IR 05000244/2018003

Integrated Inspection Report 05000244/2018003

ML18306A472
Person / Time
Site:	Ginna
Issue date:	11/02/2018
From:	Erin Carfang Reactor Projects Branch 1
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
References
IR 2018003
Download: ML18306A472 (10)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ber 2, 2018

SUBJECT:

R.E. GINNA NUCLEAR POWER PLANT, LLC: INTEGRATED INSPECTION REPORT 05000244/2018003

Dear Mr. Hanson:

On September 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at R. E. Ginna Nuclear Power Plant. On October 15, 2018, the NRC inspectors discussed the results of this inspection with Mr. William Carsky, Site Vice President and other members of your staff. The results of this inspection are documented in the enclosed report.

NRC inspectors documented one finding, of very low safety significance (Green) in this report.

This finding involved a violation of NRC requirements. Additionally, NRC inspectors documented one Severity Level IV violation with no associated finding. The NRC is treating these violations as non-cited violations (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violations or significance of these NCVs, 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; and the NRC Resident Inspector 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 Inspector 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/

Erin Carfang, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Number: 50-244 License Number: DPR-18

Enclosure:

Inspection Report 05000244/2018003

Inspection Report

Docket Number: 50-244 License Number: DPR-18]

Report Number: 05000244/2018003 Enterprise Identifier: I-2018-003-0063 Licensee: Exelon Generation Company, LLC Facility: R. E. Ginna Nuclear Power Plant, LLC Location: Ontario, New York Inspection Dates: July 1, 2018, to September 30, 2018 Inspectors: N. Perry, Senior Resident Inspector J. Schussler, Resident Inspector H. Anagnostopoulos, Senior Health Physicist J. Bream, Physical Security Inspector E. Burket, Reactor Inspector J. DeBoer, Emergency Preparedness Inspector M. Patel, Operations Engineer S. Obadina, Project Engineer Approved By: E. Carfang, Chief Reactor Projects Branch One Division of Reactor Projects Enclosure

SUMMARY

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

Ginna by conducting the baseline inspections described in this report 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. NRC identified and self-revealing findings, violations and additional items are summarized in the table below.

List of Findings and Violations Failure to Procedurally Vent Flow Transmitter Results in Auxiliary Feedwater Train Inoperable Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.1] - 71111.22 Systems NCV 05000244/2018003-02 Identification Closed An NRC identified Green Non cited Violation (NCV) of Technical Specification 5.4.1.a,

Procedures, was identified for the failure of Exelon to adequately ensure entrapped air from instrument lines associated with flow transmitters FT-2002 and FT-2014 was vented in accordance with technical procedures in March of 2017 and May of 2018, which resulted in NRC inspectors identifying flow indicators FI-2022A and FI-2030 reading erratically, and the B motor driven auxiliary feedwater train being declared inoperable.

Reactor Coolant Pressure Boundary Exceeds Technical Specification Limits Cornerstone Severity Cross-Cutting Inspection Aspect Results Section Not Applicable Severity Level IV Not Applicable 71152 NCV 05000244/2018003-01 Closed A self-revealed Severity Level IV Non-cited Violation (NCV) of Technical Specification 3.4.13,

Reactor Coolant System Operational Leakage, was identified when reactor coolant pressure boundary leakage was found on a chemical and volume control system letdown line.

Additional Tracking Items Type Issue Number Title Inspection Status Results Section LER 05000244/2018-001-00 Leakage in Reactor 71153 Closed Coolant System Pressure Boundary

PLANT STATUS

Ginna began the inspection period at 100 percent power. The unit remained at, or near, 100 percent power for the entire inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/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 performed plant status activities described in IMC 2515, Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess Exelons performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

71111.04 - Equipment Alignment Partial Walkdown

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) A auxiliary feedwater on July 27, 2018

(2) A safety injection on September 13, 2018

(3) A spent fuel pool cooling on September 26, 2018

71111.05AQ - Fire Protection Annual/Quarterly Quarterly Inspection

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Intermediate building steam header floor on July 26, 2018

(2) Main control room on August 12, 2018

(3) Turbine building top floor on August 12, 2018

(4) Cable tunnel on September 26, 2018

(5) B Emergency diesel generator room on September 27, 2018

Annual Inspection (1 Sample)

(1) The inspectors evaluated fire brigade performance during an unannounced backshift drill on August 30, 2018.

