLC - NRC Biennial Problem Identification and Resolution Inspection Report 05000244/2018011

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

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BOULEVARD, SUITE 100 KING OF PRUSSIA, PA 19406

-2713 May 17, 2018 Mr. Bryan C. Hanson Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 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 staf During that discussion your staff requested to provide additional information for consideratio 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 repor The NRC inspection team reviewed the station's corrective action program and the station's 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 program Based on the samples reviewed, the team determined that your staff's performance in each of these areas adequately supported nuclear safet The team identified two findings in the area of Corrective Action Program, Problem Identification

. The team also evaluated the station's processes for use of industry and NRC operating experience information and the effectiveness of the station's audits and self

-assessment Based on the samples reviewed, the team determined that your staff's performance in each of these areas adequately supported nuclear safet Finally the team reviewed the station's programs to establish and maintain a safety

-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these program Based on the team's observations and the results of these interviews

, the team found no evidence of challenges to your organization's safety

-conscious work environmen Your employees appeared willing to raise nuclear safety concerns through at least one of the several means availabl NRC inspectors documented two finding s of very low safety significance (Green)

in this repor Both of these findings involved violations of NRC requirements and are being treated as non-cited violation s (NCV s) consistent with Section 2.3.2.a of the Enforcement Polic If you contest the violation s or significance, you should provide a response within 30 days of the date B. Hanson 2 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 Ginn 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 Ginn 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 cc w/encl:

Distribution via ListServ

ML18137A043 SUNSI Review Non-Sensitive Sensitive Publicly Available Non-Publicly Available OFFICE RI/DRP RI/DRP RI/DRP RI/DRP NAME JHawkins/telecon ARosebrook MFerdas/email MCatts DATE 5/3/18 5/7/18 5/14/18 5/16/18 1 Enclosure U.S. NUCLEAR REGULATORY COMMISSION

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

2

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring

Exelon's 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 NRC's 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 Exelon's 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 Aspect Report Section Reactor Safety- Mitigating Systems Green NCV 05000244/2018011

-01 Closed None. 71152B 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 Exel on 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 Aspect Report Section Reactor Safety- Barrier Integrity Green NCV 05000244/2018011

-02 Closed H.12 - HU - Avoid Complacency 71152B 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 as sembly.

3

INSPECTION SCOPE

S This inspection w as 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 Exelon's 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 (1 Sample)

The inspectors performed a biennial assessment of Exelon's 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 evaluate d Exelon's effectiveness in identification , prioritization and evaluation, and correcting problems, and verified the station complied with NRC regulations and Exelon's standards for corrective action programs.

(2) Operating Experience

- The team evaluated Exelon's effectiveness in its use of industry and NRC operating experience information and verified the station complied with Exelon's standards for the use of operating experience.

(3) Self-Assessments and Audits

- The team evaluated the effectiveness of Exelon's audits and self-assessments and verified the station complied with Exelon's standards for the use of operating experience.

(4) Safety Conscious Work Environment

- The team reviewed Exelon's 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 71152 B The NRC inspection team reviewed the station's corrective action program and the station's 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 staff's 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 station's Maintenance Rule (MR) program.

The team also evaluated the station's processes for use of industry and NRC operating experience information and the effectiveness of the station's audits and self

-assessments. Based on the samples reviewed, the team determined that Exelon's performance in each of these areas adequately supported nuclear safety.

Finally , the team reviewed the station's programs to establish and maintain a safety

-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the team's observations and the results of these interview s the team found no evidence of challenges to Exelon's 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 Aspect Report Section Reactor Safety

- Mitigating Systems Green NCV 05000244/2018011

-0 1 Closed None. 71152B 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 perform ed preconditioning evaluation s 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 request s (A R s) 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 test s for preconditioning as discussed in NRC Inspection Manual Part 9900 Technical Guidance, and required by Ginna's Inservice Test Program guidance and Exelon's corporate technical position on preconditioning; and failed to identify that those activities may have constituted unacceptable preconditioning. This performance deficiency was reasonably within the licensee's 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 affect s 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, Attachment 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 Aspect Report Section Reactor Safety

- Barrier Integrity Green NCV 05000244/2018011

-0 2 Closed H.12 - HU - Avoid Complacency 71152B 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. Specif ically , 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 Procedur e 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 Exelon's 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 add ed 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 licensee's 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 verification s, 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, Attachment 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 misplace d, and although the performance deficiency result ed 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.

Observation s and Minor Violations/Performance Deficiencies 71152 B Corrective Action Program: The team concluded that Exelon's 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 (MPFF s) 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 Ginna's documentation, the inspectors determined that Ginna's 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 inspector's 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 MP FFs, 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 Exelon's documented basis for why MPFFs wer e 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 Exelon's 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. Exelon's 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 Exelon's 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 AR s 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.