71111.06 - Flood Protection Measures Internal Flooding

The inspectors evaluated internal flooding mitigation protections for door seals in the emergency diesel generator rooms and the battery rooms on September 19, 2018.

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification

The inspectors observed control room activities during B emergency diesel generator monthly testing on August 1, 2018, and entry into abnormal procedure AP-RCC.2 for RCC/RFI Malfunction related to control rod I-11 on September 10, 2018.

Operator Performance (1 Sample)

The inspectors observed and evaluated a crew of licensed operators in the plants simulator during licensed operator requalification involving a scenario containing, but not limited to, a fire in a motor control center, a failed open pressurizer spray valve, failure of the turbine to trip, and the loss of preferred auxiliary feedwater on September 18, 2018.

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Microprocessor rod position indication system on September 28, 2018

71111.13 - Maintenance Risk Assessments and Emergent Work Control

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Planned preventive maintenance on the service air compressor on July 9, 2018

(2) Unplanned maintenance on the B motor driven auxiliary feedwater system on August 6, 2018.

(3) C and D Standby auxiliary feedwater system unplanned maintenance on August 16, 2018

(4) Offsite circuit 7T planned maintenance on September 10, 2018

(5) Boric acid blender planned maintenance on September 25, 2018

71111.15 - Operability Determinations and Functionality Assessments

The inspectors evaluated the following operability determinations and functionality assessments:

(1) B motor driven auxiliary feedwater FI-2022A/FI-2030 flow indicators on August 8, 2018

(2) C standby auxiliary feedwater operability determination for motor operated valve 9704A on August 17, 2018

(3) Core exit thermocouple G7 temperature decrease on August 23, 2018

(4) A emergency diesel generator lube oil heaters out of service on September 12, 2018

71111.18 - Plant Modifications

The inspectors evaluated the following temporary or permanent modifications:

(1) Engineering Change Package 18-000099, Reactor make up water heater

(2) Engineering Change Package 17-000051, Lube Oil Heaters (Emergency diesel generator)

71111.19 - Post-Maintenance Testing

The inspectors evaluated post maintenance testing for the following maintenance/repair activities:

(1) Air operated valve 4562 planned maintenance on July 20, 2018

(2) Motor operated valve 9704A planned maintenance on August 1, 2018

(3) NFPA diesel generator planned maintenance on August 28-29, 2018

(4) Component cooling water valve 745 unplanned maintenance on September 28, 2018

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Routine

(1) STP-O-12.2 Emergency diesel generator B monthly on August 1, 2018

(2) STP-O-40.5 NFPA diesel generator on August 6, 2018

(3) STP-O-6.13 Daily surveillance logs on August 17, 2018

(4) STP O-2.1 A safety injection quarterly on September 13, 2018

Inservice (1 Sample)

(1) STP-O-36Q-D Standby auxiliary feedwater pump D quarterly with local start on July 30, 2018

71114.02 - Alert and Notification System Evaluation

The Inspectors evaluated the maintenance and testing of the alert and notification system (ANS) from August 2016 to July 2018.

71114.03 - Emergency Response Organization Staffing and Augmentation System

The inspectors conducted a review of the Exelons Emergency Response Organization (ERO) augmentation staffing requirements and the process for notifying and augmenting the ERO.

71114.05 - Maintenance of Emergency Preparedness

The inspectors reviewed a number of activities to evaluate the efficacy of Exelons efforts to maintain Ginnas emergency preparedness programs.

71114.06 - Drill Evaluation Emergency Planning Drill

The inspectors evaluated the conduct of an off year emergency preparedness exercise on August 14, 2018. The exercise scenario involved declaration of a Site Area Emergency based on a loss of coolant accident and lowering reactor vessel level indication, the declaration of a General Emergency and Protective Action Recommendations to the state and local counties based on loss of coolant accident in containment, and a containment penetration failing.

71124.04 - Occupational Dose Assessment Source Term Characterization

===The inspectors evaluated Exelons source term characterization.

External Dosimetry===

The inspectors evaluated Exelons external dosimetry program.

Internal Dosimetry (1 Sample)

The inspectors evaluated Exelons internal dosimetry program.

Special Dosimetric Situations (1 Sample)

The inspectors evaluated Exelons performance for special dosimetric situations.

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification

The inspectors verified Exelons performance indicators submittals listed below.

(1) Alert and Notification System July 1, 2017, through June 30, 2018

(2) Drill and Exercise Performance July 1, 2017, through June 30, 2018

(3) Emergency Response Organization Drill Participation July 1, 2017, through June 30, 2018

(4) Emergency Alternating Current Power System July 1, 2017, through June 30, 2018

(5) High Pressure Injection System July 1, 2017, through June 30, 2018

(6) Heat Removal System July 1, 2017, through June 30, 2018

(7) Residual Heat Removal System July 1, 2017, through June 30, 2018

(8) Cooling Water Systems July 1, 2017, through June 30, 2018

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues

The inspectors reviewed Exelons implementation of its corrective action program related to the following issues:

(1) Reactor Coolant System Pressure Boundary Leak on the Chemical and Volume Control System Normal Letdown Line (Action Requests 4096294 and 4097619).

(2) Electrical System 480 Volt Ground Trend Evaluation. (Action Requests 04157619,

===04155223, 04132998).

71153 - Follow-up of Events and Notices of Enforcement Discretion Licensee Event Report ===

The inspectors evaluated the following licensee event report (LER):

(1) LER 050000244/2018-001-00, Leakage in Reactor Coolant System Pressure Boundary (ADAMS accession: ML18086A032)

The inspectors determined it was not reasonable to foresee or correct the cause discussed in the LER, therefore no performance deficiency was identified. The circumstances surrounding this LER are documented in report Section 71152. This LER is closed.

INSPECTION RESULTS

Failure to Procedurally Vent Flow Transmitter Results in Auxiliary Feedwater Train Inoperable Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.1] - 71111.22 Systems NCV 05000244/2018003-02 Identification Closed An NRC identified Green Non-cited Violation of Technical Specification 5.4.1.a, Procedures, was identified for the failure of Exelon to adequately ensure entrapped air from instrument lines associated with flow transmitters FT-2002 and FT-2014 was vented in accordance with technical procedures in March of 2017 and May of 2018, which resulted in NRC inspectors identifying flow indicators FI-2022A and FI-2030 reading erratically, and the B motor driven auxiliary feedwater train being declared inoperable.

Description:

On July 30, 2018, a portion of condensate system which is used to supply blocking water to the auxiliary feedwater pumps was placed in a testing lineup. Exelon determined the lineup allowed an existing system air void to relocate in the auxiliary feedwater discharge piping. As a result, on August 6, 2018, the inspectors identified that the B motor driven auxiliary feedwater flow indicators, FI-2022A and FI-2030, on the main control board were displaying flow measurements while the B motor driven auxiliary feedwater pump was not running. The flow indicators fluctuated between 0 and 19.33 gallons per minute. Each flow indicator is expected to be reading zero gallons per minute while the pump is not running.

In response to the inspectors observations, Exelon completed an instrument channel check of FI-2022A and FI-2030. After concluding FI-2030 was displaying flow measurements that exceeded the channel check criteria, Exelon declared the B motor driven auxiliary feedwater train was inoperable. As a result the applicable technical specification action statement, 3.7.5, was entered to restore the B auxiliary motor driven train within seven days. Exelon staff determined that the instrument discrepancy started on July 30, 2018, and subsequently performed a technical evaluation to document system operability. A past operability review showed that the allowed technical specification outage time would not have been exceeded so no violation of technical specification 3.7.5 occurred.

Upon review of Exelon procedures, CPI-FLO-2002, Calibration of 1B Motor Driven Auxilary Feedwater Pump Discharge Flow Loop 2002, Revision 23 and CPI-FLO-2014, Calibration of 1B Motor Driven Auxiliary Feedwater Pump Discharge Flow Loop 2014 and Service Water Pressure Indicators PI-2198 and PI-2199, Revision 01700, used to calibrate and vent flow indicators FI-2022A and FI-2030 the inspectors determined that Exelon personnel did not adequately ensure they were written to vent entrapped air from the associated instrument lines. Specifically, paragraph 7.2 of CPI-FLO-2002 and paragraph 7.4 of CPI-FLO-2014 provided instructions to vent on the low and high side instrument lines by opening vent screws and test tee plugs. Subsequently, these steps did not adequately ensure entrapped air from instrument lines associated with flow transmitters FT-2002 and FT-2014 were vented.