" Exelon's evaluation of the event determined that improper tool usage

, while lifting leads to support a power supply replacement

, caused the inverter swap. Exelon's corrective actions included revising P rocedure 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 Acti on Program Area of Timely and Effective Corrective Actions

.

Observation and Minor Performance Deficiency 71152 B Operating Experience:

The team identified some issues in Exelon's 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 71152 B Self-Assessments and Audits:

The team identified some issues in Exelon's 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 (F ASA 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 (N OS) 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 audit's 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 71152 B Safety Conscious Work Environment:

The team found no evidence of challenges to Exelon's organization's safety

-conscious work environment. Site employees appeared willing to raise nuclear safety concerns through at least one of the several means available

. Observation 71152 B 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 MEETING S 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

711 52 B 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

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-12 5-1003, Corrective Action Program Evaluation Manual, Revision 4

PI-A A-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), Revisio

n 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)

- Aut o-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* 04114953* 04111374* 04111322* 04111374* 04111669* 04111709* 04112168* 04112392* 04112598* 04112750* 04112800* 04112812* 04116888* 04110783* 04117873* 04117874* 04117878* 04117880* 04117882* 04118265* 04119043* 01701238 01701311 01933869 01938885 01948599 01950285 01956230 01961032 01962316 01962318 01963575 02132702 02178745 02397449 02399951 02405851 02409910 02424722 02429230 02434592 02434979 02439937 02449963 02458481 02458739 02465416 02470437 02471785 02473775 02475400 02476668 02483272 02492151 02494125 02494412 02500256 02502343 02502359 02506563 02509756 02512443 02514628 02514655 02514772 02516547 02516554 02516978 02523193 02528317 02530555 02535825 02535895 02535900 02535909 02544137 02546188 02573642 02574211 02575341 02577596 02577698 02580574 02582826 02585574 02592360 02601330 02609057

02609137 02610810 02612275 02615048 02617579 02618563 02619403 02620316 02620792 02620843 02625128 02626369 02628278 02629046 02630625 02630722 02631153 02633355 02633728 02634523 02634583 02634645 02635546 02636117 02636164 02638320 02639723 02639792 02640633 02640712 02640720 02641476 02646017 02646791 02648547 02649359 02655409 02657276 02657285 02659732 02661766 02664538 02664640 02665131 02665316 02665838 02666602 02666793 02666866 02669156 02669354 02670975 02671948 02673198 02674062 02674062 02679127 02680604 02681417 02682945 02683617 02684098 02684215 02684662 02684850 02685880 02693831 02695299 02695445 02695917 02695937 02696733 02696981 02698012 02698549 02702341 02702383 02702771 02703675 02706311 02707246 02707249 02709964 02710347 02711117 02711794 02712688 02713354 02714782 02715246 02715731 02716996 02724064 02730010 02730711 02732752 02735369 02735697 02735709 02735815 02736095 02736152 02736383 02736488 02736494 02736495 02736543 02736798 02737109 02737173 02737475 02738390 02739509 02741463 02742213 02742444 02769127 03943647 03949351 03950704 03952606 03954743 03960291 03961753 03962433 03963060 03963193 03964222 03964471 03965151 03965439 03966140 03970849 03970993 03972024 03973119 03973323 03973710 03975046 03977182 03980222 03982757 03985259 03988081 03988754 03994820 03996769 03997830 03998922 03999507 03999538 04001424 04002200 04004545 04005936 04005948 04006292 04006765 04007556 04007570 04009546 04009869 04009990 04010037 04010823 04011557 04011603 04014045 04020146 04020622 04021265 04022430 04028605 04029298 04029514 04034008 04035608 04045306 04049372 04050245 04050403 04057555 04059218 04063272 04064822 04065573 04065575 04070378 04070436 04074362 04074792 04074828 04074961 04075248 04075866 04077758 04078493 04084880 04084950 04086960 04087519 04087990 04091114 04091598 04092244 04092597 04092735 04093825 04094539 04096206 04096294 04097001 04097005 04097015 04097056 04097393 04111709 2009-003680 2009-002332 2011-000411

Enclosure 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 02583237 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 03201-0102, 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

02458739 02470437 02470437 02473775 02475400 02494125 02500256 02509756 02516978 02546188 02605068 02605068 02605068 02626369 02639792 02645234 02664538 02673403 02684864 02685880 02695299 02702977 02703851 02704389 02714782 02714782 02714782 02720218 02723588 02725362 03962433 03962443 03977602 03979499 04013155 04018594 04038690 04040386 04043070 04045306 04059150 04087519 04096294 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