Corrective Actions: On August 6, 2018, Exelon performed trouble shooting and a venting procedure to remove air trapped in flow transmitters FT-2002 and FT-2014 instrument sensing lines. After successful venting and an instrument channel check the B motor driven auxiliary train was returned to operable. Additionally, Exelon will be reviewing the associated venting procedures for necessary changes.

Corrective Action References: 04161976, 04162074, 04162689, 04165260

Performance Assessment:

Performance Deficiency: The inspectors determined that Exelon personnel did not adequately ensure procedures, CPI-FLO-2002, Calibration of 1B Motor Driven Auxilary Feedwater Pump Discharge Flow Loop 2002, Revision 23 and CPI-FLO-2014, Calibration of 1B Motor Driven Auxiliary Feedwater Pump Discharge Flow Loop 2014 and Service Water Pressure Indicators PI-2198 and PI-2199, Revision 01700 were written to vent entrapped air from the associated instrument lines. Specifically, paragraph 7.2 of CPI-FLO-2002 and paragraph 7.4 of CPI-FLO-2014 provided instructions to vent on the low and high side instrument lines by opening vent screws and test tee plugs, but did not ensure entrapped air was vented. This performance deficiency was reasonably within the licensees ability to foresee and prevent.

Screening: The inspectors determined the performance deficiency was more than minor because it adversely affected the Procedure Quality attribute of the Mitigating Systems Cornerstone and affected the associate cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Additionally, this issue is similar to Example 3.j of IMC 0612, Appendix E, Examples of Minor Issues, issued August 11, 2009, because the inadequate venting led to flow indicator FI-2030 failing the channel check acceptance criteria and consequently a reasonable doubt on the operability of the B motor driven auxiliary feedwater train.

Significance: The inspectors assessed the significance of the finding using IMC 0609, 4, Initial Characterization of Findings worksheet, which directs the user to IMC 0609 Appendix A The Significance Determination Process (SDP) for Findings At-Power. The inspectors assessed significance of the failure to adequately vent the B auxiliary feedwater system in accordance with IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, Section A, Mitigating SSC and Functionality (except Reactivity Control Systems - see Section C below). Additionally, Exelon was able to provide an operability determination and technical evaluation which concluded that during the time frame from July 30, 2018, to August 6, 2018, the inaccurate flow measurements on FI-2022A and FI-2030 would not have prevented the B auxiliary feedwater train from performing its safety function and consequently would have been operable during that time period. The finding was determined to be of very low safety significance (Green), because the performance deficiency affected the design or qualification of a mitigating SSC, which maintained its operability.

Cross-Cutting Aspect: This finding has a cross-cutting aspect in the area of Problem Identification and Resolution associated with Identification, in that Exelon individuals did not identify the issue in a timely manner. Specifically, Exelon failed to recognize the erratic flow measurements of instruments FI-2022A and FI-2030 on the main control board for approximately one week. (P.1)

Enforcement:

Violation: Technical Specification 5.4.1.a, Procedures, requires 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 3.l, identifies venting Auxiliary Feedwater System as a recommended procedure. Exelon procedure CPI-FLO-2002, Calibration of 1B Motor Driven Auxilary Feedwater Pump Discharge Flow Loop 2002, Revision 23, Paragraph 7.2 and CPI-FLO-2014, Calibration of 1B Motor Driven Auxiliary Feedwater Pump Discharge Flow Loop 2014 and Service Water Pressure Indicators PI-2198 and PI-2199, Revision 01700, Paragraph 7.4 implements this requirement.

Contrary to the above, on March 24, 2017, and May 17, 2018, Exelon staff did not adequately ensure procedures CPI-FLO-2002 and CPI-FLO-2014, paragraphs 7.2 and 7.4 respectively, were written to vent entrapped air from the associated instrument lines. Specifically, paragraph 7.2 of CPI-FLO-2002 and paragraph 7.4 of CPI-FLO-2014 provides instructions to vent on the low and high side instrument lines by opening vent screws and test tee plugs. As a result, the instrument lines had entrapped air, erratic flow readings on FI-2022A and FI-2030, the B auxiliary feedwater train was declared inoperable, and there was a need for a technical evaluation detailing system operability.

Disposition: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement policy.

Reactor Coolant Pressure Boundary Exceeds Technical Specification Limits Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV Not Applicable 71152 NCV 05000244/2018003-01 Closed A self-revealed Severity Level IV Non-cited Violation of Technical Specification 3.4.13, Reactor Coolant System (RCS) Operational Leakage, was identified when reactor coolant pressure boundary leakage was found on a chemical and volume control system (CVCS)letdown line.

Description:

On January 23, 2018, Exelon staff noted an increase in unidentified reactor coolant system leakage as documented in AR 4096294. After a containment entry on January 26, 2018, Exelon staff identified a through-wall pinhole leak in a socket weld on the A CVCS normal letdown line downstream of letdown orifice LCH01, and upstream of AOV-200A.

The inspectors reviewed inservice inspection results of the weld to determine whether they met the acceptance criteria of the American Society of Mechanical Engineers inspection code. The inspectors concluded that since the weld was appropriately scoped into Exelons inservice inspection program and past inspection results demonstrated adequate structural integrity, that the degradation of this weld was not within Exelons ability to foresee and prevent, and therefore, is not a performance deficiency.

Upon identification of the leak, Exelon operators entered Technical Specification Limiting Condition of Operation 3.4.13, Operational Leakage, Action B.1, which requires the reactor to be Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. See additional details in Section 71152 of this report.

Corrective Actions: Exelon operators isolated the leak by closing two valves upstream of the leak location and exited the Technical Specification Limiting Condition of Operation. Exelon removed the degraded weld and repaired the weld in accordance with regulatory requirements including the applicable editions of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code.

Corrective Action References: ARs 4096294 and 4097619

Performance Assessment:

The inspectors determined the violation was not reasonably foreseeable and preventable by Exelon, and therefore, is not a performance deficiency.

Enforcement:

This issue is considered within the traditional enforcement process because there was no performance deficiency associated with the violation of NRC requirements.

Violation: Technical Specification 3.4.13, RCS Operational Leakage, prohibits pressure boundary leakage.

Contrary to the above, from January 23 to 26, 2018, a reactor coolant pressure boundary leak existed when a weld in the chemical volume and control system developed a through-wall leak.

Severity: The NRC Enforcement Policy, Section 2.2.1 states, in part, that, whenever possible, the NRC uses risk information in assessing the safety significance of violations. Accordingly, after considering that the condition represented very low safety significance, the inspectors concluded that the violation would be best characterized as Severity Level IV under the traditional enforcement process. For information, the inspectors screened the significance of the condition using IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, and determined that the condition was of very low safety significance (Green) because the very small leak did not result in exceeding the RCS leak rate for a small loss of coolant accident and did not affect systems used to mitigate a loss of coolant accident.

Disposition: This violation is being treated as a Non-cited Violation, consistent with Section 2.3.2 of the Enforcement Policy.

The disposition of this violation closes LER 05000244/2018-001-00.

Observations

71152 - Follow-up of

Selected Issues Review of Repetitive 480VAC System Grounds:

The inspectors assessed Exelons corrective actions related to troubleshooting and monitoring of 480 V system ground faults. The inspectors noted that there has been an increase in the number of 480 V ground issue reports since November 2017. Exelon could not determine the likely cause of the grounds due to intermittent ground indications and various system related components failures causing the 480 V system grounds. The inspectors determined that Exelon conducted an appropriate review of the issue and had developed corrective actions to enhance monitoring and troubleshooting activities associated with 480 V grounds during the 2020 refueling outage. During this PI&R sample inspection the inspectors reviewed and assessed Exelons current troubleshooting process to identify the cause of the 480 V grounds and also assessed the planned enhanced disturbance monitoring system that will be installed on each of the 480 V buses during the upcoming 2020 refueling outage. The inspectors determined that Exelon conducted an appropriate review of the failures and are developing appropriate corrective actions to troubleshoot and monitor the 480 V system grounds.

Leak on the Chemical and Volume Control System Normal Letdown Line On January 23, 2018, Exelon staff noted an increase in unidentified reactor coolant system leakage as documented in AR 4096294. After a containment entry on January 26, 2018, Exelon staff identified a through-wall pinhole leak in a socket weld on the A chemical and volume control system normal letdown line downstream of letdown orifice LCH01, and upstream of AOV-200A. Exelon reported this condition to the NRC in Event Notification 53185 and Licensee Event Report 05000244/2018-001.

The chemical and volume control system is designed to control the reactor coolant inventory, chemistry conditions, activity level, and boron concentration. The letdown lines of the chemical and volume control system are part of the reactor coolant pressure boundary.

Upon identification of the leak, the inspectors noted that the station appropriately entered Technical Specification Limiting Condition of Operation 3.4.13, Operational Leakage, Action B.1, which requires the reactor to be Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

Exelon subsequently isolated the leak by closing two valves upstream of the leak location and exited the Technical Specification Limiting Condition of Operation. Exelon staff removed the degraded weld and repaired the location in accordance with the applicable edition of the American Society of Mechanical Engineering Boiler and Pressure Vessel Code as referenced in NRC regulatory requirements.

In accordance with their corrective action program procedures, Exelon performed a corrective action program evaluation of the leak. The inspectors noted that Exelon determined the most probable cause of the leak was an orifice wear/erosion caused by cavitation, which resulted in increased system vibrations. The inspectors also noted that the most probable cause was supported by the industry operating experience and guidance on piping failures.

Exelon performed an extent of condition review of 18 welds susceptible to similar conditions and degradation mechanisms. The inspectors noted that the inspection results of the extent of condition review met the applicable acceptance criteria and did not reveal signs of degradation.

EXIT MEETINGS AND DEBRIEFS

The inspectors confirmed that proprietary information was controlled to protect from public disclosure.

• On July 26, 2018, the inspectors presented the inspection results to Mr. Daren Blankenship, Acting Site Vice President, and other members of the Exelon staff.

• On August 2, 2018, the inspectors conducted a debrief meeting and presented the preliminary inspection results to Mr. P. Swift, Ginna Plant Manager, and other members of the Exelon staff.

• On September 12, 2018, the inspectors presented the results of the IP 71152A inspection to Mr. W. Carsky, Site Vice President, and other members of Exelon staff.

• On September 24, 2018, the inspectors debriefed the inspection results of the problem identification and resolution sample associated with electrical system 480 Volt Ground troubleshooting and monitoring program.

• On October 15, 2018, the inspectors presented the integrated quarterly resident inspector report inspection results to Mr. W. Carsky, Site Vice President, and other members of the Ginna staff.

DOCUMENTS REVIEWED

71111.04

Procedures

STP-O-30.1, Safety Injection System Valve and Breaker Position Verification, Revision 002

STP-O-30.4, Auxiliary Feedwater System Valve and Breaker Position Verification,

Revision 00402

Drawings

33013-1262, Safety Injection and Accumulators (SI) P&ID, Revision 35

71111.05AQ - Fire Protection Annual/Quarterly

Procedures

FRP-20.0, Control Room, Revision 010

SC-3.15.3, Portable Extinguisher Inspection, Revision 053

71111.11 - Licensed Operator Requalification Program

Procedures

HU-AA-1211, Pre-Job Briefings, Revision 11

OP-AA-101-113-1006, 4.0 Crew Critique Guidelines, Revision 9

TQ-GI-150-F31 (LORT), Ginna Site Specific License Operator Requalification Training Program,

Revision 6

71111.12 - Maintenance Effectiveness

Procedures

ER-AA-310, Implementation of the Maintenance Rule, Revision 11

ER-AA-310-1001, Maintenance Rule - Scoping, Revision 4

ER-AA-310-1002, Maintenance Rule Functions - Safety Significance Classification, Revision 3

ER-AA-310-1003, Maintenance Rule - Performance Criteria Selection, Revision 5

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

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Procedures

OP-AA-102-102, General Area Checks and Operator Field Rounds, Revision 15

OP-AA-108-117, Protected Equipment Program, Revision 5

OPG-PROTECTED-EQUIPMENT, Operations Protected Equipment Program,

Revision 20

WC-AA-101, On-Line Work Control Process, Revision 28

WC-AA-101-1006, On-Line Risk Management and Assessment, Revision 2

WC-AA-104, Integrated Risk Management, Revision 25

STP-O-30.5, Standby Auxiliary Feedwater Pumps Valves and Breakers, Revision 00400

71111.15

Procedures

OP-AA-108-115, Operability Determinations, Revision 21

Technical Evaluation

ECP-17-000051, Engineering Technical Evaluation for Lube Oil Heaters, Revision 0000

ESR-18-0182, Technical Evaluation, Past operability for B MDAFW pumps and flor indicators

for IRs 04161976 and 04162074, Revision 001

OPEVAL-18-006, Reactor Coolant System and Incore Flux and Temperature Monitoring,

Revision 000

OPEVAL-18-005, IR 04164728 Improper Operation of Valve 9704A, Revision 000

Action Requests

04164728

71111.18

Procedures

CC-AA-112, Temporary Configuration Changes, Revision 27

S-35, Reactor Make up Water Heater Operations, Revision 006 and 007

Technical Evaluation

ECP-17-000051, Engineering Technical Evaluation for Lube Oil Heaters, Revision 0000

ECP-18-000099, Engineering Technical Evaluation for RMW Heater PCTC, Revision 000

Action Requests

04170132

04171587

Vendor Technical Documents

VTD-A0152-4080, Installation and Maintenance - Chromalox Immersion Heaters, Revision 001

Drawings

33013-1265, Sheet 1, Chemical and Volume Control System Charging P&ID, Revision 12

33013-1265, Sheet 2, Chemical and Volume Control System Charging P&ID, Revision 27

33013-1266, Auxiliary Building Chemical Volume Control System Boric Acid P&ID, Revision 36

Work Orders

C93654947

71111.22

Procedures

STP-O-2.1QA, Safety Injection Pump Quarterly Test, Revision 016

CPI-FLO-2002, Calibration of 1B Motor Driven Auxiliary Feedwater Pump Discharge Flow Loop

2002, Revision 023

CPI-FLO-2014, Calibration of 1B Motor Driven Auxiliary Feedwater Pump Discharge Flow Loop

2014 and Service Water Pressure Indicators PI-2198 and PI-2199, Revision 01700

MA-AA-716-004, Conduct of Troubleshooting, Revision 15

O-6.13, Daily Surveillance Log, Revision 195

STP-O-12.2, Emergency Diesel Generator B, Revision 020

STP-O-36Q-D, Standby Auxiliary Feedwater Pump D - Quarterly, Revision 018

STP-O-40.5, NFPA Diesel Generator (KDG09) Run Test, Revision 009

Action Requests (*initiated in response to inspection)

04161976* 04162689* 04160099

04162074* 04165260

Work Orders

C93676824 C93607061

C93630315

Engineering Evaluations

ESR-18-0182, Technical Evaluation, Past Operability for B MDAFW pumps and flor indicators

for IRs 04161976 and 04162074, Revision 001

Drawings

33013-1237, Auxiliary Feedwater, P&ID, Revision 73

33013-1238, Stand By Auxiliary Feedwater P&ID, Revision 42

71114.05

Procedures

EP-AA-1000, Exelon Nuclear Standardized Radiological Emergency Plan, Revision 1000

EP-AA-1012, Exelon Nuclear Radiological Emergency Plan Annex for Ginna Station, Revision 5

Drawings

33013-2559, Fire Response Plan Control Building Plan Views, Revision 14

71152 - Problem Identification and Resolution

Procedures

M-48.17, Locating System Grounds on 480 Volt Buses, Rev. 00400

PI-AA-120, Issue Identification and Screening Process, Revision 8

PI-AA-125, Corrective Action Program (CAP) Procedure, Revision 6

WC-AA-120, Preventive Maintenance (PM) Database Revision Requirements, Revision 18

Action Requests

04082008 04087016 04091493

04084950 04087990 04091598

04086960 04091114 04092597

Work Orders

C93652000 C93653534

C93652077 C93674844

Cause Analysis

4097619, Through Weld Leak Upstream of V200A, dated 3/16/2018

Drawings

21946-0050B, 480V Bus 14 - Ground Detection Scheme, Rev. 3

33013-1260, Reactor Coolant, Revision 27

33013-1264, Chemical and Volume Control Letdown, Revision 28

Operating Experience

70077135, NRC Information Notice 2007-36 EDG Volt Regulator, dated May 16, 2008

Miscellaneous

Hand-wheel Assembly (SW Valve 5175), Revision 21-RP00532

Inservice Testing Basis Document Section 15 Saltwater System

PRC PowerPoint Presentation, Addition of Disturbance Monitors on 480 Buses and a PPCS

Alarm for LVC, Dated September 5, 2018.

Troubleshooting Instructions for Bus 14 performed on September 5, 2018.

71153

Miscellaneous

R.E. Ginna Nuclear Power Plant Technical Specification Bases, Revision 86